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Keywords

damagesliabilitytrialsummary judgmentcopyrightjury trialstatutory damages
damagestrialcopyrightjury trialstatutory damages

Related Cases

Feltner v. Columbia Pictures Television, Inc., 523 U.S. 340, 118 S.Ct. 1279, 140 L.Ed.2d 438, 163 A.L.R. Fed. 721, 98 Copr.L.Dec. P 27,752, 46 U.S.P.Q.2d 1161, 26 Media L. Rep. 1513, 98 Cal. Daily Op. Serv. 2324, 98 Daily Journal D.A.R. 3175, 98 CJ C.A.R. 1542, 11 Fla. L. Weekly Fed. S 417

Facts

Columbia Pictures Television, Inc. terminated licensing agreements with C. Elvin Feltner's television stations due to delinquent royalty payments. Despite the termination, the stations continued to broadcast several television series, prompting Columbia to sue Feltner for copyright infringement. The District Court granted partial summary judgment to Columbia on liability and awarded statutory damages after denying Feltner's request for a jury trial.

Columbia Pictures Television, Inc. terminated licensing agreements with C. Elvin Feltner's television stations due to delinquent royalty payments. Despite the termination, the stations continued to broadcast several television series, prompting Columbia to sue Feltner for copyright infringement.

Issue

Does the Seventh Amendment provide a right to a jury trial on the issue of statutory damages in copyright infringement cases under § 504(c) of the Copyright Act?

Does the Seventh Amendment provide a right to a jury trial on the issue of statutory damages in copyright infringement cases under § 504(c) of the Copyright Act?

Rule

The Seventh Amendment guarantees a right to a jury trial in civil cases where legal rights are at stake, including statutory damages actions that are analogous to common-law causes of action.

The Seventh Amendment provides a right to a jury trial on all issues pertinent to an award of statutory damages under § 504(c), including the amount itself.

Analysis

The Court analyzed the historical context of copyright actions and determined that statutory damages under § 504(c) are akin to common-law actions traditionally tried before juries. The Court found that the consistent practice in copyright cases was for juries to determine the amount of damages, thus affirming the applicability of the Seventh Amendment.

The Court analyzed the historical context of copyright actions and determined that statutory damages under § 504(c) are akin to common-law actions traditionally tried before juries.

Conclusion

The Supreme Court reversed the lower court's decision, holding that the Seventh Amendment provides a right to a jury trial on all issues pertinent to an award of statutory damages under § 504(c) of the Copyright Act.

The Supreme Court reversed the lower court's decision, holding that the Seventh Amendment provides a right to a jury trial on all issues pertinent to an award of statutory damages under § 504(c) of the Copyright Act.

Who won?

Columbia Pictures Television, Inc. prevailed because the Supreme Court ruled that the Seventh Amendment guarantees a jury trial for statutory damages, reversing the lower court's decision that denied this right.

Columbia Pictures Television, Inc. prevailed because the Supreme Court ruled that the Seventh Amendment guarantees a jury trial for statutory damages.

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