Bee Creek Photography v. Austin Media Rooms LLC

CourtDistrict Court, W.D. Texas
DecidedApril 25, 2025
Docket1:23-cv-01270
StatusUnknown

This text of Bee Creek Photography v. Austin Media Rooms LLC (Bee Creek Photography v. Austin Media Rooms LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bee Creek Photography v. Austin Media Rooms LLC, (W.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

BEE CREEK PHOTOGRAPHY, § Plaintiff § § v. § No. 1:23-CV-01270-RP § AUSTIN MEDIA ROOMS LLC, § Defendant §

REPORT AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

TO: THE HONORABLE ROBERT PITMAN UNITED STATES DISTRICT JUDGE

Before the Court is Plaintiff Bee Creek Photography’s (“Bee Creek”) motion for default judgment, Dkt. 9. After reviewing the motion and the relevant case law, the undersigned recommends that the District Judge grant Bee Creek’s motion. I. BACKGROUND Bee Creek, a professional photography sole proprietorship, sues Defendant Austin Media Rooms (“AMR”) for copyright infringement pursuant to 17 U.S.C. § 101, et seq., alleging that AMR displayed Bee Creek’s Austin, Texas skyline photograph on its websites without permission from Bee Creek. Dkts. 1, at 3-4; 9-1, at 1-2. Bee Creek registered the skyline photograph with the U.S. Copyright Office on October 6, 2015. Dkt. 9-6, at 2. According to Bee Creek, AMR began displaying the photograph on its websites “on or about July 8, 2019.” Dkt. 9-1, at 2. Bee Creek states that AMR neither licensed the photograph from Bee Creek nor had Bee Creek’s permission or consent to publish the photograph. Id. Bee Creek sued AMR on October 19, 2023, alleging one count of copyright infringement under 17 U.S.C. § 501 for reproducing, distributing, and publicly displaying the skyline photograph for its own

purposes. Dkt. 1, at 6. AMR did not respond to the suit by the answer deadline, and has not appeared before this Court. Bee Creek moved for entry of default, which the clerk entered. Dkts. 7; 8. Bee Creek now moves for default judgment. Dkt. 9. II. LEGAL STANDARD Under Rule 55 of the Federal Rules of Civil Procedure, federal courts have the authority to enter a default judgment against a defendant that has failed to plead or

otherwise defend itself. Fed. R. Civ. P. 55(a)-(b). That said, “[d]efault judgments are a drastic remedy, not favored by the Federal Rules and resorted to by courts only in extreme situations.” Sun Bank of Ocala v. Pelican Homestead & Sav. Ass’n, 874 F.2d 274, 276 (5th Cir. 1989). A party is not entitled to a default judgment simply because the defendant is in default. Ganther v. Ingle, 75 F.3d 207, 212 (5th Cir. 1996). Rather, a default judgment is generally committed to the discretion of the district court. Mason v. Lister, 562 F.2d 343, 345 (5th Cir. 1977).

In considering Bee Creek’s motion, the Court must determine: (1) whether default judgment is procedurally warranted; (2) whether Bee Creek’s complaint sets forth facts sufficient to establish that it is entitled to relief; and (3) what form of relief, if any, Bee Creek should receive. United States v. 1998 Freightliner Vin #: 1FUYCZYB3WP886986, 548 F. Supp. 2d 381, 384 (W.D. Tex. 2008); see also J & J Sports Prods., Inc. v. Morelia Mexican Rest., Inc., 126 F. Supp. 3d 809, 813 (N.D. Tex. 2015) (using the same framework). III. DISCUSSION

A. Default judgment is procedurally warranted. To determine whether entry of a default judgment is procedurally warranted, district courts in the Fifth Circuit consider six factors: “[1] whether material issues of fact are at issue, [2] whether there has been substantial prejudice, [3] whether the grounds for default are clearly established, [4] whether the default was caused by a good faith mistake or excusable neglect, [5] the harshness of a default judgment, and [6] whether the court would think itself obliged to set aside the default on the

defendant’s motion.” Lindsey v. Prive Corp., 161 F.3d 886, 893 (5th Cir. 1998). On balance, the Lindsey factors weigh in favor of entering a default judgment against AMR. Because AMR has not filed a responsive pleading, there are no material facts in dispute. See Nishimatsu Constr. Co., Ltd. v. Hous. Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975) (“The defendant, by his default, admits the plaintiff’s well- pleaded allegations of fact.”). AMR’s failure to appear and respond has ground the

adversary process to a halt, prejudicing Bee Creek’s interest in pursuing his claim for relief. See J & J Sports, 126 F. Supp. 3d at 814 (“Defendants’ failure to respond threatens to bring the adversary process to a halt, effectively prejudicing Plaintiff’s interests.”) (internal citation and quotation marks omitted). The grounds for default are established: AMR was properly served and has failed to appear and participate at all, much less timely file a responsive pleading. See Dkt. 5. There is no indication that the default was caused by a good faith mistake or excusable neglect. The undersigned therefore finds that default judgment is procedurally warranted.1 B. Bee Creek’s complaint is sufficient to establish its right to relief.

Default judgment is proper only if the well-pleaded factual allegations in Bee Creek’s complaint establish a valid cause of action. Nishimatsu Constr. Co., 515 F.2d at 1206. By defaulting, a defendant “admits the plaintiff’s well-pleaded allegations of fact.” Id. In determining whether factual allegations are sufficient to support a default judgment, the Fifth Circuit employs the same analysis used to determine sufficiency under Rule 8. Wooten v. McDonald Transit Assocs., Inc., 788 F.3d 490, 498

(5th Cir. 2015). A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The factual allegations in the complaint need only “be enough to raise a right to relief above the speculative level, on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Wooten, 788 F.3d at 498 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). While “detailed factual allegations” are not required, the pleading must present “more than an unadorned, the-defendant-unlawfully-harmed-

me accusation.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). For Bee Creek to prevail on its copyright-infringement claim, it must show that: (1) it owns a valid copyright and (2) AMR copied constituent elements of Bee Creek’s work that are original. Baisden v. I’m Ready Prods., Inc., 693 F.3d 491, 499

1 Bee Creek has established AMR was properly served, and the District Judge entered default. Fed. R. Civ. P. 55(a); Dkts. 6; 7; 8. As AMR is a non-individual defendant, the undersigned finds that the defendant in this action is not a minor or incompetent person and is not in military service. See Fed. R. Civ. P. 55(b)(2); 50 U.S.C.

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Bluebook (online)
Bee Creek Photography v. Austin Media Rooms LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bee-creek-photography-v-austin-media-rooms-llc-txwd-2025.