Baronius Press Ltd v. Faithlife Corporation
2:22-cv-01635
| W.D. Wash. | Feb 4, 2025Background
- The case involves Baronius Press Ltd. (plaintiff) suing Faithlife Corporation (defendant) for copyright infringement and DMCA violations concerning two works: the original German-language "Grundriss der katholischen Dogmatik" and its English translations (the Lynch Translation and a 2018 Revised Translation).
- Baronius obtained rights to the Lynch Translation from Mercier Press and claims an exclusive license to produce an English edition from Nova (the Revised Translation).
- Faithlife, for a few months in 2019, made the Lynch Translation available and sold 75 copies.
- Baronius' complaint asserted four claims: two for copyright infringement (related to Grundriss English Edition and the Lynch Translation) and two DMCA claims.
- The district court previously dismissed Baronius' claims related to the German original, finding Baronius only had rights to the revised English translation; however, infringement claims as to the Revised Translation survived.
- A joint stipulation later confirmed Baronius did not allege Faithlife published the Revised Translation, prompting Faithlife’s Rule 11 motion for sanctions against claims 1 and 3, arguing there was no factual basis left for these claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Baronius has a factual/legal basis for claiming rights to "Grundriss English Edition" (Claim 1) | License agreement gives rights to any English translation of Grundriss | Baronius only has rights to publish the 2018 Revised Translation | Sufficient factual basis exists; claim not legally or factually baseless |
| Whether Baronius' DMCA claim (Claim 3) survives if Claim 1 does | DMCA claim tied to copyright claim over English Edition | DMCA claim baseless since underlying copyright claim has no support | DMCA claim survives because underlying claim survives |
| Whether Baronius acted in bad faith or without factual basis under Rule 11 | Argument not made in bad faith; confusion over term definition | Claims have no factual basis after new stipulation; sanctions warranted | No bad faith found; sanctions not warranted |
| Whether issue of contract interpretation should have been argued earlier | Admitted could have been argued earlier, but oversight not in bad faith | Should have been presented at motion to dismiss or in complaint | Late argument not grounds for sanctions, no evidence of bad faith |
Key Cases Cited
- Christian v. Mattel, Inc., 286 F.3d 1118 (9th Cir. 2002) (Rule 11 requires filings to be grounded in fact and law and not filed for improper purpose)
- Fink v. Gomez, 239 F.3d 989 (9th Cir. 2001) (Court’s inherent power to impose sanctions for bad faith or vexatious conduct)
- Golden Eagle Distrib. Corp. v. Burroughs Corp., 801 F.2d 1531 (9th Cir. 1986) (Rule 11's purpose to deter frivolous claims and unnecessary litigation costs)