Crisman v. Van Der Hoog

CourtDistrict Court, N.D. California
DecidedNovember 2, 2021
Docket3:20-cv-02723
StatusUnknown

This text of Crisman v. Van Der Hoog (Crisman v. Van Der Hoog) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crisman v. Van Der Hoog, (N.D. Cal. 2021).

Opinion

1 UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 4 CHRIS CRISMAN, Case No. 20-cv-02723-JD

5 Plaintiff, ORDER RE DEFAULT JUDGMENT v. 6 Re: Dkt. No. 20 7 MASJA VAN DER HOOG, Defendant. 8

9 This is a copyright infringement action brought by plaintiff Chris Crisman against 10 defendant Masja Van Der Hoog, d/b/a Aster Acupuncture (Aster), concerning the unlicensed use 11 of Crisman’s photograph on Aster’s website to promote its acupuncture, massage, and cupping 12 services in violation of the Copyright Act, 17 U.S.C. § 501. See Dkt. No. 1. Aster has failed to 13 appear in the action, and Crisman has moved for default judgment. Dkt. No. 20. The motion is 14 granted. 15 I. JURISDICTION & SERVICE 16 “In default judgment proceedings, the Court has an affirmative duty to consider whether it 17 has jurisdiction over the subject matter and parties to the case.” FormFactor, Inc. v. Mr. Prober 18 Tech. Inc., No. 13-CV-03688-JD, 2015 WL 1870236, at *1 (N.D. Cal. Apr. 23, 2015) (citing In re 19 Tuli, 172 F.3d 707, 712 (9th Cir. 1999)). Because this is a copyright infringement case, the Court 20 has subject matter jurisdiction under 28 U.S.C. § 1338(a). The Court also has personal jurisdiction 21 over Aster, which has its principal place of business in Oakland, California. See Goodyear 22 Dunlop Tires Operations v. Brown, 564 U.S. 915, 924 (2011). The complaint and default 23 judgment papers were served on July 13, 2021. See Dkt. 25. 24 II. DEFAULT JUDGMENT 25 “Under Federal Rule of Civil Procedure 55(b)(2), a party may apply to the Court for entry 26 of judgment by default against a defendant that has failed to defend against the action.” See 27 FormFactor, 2015 WL 1870236, at *2. “‘The district court’s decision whether to enter a default 1 1980)). The decision is based on the following factors: 2 (1) the possibility of prejudice to the plaintiff, (2) the merits of plaintiff's substantive claim, (3) the sufficiency of the complaint, (4) the sum of money at 3 stake in the action; (5) the possibility of a dispute concerning material facts; (6) whether the default was due to excusable neglect, and (7) the strong policy 4 underlying the Federal Rules of Civil Procedure favoring decisions on the merits. 5 Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986). 6 The main inquiries under the Eitel factors are the merits of the claim and the sufficiency of 7 the complaint, which are typically considered together, “because after the entry of default, well- 8 pleaded allegations in the complaint are deemed true, except as to the amount of damages.” 9 FormFactor, 2015 WL 1870236, at *2 (quoting Fair Hous. of Marin v. Combs, 285 F.3d 899, 906 10 (9th Cir. 2002)). 11 To state a claim for copyright infringement, a plaintiff “must show ownership of the 12 allegedly infringed material” and “must demonstrate that the alleged infringer violated at least one 13 exclusive right granted to copyright holders under 17 U.S.C. § 106.” FormFactor, 2015 WL 14 1870236, at *2 (cleaned up) (citing Perfect 10, Inc. v. Amazon.com, Inc., 508 F.3d 1146, 1159 (9th 15 Cir. 2007)). Crisman has done so here. The complaint alleges that he registered the photograph in 16 2011, and that Aster copied it without permission in violation of Crisman’s exclusive right to 17 “reproduce the copyrighted work” under 17 U.S.C. § 106(1). Dkt. No. 1 ¶¶ 11-12, 15-18. 18 Consequently, these factors weigh in favor of default judgment. 