Cortes-Ramos v. Sony Corporation of America
Opinion
*25 This appeal is from an order granting a motion for attorney's fees pursuant to the Copyright Act. We reverse.
On July 28, 2014, the plaintiff, Luis Adrián Cortés-Ramos, filed a complaint in the District of Puerto Rico against Sony Corporation of America (Sony) and other related defendants, in connection with a songwriting contest that Sony had co-sponsored. The suit alleged various claims under Puerto Rico and federal law, including claims under the Copyright Act.
The District Court dismissed with prejudice all of the claims on the grounds that they were subject to mandatory arbitration pursuant to an agreement that Cortés-Ramos had signed when he entered the contest and that he had failed to allege facts sufficient to support his claims under Fed. R. Civ. P. 12(b)(6). We affirmed the District Court's order dismissing the claims.
See
Cortés-Ramos
v.
Sony Corp. of Am.
,
The defendants then moved for attorney's fees pursuant to § 505 of the Copyright Act, which provides for a "reasonable attorney's fee to the prevailing party."
Cortés-Ramos now argues that the District Court erred in awarding attorney's fees because the defendants do not qualify as prevailing parties under § 505. We agree.
In evaluating a similarly worded attorney's fees provision to the one that we confront here,
see
When these parties were last before us on appeal, we did affirm the District Court's order dismissing Cortés-Ramos' claims (including the Copyright Act claims) "with prejudice."
Cortés-Ramos
,
Thus, the only material alteration in the parties' legal relationship concerning the Copyright Act arises from a ruling regarding the forum in which Cortés-Ramos'
*26
Copyright Act claims must be heard. But, the Copyright Act-unlike the Federal Arbitration Act,
see
We therefore reverse the order of the District Court granting attorney's fees to the defendants.
Reference
- Full Case Name
- Luis Adrián CORTÉS-RAMOS, Plaintiff, Appellant, v. SONY CORPORATION OF AMERICA, Sony ATV Music Publishing, LLC, Sony Music Holdings Inc., Agent of Sony Music Entertainment, Sony Pictures Television, Inc., Sony Music Brazil, Sony Electronics, Inc., Defendants, Appellees, Enrique Martin-Morales, A/K/A Ricky Martin, Defendant.
- Cited By
- 6 cases
- Status
- Published