Good Job Games Bilism Yazilim Ve Pazarlama A.S. v. SayGames LLC

CourtDistrict Court, N.D. California
DecidedMay 4, 2023
Docket3:19-cv-07916
StatusUnknown

This text of Good Job Games Bilism Yazilim Ve Pazarlama A.S. v. SayGames LLC (Good Job Games Bilism Yazilim Ve Pazarlama A.S. v. SayGames LLC) 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
Good Job Games Bilism Yazilim Ve Pazarlama A.S. v. SayGames LLC, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 GOOD JOB GAMES BILISM YAZILIM Case No. 19-cv-07916-EMC VE PAZARLAMA A., 8 Plaintiff, ORDER GRANTING DEFENDANT’S 9 MOTION FOR ATTORNEY’S FEES v. 10 Docket No. 103 SAYGAMES LLC, et al., 11 Defendants. 12 13 14 Plaintiff Good Job Games (“GJG”) sued Defendant SayGames, LLC (“SG”) for copyright 15 infringement. The Court initially dismissed GJG’s amended complaint for failure to state a claim 16 with leave to amend. GJG never amended its complaint. SG subsequently moved for attorney’s 17 fees under Section 505 of the Copyright Act. In response, GJG filed a notice of voluntary 18 dismissal without prejudice pursuant to Rule 41(a)(1). 19 Pending before the Court is SG’s motion for attorney’s fees. Having considered the papers 20 submitted as well as the oral argument of counsel, the Court hereby GRANTS the motion. 21 I. FACTUAL AND PROCEDURAL BACKGROUND 22 GJG and SG are both mobile videogame developers. In September 2019, GJG released a 23 game called Crazy Jump 3D, in which players launch objects from a cannon and into a bucket by 24 manipulating objects that alter their trajectory. Docket No. 71 (“FAC”) ¶ 50. In October 2019, 25 SG published its own game, Cannon Shot!, in which players fire balls from a cannon into a bucket 26 by navigating them through various obstacles. FAC ¶ 51. 27 GJG filed suit against SG on December 3, 2019, claiming that SG’s mobile game Cannon 1 of personal jurisdiction and failure to state a claim. Docket No. 20. The Court granted SG’s 2 motion to dismiss on jurisdictional grounds. Docket No. 30. GJG appealed, and the Ninth Circuit 3 reversed and remanded for jurisdictional discovery. Docket No. 43, 44. 4 GJG filed an amended complaint following jurisdictional discovery. Docket No. 71. In a 5 motion to dismiss, SG renewed the arguments for lack of personal jurisdiction and failure to state 6 a claim. Docket No. 75. The Court found personal jurisdiction over SG but dismissed the 7 amended complaint for failure to state a claim on the merits of the copyright claim. Docket No. 8 100 (“Order”), at 16. In particular, the Court found that several of the common features between 9 Crazy Jump 3D and Cannon Shot! are unprotected because these features are inherent aspects of 10 physics puzzle games. Id. at 14. Moreover, the protected elements that remain (i.e., colors, 11 decorative shapes, animations, design levels and layouts other than the basic design of the cannon 12 and bucket game) are not substantially similar across the games. Id. at 15. The Court concluded 13 that “[b]ecause the protected elements of the works are not substantially similar, GJG has no 14 viable copyright claim as a matter of law. Thus, the Court dismisses the complaint for failure to 15 state a claim.” Id. at 15–16. 16 The Court afforded GJG until January 6, 2023, to amend the complaint. Id. GJG failed to 17 file an amended complaint. At the hearing herein, GJG confirmed it never intended to amend. 18 On January 20, 2023, SG moved for $133,976.17 in attorney’s fees and costs pursuant to 19 Section 505 of the Copyright Act, asserting it was entitled to fees as the prevailing party. Docket 20 No. 103 (“MAF”). Two days later, GJG filed a notice to voluntarily dismiss this action without 21 prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i) and asked that each party 22 bear its own costs and fees. Docket No. 106. On February 3, 2023, GJG submitted its opposition 23 to SG’s motion for fees, arguing, inter alia, that SG is not entitled to attorney’s fees and costs 24 under the Copyright Act because SG is not a prevailing party since GJG dismissed the complaint 25 without prejudice. Docket No. 107 (“Opp.”). SG replied and requested an additional $34,790 for 26 attorney’s fees and costs associated with this instant motion, bringing the total requested amount 27 to $165,351.17. Docket No. 110 (“Repl.”). 