J & J Sports Productions, Inc. v. Martin, 4:14-cv-40133

J&J Sports held exclusive commercial (closed‑circuit/sublicensing) distribution rights to the September 17, 2011 boxing program (Mayweather v. Ortiz and undercard).
Marty’s Pub (Martin Enterprises / Edward Martin) showed the Program without a sublicense; a private investigator observed 28–31 patrons and four 42" TVs displaying the broadcast.
Defendants were served but did not answer; clerk entered default and J&J moved for default judgment.
The court could not determine from the record whether the signal was delivered by satellite or cable; adopting the District’s prevailing view, the court assumed a cable interception and applied 47 U.S.C. § 553.
Court awarded J&J actual damages equal to the $2,200 sublicensing fee, enhanced damages of $4,400 for willful commercial interception, attorneys’ fees of $1,250, and costs of $477.84, for a total judgment of $8,327.84 (plus prejudgment interest).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of §605 vs §553	J&J: §605 can apply where pay‑per‑view is transmitted by satellite or otherwise; both statutes were pleaded.	Defendants: (no answer; implied defense would be that §605 may not apply to cable theft per First Circuit).	Court: On record, cannot show satellite; applies §553 (cable theft) as most persuasive view in this District.
Effect of default on liability	J&J: Default concedes factual allegations showing unlawful interception and public exhibition.	Defendants: no response.	Court: Default establishes liability; factual allegations taken as true for damages calculation.
Damages — statutory vs actual and enhancement	J&J: Seeks statutory or actual damages plus enhanced damages for willfulness.	Defendants: no response.	Court: Awards actual damages ($2,200) instead of statutory range and grants enhanced damages ($4,400) for willful commercial conduct.
Attorneys’ fees, costs, and state claims	J&J: Seeks fees and costs; also asserted Chapter 93A and conversion claims.	Defendants: no response.	Court: Awards reasonable attorneys’ fees ($1,250) and costs ($477.84); declines duplicative recovery under Chapter 93A and conversion.

Franco v. Selective Ins. Co., 184 F.3d 4 (1st Cir.) (defaulting party concedes factual allegations for liability and damages calculation)
Charter Comm’ns Entm’t I v. Burdulis, 460 F.3d 168 (1st Cir.) (distinguishing §553 and §605; §553 governs theft of cable service in this Circuit)
PPV Connection, Inc. v. Rodriguez, 607 F. Supp. 2d 301 (D.P.R.) (discussing §605 applicability to licensed pay‑per‑view distributed via satellite/direct means)
Int’l Cablevision, Inc. v. Sykes, 75 F.3d 123 (2d Cir.) (treating interception claims under both §553 and §605 in some circumstances)
Joe Hand Promotions, Inc. v. Wing Spot Chicken & Waffles, Inc., 920 F. Supp. 2d 659 (E.D. Va.) (awarding damages and discussing statutory remedies for unauthorized public exhibition)