This document summarizes key aspects of international copyright law as it relates to works protected under the Berne Convention and foreign copyrights being enforced in US courts. It discusses how the Berne Convention abolished copyright formalities and now copyright subsists upon fixation. It defines what constitutes a Berne Convention work and notes that registration is required for foreign owners to obtain statutory damages and attorneys fees. The document also summarizes the first sale doctrine and its international exception, as well as how US courts can exercise jurisdiction over foreign infringers in certain cases.
If your business is involved in selling, recycling or loaning used goods, the U.S. Supreme Court affirmed the owner's rights to resell such items. In other words, if you bought it, you own it and you can sell it.
The case held that those who lawfully buy copyrighted works or items own them and have the right to resell them without going back to get approval of the original copyright holder. After the first sale, the copyright holder no longer has rights in the item. It's called the "first sale" doctrine.
The case, Wiley vs. Kirtsaeng, was decided in March 2013 and applied to goods manufactured outside the U.S. but subject to U.S. copyright law.
Syllabus (summary) only. The full Supreme Court decision is at: http://1.usa.gov/149xKz0.
This is a casenote I wrote concerning the tenuous balance between public domain works and the Foreign Works Restoration Act, which essentially takes foreign works out of the public domain in the US and "re-copyrights" them, essentially upending the federal copyright regime.
Yar Chaikovsky and Keith Slenkovich discuss patent exhaustionYar Chaikovsky
Yar Chaikovsky and Keith Slenkovich discuss Recent Decisions in Patent Exhaustion:
Bowman, Kirtsaeng and other developments impacting the exhaustion doctrine
Outline
1) First Sale Doctrine in Copyright Law
– Kirtsaeng v. Wiley (2013)
2) Overview of Patent Exhaustion Doctrine
– Quanta v. LG (2008)
3) Patent Exhaustion – “Territoriality Requirement”
– Jazz Photo line of cases
– Recent cases finding exhaustion with foreign sales
– Ninestar v. ITC (Fed. Cir. 2012), cert. denied (2013)
4) Self-Replicating Technology
– Bowman v. Monsanto (2013)
5) Notable Decision
– Keurig v. Sturm Foods (Fed. Cir. 2013)
Yar Chaikovsky is well regarded in the California market and peers and clients alike recognize his IP litigation practice. His fields of experience include semiconductor, communications, network and computer technologies. He achieved a stunning win for Yahoo! in a jury trial against Bedrock Computer in the Tyler Division of the Eastern District of Texas, a patent litigation hotspot which many regard as plaintiff friendly. It was the first defense verdict in a patent infringement matter in this division since 2007. He recently represented HTC in ITC and district court patent infringement cases.
Keith Slenkovich is an experienced trial lawyer, who represents technology companies in intellectual property disputes and complex commercial litigation. As lead trial counsel, Mr. Slenkovich has taken more than 20 cases to verdict in state and federal courtrooms throughout the country. His intellectual property experience includes numerous patent, trade secret, copyright and trademark cases, including disputes alleging infringement or misappropriation in the clean tech, telecommunications, semiconductor, software, and manufacturing fields.
Final Paper written on the history of the copyright code from the perspective of past, present, and future predictions for my MUS343 course that Dr. Anthony Merlino instructed.
If your business is involved in selling, recycling or loaning used goods, the U.S. Supreme Court affirmed the owner's rights to resell such items. In other words, if you bought it, you own it and you can sell it.
The case held that those who lawfully buy copyrighted works or items own them and have the right to resell them without going back to get approval of the original copyright holder. After the first sale, the copyright holder no longer has rights in the item. It's called the "first sale" doctrine.
The case, Wiley vs. Kirtsaeng, was decided in March 2013 and applied to goods manufactured outside the U.S. but subject to U.S. copyright law.
Syllabus (summary) only. The full Supreme Court decision is at: http://1.usa.gov/149xKz0.
This is a casenote I wrote concerning the tenuous balance between public domain works and the Foreign Works Restoration Act, which essentially takes foreign works out of the public domain in the US and "re-copyrights" them, essentially upending the federal copyright regime.
