Stebbins v. Rebolo

CourtDistrict Court, N.D. California
DecidedJuly 11, 2022
Docket4:22-cv-00546
StatusUnknown

This text of Stebbins v. Rebolo (Stebbins v. Rebolo) 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
Stebbins v. Rebolo, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 DAVID A. STEBBINS, Case No. 22-cv-00546-JSW

8 Plaintiff, ORDER LIFTING STAY, SCREENING 9 v. COMPLAINT, AND DISMISSING CASE 10 EMILY REBOLO, et al., Re: Dkt. Nos. 8, 14 Defendants. 11

12 13 On February 23, 2022, the Court issued an order staying this case pending resolution of 14 of Stebbins v. Polano, 4:21-cv-4184-JSW (the “Related Case”). (See Dkt. No. 14.) On July 7, 15 2022, the Court issued an order dismissing the Related Case. Now that the Related Case is 16 resolved, the Court HEREBY LIFTS THE STAY. 17 The original complaint was filed on January 27, 2022, and the matter was randomly 18 assigned to Magistrate Judge Kim. On February 3, 2022, Judge Kim granted Plaintiff’s request to 19 proceed in forma pauperis but ordered a hold on service while the motion to relate this matter to 20 Stebbins v. Polano was decided. (Dkt. No. 8.) The cases were related, and this matter was 21 reassigned to the undersigned. (Dkt. Nos. 9-10.) Shortly thereafter, the Court stayed the case 22 pending resolution of the Related Case because a ruling in that case “will be relevant and 23 potentially fully dispositive in the present case.” (Dkt. No. 14.) Now that the stay is lifted and 24 because Plaintiff is proceeding in forma pauperis, the Court must screen Plaintiff’s complaint 25 under 28 U.S.C. section 1915 (“Section 1915”). 26 Under Section 1915(e)(2)(B), the Court must dismiss an in forma pauperis action if the 27 Court finds that the action “fails to state a claim on which relief may be granted” or that the action 1 319, 324 (1989). Section 1915(e)(2) parallels the language of Federal Rules of Civil Procedure 2 12(b)(6) regarding dismissals for failure to state a claim. See 28 U.S.C. § 1915(e)(2); see also 3 Lopez v. Smith, 203 F.3d 1122, 1126-27 (9th Cir. 2000). The complaint therefore must allege 4 facts that plausibly establish each defendant’s liability. See Bell Atl. Corp. v. Twombly, 550 U.S. 5 544, 555-57 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that 6 allows the court to draw the reasonable inference that the defendant is liable for the misconduct 7 alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A complaint is “frivolous” where it lacks 8 an arguable basis either in law or in fact. Neitzke, 490 U.S. at 325 (definition of “frivolous . . . 9 embraces not only the arguable legal conclusion, but also the fanciful factual allegation”). As the 10 United States Supreme Court has explained: 11 [the in forma pauperis statute] is designed largely to discourage the filing of, and waste of judicial and private resources upon, baseless 12 lawsuits that paying litigants generally do not initiate because of the costs of bringing suit . . . .[It affords] judges not only the authority to 13 dismiss a claim based on an indisputably meritless legal theory, but also the unusual power to pierce the veil of the complaint's factual 14 allegations and dismiss those claims whose factual contentions are clearly baseless. 15 Neitzke, 490 U.S. at 327-28 (emphasis added). “Dismissals on these grounds are often made sua 16 sponte prior to the issuance of process, so as to spare prospective defendants the inconvenience 17 and expense of answering such complaints.” Id. at 324. 18 Plaintiff brings this complaint about the infringement of several purportedly copyrighted 19 works. (See FAC ¶¶ 19-39.) “To establish to establish infringement of a copyright, two elements 20 must be proven: (1) ownership of a valid copyright, and (2) copying of constituent elements of the 21 work that are original.” Feist Publications, Inc. v. Rural Tel. Serv., Co., 499 U.S. 340, 361 (1991). 