Criminal Copyright Infringement - Counsel Must Know of Statute of Limitations Defenses To Enter Plea Agreement

 In United States v. Boyd, 2011 WL 285196 (2d Cir. Jan. 31, 2011), the Second Circuit vacated the district court's decision that a defendant did not have ineffective assistance of counsel in negotiating a criminal copyright infringement plea agreement.   The Defendant tried to vacate his guiltly plea by claiming that his counsel was unware of the five-year statute of limitations applicable to criminal copyright infringement claims.

United States v Boyd

18 U.S.C. § 2319. Criminal infringement of a copyright

(a) Any person who violates section 506 (a) (relating to criminal offenses) of title 17 shall be punished as provided in subsections (b), (c), and (d) and such penalties shall be in addition to any other provisions of title 17 or any other law.
(b) Any person who commits an offense under section 506 (a)(1)(A) of title 17—
(1) shall be imprisoned not more than 5 years, or fined in the amount set forth in this title, or both, if the offense consists of the reproduction or distribution, including by electronic means, during any 180-day period, of at least 10 copies or phonorecords, of 1 or more copyrighted works, which have a total retail value of more than $2,500;
(2) shall be imprisoned not more than 10 years, or fined in the amount set forth in this title, or both, if the offense is a felony and is a second or subsequent offense under subsection (a); and
(3) shall be imprisoned not more than 1 year, or fined in the amount set forth in this title, or both, in any other case.
(c) Any person who commits an offense under section 506 (a)(1)(B) of title 17—
(1) shall be imprisoned not more than 3 years, or fined in the amount set forth in this title, or both, if the offense consists of the reproduction or distribution of 10 or more copies or phonorecords of 1 or more copyrighted works, which have a total retail value of $2,500 or more;
(2) shall be imprisoned not more than 6 years, or fined in the amount set forth in this title, or both, if the offense is a felony and is a second or subsequent offense under subsection (a); and
(3) shall be imprisoned not more than 1 year, or fined in the amount set forth in this title, or both, if the offense consists of the reproduction or distribution of 1 or more copies or phonorecords of 1 or more copyrighted works, which have a total retail value of more than $1,000.
(d) Any person who commits an offense under section 506 (a)(1)(C) of title 17—
(1) shall be imprisoned not more than 3 years, fined under this title, or both;
(2) shall be imprisoned not more than 5 years, fined under this title, or both, if the offense was committed for purposes of commercial advantage or private financial gain;
(3) shall be imprisoned not more than 6 years, fined under this title, or both, if the offense is a felony and is a second or subsequent offense under subsection (a); and
(4) shall be imprisoned not more than 10 years, fined under this title, or both, if the offense is a felony and is a second or subsequent offense under paragraph (2).
(e) (1) During preparation of the presentence report pursuant to Rule 32(c) of the Federal Rules of Criminal Procedure, victims of the offense shall be permitted to submit, and the probation officer shall receive, a victim impact statement that identifies the victim of the offense and the extent and scope of the injury and loss suffered by the victim, including the estimated economic impact of the offense on that victim.
(2) Persons permitted to submit victim impact statements shall include—
(A) producers and sellers of legitimate works affected by conduct involved in the offense;
(B) holders of intellectual property rights in such works; and
(C) the legal representatives of such producers, sellers, and holders.
(f) As used in this section—
(1) the terms “phonorecord” and “copies” have, respectively, the meanings set forth in section 101 (relating to definitions) of title 17;
(2) the terms “reproduction” and “distribution” refer to the exclusive rights of a copyright owner under clauses (1) and (3) respectively of section 106 (relating to exclusive rights in copyrighted works), as limited by sections 107 through 122, of title 17;
(3) the term “financial gain” has the meaning given the term in section 101 of title 17; and
(4) the term “work being prepared for commercial distribution” has the meaning given the term in section 506 (a) of title 17.


















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Nazi Art Looting: Sixth Circuit Cloaks Nazi-Era Atrocities in Sovereign Immunity

Flag of Tennessee

The United States won World War II. As part of the postwar cleanup, the US did everything in its power to undo the damage the Nazis had wrought. Nowhere was this damage more atrocious than in what the Nazis inflicted on the Jewish minority. The Jews were a non-violent, law abiding minority. Nazis expropriated and murdered them wholesale.

Some escaped. Some watched helplessly from abroad as their relatives were murdered. Such was the fate of the Westfield family. Residents of Tennessee, their relative was murdered, his assets auctioned off, the money went to finance the Nazi war machine.