Yar Chaikovsky and Keith Slenkovich discuss patent exhaustionYar Chaikovsky
Yar Chaikovsky and Keith Slenkovich discuss Recent Decisions in Patent Exhaustion:
Bowman, Kirtsaeng and other developments impacting the exhaustion doctrine
Outline
1) First Sale Doctrine in Copyright Law
– Kirtsaeng v. Wiley (2013)
2) Overview of Patent Exhaustion Doctrine
– Quanta v. LG (2008)
3) Patent Exhaustion – “Territoriality Requirement”
– Jazz Photo line of cases
– Recent cases finding exhaustion with foreign sales
– Ninestar v. ITC (Fed. Cir. 2012), cert. denied (2013)
4) Self-Replicating Technology
– Bowman v. Monsanto (2013)
5) Notable Decision
– Keurig v. Sturm Foods (Fed. Cir. 2013)
Yar Chaikovsky is well regarded in the California market and peers and clients alike recognize his IP litigation practice. His fields of experience include semiconductor, communications, network and computer technologies. He achieved a stunning win for Yahoo! in a jury trial against Bedrock Computer in the Tyler Division of the Eastern District of Texas, a patent litigation hotspot which many regard as plaintiff friendly. It was the first defense verdict in a patent infringement matter in this division since 2007. He recently represented HTC in ITC and district court patent infringement cases.
Keith Slenkovich is an experienced trial lawyer, who represents technology companies in intellectual property disputes and complex commercial litigation. As lead trial counsel, Mr. Slenkovich has taken more than 20 cases to verdict in state and federal courtrooms throughout the country. His intellectual property experience includes numerous patent, trade secret, copyright and trademark cases, including disputes alleging infringement or misappropriation in the clean tech, telecommunications, semiconductor, software, and manufacturing fields.
Final Paper written on the history of the copyright code from the perspective of past, present, and future predictions for my MUS343 course that Dr. Anthony Merlino instructed.
I’m so confused — what is prior art now? Marc Hubbard
How did the America Invents Act (AIA) change the definition of prior art when it switched the U.S. patent system from first-to-invent to first-to-file.
• What has changed?
– New Rules Governing Prior Art
– Post Grant Review
– Microentity Fees
– Priority Examination of “Important” Technologies
– Fee Diversion
• How do the changes affect small business?
• What steps can you take now?
When is it OK to reuse other people's photos or other contentJane Lambert
A talk on an issue upon which I am frequently consulted. Photographs are "artistic works" in which copyright is likely to subsist in the UK and around the work. Reproducing them without the copyright owner's permission is likely to infringe copyright with potentially serious consequences but there are exceptions and a lot of material is licensed on conditions.
Mr. Rothe is an attorney with RatnerPrestia, PC, a law firm located in Valley Forge, PA. Christopher counsels clients in all areas of intellectual property law, including patents, IP risk management, and IP transactions. Mr. Rothe has expertise in prosecuting domestic and international patent applications. He is currently responsible for managing patent portfolios for a major U.S. manufacturer of surgical implants, and one of the nation's top children's hospitals.
Mr. Rothe is accustomed to explaining complex IP issues to individuals with various backgrounds, including general counsels, company presidents, CEOs, technology transfer specialists, marketing directors, engineers, scientists, and beginning entrepreneurs.
Mr. Rothe received a law degree from Villanova University School of Law. Before attending law school, Mr. Rothe spent four years working as an engineer in private practice. He received a B.S. in civil engineering from the Pennsylvania State University in 1992.
These are the slides for a seminar on creative output that I gave on 30 Oct 2013.
"Creative output" for these purposes means works of art and literature and design. Works of art and literature connote visual and literary arts and performing arts. Investment in visual and literary arts are protected by copyright and performing arts by rights in performances.
Design means the design of products that are likely to be reproduced though not necessarily in a large scale, Design can be functional or ornamental. Functional designs are protected by unregistered design right. Ornamental designs that are new and have individual character can be protected by registration as registered designs or as registered Community designs. There is also 3 year protection throughout the EU against copying for designs that could be registered as registered or registered Community designs.
This presentation considers copyright: subsistence, qualification, title, duration, infringement, economic and moral rights. It also touches on rights in performances, design rights, registered designs and registered and unregistered Community designs.
Katrina begins her new life as an adult and member of the OWBC club. What challenges will she face? Will she be ready to marry Destry the man she has chosen or will she get too scared?
Making Joyful Noise With Your Computer For Fun and ProfitCDPUG
This is the June 2011 program presented by Will Cheshier. The title is "Making Joyful Noise With Your Computer For Fun and Profit."
