LADS Network Solutions, Inc. v. Agilis Systems, LLC
138 F.4th 1059
| 8th Cir. | 2025Background
- LADS Network Solutions, Inc. sued Agilis Systems, LLC, alleging copyright infringement related to courier management software (GPStrac) after Agilis's license expired.
- LADS's copyright application claimed the first publication date as May 1, 2000, but the source code submitted included references that did not exist on that date.
- The Copyright Office originally found a discrepancy (a 2004 notice in the code) and allowed LADS to resubmit with corrected code or alter the publication date; LADS resubmitted what it believed was the correct code.
- Agilis, in defending against the lawsuit, argued that inaccuracies in LADS's copyright application (the API date references) were knowingly submitted, warranting invalidation under 17 U.S.C. § 411(b).
- The district court granted summary judgment to Agilis, invalidating LADS's copyright for alleged knowing falsehoods in its application; LADS appealed.
- The Eighth Circuit reversed, finding genuine factual disputes as to actual knowledge or willful blindness by LADS regarding the problematic API references in the deposited code.
Issues
| Issue | Plaintiff's Argument (LADS) | Defendant's Argument (Agilis) | Held |
|---|---|---|---|
| Whether inclusion of inaccurate publication date in application, if done with knowledge, invalidates copyright under 17 U.S.C. § 411(b) | LADS did not knowingly submit inaccurate code; required actual knowledge or intent to defraud | API references show LADS knew code was newer than claimed; knowledge alone suffices | There is a genuine factual dispute about knowledge; summary judgment reversed |
| Does § 411(b) require actual knowledge or intent to defraud? | Argues for higher standard (intent to defraud) | Argues that actual knowledge or willful blindness is sufficient | Court need not resolve: Agilis not entitled to SJ even on lower standard |
| Was the code submitted to the Copyright Office with knowledge of its inaccuracy? | No evidence the employee or LADS knew API's creation date | API references in code prove knowledge | API references alone do not establish actual knowledge; factual dispute |
| Did the district court err in granting summary judgment on the copyright's validity? | Genuine factual dispute precludes summary judgment | No genuine dispute; knowledge evident | Summary judgment was error; case remanded for further proceedings |
Key Cases Cited
- Unicolors, Inc. v. H&M Hennes & Mauritz, L.P., 595 U.S. 178 (2022) (interprets § 411(b) and knowledge requirement for copyright application inaccuracies)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard; burden shifting framework)
- Global-Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (2011) (willful blindness as a form of knowledge)
- Turner v. XTO Energy, Inc., 989 F.3d 625 (8th Cir. 2021) (standard of review for summary judgment)