1 II. LEGAL STANDARD 2 A. Prevailing Party 3 Section 505 of the Copyright Act allows a court to award “a reasonable attorney’s fee to 4 the prevailing party as part of the costs.” 17 U.S.C. § 505 (emphasis added). Per the plain 5 language of Section 505, a district court’s “discretion to award attorney’s fees . . . is triggered only 6 if the party in fact prevailed on the copyright claim.” Cadkin v. Loose, 569 F.3d 1142, 1147 (9th 7 Cir. 2009) (citing Fantasy, Inc. v. Fogerty, 94 F.3d 553, 555 (9th Cir. 1996)). 8 B. Discretionary Factors 9 Once a district court determines that the threshold requirement of “prevailing party” has 10 been satisfied, it may then apply Section 505 by “first, deciding whether an award of attorney’s 11 fees is appropriate [through the balancing of several non-exclusive factors] and, second, 12 calculating the amount of the award.” Id. The factors identified by the Supreme Court for the first 13 prong include “‘frivolousness, motivation, objective unreasonableness (both in the factual and in 14 the legal components of the case) and the need in particular circumstances to advance 15 considerations of compensation and deterrence’ . . . so long as such factors are faithful to the 16 purposes of the Copyright Act.” Fogerty v. Fantasy, Inc., 510 U.S. 517, 534 n.19 (1994). 17 “Although objective reasonableness carries significant weight, courts must view all the 18 circumstances of a case on their own terms, in light of the Copyright Act’s essential goals.” 19 Kirtsaeng v. John Wiley & Sons, Inc., 579 U.S. 197, 209 (2016). 20 III. DISCUSSION 21 A. Prevailing Party 22 The Court first considers the threshold issue of whether SG is a prevailing party in light of 23 the Court’s dismissal of GJG’s complaint with leave to amend, GJG’s failure to amend within the 24 time allowed for amendment, and GJG’s subsequent voluntary dismissal of the action without 25 prejudice pursuant to Rule 41(a)(1). 26 Following the dismissal of a claim, a defendant is a prevailing party if the dismissal creates 27 a “material alteration of the legal relationship of the parties.” Cadkin, 569 F.3d at 1148. Material 1 federal court” is impeded. Id. at 1150 (finding material alteration where “plaintiff is judicially 2 precluded from refiling the claim against the defendant in federal court”). Typically, a dismissal 3 without prejudice—unlike dismissal with prejudice—does not materially alter the legal 4 relationship of the parties. Id. at 1150 (holding that defendants are not prevailing party where the 5 dismissal without prejudice does not deprive plaintiffs of the ability to refile their copyright claims 6 in federal court); Anderson, 2020 WL 5057581, at *4 (“[D]ismissal with prejudice may serve as a 7 basis for awarding attorney’s fees to a defendant as the prevailing party.”). In this case, the Court 8 did not dismiss without prejudice; it dismissed the complaint on the merits as a matter of law and 9 gave leave to amend within 30 days which GJG failed to do. 10 GJG argues that the Court’s dismissal with leave and GJG’s voluntary dismissal without 11 prejudice do not materially alter the parties’ legal relationship because GJG remains free to refile 12 copyright claim in federal court. See Opp. at 2–6. SG responds that after the time permitted for 13 leave to amend expired, the dismissal in this particular case precludes GJG from refiling a 14 copyright claim, at least a claim identical to the one in the FAC—the copyright infringement claim 15 against the accused game at issue. The Court thus examines the preclusive effect resulting from 16 its dismissal of the parties.

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Bluebook (online)
Good Job Games Bilism Yazilim Ve Pazarlama A.S. v. SayGames LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/good-job-games-bilism-yazilim-ve-pazarlama-as-v-saygames-llc-cand-2023.