Sure, music has charms to "soothe the savage breast", but it also has been known to help out in movies (can you imagine "2001" without daaaaaaaaaa, daaaaaaaaaa, daaaaaaaaaa, DA DAAAAAAAA, boom boom boom boom, etc? Me neither). It's also good for podcasts, home videos and it's just plain fun. Computer music and sound has come to the point where anyone can produce professional-quality recordings on a laptop for not a lot of money. At the July CDPUG meeting we'll be talking about the equipment and techniques needed to get sound into and out of your computer so you can join the fun.
Will Cheshier is a graphic designer and regionally active singer/songwriter and guitarist. He also suffers from Musical G.A.S. (Gear Acquisition Syndrome). He has been recording in professional studios and at home since the 80s with an excessive amount of acquired gear, so he knows a thing or two about what works and a lot about what doesn't when it comes to computer sound
I’m so confused — what is prior art now? Marc Hubbard
How did the America Invents Act (AIA) change the definition of prior art when it switched the U.S. patent system from first-to-invent to first-to-file.
• What has changed?
– New Rules Governing Prior Art
– Post Grant Review
– Microentity Fees
– Priority Examination of “Important” Technologies
– Fee Diversion
• How do the changes affect small business?
• What steps can you take now?
When is it OK to reuse other people's photos or other contentJane Lambert
A talk on an issue upon which I am frequently consulted. Photographs are "artistic works" in which copyright is likely to subsist in the UK and around the work. Reproducing them without the copyright owner's permission is likely to infringe copyright with potentially serious consequences but there are exceptions and a lot of material is licensed on conditions.
Mr. Rothe is an attorney with RatnerPrestia, PC, a law firm located in Valley Forge, PA. Christopher counsels clients in all areas of intellectual property law, including patents, IP risk management, and IP transactions. Mr. Rothe has expertise in prosecuting domestic and international patent applications. He is currently responsible for managing patent portfolios for a major U.S. manufacturer of surgical implants, and one of the nation's top children's hospitals.
Mr. Rothe is accustomed to explaining complex IP issues to individuals with various backgrounds, including general counsels, company presidents, CEOs, technology transfer specialists, marketing directors, engineers, scientists, and beginning entrepreneurs.
Mr. Rothe received a law degree from Villanova University School of Law. Before attending law school, Mr. Rothe spent four years working as an engineer in private practice. He received a B.S. in civil engineering from the Pennsylvania State University in 1992.
These are the slides for a seminar on creative output that I gave on 30 Oct 2013.
"Creative output" for these purposes means works of art and literature and design. Works of art and literature connote visual and literary arts and performing arts. Investment in visual and literary arts are protected by copyright and performing arts by rights in performances.
Design means the design of products that are likely to be reproduced though not necessarily in a large scale, Design can be functional or ornamental. Functional designs are protected by unregistered design right. Ornamental designs that are new and have individual character can be protected by registration as registered designs or as registered Community designs. There is also 3 year protection throughout the EU against copying for designs that could be registered as registered or registered Community designs.
This presentation considers copyright: subsistence, qualification, title, duration, infringement, economic and moral rights. It also touches on rights in performances, design rights, registered designs and registered and unregistered Community designs.
Katrina begins her new life as an adult and member of the OWBC club. What challenges will she face? Will she be ready to marry Destry the man she has chosen or will she get too scared?
Making Joyful Noise With Your Computer For Fun and ProfitCDPUG
This is the June 2011 program presented by Will Cheshier. The title is "Making Joyful Noise With Your Computer For Fun and Profit."
Sure, music has charms to "soothe the savage breast", but it also has been known to help out in movies (can you imagine "2001" without daaaaaaaaaa, daaaaaaaaaa, daaaaaaaaaa, DA DAAAAAAAA, boom boom boom boom, etc? Me neither). It's also good for podcasts, home videos and it's just plain fun. Computer music and sound has come to the point where anyone can produce professional-quality recordings on a laptop for not a lot of money. At the July CDPUG meeting we'll be talking about the equipment and techniques needed to get sound into and out of your computer so you can join the fun.