22 Plaintiff’s claims based on infringement of the April 10, 2021 livestream are dismissed 23 with prejudice. The Court dismissed, with prejudice, Plaintiff’s claims based on this livestream in 24 the Related Case, Stebbins v. Polano, 4:21-cv-4184-JSW, on the basis that the livestream lacks 25 creativity and human authorship because the recording occurred unbeknownst to Plaintiff. (See 26 Related Case, Dkt. No. 157.) For this reason, the copyright infringement claims based on the 27 April 10, 2021 livestream are dismissed, with prejudice, for failure to state a claim. 1 Plaintiff also brings copyright infringement claims against several defendants based on the 2 use of ten 2D images. (FAC ¶¶ 33-39.) The U.S. Copyright Office rejected Plaintiff’s request to 3 register the images for copyright protection because they are “basic geometric shapes,” which lack 4 sufficient creativity and human authorship for copyright protection lacked sufficient creativity. 5 (Id. ¶¶ 39, 161.) Based on the Copyright Office’s refusal, Plaintiff does not have a presumption of 6 validity over the 2D images. 7 Furthermore, Plaintiff’s allegations fall short of establishing the copyrightability of the 2D 8 images. As described in the complaint, the images are a “blue honeycomb background” 9 comprised of hexagons. (Id. ¶ 161.) But as the U.S. Copyright Office found, there is no copyright 10 protection for basic geometric shapes. Nevertheless, Plaintiff alleges the images meet the standard 11 for creativity because he put the “hexagons in a honeycomb pattern with a gradiant [sic] color 12 scheme.” (Id.) As alleged, the Court concludes that there is an insufficient degree of creativity in 13 the arrangement and selection of the hexagons to qualify for copyright protection. For this reason, 14 the Court dismisses the copyright infringement claims based on the ten 2D images. 15 Finally, Plaintiff asserts additional copyright infringement claims based on the alleged 16 copying of other livestream videos. (See FAC ¶¶ 26-32.) Plaintiff registered these livestreams 17 with the U.S. Copyright Office. (See id. ¶¶ 27-28, 30, 32.) Although registration constitutes 18 “prima facie evidence of the validity of the copyright,” the presumption of validity may be 19 overcome by some evidence or proof to dispute or deny the plaintiff’s prima facie case of 20 infringement. Lamps Plus, Inc. v. Seattle Lighting Fixture Co., 345 F.3d 1140, 1145 (9th Cir. 21 2003) (citation omitted); see also Neitzke, 490 U.S. at 327 (“[Section 1915] accords judges…the 22 unusual power to pierce the veil of the complaint’s factual allegations and dismiss those claims 23 whose factual contentions are clearly baseless.”). 24 Here, the Court has sufficient evidence to dispute the presumption of validity afforded by 25 registration. In the Related Case, the record showed that Plaintiff did not disclose the true nature 26 and circumstances of the April 10, 2021 livestream video to the U.S. Copyright Office in his 27 registration application. (See Related Case, Dkt. Nos. 138, 157.) Thus, although Plaintiff 1 presumption of validity, and upon examination of the allegations in the complaint, determined the 2 April 10, 2021 was not copyrightable. (Id., Dkt. No. 157.) The Court finds that Plaintiff’s proven 3 lack of candor in his prior application overcomes the presumption of validity afforded by 4 registration of the other livestream videos. 5 Without the presumption of validity, Plaintiff’s allegations of ownership regarding the 6 additional livestreams are insufficient.

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
David Stebbins v. Microsoft
520 F. App'x 589 (Ninth Circuit, 2013)
David Stebbins v. Rita Stebbins
575 F. App'x 705 (Eighth Circuit, 2014)
Lopez v. Smith
203 F.3d 1122 (Ninth Circuit, 2000)
Lamps Plus, Inc. v. Seattle Lighting Fixture Co.
345 F.3d 1140 (Ninth Circuit, 2003)

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Stebbins v. Rebolo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stebbins-v-rebolo-cand-2022.