In 1954, the Second Circuit, at the behest of the U.S. State Department, stripped the Nazis of sovereign immunity.

On February 2, 2011, the Nazis got sovereign immunity back in Westfield v. Federal Republic of Germany (6th Cir.).

I have posted the Westfield case below and the full text of the Second Circuit's Bernstein case.   This appears to be a circuit split over whether the Nazis were a criminal conspiracy or whether they were a legitimate government, a question that was resolved against the Nazis at Nuremberg in 1946 in the negative.

The Sixth Circuit did not cite Bernstein, nor did it cite Republic of Austria v. Altmann.  http://en.wikipedia.org/wiki/Republic_of_Austria_v._Altmann

The Sixth Circuit held that murdering Westfield and auctioning off his art collection (part of which is at the Boston Museum of Fine Arts), did not have a "direct effect" in the United States, even though the Nazis knew that his heirs resided in Tennessee.   Art museums in the U.S. today are actively concealing their role in laundering artworks stolen by the Nazis and battling all efforts at disclosure of Nazi-era and post War collecting practices.  U.S. museums now claim that they have a "fiduciary duty" to conceal documents and research relating to the provenance of stolen artworks in their collections and to force dispossessed Holocaust survivors and their heirs to litigate to track the artworks.

The U.S. State Department should intervene in the case and ask the Sixth Circuit to reconsider in light of Bernstein.   Tennessee shouldn't be the only state in the U.S. that lost World War II.

Westfield v Fed Rep of Germany 6th Circuit Feb 2 2011

210 F.2d 375

BERNSTEIN, v. N. V. NEDERLANDSCHE- AMERIKAANSCHE STOOMVAART- MAATSCHAPPIJ

(Chemical Bank& Trust Co., Third-Party Defendant). No. 21193.
United States Court of Appeals, Second Circuit.
Submitted Jan. 11, 1954.
Decided Feb. 5, 1954.
Bennet, House & Couts, New York City, for plaintiff-petitioner; Victor House, Albert I. Edelman and Werner Ilsen, New York City, of counsel.
Burlingham, Hupper & Kennedy, New York City, for defendant Holland-America Line; Harold M. Kennedy, and Harvey C. Allen, Jr., New York City, of counsel.

Sherman & Sterling & Wright, New York City, for Third-Party Defendant, Chemical Bank & Trust Company; John A. Wilson, M. VanVoorhies and Edmond K. Leach, New York City, of counsel.

Petition to amend the mandate of this court handed down in a prior appeal in this case, 173 F.2d 71. Petition granted.

Before AUGUSTUS N. HAND, CLARK and FRANK, Circuit Judges.

Petition to amend the mandate of this court handed down in a prior appeal in this case, 173 F.2d 71. Petition granted.

PER CURIAM.

In the prior appeal in this case, 173 F.2d 71, 75-76, because of the lack of a definitive expression of Executive Policy, we felt constrained to follow the decision of this court in Bernstein v. Van Heyghen Freres Societe Anonyme, 2 Cir., 163 F.2d 246, certiorari denied 332 U.S. 772, 68 S.Ct. 88, 92 L.Ed. 357, by ordering the plaintiff to refrain from alleging matters which would cause the court to pass on the validity of acts of officials of the German government. Following our decision, however, the State Department issued Press Release No. 296 on April 27, 1949, entitled: 'Jurisdiction of United States Courts Re Suits for Identifiable Property Involved in Nazi Forced Transfers.' The substance of this Release follows:
2

'As a matter of general interest, the Department publishes herewith a copy of a letter of April 13, 1949 from Jack B. Tate, Acting Legal Advisor, Department of State, to the Attorneys for the plaintiff in Civil Action No. 31-555 in the United States District Court for the Southern District of New York.
3
'The letter repeats this Government's opposition to forcible acts of dispossession of a discriminatory and confiscatory nature practiced by the Germans on the countries or peoples subject to their controls; states that it is this Government's policy to undo the forced transfers and restitute identifiable property to the victims of Nazi persecution wrongfully deprived of such property; and sets forth that the policy of the Executive, with respect to claims asserted in the United States for restitution of such property, is to relieve American courts from any restraint upon the exercise of their jurisdiction to pass upon the validity of the acts of Nazi officials.'
4
The letter from Mr. Tate is then quoted, pertinent parts of which follow:
5
'1. This Government has consistently opposed the forcible acts of dispossession of a discriminatory and confiscatory nature practiced by the Germans on the countries or people subject to their controls. * * *
6
'3. The policy of the Executive, with respect to claims asserted in the United States for the restitution of identifiable property (or compensation in lieu thereof) lost through force, coercion, or duress as a result of Nazi persecution in German, is to relieve American courts from any restraint upon the exercise of their jurisdiction to pass upon the validity of the acts of Nazi officials.'
7
In view of this supervening expression of Executive Policy, we amend our mandate in this case by striking out all restraints based on the inability of the court to pass on acts of officials in Germany during the period in question. See 173 F.2d at pages 75-76. This will permit the district court to accept the Release in evidence and conduct the trial of this case without regard to the restraint we previously placed upon it.
.
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Defamation Claim Based on Copyright Registration Statement Part II