Will Cheshier is a graphic designer and regionally active singer/songwriter and guitarist. He also suffers from Musical G.A.S. (Gear Acquisition Syndrome). He has been recording in professional studios and at home since the 80s with an excessive amount of acquired gear, so he knows a thing or two about what works and a lot about what doesn't when it comes to computer sound
Art Litigation and Dispute Resolution InstituteRaymond Dowd
I Co-Chaired the first-ever Art Litigation and Dispute Resolution Institute with the Hon. Stephen G. Crane at New York County Lawyers\' Association this past November - the CLE will soon be available on DVD
Copyright litigation handbook contents and overviewRaymond Dowd
Litigation handbook for attorneys handling copyright infringement, copyright ownership, and copyright licensing cases. Includes Copyright Act, Federal Rules of Civil Procedure, Federal Rules of Evidence, case annotations
Federal Bar Association ND Ohio IP Crimes Seminar on Nazi Art LootingRaymond Dowd
Murder, Mystery and Egon Schiele\'s Dead City: Nazi Art Loooting and Swiss Laundering of Stolen Art. Presentation during Intellectual Property Crimes seminar at the Northern District of Ohio Chapter of the Federal Bar Association in the Carl B. Stokes U.S. Courthouse
Sothebys Institute Egon Schieles Dead CityRaymond Dowd
Presentation at New York State Bar Association and Sotheby\'s Institute of Art on Egon Schiele\'s Dead City and Nazi Art Looting - Current Legal Issues
The Federal Circuit Review is a monthly newsletter featuring the latest case summaries handed down from the U.S. Court of Appeals for the Federal Circuit.
In this Issue:
• Double Patenting Applies With Distinct Inventive Entities
• Inducement Judgment Remanded in Light of Akamai
• First Sale Doctrine Applies to Sales Made Abroad
Intellectual Property Rights Violations: Federal Civil Remedies and Criminal ...Karol Pessin
"Intellectual Property Rights Violations: Federal Civil Remedies and Criminal Penalties Related to Copyrights, Trademarks, and Patents," CRS Report for Congress, October 2008. Order Code: RL34109. Author: Brian T. Yeh, Legislative Attorney, American Law Division.
From the report:
"This report summarizes the federal civil remedies and criminal penalties that
may be available for violations of the rights granted by the federal intellectual
property laws: the Copyright Act of 1976, the Patent Act of 1952, and the Trademark
Act of 1946 (conventionally known as the Lanham Act)."
What Licensing Lawyers Should Know About LitigationRoger Royse
Licensing agreements are supposed to reflect the intent of the contracting parties in connection with permission to use intellectual property rights. When litigators and the courts get ahold of such agreements, however, the results can be far afield of what the parties expressed in their agreement. This webinar will focus on some of those unintended consequences, both as a matter of contract law in general and as a matter of licensing law specifically.
Speaker:
Thomas Moore III - Attorney, Royse Law Firm, PC
What Licensing Lawyers Should Know About LitigationRoger Royse
Licensing agreements are supposed to reflect the intent of the contracting parties in connection with permission to use intellectual property rights. When litigators and the courts get ahold of such agreements, however, the results can be far afield of what the parties expressed in their agreement. This webinar will focus on some of those unintended consequences, both as a matter of contract law in general and as a matter of licensing law specifically.
Speaker:
Thomas Moore III - Attorney, Royse Law Firm, PC (9/2015)
What is the threat to culture by a read-only world, and how do t.pdfforwardcom41
What is the threat to culture by a \"read-only world,\" and how do the CC licenses provided by
Lessig address this threat?
Solution
The primary argument against the current state of copyright is the length of copyright. As
stated above, the Constitution established copyright for a “limited period”. In the first one
hundred years of United States history, the term of copyright was increased once (to a 42 year
maximum). In the next fifty years, the term was increased once more (to a maximum of 56
years). In the past forty years, Congress has increased the terms of existing and future
copyrights; most recently, in 1998, Congress extended existing copyrights by twenty years
(Lessig Free Culture ).
This prevents many works from entering the “public domain” and becoming part of the
common culture. A good example of this is Walt Disney’s “Steamboat Willie”, the first
appearance of Mickey Mouse. Before the 1998 copyright amendments, “Steamboat Willie”
would have become public domain in 2003: now, it is under copyright until 2023, assuming the
law is not changed again. This is particularly ironic, given that Walt Disney and the Disney
corporation have made extensive use of “public domain” works (such as The Hunchback of
Notre Dame and Treasure Island) in their own production of derivative copyrighted works.
