Baronius Press Ltd v. Faithlife Corporation
2:22-cv-01635
| W.D. Wash. | May 1, 2024Background
- Baronius Press Ltd. sued Faithlife Corporation for copyright infringement and violations of the Digital Millennium Copyright Act (DMCA) regarding three works related to a religious text originally in German and its English translations.
- The works at issue are: (1) the original German book “Grundriss der katholischen Dogmatik,” (2) an English translation called the Lynch Translation (1955), and (3) a revised English version by Baronius published in 2018.
- Baronius asserts rights through contracts and assignments, specifically from Nova & Vetera for the Grundriss and Revised Edition, and from Mercier Press for the Lynch Translation.
- All Baronius’ claims survived Faithlife's motion to dismiss, although the court found limitations and ambiguities about the scope of Baronius’s ownership rights.
- Baronius moved for reconsideration of the dismissal order, arguing the court erred in its conclusions about ownership and the scope of its enforcement rights.
- The district court (Judge Tana Lin) denied the motion for reconsideration due to both procedural and substantive deficiencies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether reconsideration is proper under Rules 59/60 | Motion timely/appropriate under FRCP 59(e) and 60(b) | Order is interlocutory, not subject to these rules | Motion not proper; authority comes from local rule |
| Timeliness and compliance with local rules | Delay excusable, no prejudicial intent or gamesmanship | Motion overlength and untimely | Motion denied as untimely and overlength |
| Scope of ownership rights | Baronius owns/has rights to German work and derivatives | Baronius limited to rights based on written contract | Baronius limited to rights explicitly in contract |
| Effect of "new" evidence on ownership | New evidence expands/rightly clarifies ownership | Evidence cumulative or insufficient under Copyright Act | Written contract controls, new evidence immaterial |
Key Cases Cited
- City of Los Angeles, Harbor Div. v. Santa Monica Baykeeper, 254 F.3d 882 (9th Cir. 2001) (court's inherent authority governs reconsideration of interlocutory orders)
- Effects Assocs., Inc. v. Cohen, 908 F.2d 555 (9th Cir. 1990) (section 204 of Copyright Act requires written transfer of copyright ownership)
- Marlyn Nutraceuticals, Inc. v. Mucos Pharma GmbH & Co., 571 F.3d 873 (9th Cir. 2009) (motions for reconsideration should be granted only in highly unusual circumstances)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (courts do not accept legal conclusions as true at the motion to dismiss stage)