G&G Closed Circuit Events LLC v. Garcia

CourtDistrict Court, D. Arizona
DecidedSeptember 15, 2020
Docket2:19-cv-05134
StatusUnknown

This text of G&G Closed Circuit Events LLC v. Garcia (G&G Closed Circuit Events LLC v. Garcia) 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
G&G Closed Circuit Events LLC v. Garcia, (D. Ariz. 2020).

Opinion

1 WO 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE DISTRICT OF ARIZONA 7 G & G Closed Circuit Events, LLC, ) No. CV-19-05134-PHX-SPL ) 8 ) 9 Plaintiff, ) ORDER vs. ) ) 10 ) Erika Maria Garcia, et al, ) 11 ) 12 Defendants. ) ) 13 ) 14 Pending before the Court is Plaintiff G & G Closed Circuit Events’ (“G & G”) 15 Motion for Reconsideration. (Doc. 23). Plaintiff seeks reconsideration of this Court’s Order 16 denying attorneys’ fees and costs. (Doc. 22). For the reasons set forth below, the Motion 17 will be granted in part and denied in part. 18 I. BACKGROUND 19 On September 10, 2019, Plaintiff filed a Complaint against Defendants asserting 20 various claims arising from Defendants’ alleged unlawful interception of a television 21 broadcast. (Doc. 1). None of the Defendants answered the Complaint, responded to the 22 Complaint, or otherwise appeared in this action. On October 31, 2019, the Clerk of Court 23 entered default against Defendants pursuant to Rule 55(a) (Doc. 14), and on April 13, 2020, 24 Plaintiff filed a Motion for Default Judgment, which the Court granted (the “Default 25 Judgment”) (Docs. 17, 18). In the Default Judgment, the Court awarded Plaintiff $8,400 in 26 statutory damages and $25,000 in enhanced statutory damages under 47 U.S.C. § 553(c)(3). 27 (Doc. 18 at 2; Doc. 19). Additionally, the Court instructed Plaintiff to file an application for 28 attorneys’ fees and costs in accordance with FRCP 54(d). (Doc. 18 at 2). Plaintiff timely 1 filed such application seeking attorneys’ fees and related non-taxable costs under 47 U.S.C. 2 § 553(c)(2)(C). (Docs. 20, 20-1 at 2). On June 16, 2020, this Court entered an Order 3 summarily denying Plaintiff’s Motion for Attorneys’ Fees. (Doc. 22). On June 30, 2020, 4 Plaintiff timely filed a Motion for Reconsideration pursuant to Local Rule 7.2(g). (Doc. 23). 5 II. LEGAL STANDARD 6 a. Reconsideration 7 Reconsideration is disfavored and appropriate only in rare circumstances. Defenders 8 of Wildlife v. Browner, 909 F. Supp. 1342, 1351 (D. Ariz. 1995). A motion for 9 reconsideration will be denied “absent a showing of manifest error or a showing of new 10 facts or legal authority that could not have been brought to [the Court’s] attention earlier 11 with reasonable diligence.” Fed. R. Civ. P. 7.2(g)(1). Motions for Reconsideration are “not 12 the place for parties to make new arguments not raised in their original briefs,” nor should 13 such motions be used to ask the Court to rethink its previous decision. Motorola, Inc. v. J.B. 14 Rodgers Mech. Contractors, 215 F.R.D. 581, 582 (D. Ariz. 2003). Here, Plaintiff does not 15 present any newly discovered evidence or cite to an intervening change in law. Rather, the 16 Motion for Reconsideration rests on the claim that this Court committed clear error by 17 summarily denying the Motion for Costs and Attorneys’ Fees. (Doc. 23 at 1). 18 b. Attorneys’ fees and costs under 47 U.S.C. § 553 19 In Plaintiff’s original Complaint (Doc. 1), Plaintiff brought separate claims under 20 47 U.S.C. § 553 and 47 U.S.C. § 605, both of which regulate the unauthorized reception 21 and publication of broadcasting material (i.e., “signal piracy”). However, in Plaintiff’s 22 Application for Default Judgment by the Court (Doc. 17), Plaintiff only sought default under 23 § 553. (Doc. 17 at 3) (“Plaintiff seeks Judgment in its favor and against the Defendants for 24 violations of 47 U.S.C. § 553(c)(3)(A)(ii) and (c)(3)(B) . . . . Plaintiff also seeks the 25 opportunity to submit evidence in support of its recovery of attorneys’ fees and relevant 26 costs incurred as provided pursuant to 47 U.S.C. § 553.”). 