Livevideo.AI Corp v. Redstone et al.

CourtDistrict Court, S.D. New York
DecidedSeptember 30, 2025
Docket1:24-cv-06290
StatusUnknown

This text of Livevideo.AI Corp v. Redstone et al. (Livevideo.AI Corp v. Redstone et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Livevideo.AI Corp v. Redstone et al., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Livevideo.AI Corp, Plaintiff, 24 Civ. 6290 (DEH) v. OPINION Redstone et al., AND ORDER Defendants.

DALE E. HO, United States District Judge: Before the Court is the August 12, 2025 Report and Recommendation (the “Report” or “R&R”) issued by Magistrate Judge Moses recommending (1) “that the case be dismissed, without prejudice, pursuant to Rule 4(m),” (2) “that monetary sanctions in the amount of $10,000 . . . be imposed jointly and severally against” Plaintiff Livevideo.AI Corp (“Plaintiff” or “Livevideo”) and its counsel Alfred Camillo Constants, III (“Constants”) pursuant to Rule 11, (3) that Constants “be referred to this Court’s Grievance Committee,” and (4) “that a limited filing injunction be issued to prevent [P]laintiff from continuing to advance the frivolous claims it has raised in this action.” See R. & R. at 3-4, ECF No. 163. For the reasons stated below, Magistrate Judge Moses’s well-reasoned Report is ADOPTED IN FULL. BACKGROUND Familiarity with the factual background and relevant procedural history of this case as set out in the Report is assumed. See generally R. & R. at 4-22. This action is assigned to Magistrate Judge Moses for general pretrial supervision and report and recommendation on dispositive motions. See ECF Nos. 5, 152. On August 12, 2025, Magistrate Judge Moses issued the Report. See generally R. & R. The parties’ objections to the Report were due by August 26, 2025. See R. & R. at 50 (“The parties have 14 days from this date to file written objections to this Report and Recommendation pursuant to 28 U.S.C. § 636(b)(1) and Fed. R. Civ. P. 72(b).”). However, on August 26, 2025, Livevideo filed a letter motion seeking a 3-day extension of time to file any objections, see ECF No. 165, which the Court granted, see ECF No. 166. In granting Livevideo’s extension request, Court noted that the request was untimely and indicated that further extensions would not be granted. See id. Subsequently thereafter, Livevideo filed its Objections to the Report accompanied by the four-page declaration of Brad Greenspan (“Greenspan”).1 See Pl.’s Objs., ECF No. 167. On

September 12, 2025, Defendant National Amusements, Inc. (“NAI”) timely filed its Opposition to Plaintiff’s Objections. See Def.’s Opp’n to Pl.’s Objs. (“Def.’s Opp’n”), ECF No. 169. After reviewing the Report, Livevideo’s Objections, and NAI’s Opposition, the Court adopts the Report in its entirety. LEGAL STANDARDS2 When reviewing a Report and Recommendation, a court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1)(C). For dispositive matters, a district judge is required to “determine de novo any part of the magistrate judge’s disposition that has been properly objected to” by any party. Fed. R. Civ.

1 On September 8, 2025, Livevideo filed a document titled “notice of errata,” which claimed to correct “formatting errors” in the four-page Greenspan declaration appended to Livevideo’s Objection. See Notice of Errata, ECF No. 168. The Court notes, however, that Livevideo’s “notice of errata” actually consists of a nine-page declaration from Greenspan accompanied by four additional exhibits. Compare Pl.’s Objs. at 24-27 with Notice of Errata. Livevideo did not seek leave to file this “notice of errata” and was on notice that the Court would not grant any further extensions to submit objections to the Report. See ECF No. 166. Accordingly, the Court declines to consider this untimely and unsolicited submission. 2 All references to Rules are to the Federal Rules of Civil Procedure. In all quotations from cases, the Court omits citations, alterations, emphases, internal quotation marks, and ellipses, unless otherwise indicated. P. 72(b)(3). For those portions to which no proper objection is made, a district court need only satisfy itself that there is no “clear error on the face of the record.” Miller v. Brightstar Asia, Ltd., 43 F.4th 112, 120 n.4 (2d Cir. 2022). When a party has not properly made objections, for instance, by making “objections that are merely perfunctory responses argued in an attempt to engage the district court in a rehashing of the same arguments set forth in the original [papers, it] will not suffice to invoke de novo

review.” Owusu v. N.Y. State Ins., 655 F. Supp. 2d 308, 313 (S.D.N.Y. 2009). Accordingly, when a court is considering objections that “merely re-assert arguments already submitted to the Magistrate Judge, this Court need only review the Report and Recommendation for clear error.” Id.; see also Pinkney v. Progressive Home Health Servs., No. 06 Civ. 5023, 2008 WL 2811816, at *1 (S.D.N.Y. July 21, 2008) (“To the extent, however, that the party makes only conclusory or general objections, or simply reiterates the original arguments, the Court will review the Report strictly for clear error. . . . [N]o party [should] be allowed a ‘second bite at the apple’ by simply relitigating a prior argument.”); Vega v. Artuz, No. 97 Civ. 3775, 2002 WL 31174466, at *1 (S.D.N.Y. Sept. 30, 2002) (noting that if the district court engaged with objections that are “general and conclusory [this] would reduce the magistrate’s work to something akin to a ‘meaningless

dress rehearsal’”). DISCUSSION Livevideo raises numerous objections to each of Magistrate Judge Moses’s recommendations, including (1) that this matter be dismissed under Rule 4(m), (2) the imposition of a $10,000 penalty against Livevideo and Constants, (3) that Constants be referred to this Court’s Greivance Committee, and (4) the issuance of a limited filing injunction. See R. & R. at 3-4. The Court considers Livevideo’s objections as to each of Magistrate Judge Moses’s recommendations in turn. I. Dismissal Under Rule 4(m) A. Failure to Effectuate Timely Service The Report recommends dismissal of this matter because Livevideo “filed its operative complaint . . . on September 17, 2024, but failed to serve it on any defendant within the 90 days allotted by Rule 4(m).” R. & R. at 23. As an initial matter, Magistrate Judge Moses found in an Order dated December 18, 2025, that Livevideo’s “operative complaint is . . . the First Amended Complaint and Jury Demand at

Dkt. 35.” Dec. 18, 2025 Order at 2, ECF No. 69. As a result, Magistrate Judge Moses concluded that Livevideo’s November 6, 2024 service attempt was improper because Livevideo served NAI with the Complaint at ECF No. 32, rather than the operative Complaint at ECF No. 35. See id. Because Livevideo failed to timely object to the December 18, 2025 Order, the Court agrees with both Magistrate Judge Moses and NAI that this is no longer a “live issue,” and that the Court need not review this issue further. See R. & R. at 21 n.23 (“Plaintiff did not, however, file any objections to the 12/18/24 Order. Consequently, plaintiff has waived appellate review of this Court’s decision to vacate the entry of default against NAI.”) (citing Fed. R. Civ. P. 72(a); Kilcullen v. N.Y. State Dep’t of Transp., 55 F. App’x 583, 585 (2d Cir. 2003) (summary order)); Def.’s Opp’n at 6 (citing Mario v. P & C Food Mkts., Inc., 313 F.3d 758

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Bluebook (online)
Livevideo.AI Corp v. Redstone et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/livevideoai-corp-v-redstone-et-al-nysd-2025.