After the District Court denied summary judgment, the case went to trial. At the end of Brownstein’s case, the District Court granted Appellees judgment as a matter of law under Rule 50(a) on Brownstein’s joint authorship claim. Fed. R. Civ. P. 50(a). The District Court found that Brownstein’s claim was time-barred and that he could not succeed on the merits of his claim based on the evidence adduced at trial. The District Court severed Appellees’ counterclaim and later issued an opinion granting summary judgment to Appellees on their counterclaim.
This appeal presents two issues of first impression for our Circuit. The first is when a joint authorship claim under the Copyright Act arises and accrues and the second is whether courts have the authority to cancel copyright registrations. For the following reasons, we hold that an authorship claim arises and accrues when a plaintiff’s authorship has been “expressly repudiated”. We also hold that courts have no authority to cancel copyright registrations. We will reverse both the District Court’s grant of judgment as a matter of law to Appellees and its grant of summary judgment to Appellees on their counterclaim. Also, we will remand the case for a new trial.
Judge(s): Joseph A. Greenaway, Jr.
Jurisdiction: U.S. Court of Appeals, Third Circuit
Related Categories: Civil Procedure , Technology
|Circuit Court Judge(s)|
|Joseph Greenaway, Jr.|
|Trial Court Judge(s)|
|Appellant Lawyer(s)||Appellant Law Firm(s)|
|Jay McDaniel||McDaniel Law Firm|
|Appellee Lawyer(s)||Appellee Law Firm(s)|
|Thomas Howard||Kirsch Gartenberg & Howard|