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Copyright Case Opinion Summaries

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Plaintiff brought an action against Defendant for copyright infringement and obtained a money judgment in California. The judgment against Defendant was filed and docketed in a Minnesota district court. Plaintiff subsequently served a garnishment summons on Defendant and sought to attach Defendant’s domain name and the content of its related website. The district court concluded that neither the domain name nor its associated website constituted property subject to garnishment under Minn. Stat. 571.73(3). The court of appeals reversed. The Supreme Court affirmed, holding that an Internet domain name constitutes intangible personal property subject to attachment by garnishment under section 571.73(3)(3). View “Sprinkler Warehouse, Inc. v. Systematic Rain, Inc.” on Justia Law

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Plaintiff brought an action against Defendant for copyright infringement and obtained a money judgment in California. The judgment against Defendant was filed and docketed in a Minnesota district court. Plaintiff subsequently served a garnishment summons on Defendant and sought to attach Defendant’s domain name and the content of its related website. The district court concluded that neither the domain name nor its associated website constituted property subject to garnishment under Minn. Stat. 571.73(3). The court of appeals reversed. The Supreme Court affirmed, holding that an Internet domain name constitutes intangible personal property subject to attachment by garnishment under section 571.73(3)(3). View “Sprinkler Warehouse, Inc. v. Systematic Rain, Inc.” on Justia Law

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Halo, a Hong Kong company that designs and sells high-end modern furniture, owns two U.S. design patents, 13 U.S. copyrights, and one U.S. common law trademark, all relating to its furniture designs. Halo’s common law trademark, ODEON, is used in association with at least four of its designs. Halo sells its furniture in the U.S., including through its own retail stores. Comptoir, a Canadian corporation, also designs and markets high-end furniture that is manufactured in China, Vietnam, and India. Comptoir’s furniture is imported and sold to U.S. consumers directly at furniture shows and through distributors, including in Illinois. Halo sued, alleging infringement and violation of Illinois consumer fraud and deceptive business practices statutes. The district court dismissed on forum non conveniens grounds, finding that the balance of interests favored Canada and that Canada, where the defendants reside, was an adequate forum. The Federal Circuit reversed. The policies underlying U.S. copyright, patent, and trademark laws would be defeated if a domestic forum to adjudicate the rights they convey was denied without a sufficient showing of the adequacy of the alternative foreign jurisdiction; the Federal Court of Canada would not provide any “potential avenue for redress for the subject matter” of Halo’s dispute. View “Halo Creative & Design, Ltd. v. Comptoir des Indes Inc.” on Justia Law

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Plaintiffs, twenty-three professional football players, filed a putative class action against the NFL, claiming that films produced by NFL-affiliate NFL Films violated the players’ rights under the right-of-publicity laws of various states as well as their rights under the Lanham Act, 15 U.S.C. 1125. Twenty plaintiffs settled, but appellants elected to opt out of the settlement and pursued individual right-of-publicity and Lanham Act claims. The district court granted summary judgment for the NFL. Applying the three Porous Media Corp. v. Pall Corp., factors, the court agreed with the district court’s conclusion that the films are expressive, rather than commercial, speech and that the Copyright Act, 17 U.S.C. 301(a), therefore preempts appellants’ claims. The court also concluded that appellants’ claim of false endorsement under the Lanham Act fails as a matter of law because appellants provide no evidence that the films contain misleading or false statements regarding their current endorsement of the NFL. Accordingly, the court affirmed the judgment. View “Dryer v. National Football League” on Justia Law

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Tyrone Simmons, a writer and performer of hip hop music, filed suit against hip hop producer William C. Stanberry, Jr., rapper 50 Cent, and various corporate entities involved in the production and distribution of the 2007 song, “I Get Money…