19 The other Eitel factors also favor entry of default judgment. Crisman will be prejudiced if 20 default judgment is not granted because he will be left with no way to recover for Aster’s 21 infringement. Broad. Music, Inc. v. JMN Rest. Mgmt. Corp., No. 14-CV-01190-JD, 2014 WL 22 5106421, at *2 (N.D. Cal. Oct. 10, 2014) (“BMI”). The amount of money at stake here (Crisman 23 seeks between $25,000 to $150,000), is high for a single infringement, but the Court has discretion 24 to award $750 in statutory damages per infringement, see infra Section III.A. Because Aster has 25 not appeared, despite service and other attempts to engage her in this litigation, there is “no 26 indication that [the] default is due to excusable neglect, that the material facts are subject to 27 dispute, or that a decision on the merits will be possible.” Id. III. THE RELIEF 1 Crisman asks for statutory damages, attorneys’ fees, and costs, with pre- and post- 2 judgment interest. Dkt. No. 20-1 at 6. He also seeks a permanent injunction pursuant to 17 U.S.C. 3 § 502, enjoining Aster from further infringement. 4 A. Statutory Damages 5 A copyright infringement plaintiff may recover either actual damages or statutory damages 6 under 17 U.S.C. § 504(a). Crisman has proposed to recover the latter, in a minimum amount of 7 $25,000. Section 504(c) of the Copyright Act provides for statutory damages “in a sum of not less 8 than $750 or more than $30,000 as the court considers just,” per infringement. Id. § 504(c)(1). 9 Additionally, if the “infringement was committed willfully, the court in its discretion may increase 10 the award of statutory damages to a sum of not more than $150,000.” Id. § 504(c)(2). 11 Crisman has alleged willful infringement, and these allegations are deemed true upon 12 default. See Derek Andrew, Inc. v. Poof Apparel Corp., 528 F.3d 696, 702 (9th Cir. 2008). Even 13 so, an award of $25,000 as Crisman urges is not automatic. The Court has “wide discretion in 14 determining the amount of statutory damages to be awarded, constrained only by the specified 15 maxima and minima” in the Copyright Act. BMI, 2014 WL 5106421, at *3 (quoting Harris v. 16 Emus Records Corp., 734 F.2d 1329, 1335 (9th Cir.1984)). 17 Crisman says that a reasonable statutory damages award would be five times his licensing 18 fee for the exclusive use of a photograph for a one-year term, which ranges from $2,500 to $5,000. 19 Dkt. No. 20 at 10. This multiplier is too steep for the record in this case. To start, there is a “rule 20 of thumb” in infringement cases that damages should be approximately three times the amount of 21 the estimated licensing fee. BMI, 2014 WL 5106421, at *3. The circumstances here do not 22 warrant a scarcity multiplier. The photograph at issue depicts two masseuses performing 23 massages, and although Crisman says it required “significant skill in lighting and postproduction,” 24 Dkt. No. 1 ¶ 6, the photo is not especially rare or unique. See Stockfood America, Inc. v. Sequoia 25 Wholesale Florist, Inc., No. 20-cv-03597-DMR, 2021 WL 4597080, at *5-6 (N.D. Cal.

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Related

Goodyear Dunlop Tires Operations, S. A. v. Brown
131 S. Ct. 2846 (Supreme Court, 2011)
Gary R. Eitel v. William D. McCool
782 F.2d 1470 (Ninth Circuit, 1986)
Perfect 10, Inc. v. Amazon. Com, Inc.
508 F.3d 1146 (Ninth Circuit, 2007)
Derek Andrew, Inc. v. Poof Apparel Corp.
528 F.3d 696 (Ninth Circuit, 2008)
Harris v. Emus Records Corp.
734 F.2d 1329 (Ninth Circuit, 1984)

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Bluebook (online)
Crisman v. Van Der Hoog, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crisman-v-van-der-hoog-cand-2021.