T-Peg v. Vermont Timber Works

2007 DNH 125
CourtDistrict Court, D. New Hampshire
DecidedOctober 11, 2007
Docket03-CV-462-SM
StatusPublished
Cited by1 cases

This text of 2007 DNH 125 (T-Peg v. Vermont Timber Works) 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 Works, 2007 DNH 125 (D.N.H. 2007).

Opinion

T-Peg v . Vermont Timber Works 03-CV-462-SM 10/11/07 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 . 2007 DNH 125 Vermont Timber Works, Inc. and Douglas S . Friant, Defendants

O R D E R

Before the court is plaintiffs’ objection (document n o . 120)

to an order of the magistrate judge (document n o . 5 2 ) , in which

it was determined that “plaintiff has committed itself to

statutory damages and has made an election under [17] U.S.C. §

504(c).” Based upon that determination, the magistrate ordered

plaintiff to “amend its complaint to conform with [its] election”

and ruled that plaintiff would “not be permitted to seek actual

damages and any additional profits.” For the reasons given

below, the magistrate’s order is modified.

Under Federal Rule of Civil Procedure 72(a), “[t]he district

judge in the case must consider timely objections [to the

pretrial orders of a magistrate judge on nondispositive matters] and modify or set aside any part of [such an] order that is

clearly erroneous or is contrary to law.”

At issue here is the magistrate judge’s construction of a

September 2 9 , 2004, letter from plaintiffs’ counsel to

defendants’ counsel, written in the context of a dispute over

defendants’ attempt to discover information related to

plaintiffs’ alleged lost profits. That letter stated, in

pertinent part:

I continue to reject your assertions concerning our responses to discovery you have propounded. My client, however, does not desire to expend further resources fighting over this issue.

Accordingly, my client has instructed me to inform you that it will not seek any damages arising out of its lost profits, and will seek disgorgement of Vermont Timber Works’ profits and statutory damages, along with interest and attorneys fees. . . .

My client’s election, however, makes discovery concerning Vermont Timber Works’ profits directly relevant to this action, as it has been all along.

(Pl.’s O b j . (document n o . 1 2 0 ) , Ex. A.) According to the

magistrate judge’s order, the September 29 letter announced an

election by plaintiffs to relinquish any claim for defendants’

profits and to pursue statutory damages only.

2 Under 17 U . S . C . § 504(a), “an infringer of copyright is

liable for either— (1) the copyright owner’s actual damages and

any additional profits of the infringer, as provided by

subsection ( b ) ; or (2) statutory damages, as provided by

subsection (c).” “Remedies for infringement under the Copyright

Act of 1976 may be pleaded in the alternative.” Oboler v .

Goldin, 714 F.2d 2 1 1 , 213 (2d Cir. 1983). Regarding the timing

of a plaintiff’s choice between the two permissible forms of

recovery, “[t]he copyright owner may elect, at any time before

final judgment is rendered, to recover, instead of actual damages

and profits, an award of statutory damages.” 17 U . S . C . §

504(c)(1) (emphasis added); but see 4 MELVILLE B . NIMMER & DAVID

NIMMER, NIMMER ON COPYRIGHT § 14.04[A], at 14-67 (2007) (“it would

seem that, in those cases in which the defendant has requested a

trial by jury, the plaintiff’s last opportunity to elect

statutory damages effectively matures when the case is submitted

to the jury for deliberation”).

In Latin American Music C o . v . Spanish Broadcasting Systems,

Inc., 866 F . Supp. 780 ( S . D . N . Y . 1994), the court ruled that

“once a plaintiff elects statutory damages he may no longer seek

actual damages,” id. at 782 (citing Twin Peaks Prods., Inc. v .

Publ’ns Int’l, Ltd., 996 F.2d 1366, 1380 (2d Cir. 1993); Oboler,

3 714 F.2d at 2 1 3 ) , and went on to explain that “if a plaintiff is

unable to demonstrate actual damages, he is restricted to an

award of statutory damages,” id. (citing Lottie Joplin Thomas

Trust v . Crown Publishers, Inc., 592 F.2d 6 5 1 , 657 (2d Cir.

1978); Robert Stigwood Group Ltd. v . O’Reilly, 530 F.2d 1096,

1101 n.11 (2d Cir. 1976); Plymouth Music C o . v . Magnus Organ

Corp., 456 F. Supp. 676, 681 (S.D.N.Y. 1978). However, neither

Latin American Music nor any of the cases upon which it relies

appear to have involved a copyright owner, like the one in this

case, who gave up actual damages while seeking to retain the

opportunity, at a later date, to elect between the infringer’s

additional profits and statutory damages. Accordingly, the

statement in Latin American Music to the effect that a

plaintiff’s inability to prove actual damages limits that

plaintiff to the recovery of statutory damages has no application

to this case.

Moreover, none of the cases mentioned above – nor any other

case the court has been able to find – stands for the proposition

that a plaintiff’s decision to forego one of the two elements of

damages under § 504(a)(1) necessarily requires a renunciation of

both forms of § 504(a)(1) damages, and commits a plaintiff to an

irrevocable election of § 504(a)(2) damages. In Business Trends

4 Analysts, Inc. v . The Freedonia Group, Inc., 700 F. Supp. 1213

(S.D.N.Y. 1988), the trial court awarded a copyright owner the

infringer’s profits, notwithstanding the plaintiff’s failure “to

establish actual damages as a consequence of the infringement

under 17 U.S.C. § 504(a),” id. at 1237, necessarily concluding

that an infringer’s profits are available to a prevailing

copyright owner who does not also recover its own actual damages.

Finally, in the only two reported cases to hold an election of

remedies to be irrevocable, the attempt to revisit a prior

election took place after final judgment, on appeal. See Jordan

v . Time, Inc., 111 F.3d 1 0 2 , 104 (11th Cir. 1997) (“A plaintiff

is precluded from electing statutory damages and then appealing

the award of actual damages; plaintiff does not get two bites of

the apple.”); Twin Peaks, 996 F.2d at 1380 (“We do not think the

election continues into the appellate stage. Once a plaintiff

has elected statutory damages, it has given up the right to seek

actual damages and may not renew that right on appeal by cross-

appealing to seek an increase in the actual damages.”). In

short, there is nothing in either the Copyright Act or the

decisional law to suggest that a copyright owner’s choice to

waive its own actual damages irrevocably limits it to the

recovery of statutory damages.

5 Defendants’ arguments to the contrary are unavailing.

First, notwithstanding counsel’s use of the word “election” in

the September 29 letter, that letter cannot reasonably be read as

a § 504(c) election. In plain language, plaintiffs’ counsel gave

up a claim for actual damages, but forestalled, permissibly, an

election between defendants’ profits and statutory damages.

Moreover, plaintiffs are not attempting to recover, nor would

they be entitled to recover, both defendants’ profits and

statutory damages. See NIMMER & NIMMER, supra, § 14.01[B]

(“Contrary to some decisions under the 1909 Act, it is further

clear, under the current Act, that an election to recover

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Related

Fritz v. Brown and Daly
2007 DNH 104 (D. New Hampshire, 2007)

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2007 DNH 125, Counsel Stack Legal Research, https://law.counselstack.com/opinion/t-peg-v-vermont-timber-works-nhd-2007.