Mattel, Inc. v. Mga Entertainment, Inc.
705 F.3d 1108
| 9th Cir. | 2013Background
- Remand order led to new trial; jury rejected Mattel’s copyright claim against MGA’s Bratz dolls.
- Mattel sought to amend in 2006 to add a trade-secret claim; MGA filed a misappropriation counterclaim in 2010.
- District court denied Mattel’s statute-of-limitations motion, ruling MGA’s counterclaim was compulsory due to logical relationship.
- Jury awarded MGA over $80 million in damages and the district court awarded equal exemplary damages plus fees under both the California USTA and Copyright Act.
- This court vacated the ruling on compulsory counterclaim, remanding to dismiss MGA’s trade-secret claim without prejudice; upheld the copyright fees as exercised properly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MGA’s counterclaim-in-reply was compulsory | Mattel contends counterclaim arises from related facts | MGA argues independent facts justify compulsory status | Counterclaim not compulsory; reversed and remanded |
| Whether the district court properly awarded attorneys’ fees under the Copyright Act | Mattel claims fee award inappropriate if claim reasonable | MGA argues fee award furthers the Act’s purpose | Fees affirmed; district court did not abuse discretion |
Key Cases Cited
- In re Pegasus Gold Corp., 394 F.3d 1189 (9th Cir. 2005) (applies logical relationship test for compulsory counterclaims)
- Moore v. N.Y. Cotton Exch., 270 U.S. 593 (1905) (core facts determine relation of claims)
- Fantasy, Inc. v. Fogerty, 94 F.3d 553 (9th Cir. 1996) (copyright fee discretion; public policy aims of the Act)