27 Under § 605, not applicable here, awarding reasonable attorneys’ fees is mandatory: 28 “The court . . . (iii) shall direct the recovery of full costs, including awarding reasonable 1 attorneys’ fees to an aggrieved party who prevails.” 47 USC § 605(e)(3)(B)(iii) (emphasis 2 added). However, under § 553, attorneys’ fees are discretionary: “The court may . . . direct 3 the recovery of full costs, including awarding reasonable attorneys’ fees to an aggrieved 4 party who prevails.” 47 USC § 553(c)(2)(C) (emphasis added). Because Plaintiff only 5 obtained default judgment on the § 553 claim, it is within this Court’s discretion to 6 determine whether attorneys’ fees should be awarded. 7 There is a circuit split about what activity falls under § 553 and what activity falls 8 under § 605—and the extent to which the provisions overlap. See J & J Sports Prods., Inc. 9 v. Indigo Bar & Lounge, Inc., No. 1:13-CV-1787-WSD, 2014 WL 1347065, at *2 (N.D. 10 Ga. Apr. 3, 2014) (explaining that “some circuits have held that § 605 applies to satellite 11 transmissions and cable programming transmitted over a cable network . . . . Other circuits 12 have held that only § 553 covers cable programming transmitted over a cable network” and 13 citing circuit decisions). The Ninth Circuit has not yet clarified the extent of overlap, so 14 many plaintiffs in this Circuit assert claims under both sections. And where a party prevails 15 on both claims, courts generally award attorneys’ fees only under the mandatory § 605 16 provision. See, e.g., Kingvision Pay-Per-View, Ltd. v. Backman, 102 F. Supp. 2d 1196, 1197 17 (N.D. Cal. 2000) (“Based on the pleadings, Defendant is liable for conduct that violates both 18 47 U.S.C. § 605 and § 553 . . . While a few courts have multiplied awards when liability 19 exists under both provisions, the majority of courts—including most courts in the Ninth 20 Circuit—have imposed damages pursuant to § 605 alone rather than cumulatively.”); J & J 21 Sports Prods., Inc. v. Macia, No. 13-CV-00921-DGC, Docs. 16, 17, & 18 (D. Ariz. 2014) 22 (plaintiff obtaining default judgment on both claims but only requesting and receiving 23 attorneys’ fees under § 605); J & J Sports Prods., Inc. v. Margaillan, No. CV 13-312-TUC- 24 CKJ, 2014 WL 169801, at *1 (D. Ariz. Jan. 15, 2014) (same). 25 Although it does not appear that this Court has ever considered only an award for 26 attorneys’ fees under § 553, other district courts within the Ninth Circuit have considered 27 the issue. Rather than summarily denying the request, courts in the Ninth Circuit consider 28 them on the merits and award attorneys’ fees to the extent they are reasonable. See, e.g., 1 J & J Sports Prods., Inc. v. Medoza-Lopez, No. 17-CV-06421-YGR-JSC, 2018 WL 2 5099262, at *1 (N.D. Cal. Aug. 13, 2018) (awarding attorneys’ fees for lead counsel under 3 § 553 only, but excluding fees for research attorney and administrative assistant as not 4 adequately supported in the record); Comcast of Ill. X, LLC v. Jung Kwak, No. CIV. 03- 5 00962 DAE-PA, 2010 WL 3781768, at *5 (D. Nev. Sept. 17, 2010) (awarding attorneys’ 6 fees under § 553 only, but making a “number of reductions” based on mistakes and 7 redundancies in the record). Courts in other circuits do the same.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Defenders of Wildlife v. Browner
909 F. Supp. 1342 (D. Arizona, 1995)
Kingvision Pay-Per-View, Ltd. v. Backman
102 F. Supp. 2d 1196 (N.D. California, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
G&G Closed Circuit Events LLC v. Garcia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gg-closed-circuit-events-llc-v-garcia-azd-2020.