Leonard v. Stemtech Health Sciences Inc.
1:08-cv-00067
D. Del.Jul 8, 2014Background
- Litigation involves Leonard v. Stemtech with a jury verdict of $1.6 million for copyright infringement and related injuries.
- Plaintiff sought prejudgment interest from June 1, 2006 at 11% and submitted competing judgment forms.
- Court denied Plaintiff's prejudgment interest request following briefing (D.I. 241).
- Law; Third Circuit recognizes prejudgment interest in copyright cases at district court’s discretion for fairness.
- Court found the verdict already adequately compensates Leonard and interest would be a windfall.
- Court noted substantial difficulty in calculating 92+ separate accrual dates and varying interest rates without an expert analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prejudgment interest may be awarded in copyright case | Leonard seeks interest to fully compensate and deter unjust enrichment | Interest is inequitable and unnecessary given the verdict | Denied; no prejudgment interest awarded |
| Whether awarding interest is feasible given infringement complexity | Interest calculation aligns with full compensation | Calculating 92 accruals is impractical | Denied due to impracticability of precise calculation |
| Whether the verdict already fully compensates Leonard | Verdict plus interest would fully compensate | Verdict already compensates; interest would be windfall | Denied; verdict suffices to compensate |
Key Cases Cited
- William A. Graham Co. v. Haughey, 646 F.3d 138 (3d Cir. 2011) (prejudgment interest permitted in copyright cases at court’s discretion for fairness)
- Pignataro v. Port Authority, 593 F.3d 265 (3d Cir. 2010) (strong presumption in favor of prejudgment interest; explain denial)
- Kansas v. Colorado, 533 U.S. 1 (Sup. Ct. 2001) (monetary awards include interest to fully compensate)
- Booker v. Taylor Milk Co., 64 F.3d 860 (3d Cir. 1995) (strong presumption in favor of prejudgment interest)