T-Peg v. Vermont Timber

2005 DNH 152
CourtDistrict Court, D. New Hampshire
DecidedNovember 8, 2005
Docket03-CV-462-SM
StatusPublished
Cited by1 cases

This text of 2005 DNH 152 (T-Peg v. Vermont Timber) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
T-Peg v. Vermont Timber, 2005 DNH 152 (D.N.H. 2005).

Opinion

T-Peg v . Vermont Timber 03-CV-462-SM 11/08/05 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

T-Peg, Inc. and Timberpeg East, Inc., Plaintiffs

v. Civil N o . 03-cv-462-SM Opinion N o . 2005 DNH 152 Vermont Timber Works, Inc. and Douglas S . Friant, Defendants

O R D E R

Defendants (collectively “VTW”) prevailed in plaintiffs’

(collectively “Timberpeg”) copyright infringement suit.

Defendants now move for costs and attorneys’ fees. Plaintiffs

object. For the reasons given below, VTW’s motion for attorneys’

fees is granted.

Under the Copyright Act, “the court in its discretion . . .

may . . . award a reasonable attorney’s fee to the prevailing

party as a part of the costs.” 17 U.S.C. § 505. A number of

factors are properly considered in determining fee awards.

These factors include “frivolousness, motivation, objective unreasonableness (both in the factual and in the legal components of the case) and the need in particular circumstances to advance considerations of compensation and deterrence.” Lieb v . Topstone Industries, Inc., 788 F.2d 1 5 1 , 156 ([3d Cir.] 1986). We agree that such factors may be used to guide courts’ discretion, so long as such factors are faithful to the purposes of the Copyright Act and are applied to prevailing plaintiffs and defendants in an evenhanded manner.1

Fogerty v . Fantasy, Inc., 510 U.S. 5 1 7 , 534 n.19 (1994). When

assessing factors such as frivolousness and objective

unreasonableness, the analysis should focus on what a party knew

when it pressed a claim or defense, rather than on what decisions

that party might have made with the benefit of the court’s

subsequent resolution of the case. See InvesSys, Inc. v . McGraw-

Hill Cos., 369 F.3d 1 6 , 21 (1st Cir. 2004) (citing Tang v . R.I.

Dep’t of Elderly Affairs, 163 F.3d 7 , 13 (1st Cir. 1998)).

Here, it might be a stretch to say that Timberpeg’s suit was

patently frivolous from the outset. When Timberpeg filed suit,

its agents knew that: (1) Stanley Isbitski was a former

client/customer for whom Timberpeg prepared several sets of house

1 “[T]he overriding purpose of the Copyright Act [is] to encourage the production of original literary, artistic, and musical expression for the public good.” Lotus Dev. Corp. v . Borland Int’l, Inc., 140 F.3d 7 0 , 73 (1st Cir. 1998) (citing Fogerty, 510 U.S. at 5 3 4 ) .

2 plans; (2) one set of Timberpeg’s plans had been placed on file

by Isbitski with the Town of Salisbury; (3) Isbitski showed

Timberpeg’s plans to VTW; (4) VTW designed a post-and-beam frame

to support a portion of the house designed by Timberpeg; and (5)

the house ultimately built on the VTW frame was substantially

similar in appearance and lay-out to the house Timberpeg designed

for Isbitski. Based upon that knowledge, Timberpeg could have

plausibly thought, initially at least, that VTW copied its

architectural plans.

Objective reasonableness, however, is a different matter.

The objective reasonableness inquiry includes an examination of

both the factual basis and the legal basis for a party’s claim or

defense. Fogerty, 510 U.S. at 534 n.19.

Timberpeg argues, based upon the undisputed fact that the

VTW frame was capable of supporting a portion of the house

Timberpeg designed, that it was objectively reasonable for it to

conclude, as a factual matter, that VTW’s “timberframe must have

been prepared on the basis of [Timberpeg’s] architectural plans.”

The reasonableness of that conclusion was bolstered, Timberpeg

3 contends, by its discovery, prior to filing suit, that Isbitski

had actually shown Timberpeg’s plans to a VTW frame designer.

While it might have been objectively reasonable, as a factual

matter, for Timberpeg to have concluded that VTW based its frame

design on the floor plans and elevations Timberpeg had prepared

for Isbitski, it was certainly not reasonable for Timberpeg to

conclude that VTW copied a Timberpeg frame design, since

Timberpeg never designed a frame.

Timberpeg also contends that its legal theory of liability

was objectively reasonable. Relying upon language from Hunt v .

Pasternack, 192 F.3d 877 (9th Cir. 1999), and the legislative

history of the Architectural Works Copyright Protection Act

(“AWCPA”), Timberpeg grounded its copyright infringement claim on

VTW’s “mere use[] of the plans to design a structure, as opposed

to first duplicating the plans [and] then using the duplicated

plans to design/create a structure.” The question, then, is

whether it was objectively reasonable for Timberpeg to assert

that VTW’s timberframe design, or the timberframe itself,

constituted an infringing copy of Timberpeg’s architectural plans

4 or the architectural work embodied in those plans. The answer,

quite plainly, is “no.”

Academic support does exist for the proposition that a

completed building or structure can itself constitute an

infringing copy of an architectural work. See, e.g., Louis

Altman, Copyright on Architectural Works, 33 I D E A 1 , 61 (1992)

(“In contrast to the pre-1990 law, building designs covered by

the Architectural Works Copyright Protection Act can be infringed

not only by copying the design in the form of two-dimensional

plans or drawings or a three-dimensional model, but also by the

construction of a full-sized building which embodies the

protected design . . .”) (footnotes omitted); Andrew S . Pollock,

Comment, The Architectural Works Copyright Protection Act: An

Analysis of Probable Ramifications and Arising Issues, 70 N E B . L .

R E V . 873, 881-87 (1991). Moreover, as Timberpeg correctly notes,

Hunt characterizes the House Report on the A W C P A as making it

“clear that an unconstructed work, embodied only in plans or

drawings, can be infringed by a structure that embodies the

copied design.” 192 F.3d at 880 (emphasis added). And, H . R .

R E P . N o . 101-735, reprinted in 1990 U . S . C . C . A . N . 6935, uses the

5 term “infringing buildings” at several points. Id. at 6944 &

6953 n.50.

S o , it cannot be said that Timberpeg’s legal theory of

liability – that a structure can itself constitute an infringing

copy of an architectural work – was, in the abstract, objectively

unreasonable. But the issue here is more focused. First, VTW

did not design or construct a building that looked like the one

designed by Timberpeg. Indeed, VTW did not design or construct

any building at all; it designed and constructed a discrete

component of a building - a post-and-beam frame. Timberpeg did

not design a post-and-beam frame; it simply designed floor plans

and elevations according to the general specifications provided

by Isbitski. And, the record is clear that a number of

alternative frame types and designs would suffice to support the

building Timberpeg designed.

When Timberpeg filed suit it knew that it had not developed

a frame design for Isbitski (that i s , it never created an

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