Rimini Street, Inc. v. Oracle International Corporation
2:14-cv-01699
| D. Nev. | Aug 15, 2023Background
- Oracle sued Rimini Street and Seth Ravin for copyright infringement, DMCA violations, false advertising, and unfair competition based on Rimini’s copying of Oracle enterprise software and marketing statements.
- After a bench trial the district court ruled largely for Oracle, entered findings of fact and conclusions of law, and issued a permanent injunction requiring Rimini to delete specified code and cease certain marketing statements.
- Rimini appealed and moved for an emergency stay of the injunction pending appeal under Fed. R. Civ. P. 62(d); Oracle opposed and the court held expedited briefing.
- The court evaluated the four Nken/Sierra Club stay factors: likelihood of success, irreparable harm, harm to other parties, and public interest; it found Rimini had not met its burden to justify a stay.
- The court denied Rimini’s stay motion but provisionally granted a temporary administrative stay of the injunction to allow Rimini to seek a stay from the Ninth Circuit, requiring Rimini to file that motion by August 25, 2023 and to notify the district court of the Ninth Circuit’s ruling within five days.
- The court relied on Rimini’s contradictory public statements and prior noncompliance as undermining its irreparable-harm and equity arguments; the court emphasized public interest in preventing false advertising and protecting copyright rights.
Issues
| Issue | Plaintiff's Argument (Oracle) | Defendant's Argument (Rimini) | Held |
|---|---|---|---|
| Likelihood of success on appeal | Bench findings and injunction are correct; injunction supported by evidence | Injunction is overbroad; court misapplied derivative-works and license law; Lanham Act findings flawed | Rimini failed to show a strong likelihood of success; factor disfavors stay |
| Irreparable harm absent stay | Oracle disputes Rimini’s claims of irreparable harm; points to Rimini’s public statements and prior noncompliance | Deleting code, altering processes, and required disclosures will cause irreparable business and First Amendment harms | Court found Rimini’s showing insufficient; close call but overall does not favor stay; however granted temporary administrative stay to permit Ninth Circuit review |
| Substantial injury to other parties | Oracle: continued infringement and false advertising injures Oracle’s customer relationships and business | Rimini: a stay would not harm Oracle; Oracle presented no evidence of harm | Court sided with Oracle — staying would substantially injure Oracle; factor disfavors stay |
| Public interest | Protecting copyrights, preventing false and misleading commercial speech, and enforcing injunctions serves public interest | First Amendment and competition interests favor allowing Rimini to continue operating while appeal proceeds | Court held public interest favors enforcement of the injunction and preventing false advertising |
Key Cases Cited
- Sierra Club v. Trump, 929 F.3d 670 (9th Cir. 2019) (articulating stay factors and standard for stays pending appeal)
- Nken v. Holder, 556 U.S. 418 (U.S. 2009) (governing standard for stays pending appeal)
- Doe #1 v. Trump, 957 F.3d 1050 (9th Cir. 2020) (clarifying irreparable-harm inquiry for stays)
- United States v. Schiff, 379 F.3d 621 (9th Cir. 2004) (fraudulent commercial speech may be enjoined)
- CTIA—The Wireless Ass'n v. City of Berkeley, 928 F.3d 832 (9th Cir. 2019) (First Amendment disclosure principles)
- Al Otro Lado v. Wolf, 952 F.3d 999 (9th Cir. 2020) (discussion of self-inflicted harms and equitable considerations)
- Miller for & on Behalf of N.L.R.B. v. California Pac. Med. Ctr., 991 F.2d 536 (9th Cir. 1993) (injunctions are equitable and governed by equitable principles)