Malmesbury Bible courtesy Wikimedia Commons

Previously, I posted on a case involving a defamation claim based on copyright registration statement, link and link to case here .

Complaint by an alleged author, based on an unpublished underlying work, complaining that a published work was derivative of her work, and infringed on her copyright and her method of bible study.  Complaint here:

Morris v Atchity Complaint


I noted in my prior post that I hadn't bothered to check the docket sheet to figure out what statement in a copyright registration statement could support a claim for defamation.   My laziness and ignorance was rewarded by American University Washington College of Law student Mark Tratos picking up on the theme, on the Intellectual Property Brief blog here.

So, rather than have everyone speculate, I did what I should have done.  Kenneth Atchity's counterclaim for based on the following allegation:

"Margaret Morris wrote and represented to the United States Copyright Office, under penalty of perjury, that "A contract for this ghostwritten book was offered and my agent Atchity concealed it and allowed it to be illegally signed."

It would seem that Morris' statement would be privileged, since it is a quasi-judicial function and the federal government specifically invites copyright "claims" and requires that they be submitted under penalty of perjury.   Ordinarily, such statements enjoy immunity.

I found a couple of discussions of the Administrative Procedure Act in the case law that generally relate to this, but nothing really on point, see below.    I discuss the application of the Administrative Procedure Act in my Copyright Litigation Handbook 2010, available from West Publishing or Amazon.

Utica College v. Gordon, 2009 WL 3418136, 4 (N.D.N.Y. 2009) appeal denied here.


"...an application for the registration of a copyright is more akin to an administrative proceeding. See 17 U.S.C. § 701(a) (“All administrative functions and duties under this title, except as otherwise specified, are the responsibility of the Register of Copyrights as director of the Copyright Office of the Library of Congress.”) (emphasis added). Additionally, the decision to grant a copyright registration is subject to the Administrative Procedure Act. 17 U.S.C. § 701(e). Therefore, defendants are not entitled to attorneys' fees because even if plaintiff's applications for copyright registration were objectively unreasonable, the applications did not constitute civil actions brought under title 17.



Darden v. Peters, 488 F.3d 277, 283 -286 (4th Cir. 2007)

