Joe Hand Promotions Incorporated v. Hernandez

CourtDistrict Court, D. Arizona
DecidedSeptember 2, 2022
Docket2:21-cv-00966
StatusUnknown

This text of Joe Hand Promotions Incorporated v. Hernandez (Joe Hand Promotions Incorporated v. Hernandez) 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
Joe Hand Promotions Incorporated v. Hernandez, (D. Ariz. 2022).

Opinion

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

9 Joe Hand Promotions Incorporated, No. CV-21-00966-PHX-DJH

10 Plaintiff, ORDER

11 v.

12 Jose Alfonso Velasco Hernandez, et al.,

13 Defendants. 14 15 Pending before the Court is Plaintiff’s Motion for Default Judgment (Doc. 16). 16 Defendants have not filed a response, nor have they appeared or otherwise defended this 17 action. For the following reasons the Court will grant Plaintiff’s Motion in part. 18 I. Background 19 As alleged in the Complaint, Defendant JR Mexican Food LLC and its “officer, 20 director, shareholder, member or principal,” Defendant Jose Alfonso Velasco Hernandez 21 (“Hernandez”), are Arizona residents who obtained and willfully played a television 22 program (the “Program”) in their restaurant without Plaintiff’s authorization on July 20, 23 2019. (Doc. 1 at ¶¶ 5–7, 10). 24 The Complaint brings two claims. The first is under the Federal Communications 25 Act for satellite and cable piracy under 47 U.S.C. §§ 553 and 605. (Id. at ¶¶ 17–20). The 26 second is for copyright infringement under 17 U.S.C. §§ 106 and 501. (Id. at ¶¶ 21–24). 27 For damages, the Complaint sought up to $110,000.00 for willful violation of § 605 and 28 up to $60,000.00 for willful violation of § 553, and up to $150,000 for a willful violation 1 of § 501, in addition to attorney fees and costs. (Id. at 7). Plaintiff’s Motion for Default 2 Judgment, however, only seeks $30,000 under § 605(e)(3)(C), plus attorney fees and costs. 3 On September 2, 2021, the Clerk entered default against Defendants under Federal 4 Rule of Civil Procedure 55(a). (Doc. 15). 5 II. Legal Standard 6 Courts strongly prefer to decide cases on their merits, but they may use their 7 discretion to enter default judgment. Eitel v. McCool, 782 F.2d 1470, 1472 (9th Cir. 1986); 8 see also Fed. R. Civ. P. 55. If default judgment is sought against a party that failed to plead 9 or otherwise defend, courts must determine they have subject matter jurisdiction over the 10 matter and personal jurisdiction over the party. In re Tuli, 172 F.3d 707, 712 (9th Cir. 11 1999). If there is jurisdiction, courts must then consider several factors to determine 12 whether default judgment is appropriate: “(1) the possibility of prejudice to the plaintiff, 13 (2) the merits of plaintiff's substantive claim, (3) the sufficiency of the complaint, (4) the 14 sum of money at stake in the action; (5) the possibility of a dispute concerning material 15 facts; (6) whether the default was due to excusable neglect, and (7) the strong policy 16 underlying the Federal Rules of Civil Procedure favoring decisions on the merits.” Eitel, 17 782 F.2d at 1471–72. Upon default, a complaint’s factual allegations are taken as true, 18 except for those relating to damages. Geddes v. United Fin. Grp., 559 F.2d 557, 560 (9th 19 Cir. 1977). 20 III. Jurisdiction and Eitel Analysis 21 Because the Complaint invokes federal causes of action, piracy and copyright 22 infringement, the Court has original jurisdiction over this matter. See 28 U.S.C. § 1331. 23 Defendants, alleged to be Arizona residents (Doc. 1 at ¶ 6–7), are at home in this 24 jurisdiction and, therefore, subject to the Court’s personal jurisdiction. See Int’l Shoe Co. 25 v. State of Wash., 326 U.S. 310, 317 (1945). Having found subject matter jurisdiction and 26 personal jurisdiction over Defendants, the Court proceeds to the Eitel factors. 27 a. Possibility of Prejudice to Plaintiff 28 Without a judgment against Defendants, Plaintiff’s alleged injury would lack a 1 remedy. Therefore, this factor favors entry of default judgment. 2 b. Merits of Substantive Claim and Sufficiency of Complaint 3 “Under an Eitel analysis, the merits of plaintiff’s substantive claims and the 4 sufficiency of the complaint are often analyzed together.” Dr. JKL Ltd. v. HPC IT Educ. 5 Ctr., 749 F. Supp. 2d 1038, 1048 (N.D. Cal. 2010). The Complaint’s § 605 claim requires 6 Plaintiff show Defendants received and used a television program for its benefit without 7 Plaintiff’s authorization. § 605(a); DirecTV, Inc. v. Webb, 545 F.3d 837, 844 (9th Cir. 8 2008). The Complaint’s allegations establish that Defendants received the Program 9 without Plaintiff’s permission and played it at their restaurant. (Doc. 1 at ¶¶ 11–16).1 The 10 Complaint’s copyright infringement claim requires Plaintiff show ownership of a valid 11 copyright and that Defendants violated one or more of Plaintiff’s rights as the copyright 12 owner. UMG Recordings, Inc. v. Augusto, 628 F.3d 1175, 1178 (9th Cir. 2011). The 13 Complaint adequately alleges that Plaintiff was the Program’s copyright owner, and that 14 Defendants’ unauthorized distribution of the program violated Plaintiff’s rights. (Doc. 1 15 at ¶¶ 5, 9–24). 16 The Court finds that the Complaint has merit and would sufficiently put Defendants 17 on notice of the claims at issue. This factor favors entry of default judgment. 18 c. Sum at Stake 19 Here, the Court considers the amount of money at stake in relation to the seriousness 20 of a defendant’s conduct. See Pepsico, Inc. v. Cal. Sec. Cans, 238 F. Supp. 2d 1172, 1176 21 (C.D. Cal. 2002). “If the sum of money at stake is completely disproportionate or 22 inappropriate, default judgment is disfavored.” Gemmel v. Systemhouse, Inc., 2008 WL 23 65604, at *4 (D. Ariz. Jan. 3, 2008).

