Mech-Tech College, LLC v. Friger-Salgueiro
3:19-cv-01690
D.P.R.Mar 29, 2021Background
- Plaintiff Artificial Intelligence, Corp. (AIC) produces a TV program "Mech-Tech Racing" and created short automotive review "capsules" beginning ~2007; AIC paid production costs.
- Defendant Osvaldo Friger worked on those capsules under a contract from Nov 2010 to Oct 2017.
- AIC alleges that in or about January 2019 Friger (and/or his company) publicly displayed and commercially exploited three identified review capsules on Friger’s personal YouTube channel without AIC’s consent.
- Friger filed a state-court suit in Dec 2018 asserting unauthorized use of his image; AIC registered copyrights for the three capsules on May 2, 2019 (after the state suit).
- Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing AIC’s pleadings were conclusory, the challenged videos appeared on Mech Tech’s (not Friger’s) YouTube channel, and the claim reflected forum shopping.
- The district court granted the motion in part: it dismissed all claims against Friger Entertainment, LLC with prejudice but denied dismissal as to Friger individually, finding AIC’s amended complaint states a plausible copyright-infringement claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pleading sufficiency for copyright infringement | AIC alleges unauthorized public display and commercial exploitation of three identified capsules, with registration information and dates | Allegations are conclusory; screenshots show videos on Mech Tech’s YouTube, not Friger’s; videos in public domain | Complaint states a plausible claim as to Friger individually; survives 12(b)(6) |
| Copyright ownership / registration timing | AIC owns copyrights and registered the capsules (registration May 2, 2019) | Implied attack on timing and strength of claim because registration post-dates some events | Court accepted ownership allegation for pleading purposes; factual disputes left for discovery |
| Use of defendants’ extrinsic screenshots | AIC alleges display in Jan 2019 | Defendants submitted screenshots showing no Mech Tech videos on Friger’s channel (but screenshots are from later date) | Court declined to treat post‑complaint screenshots as dispositive at pleading stage; accepted complaint allegations as plausible |
| Corporate liability of Friger Entertainment, LLC | AIC named Friger Entertainment as co-defendant | Defendants argued the corporation had no involvement in the alleged exploitation | Court found allegations insufficient as to the corporation and dismissed all claims against Friger Entertainment, LLC with prejudice |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (establishes the "plausibility" pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (applies and refines Twombly; discard legal conclusions at pleading stage)
- Feist Publ'ns, Inc. v. Rural Tel. Servs. Co., 499 U.S. 340 (copyright-infringement requires ownership and copying)
- Mag Jewelry Co. v. Cherokee, Inc., 496 F.3d 108 (1st Cir. 2007) (two-element framework for copyright claims)
- Johnson v. Gordon, 409 F.3d 12 (1st Cir. 2005) (actionable copying requires substantial similarity)
- Sepúlveda-Villarini v. Dep’t of Educ. of P.R., 628 F.3d 25 (1st Cir. 2010) (pleading facts must make claim plausible, not merely conceivable)