The Copyright Act provides that “all actions taken by the Register of Copyrights under this title are subject to the provisions of the Administrative Procedure Act.” 17 U.S.C. § 701(e).FN2 One routine function of the Register is to examine applications for registration to determine if “the material deposited constitutes copyrightable subject matter and ... the other legal and formal requirements of [the Copyright Act] have been met.” 17 U.S.C. § 410(a). If so, then the Register must issue a certificate of registration to the applicant, see 17 U.S.C. § 410(a); if, however, the Register determines that “the material deposited does not constitute copyrightable subject matter or that the claim is invalid for any other reason,” then the Register must refuse registration and notify the applicant of the reasons for refusal, 17 U.S.C. § 410(b). Because the Register's denial of a copyright registration application is, by the statute's plain terms, an action taken by the Register under the Copyright Act, the APA governs judicial review. See 17 U.S.C. § 701(e); Atari Games Corp. v. Oman, 888 F.2d 878, 879 & n. 1 (D.C.Cir.1989) (“ Atari I ”); Nova Stylings, Inc. v. Ladd, 695 F.2d 1179, 1182 (9th Cir.1983).
FN2. The Copyright Act excepts the Register's performance of a single function from APA review: authorization of, or refusal to authorize, copies or reproductions of “deposited articles retained under the control of the Copyright Office.” 17 U.S.C. § 706(b); see 17 U.S.C. § 701(e). This narrow exception is not at issue here.
The district court concluded that the proper standard of review under the APA is the familiar “abuse of discretion” standard whereby a reviewing court will “set aside agency action, findings, and conclusions” that are “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A). This is consistent with the few federal decisions-most of which were issued by the same court-addressing the proper review standard under the APA for courts directly reviewing a registration decision. See Atari Games Corp. v. Oman, 979 F.2d 242, 243 (D.C.Cir.1992) (“ Atari II ”); OddzOn Prods., Inc. v. Oman, 924 F.2d 346, 347-48 (D.C.Cir.1991); Atari I, 888 F.2d at 881; Coach, Inc. v. Peters, 386 F.Supp.2d 495, 497 (S.D.N.Y.2005). See generally 3 Melville B. Nimmer & David Nimmer, Nimmer on Copyright § 12.11[B][3], at 12-208 (2005).
[2] Darden does not contest the general applicability of the APA to his claim; indeed, he expressly brought this action under the APA. Darden contends, however, that the district court incorrectly applied the abuse of discretion standard set forth in section 706(2)(A) of the APA. Darden suggests instead that section 706(2)(B) applies to a challenge of the Register's denial of a copyright registration application and mandates a de novo standard of review. Section 706(2)(B) directs that the reviewing court set aside agency actions the court finds to be “contrary to constitutional right, power, privilege, or immunity.” 5 U.S.C. § 706(2)(B). Under the APA, constitutional questions that arise during APA review fall expressly within *284 the domain of the courts. See 5 U.S.C. § 706 (requiring that “[t]o the extent necessary to decision and when presented, the reviewing court shall ... interpret constitutional and statutory provisions”) (emphasis added). Thus, judicial review of a claim that the agency's actions violated a claimant's constitutional rights is conducted de novo. See Western Energy Co. v. United States Dep't of Interior, 932 F.2d 807, 809 (9th Cir.1991).
[3] [4] [5] Darden cites no authority even remotely suggesting that any court has ever regarded the agency's routine decision to deny registration as having constitutional ramifications for the claimant. Darden derives the basis for his argument from Article I of the United States Constitution which grants Congress the power to provide copyright protection to the extent Congress sees fit. See U.S. Const. Art. I, § 8, cl. 8 (granting Congress legislative power “[t]o promote the Progress of Science and useful Arts, by securing ... to Authors and Inventors the exclusive Right to their respective Writings and Discoveries”). Congress is under no mandate from this clause, however, to provide copyright protection. See Silvers v. Sony Pictures Entertainment, Inc., 402 F.3d 881, 883 (9th Cir.2005) (“As is clear from its text, that clause of the Constitution grants no substantive protections to authors. Rather, Congress is empowered to provide copyright protection.”). Copyright is solely a creature of statute; whatever rights and remedies exist do so only because Congress provided them. See Sony Corp. of Am. v. Universal City Studios, Inc., 464 U.S. 417, 431, 104 S.Ct. 774, 78 L.Ed.2d 574 (1984). Thus, as there is no constitutional right to copyright registration, the Register's refusal to register Darden's claim cannot be “contrary to constitutional right” as it must be for section 706(2)(B) to apply.
[6] Darden next contends that because the Register's decision was based on the agency's incorrect resolution of a legal question, i.e., whether Darden's claim lacked sufficient originality to be registrable, the Register's decision is subject to de novo review. More particularly, Darden argues that the Register's refusal to find sufficient originality in his submitted works despite the “extremely low” amount of creativity required for a work to be copyrightable, Feist Publications, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340, 345, 111 S.Ct. 1282, 113 L.Ed.2d 358 (1991), was an erroneous conclusion that must be set aside under the “not in accordance with law” provision of section 706(2)(A) of the APA. Additionally, Darden cites various decisions noting, in the context of copyright infringement litigation, “that copyrightability is always an issue of law” for the court. Gaiman v. McFarlane, 360 F.3d 644, 648 (7th Cir.2004); see Yankee Candle Co. v. Bridgewater Candle Co., 259 F.3d 25, 34 n. 5 (1st Cir.2001); Collezione Europa U.S.A. v. Hillsdale House, 243 F.Supp.2d 444, 452 (M.D.N.C.2003).