24 1 Because Plaintiff raises this point in its Motion, the Court notes that Hernandez may be held individually liable for § 605 violations at his business. (Doc. 16 1 at 15). Courts in 25 the Ninth Circuit have found that individual liability for § 605 violations when an individual “had a right and ability to supervise the violations and that he had a strong 26 financial interest in such activities.” J & J Sports Prods., Inc. v. Mikhael, 2016 WL 2984191, at *2 (C.D. Cal. May 19, 2016) (cleaned up). The Court must accept the 27 Complaint’s allegation that Hernandez had the “right and ability to supervise and an obvious and direct financial interest” in the restaurant. (Doc. 1 at ¶ 8). Because he has 28 supervisory authority and a strong financial interest, Hernandez may be held individually liable for the § 605 claim. 1 Plaintiff seeks $30,000 in addition to attorney fees and costs because Defendants 2 pirated the Program on July 20, 2019. For reasons explained below, the Court finds this 3 amount excessive and will only award half that amount. Nonetheless, the amount at stake 4 is significant and Defendants actions are serious enough to warrant mandatory statutory 5 damages. See § 605.

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Related

Silge v. Merz
510 F.3d 157 (Second Circuit, 2007)
International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
UMG Recordings, Inc. v. Augusto
628 F.3d 1175 (Ninth Circuit, 2011)
Gary R. Eitel v. William D. McCool
782 F.2d 1470 (Ninth Circuit, 1986)
DirecTV, Inc. v. Webb
545 F.3d 837 (Ninth Circuit, 2008)
Pepsico, Inc. v. California Security Cans
238 F. Supp. 2d 1172 (C.D. California, 2002)
Dr. JKL Ltd. v. HPC IT EDUCATION CENTER
749 F. Supp. 2d 1038 (N.D. California, 2010)
Ryan v. City of Shawnee
13 F.3d 345 (Tenth Circuit, 1993)

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