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What you appear to be asking is whether, somehow, The entire Silmarillion was, by its title being mentioned, incorporated by reference into The Lord of the Rings and hence its film rights?
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Maybe I'm missing something - but I didn't think Sauron's argument was this at all. Of course any such claim would be ridiculous. But this, surely is a valid point: the rights owned by Zaentz include any material in the appendices to LotR. Now, the appendices contain (almost) no information on the first age. Appendix A does, however, include a long synopsis of the story of the downfall of Numenor and the establishment of the realms in exile. One could, then, imagine the holders of the film rights attempting to produce an adaptation of this story (though there is, of course, vastly more material on the same subject that is
not within their rights).