Coe v. Red Voice Media Incorporated

CourtDistrict Court, D. Arizona
DecidedMarch 26, 2025
Docket2:24-cv-03572
StatusUnknown

This text of Coe v. Red Voice Media Incorporated (Coe v. Red Voice Media Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coe v. Red Voice Media Incorporated, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8

Bryan C oe, ) No. CV-24-03572-PHX-SPL ) 9 ) 10 Plaintiff, ) ORDER vs. ) ) 11 ) Red Voice Media Incorporated, ) 12 ) 13 Defendant. ) ) 14 )

15 Before Court is Plaintiff Bryan Coe’s Motion for Default Judgment (Doc. 12) 16 against Defendant Red Voice Media Incorporated. For the following reasons, the Motion 17 will be granted. 18 I. BACKGROUND 19 On December 17, 2024, Plaintiff filed a Complaint against Defendant alleging that 20 Defendant violated the Copyright Act, 17 U.S.C. § 501. (Doc. 1 at 1). Plaintiff is a 21 professional videographer and created a video of a Halloween parade in New York, New 22 York, which he first published on November 2, 2022. (Id. at 2–3). On December 10, 2022, 23 the video was registered by the United States Copyright Office. (Id. at 3). Plaintiff created 24 the video “with the intention of it being used commercially and for the purpose of display 25 and/or public distribution.” (Id.). 26 Defendant is a media company that owns and operates a website, from which it 27 derives revenue from paid advertisements. (Id. at 1–3). On November 1, 2022, Defendant 28 displayed Plaintiff’s video on its website as a part of an online story about the parade. (Id. 1 at 4). Defendant did not have permission or authorization to copy or display the video. (Id.) 2 Plaintiff alleges that the video uploaded and published by Defendant is an exact copy of 3 his video. (Doc. 1 at 5). Plaintiff discovered the alleged infringement on December 5, 2022. 4 (Id. at 4). 5 Plaintiff alleges that Defendant took an active role in selecting Plaintiff’s video to 6 display on its website, willfully posted the video, and received a financial benefit directly 7 attributable to its infringement. (Id. at 5). Plaintiff further alleges that Defendant’s use of 8 the video has harmed Plaintiff’s potential market for the video. (Id. at 6). 9 On March 17, 2023, Plaintiff’s counsel contacted Defendant to address the alleged 10 infringement and received no response. (Id.). On December 17, 2024, Plaintiff filed his 11 Complaint. (Doc. 1). Plaintiff served Defendant on January 9, 2025. (Doc. 8). The 12 Defendant failed to appear in this action, and Plaintiff filed an Application for Entry of 13 Default on February 5, 2025. (Doc. 9). The Clerk filed the Entry of Default on February 6, 14 2025 (Doc. 10), and Plaintiff filed its present Motion for Default Judgment pursuant to Fed. 15 R. Civ. P. 55(b)(2) on March 20, 2025. (Doc. 12). 16 II. DISCUSSION 17 a. Subject Matter Jurisdiction, Personal Jurisdiction, and Service 18 When default judgment is sought against a non-appearing party, a court has “an 19 affirmative duty to look into its jurisdiction over both the subject matter and the parties.” 20 In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999) (“To avoid entering a default judgment that 21 can later be successfully attacked as void, a court should determine whether it has the 22 power, i.e., the jurisdiction, to enter judgment in the first place.”). A court has a similar 23 duty with respect to service of process. See Fishman v. AIG Ins. Co., No. CV 07-0589- 24 PHX-RCB, 2007 WL 4248867, at *3 (D. Ariz. Nov. 30, 2007) (“Because defendant has 25 not been properly served, the court lacks jurisdiction to consider plaintiff’s motions for 26 default judgment.”). These considerations are “critical because ‘[w]ithout a proper basis 27 for jurisdiction, or in the absence of proper service of process, the district court has no 28 power to render any judgment against the defendant’s person or property unless the 1 defendant has consented to jurisdiction or waived the lack of process.’” Id. (citing S.E.C. 2 v. Ross, 504 F.3d 1130, 1138–39 (9th Cir. 2007)). 3 First, the Court may exercise subject matter jurisdiction because Plaintiff’s 4 Copyright Act claims invoke federal question jurisdiction. See 28 U.S.C. § 1331. Next, as 5 to personal jurisdiction, this Court has personal jurisdiction over Defendant because 6 Defendant is an Arizona corporation with its principal place of business in Maricopa 7 County, Arizona, and was properly served. (Doc. 1 at 2); see Pennoyer v. Neff, 95 U.S. 8 714, 722 (1877) (noting that “every State possesses exclusive jurisdiction and sovereignty 9 over persons and property within its territory”); Benny v. Pipes, 799 F.2d 489, 492 (9th Cir. 10 1986) (noting that a federal court lacks personal jurisdiction over defendant unless 11 defendant properly served). With respect to service, Defendant was properly served on 12 January 9, 2025, by serving the summons on Defendant’s statutory agent representative, 13 who was designated by law to accept service of behalf of Defendant in accordance with 14 Fed. R. Civ. P. 4(h)(1)(B). (Doc. 8). With preliminary considerations of jurisdiction and 15 service of process out of the way, this Court turns to whether default judgment is 16 appropriate. 17 b. Default Judgment Analysis: Eitel Factors 18 A court has the discretion to enter a default judgment after a defendant’s default. 19 Eitel v. McCool, 782 F.2d 1470, 1471 (9th Cir. 1986). In exercising this discretion, a court 20 must consider the seven “Eitel factors”: (1) the possibility of prejudice to the plaintiff; 21 (2) the claim’s merits; (3) the complaint’s sufficiency; (4) the sum of money at stake; 22 (5) the possibility of a dispute concerning material facts; (6) whether the default was due 23 to excusable neglect; and (7) the policy favoring decisions on the merits. Id. at 1471–72. 24 In applying these factors, the Complaint’s factual allegations, except those pertaining to 25 the amount of damages, will be taken as true. Geddes v. United Fin. Grp., 559 F.2d 557, 26 560 (9th Cir. 1977). 27 i. First, Fifth, Sixth, and Seventh Eitel Factors 28 The first, fifth, sixth, and seventh factors weigh in favor of or are neutral about 1 default judgment in cases in which the defendants have not participated in the litigation at 2 all. Zekelman Indus. Inc. v. Marker, No. CV-19-02109-PHX-DWL, 2020 WL 1495210, at 3 *3 (D. Ariz. Mar. 27, 2020) (D. Ariz. Mar. 26, 2020) (“In cases like this one, in which 4 Defendants have not participated in the litigation at all, the first, fifth, sixth, and seventh 5 factors are easily addressed.”). Regarding the first factor, which considers the possibility 6 of prejudice to the plaintiff, Plaintiff here will be left without recourse and would therefore 7 suffer prejudice in the absence of default judgment. Id. As to the fifth factor, which 8 considers the possibility of a dispute regarding material facts, Defendant’s failure to 9 participate means there is no dispute of material fact. Id. at *4. The sixth factor considers 10 whether the default was due to excusable neglect. Id. Here, Defendant’s failure to 11 participate after being properly served does not indicate that default was due to excusable 12 neglect. Id. Lastly, the seventh factor—which considers the policy favoring decisions on 13 the merits—would typically weigh against an entry of default judgment. Id. However, this 14 consideration is not dispositive, as default judgments exist to deal with wholly 15 unresponsive parties. Id.

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