Indeed, “Steamboat Willie” is itself a parody of a contemporary Buster Keaton film, “Steamboat
Bill Jr.” (Lessig Free Culture )
“Fair use” is a controversial provision in copyright law because it is not clearly defined. The
U.S. Copyright Office states “The distinction between fair use and infringement may be unclear
and not easily defined. There is no specific number of words, lines, or notes that may safely be
taken without permission” (“Fair Use”). In practice, it is up to the user to defend his “fair use”
right and bear the legal costs of doing so. Jon Else, a documentary filmmaker, was quoted a
$10,000 fee to license four and a half seconds of a Simpsons episode that was playing in the
background of one scene in a documentary about opera. When he suggested that this was
covered under “fair use”, Fox (the copyright distributor) threatened to sue him, leading Else to
edit the scene .
In some cases, it is difficult or impossible to find the original copyright owner, especially
since copyright registration is no longer required. These works are commonly called “orphan
works”. Without permission, these works cannot be reprinted or redistributed, and disappear
from the culture. When Carnegie Mellon attempted to obtain permission to digitize works in
their libraries, they found that 22% of the publishers of those works could not be contacted
(“Report on Orphan”). If the owners or publishers of a work cannot be contacted, there is no
way
to reach an agreement on reprinting and reproduction rights. Without such an agreement, the
work in question will eventually become unavailable, except possibly through resellers of used
media or through illicit chann.
Kiobel: Major U.S. Jurisdictional Limitation for Overseas Actions
International Copyright Foreign Copyrights In Us Courts
1. International Copyright: Foreign
Copyrights in the U.S.
New York County Lawyers’ Association
October 22, 2008
New York City
Raymond J. Dowd – Partner
Dunnington Bartholow & Miller LLP
Author – Copyright Litigation Handbook
(West 3d Ed. 2008)
1
2. Copyright protects
original works of authorship fixed in any
tangible medium of expression . . . from
which they can be perceived, reproduced, or
otherwise communicated, either directly or
with the aid of a machine . . . 17 U.S.C. § 102
www.dunnington.com
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3. Works protected by copyright:
literary works (including photography, software)
musical works (lyrics)
dramatic works (with music)
pantomimes/choreographic works
pictorial, graphic, sculptural works
motion pictures, audiovisual works
sound recordings
architectural works
17 U.S.C. § 102
www.dunnington.com
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4. Berne Convention Implementation Act of
1988
Abolished requirement of “formalities” for a
copyright to be protected
Formalities are 1. copyright notice and 2. copyright
registration
Now copyright subsists upon fixation
Registration required for U.S. owners to go to court
Registration required for Berne Convention owners
to get statutory damages and attorneys fees
See materials CLH at §§ 1:3, 1:4; 1:5; 1:7
www.dunnington.com
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5. Definition of “Berne Convention
work” (Part I)
A work is a “Berne Convention work” if —
(1) in the case of an unpublished work, one or more of the authors is
a national of a nation adhering to the Berne Convention, or in the case
of a published work, one or more of the authors is a national of a nation
adhering to the Berne Convention on the date of first publication;
(2) the work was first published in a nation adhering to the Berne Convention,
or was simultaneously first published in a nation adhering to the Berne
Convention and in a foreign nation that does not adhere to the Berne
Convention;
www.dunnington.com
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6. Definition of “Berne Convention work” (Part II)
(3) in the case of an audiovisual work —
(A) if one or more of the authors is a legal entity, that author has its
headquarters in a nation adhering to the Berne Convention; or
(B) if one or more of the authors is an individual, that author is domiciled,
or has his or her habitual residence in, a nation adhering to the Berne
Convention; or
(4) in the case of a pictorial, graphic, or sculptural work that is incorporated
in a building or other structure, the building or structure is located in a nation adhering
to the Berne Convention; or
(5) in the case of an architectural work embodied in a building, such building is
erected in a country adhering to the Berne Convention.
For purposes of paragraph (1), an author who is domiciled in or has his or her
habitual residence in, a nation adhering to the Berne Convention is considered
to be a national of that nation. For purposes of paragraph (2), a work is
considered to have been simultaneously published in two or more nations if
its dates of publication are within 30 days of one another.
www.dunnington.com
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7. Berne Convention works
Statutory damages and attorneys fees strong
incentives for Berne Convention work
owners to register copyrights in U.S.
