A lawsuit by investors in the film sought that amount, blaming the 2006 movie's poor showing on Hilton's failure to promote the film. Hilton claims she did everything she could to plug it.
U.S. District Judge Federico Moreno says Hilton could still have to repay some of the $1 million she was paid to make the film. The judge on Tuesday ordered lawyers to file more legal papers in the coming weeks on that issue.
There was no immediate response Tuesday to requests for comment from Hilton's publicist or attorney, or the attorney for investors.