Justia Copyright Opinion Summaries

After participating in a songwriting contest co-sponsored by Sony and a well-known Puerto Rican singer, the plaintiff submitted an original song and accompanying music video for consideration. Upon advancing as a finalist, the plaintiff was asked to sign documents related to contest participation. Another entrant was ultimately selected as the contest winner. Later, the defendant released a song and video that the plaintiff claimed were substantially similar to his contest submission, leading the plaintiff to file suit for copyright infringement and allege fraudulent inducement into the contest.Following extensive procedural history, including several prior appeals and a Supreme Court decision clarifying when copyright owners may sue, the United States District Court for the District of Puerto Rico dismissed the plaintiff’s earlier complaint without prejudice due to the timing of his copyright registration. The plaintiff then filed a new action, again asserting copyright infringement. The defendant responded with counterclaims challenging the validity of the plaintiff’s copyright registration and moved for summary judgment, arguing that the plaintiff had assigned his copyright to Sony by agreeing to the contest’s rules. The district court adopted a magistrate judge’s recommendation granting summary judgment to the defendant, dismissed the plaintiff’s remaining claims, and invalidated the plaintiff’s copyright registration, all without permitting discovery.On appeal, the United States Court of Appeals for the First Circuit held that the district court abused its discretion by granting summary judgment and invalidating the copyright registration without affording the plaintiff a fair opportunity to conduct discovery, particularly since the relevant evidence was largely under the defendant’s and Sony’s control. The First Circuit vacated the district court’s summary judgment order and the invalidation of the copyright registration, remanding the case for further proceedings to allow discovery. View "Cortes-Ramos v. Martin-Morales" on Justia Law

A graphic designer was commissioned in 2016 to create a room-sized artwork for a brewery’s exhibition at an annual fair produced by the defendant. The agreement specified that the designer would retain copyright ownership and that the installation could only be shown in person to paying patrons at the 2016 event. During the fair, the defendant created and widely disseminated marketing videos online featuring the designer’s work without attribution, despite the designer’s requests for credit. The designer applied for copyright registration in April 2017, and the work was eventually registered, though the exact date of registration is not in the record.The designer first filed a pro se copyright infringement suit in the United States District Court for the District of Massachusetts in early 2018, but the court dismissed it without prejudice for failure to allege copyright registration. Instead of amending, the designer filed a second action in state court, which was removed to federal court. After amending her complaint, the district court again dismissed the copyright claims, this time with prejudice, for failure to state a plausible claim and failure to allege registration. The designer did not respond to the motion to dismiss. In December 2020, now represented by counsel, she filed the present suit in federal court, which was dismissed with prejudice on claim preclusion grounds. On appeal, the United States Court of Appeals for the First Circuit reversed and remanded for further consideration.On remand, the district court again dismissed the case, this time on both claim preclusion and statute of limitations grounds. The United States Court of Appeals for the First Circuit affirmed the dismissal, holding that the copyright infringement claims were untimely under the three-year statute of limitations, as the plaintiff knew or should have known of the alleged infringement by early 2017. The court also found no basis for equitable tolling. View "Foss v. Eastern States Exposition" on Justia Law