Cortes-Ramos v. Sony Corporation of America, 889 F.3d 24

In July 2014 Luis Adrián Cortés‑Ramos sued Sony and related entities over a songwriting contest, asserting federal and Puerto Rico claims, including copyright claims under 17 U.S.C. § 505.
The district court dismissed all claims with prejudice, finding they were subject to mandatory arbitration under a contest agreement and, alternatively, for failure to state a claim under Rule 12(b)(6).
This Court affirmed the dismissal only insofar as it compelled arbitration, noting the claims were not extinguished but left to the arbitrator.
After the appeal, defendants moved for attorney’s fees under the Copyright Act, § 505, and the district court awarded $47,601.78.
Cortés‑Ramos appealed the fee award, arguing defendants were not "prevailing parties" under § 505 because the arbitration order did not materially alter the parties’ legal relationship.

Issue	Cortés‑Ramos' Argument	Sony's Argument	Held
Whether defendants are "prevailing parties" under § 505 entitled to attorney's fees	No — compelling arbitration is a procedural victory, not a material alteration of legal relationship	Yes — dismissal with prejudice and affirmance support prevailing‑party status and fee award	Reversed — defendants are not prevailing parties because compelling arbitration did not materially alter legal relationship

Sole v. Wyner, 551 U.S. 74 (Sup. Ct. 2007) (prevailing‑party inquiry focuses on material alteration of legal relationship that Congress sought to promote in fee statutes)
Cortés‑Ramos v. Sony Corp. of Am., 836 F.3d 128 (1st Cir. 2016) (appellate decision affirming district court's order compelling arbitration; claims not extinguished)
Next Step Med. Co. v. Johnson & Johnson Int'l, 619 F.3d 67 (1st Cir. 2010) (compelled arbitration leaves claims to arbitrator and does not extinguish them)