Synopsys, Inc. v. Sunlune Corporation, 5:24-cv-00220

Synopsys, Inc., a leading electronic design automation (EDA) software company, accused Sunlune Corporation of using counterfeit license keys to access Synopsys’ software beyond the scope of its license, and to access unlicensed products.
Synopsys does not sell its software, instead licensing it to customers who must use license keys that limit and regulate access.
Sunlune, a chip design company, had an EULA with Synopsys and was licensed for only select software, but used counterfeit keys over 11,000 times (potentially over 15,000) to bypass Synopsys’ technological access controls.
Sunlune did not appear in court through counsel, despite repeated court instructions that corporations must appear through licensed attorneys in federal court.
Synopsys sought default judgment under the DMCA after Sunlune failed to properly defend; prior restraining and preliminary injunctions had already barred Sunlune from using Synopsys’ software.
The court granted Synopsys’ motion for default judgment, awarding $27.5 million in statutory damages and imposing a permanent injunction; it dismissed the breach of contract claim without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Sunlune violate the DMCA by circumventing Synopsys’ technological measures?	Sunlune used counterfeit keys to bypass access controls and access protected software.	No properly advanced argument; Sunlune failed to appear through counsel.	Yes; sufficient evidence of circumvention and willful misconduct.
Should maximum statutory damages be awarded under the DMCA for each act of circumvention?	Sunlune’s conduct was egregious and willful, justifying maximum damages of $2,500 per violation.	No argument presented by defendant.	Yes; maximum statutory damages appropriate given willful, repeated violations and spoliation of evidence.
Is permanent injunctive relief appropriate under the DMCA?	Necessary to prevent further unauthorized access and future harm.	No argument presented by defendant.	Yes; permanent injunction granted, tailored to prohibit unauthorized access.
Was default judgment procedurally proper given Sunlune’s failure to appear through counsel?	Failure to appear through counsel and disregard for court orders left Synopsys with no other recourse.	Attempted to appear pro se, but not permitted for corporations.	Yes; default judgment was procedurally and substantively proper.

Aldabe v. Aldabe, 616 F.2d 1089 (9th Cir. 1980) (outlines court’s discretion for entering default judgment)
Daimler AG v. Bauman, 571 U.S. 117 (2014) (personal jurisdiction over corporations)
Fair Hous. of Marin v. Combs, 285 F.3d 899 (9th Cir. 2002) (well-pled allegations in default context deemed true)
MDY Indus., LLC v. Blizzard Ent., Inc., 629 F.3d 928 (9th Cir. 2010) (DMCA’s anticircumvention rights are distinct from copyright infringement)
TeleVideo Sys., Inc. v. Heidenthal, 826 F.2d 915 (9th Cir. 1987) (default judgment procedural standards)