WATSON MUSIC GROUP, LLC. v. FLAVOR GOD LLC
2:24-cv-10582
| D.N.J. | Aug 28, 2025Background
- Watson Music Group, LLC ("Quadrasound") sued FlavorGod LLC and Shredz Supplements LLC ("Defendants") for direct copyright infringement over the unauthorized use of the musical work "Space Jam" in a 2015 Facebook post.
- Plaintiff holds all rights to the musical work via registration and assignment in 2019; the video post was discovered in 2024 and is now removed.
- Plaintiff alleged Defendants posted an unlicensed, discernible excerpt of the work to a Facebook account associated with their business, leading to financial benefit and market harm to Plaintiff.
- Plaintiff filed for default judgment after Defendants failed to appear or respond, seeking statutory damages, attorneys’ fees, costs, post-judgment interest, and a permanent injunction.
- Court found personal and subject matter jurisdiction, and that proper service was made via alternate methods authorized by the court.
- The court ultimately granted default judgment: awarded minimum statutory damages, denied attorneys’ fees, granted costs, post-judgment interest, and a permanent injunction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction & Service | Service properly made and court has jurisdiction | No argument (default) | Jurisdiction and service proper |
| Direct Copyright Infringement | Owns valid copyright and Defendants used it without permission | No argument (default) | Plaintiff stated a legitimate claim |
| Statutory Damages (Amount) | $10,000 justified for willfulness and deterrence | No argument (default) | Only minimum $750 awarded—no evidence for higher amount |
| Attorneys’ Fees/Costs | Entitled to $5,142.50 fees and $583 costs | No argument (default) | Fees denied as unreasonable; costs granted |
| Injunction | Entitled to permanent injunction | No argument (default) | Permanent injunction granted |
Key Cases Cited
- Hritz v. Woma Corp., 732 F.2d 1178 (3d Cir. 1984) (sets discretion standard for default judgment)
- Dun & Bradstreet Software Servs., Inc. v. Grace Consulting, Inc., 307 F.3d 197 (3d Cir. 2002) (elements of direct copyright infringement)
- Schmidt v. Skolas, 770 F.3d 241 (3d Cir. 2014) (judicial notice of public records)
- Mrs. Ressler's Food Prods. v. KZY Logistics LLC, 675 F. App’x 136 (3d Cir. 2017) (culpability presumed on default)
- Comdyne I, Inc. v. Corbin, 908 F.2d 1142 (3d Cir. 1990) (allegations in default taken as true)