Banctraining Video Systems v. First American Corp.

956 F.2d 268, 1992 U.S. App. LEXIS 7831, 1992 WL 42345
CourtCourt of Appeals for the First Circuit
DecidedMarch 3, 1992
Docket91-5340
StatusUnpublished
Cited by9 cases

This text of 956 F.2d 268 (Banctraining Video Systems v. First American Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Banctraining Video Systems v. First American Corp., 956 F.2d 268, 1992 U.S. App. LEXIS 7831, 1992 WL 42345 (1st Cir. 1992).

Opinion

956 F.2d 268

1992 Copr.L.Dec. P 26,880, RICO Bus.Disp.Guide 7969,
21 U.S.P.Q.2d 2014

NOTICE: Sixth Circuit Rule 24(c) states that citation of unpublished dispositions is disfavored except for establishing res judicata, estoppel, or the law of the case and requires service of copies of cited unpublished dispositions of the Sixth Circuit.
BANCTRAINING VIDEO SYSTEMS, Plaintiff-Appellee,
v.
FIRST AMERICAN CORP., Defendant-Appellant.

No. 91-5340.

United States Court of Appeals, Sixth Circuit.

March 3, 1992.

Before RALPH B. GUY, Jr., ALAN E. NORRIS and BATCHELDER, Circuit Judges.

PER CURIAM.

The plaintiff-appellant, BancTraining Video Systems, appeals the District Court's granting of JNOV for defendant-appellee, First American Corp., on its copyright infringement claim and the District Court's granting of defendant's motion to dismiss on its claim under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1961 et seq. The issues before us are whether plaintiff proved authorship of the copyrights either as a joint author or in a work made for hire arrangement, and whether plaintiff sufficiently stated a RICO claim by alleging an intent to infringe copyrights or an intent to obstruct justice. We affirm the District Court's rulings because BancTraining failed to show that it was the author of the copyrights and failed to plead sufficiently a RICO claim.

BancTraining Video Systems is a partnership created by a joint venture agreement between Financial Shares Corp. (FSC) and CMF & Z Advertising Agency for the purpose of making and selling employee training videotapes for banks. A joint venture agreement was signed by the presidents of FSC and CMF & Z, but BancTraining is neither a party nor a signatory to the agreement.1 That agreement states: "The joint venture shall be the owner of the Program, and the videotapes and written materials prepared hereunder. Trademarks and copyrights in the Program shall be registered in the names of the parties jointly."

To produce the videotapes, the American Bankers Association (ABA) and Jeanie Jorgensen, a BancTraining employee, selected a topic. Then script-writers from FSC were hired to prepare an outline. The outline was reviewed by Jorgensen and the ABA, and the script-writers prepared the full script. Finally, video producers from CMF & Z were hired to build sets, hire actors and produce the film. Jorgensen supervised and reviewed both the script-writing and the video production, and filed the paperwork to register the copyrights on the tapes. Banctraining filed copyright registrations for each of the tapes. Each of these registrations lists "BancTraining Video Systems" as the copyright claimant and author of the tape, and contains an "X" in the "Yes" box for the question, "Was this contribution to the work a 'work made for hire?' "

Defendant, First American Corp., a bank with branches throughout Tennessee, purchased 36 videotapes from BancTraining between 1983 and 1986, as well as a number of duplicate tapes. Defendant also purchased tapes from a St. Louis firm, Bankers Training, which defendant's employees admitted copying. In 1986, Bankers Training filed suit [hereinafter "the St. Louis suit"] against defendant for copyright infringement. Upon learning of the concerns about copyright infringement, First American stopped copying tapes purchased from other tape companies, had all affiliate banks return duplicates to the training department, and erased and taped over the videotapes other than those of Bankers Training. The St. Louis suit was settled before trial, and First American's attorney discarded documents from that litigation except for some discovery materials and depositions.

Plaintiff contends that defendant's employees also copied plaintiff's tapes for use within the bank and sent copies to affiliate banks. An attorney from the St. Louis suit testified that one First American employee stated in a deposition that First American ordered BancTraining tapes, that tapes from outside sources were copied "if needed or necessary," and that a copy of one of BancTraining's tapes was made. In addition, defendant's resource catalog offered a tape-copying service, and listed one of BancTraining's tapes as being available in one-half-inch and three-fourths-inch formats, although defendant had purchased only one format from plaintiff. Defendant's employees, however, testified that they did not know of anyone's copying plaintiff's tapes. At trial, the jury found that defendant had violated the copyrights as to three of the 36 tapes. The jury awarded plaintiff statutory damages of $10,000 per tape, or $30,000. In granting defendant's motion for JNOV, the District Court held that BancTraining had demonstrated that defendant infringed the copyrights, but that it had failed to show that it owned the copyrights as a joint author or through a work made for hire agreement.

BancTraining's Second Amended Complaint also contains a RICO claim, alleging that defendant initiated a scheme in which defendant would duplicate plaintiff's tapes and send them by mail to affiliate banks. The complaint further claims that defendant contacted plaintiff by phone and mail to induce plaintiff to sell its videotapes to defendant without disclosing an intent to violate the Copyright Act, that the tapes were illegally pirated and shipped through the mail to affiliate banks in violation of 18 U.S.C. §§ 1341 & 1343, and that defendant's employees destroyed pirated tapes and documents, although there were then pending both an F.B.I. investigation and the St. Louis lawsuit.

The District Court dismissed the RICO claim, holding that the complaint failed to allege the necessary acts of racketeering activity and failed to allege an intent to defraud or to obstruct justice.

1. The JNOV Ruling

We must review de novo the District Court's granting of the JNOV. Pinney Dock & Transp. Co. v. Penn Central Corp., 838 F.2d 1445, 1472 (6th Cir.), cert. denied, 488 U.S. 880, 109 S.Ct. 196 (1988). In reviewing a motion for JNOV, we must apply the same standard the District Court should have applied: a JNOV is appropriate only when, based on the evidence, reasonable minds could not find as the jury has found. Certer v. Chattanooga, 803 F.2d 217, 225 (6th Cir.1986), vacated on other grounds, 850 F.2d 1119 (6th Cir.1988), cert. denied, 488 U.S. 1010, 109 S.Ct. 795 (1989). We are to view the facts proven at trial in the light most favorable to BancTraining, Hill v. Spiegel, Inc., 708 F.2d 233 (6th Cir.1983), and we may not consider the credibility or the weight of the evidence, Patrick v. South Central Bell Telephone Co., 641 F.2d 1192, 1197 (6th Cir.1980).

For the reasons that follow, we find that the judgment of the District Court must be affirmed.

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Bluebook (online)
956 F.2d 268, 1992 U.S. App. LEXIS 7831, 1992 WL 42345, Counsel Stack Legal Research, https://law.counselstack.com/opinion/banctraining-video-systems-v-first-american-corp-ca1-1992.