Eleventh Circuit: One-satisfaction rule applies to copyright infringement awards

In a decision this week, the Eleventh Circuit reversed the decision of a district court, holding the "one-satisfaction rule" does apply to infringement claims under the Copyright Act.

This appeal arose out of a jury award to copyright plaintiff of almost $1.6 million against two defendants who infringed the plaintiff's rights in its used boat price guide.  Pursuant to the one-satisfaction rule, the two defendants moved the district court to reduce the final judgment against them by the amounts the plaintiff obtained from co-defendants that settled before trial.  The district court declined.

The Eleventh Circuit held that the one-satisfaction rule, drawn from Rule 60(b)(5), is an appropriate rule to seek credit for settlement amounts obtained against joint tortfeasors.  As a result, the court vacated and remanded the matter to the district court to reduce the award by the amount the plaintiff had already received from the settling codefendants.

More detail of BUC Int'l Corp. v. Int'l Yacht Council Ltd. after the jump.


Eleventh Circuit: copyright in compilations of used boat listings infringed

In a decision yesterday, the Eleventh Circuit affirmed the finding of copyright infringement of a factual compilation, specifically a compilation of listings of used boats for sale.

Most notably, the court held that the proper standard for infringement was the "substantially similar" test, rather than the "virtually identical" test sometimes used for factual compilations (most often for computer programs).  Under this standard, the court affirmed the finding of infringement, and concomitant injunction and award of damages.

More details of BUC Int'l Corp. v. Int'l Yacht Council Ltd. after the jump.


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