Exclusive licensees must record to have
standing to sue in U.S.
Registration must take place prior to
infringement to obtain damages and attorneys
fees
www.dunnington.com
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11. Copyright registration as “sculptural work” denied. Originality
refers to a work’s origin with an author and to the embodiment
of more than trivial variations from works within the public
domain. Insufficient “sculptural authorship” since the shape
was determined by the building’s contours and wrapping
predetermined by the building’s shape.
“Wrapped Reichstag, Berlin 1971-95” Christo & Jeanne Claude
www.dunnington.com
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12. Determining Copyright Status of
Berne Convention Works
Title search (companies such as Thomson)
Conduct copyright investigation (see Circular 22)
Copyright Office records incomplete
From www.copyright.gov:
Protection in Foreign Countries
Even if you conclude that a work is in the public domain in the
United States, this does not necessarily mean that you are free
to use it in other countries. Every nation has its own laws
governing the length and scope of copyright protection, and
these are applicable to uses of the work within that nation’s
borders. Thus, the expiration or loss of copyright protection in
the United States may still leave the work fully protected
against unauthorized use in other countries.
www.dunnington.com
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14. Under prior law, publication without a copyright notice put a
copyrighted work in the public domain. Certain foreign works that
fell into public domain have been restored. Under current law,
copyright notices are not necessary for copyright protection.
Material entering the public domain has been greatly restricted.
See, e.g., Troll Co. v. Uneeda Doll Co., 483 F.3d 150 (2d. Cir.
2007)(foreign troll falling in and out of public domain)
www.dunnington.com
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15. The First Sale Doctrine
and Imports
www.dunnington.com
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16. First sale doctrine: once a copyright owner sells an object containing the copy, the
owner can’t control subsequent distribution. Codified at 17 U.S.C. § 109 (a).
Bourne v. Walt Disney Company, 68 F.3d 621 (2d Cir. 1995)
www.dunnington.com
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17. Once U.S. copyright owner makes “lawful copy” in U.S.A. and sells
anywhere in the world, has exhausted rights and first sale doctrine may
be asserted as a defense by a re-importer.
Quality King Dists. Inc. v. L’Anza Research Int’l, Inc., 523 U.S. 135
(1998).
www.dunnington.com
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18. International exception to the first sale doctrine: sales of copyrighted goods manufactured
and first sold outside the U.S. may not be imported to the U.S. without copyright owner’s
consent. First sale doctrine applies only where a manufacture and first sale in the United
States. See 17 U.S.C. § 602 (Infringing importation of copies or phonorecords).
Omega S.A. v. Costco Wholesale Corp., 541 F.3d 982 (9th Cir. 2008)
www.dunnington.com
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20. Where infringer is operating offshore (the island of Vanuatu), under Rule
4(k)(2) of the Federal Rules of Civil Procedure, jurisdiction may be exercised
where sufficient contacts with, or injury to, U.S. residents is alleged, even
though there are not sufficient contacts with any one state to justify jurisdiction
in that state.
Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 243 F. Supp.2d 1073,
1094 (C.D. Cal. 2003).
www.dunnington.com
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21. Extraterritorial acts: U.S. courts will exercise jurisdiction over foreign
defendants whose extraterritorial acts aid, induce or contribute to copyright
infringement by another in the United States.
GB Marketing USA Inc. v. Gerolsteiner Brunnen GmbH & Co., 782 F.
Supp. 763, 772 (W.D.N.Y. 1991).
www.dunnington.com
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23. Foreign copyright claims may be pleaded in U.S. courts in diversity
cases or under the doctrine of supplemental jurisdiction. For five
photographs of Lindsay Lohan published without authorization, the
court reserved decision on U.K. copyright claims, noting that the court
has discretion to decline such jurisdiction.
X17 Inc. v. Hollywood TV Inc., 2008 WL 4527865 (C.D. Cal. 2008).
www.dunnington.com
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24. Ownership of Russian copyrights to works first published in Russia
governed by Russian law, questions of infringements of Russian
copyrights governed by U.S. law where infringement in U.S. by U.S.
corporation.
Itar-Tass Russian News Agency v. Russian Kurier, Inc., 153 F.3d 82 (2d
Cir 1998). www.dunnington.com
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25. Thanks to Thomson West
For use of Copyright Litigation Handbook
excerpts.
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