[7] We reject Darden's argument. Essentially, Darden is claiming that the Register simply reached the wrong result, not that the Register applied the wrong legal standard or misapprehended or ignored the controlling legal principles. See Turgeau v. Administrative Review Bd., 446 F.3d 1052, 1057 (10th Cir.2006) (explaining that under § 706(2)(A) “[f]ailure to apply the correct legal standard or to provide this court with a sufficient basis to determine that appropriate legal principles have been followed is grounds for reversal”) (internal quotation marks omitted). Review under section 706(2)(A) is “narrow” and the reviewing court is not permitted to substitute its own judgment for the judgment of the agency. *285 Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983). Rather, the court is to determine “whether the decision was based on a consideration of the relevant factors,” West Virginia v. Thompson, 475 F.3d 204, 212 (4th Cir.2007) (quoting Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 416, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971)), or whether “the agency has relied on factors which Congress has not intended it to consider, [or] entirely failed to consider an important aspect of the problem,” Motor Vehicle Mfrs., 463 U.S. at 43, 103 S.Ct. 2856; see Thompson, 475 F.3d at 212.
Darden makes no assertion of this kind here; he merely argues that the agency should have concluded that the Maps and APPRAISERSdotCOM works contained the requisite level of creativity, citing Feist and other precedents. At every level of internal agency review, however, the Copyright Office recognized Feist as having established the contours of the originality element of a copyright claim. Because Darden has failed to identify any relevant factor or legal principle that the Register failed to consider, the agency's decision cannot be set aside as “contrary to law.”
[8] Finally, Darden argues that the Register's determination that a copyright claim lacked sufficient originality to warrant registration is subject to de novo review in the context of an infringement action under section 411(a) of the Copyright Act. He contends that de novo review of the copyrightability issue should also apply in the context of APA review for the sake of efficiency and predictability. We cannot agree.
Congress has afforded disappointed copyright applicants two separate methods of seeking redress for the decision of the Copyright Office not to register a copyright claim. First, as we explained previously, the applicant may file a review action under the APA against the Register of Copyrights for the sole purpose of having the denial of registration set aside. See 17 U.S.C. §§ 410(a), 701(e). Darden's action, of course, is such a case. Second, the claimant may seek judicial review of the rejected registration as part of an infringement action against an alleged infringer under section 411(a) of the Copyright Act.FN3
FN3. Registration is a prerequisite for a copyright infringement action. See 17 U.S.C. § 411(a). However, if “the deposit, application, and fee required for registration have been delivered to the Copyright Office in proper form and registration has been refused, the applicant is entitled to institute an action for infringement if notice ... is served on the Register of Copyrights” who “may, at his or her option, become a party to the action with respect to ... registrability of the copyright claim.” Id.
[9] [10] Both kinds of actions involve, to one degree or another, consideration of whether a copyrightable claim has been presented. The Register has a statutory duty to examine applications for registration to determine if “the material deposited constitutes copyrightable subject matter and ... the other legal and formal requirements of [the Copyright Act] have been met.” 17 U.S.C. § 410(a). Whether the Register issues the certificate of registration or not, the Register necessarily makes a determination about the validity of the copyright claim. And, with respect to a copyright infringement action, the plaintiff must establish “ownership of a valid copyright and copying of constituent elements of the work that are copyrightable.” Compaq Computer Corp. v. Ergonome Inc., 387 F.3d 403, 407 (5th Cir.2004) (internal quotation marks omitted). Copyright ownership, in turn, requires “proof of originality and copyrightability.” *286 Id. at 408; see Feist, 499 U.S. at 361, 111 S.Ct. 1282.
Darden's argument notwithstanding, it is not a foregone conclusion that courts owe no deference whatsoever to the Register's decision in the context of an infringement action under section 411(a). Indeed, courts are split on this issue. Compare John Muller & Co. v. New York Arrows Soccer Team, 802 F.2d 989, 990 (8th Cir.1986) (applying abuse of discretion standard to infringement claim); Norris Indus. v. I.T. & T. Corp., 696 F.2d 918, 922 (11th Cir.1983) (same), with Carol Barnhart, Inc. v. Economy Cover Corp., 773 F.2d 411, 414 (2d Cir.1985) (according no deference to Register's copyrightability conclusion); OddzOn Prods., 924 F.2d at 347-50 (same). We need not weigh in on this issue, however, as Darden brought this action against the Register under the APA seeking review of the denial of registration for insufficient originality in his works. Even if no deference is due to the Register's decision by courts adjudicating infringement actions under section 411(a), we must apply the standards set forth in the APA. To do otherwise would be to ignore the clear and unambiguous language of the statute, which we cannot do. Accordingly, we review the decision to register Darden's works for abuse of discretion.


This is a long way of saying that it seems to me that if someone else registers a claim to a work that you think you own, you file a competing registration claim that "defames" or "slanders the title" of the first claimant.   Since you are required to do so by law as a prerequisite to commencing suit in federal court, it would appear to me that any statements would be subject to absolute judicial immunity (subject to the limits of that doctrine).
Bible study was always a rough game.

Morris v Atchity Counterclaims

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Art Litigation: Nazi-Era Art Restitution - Legal Update Jan 24 New York State Bar Association

Nazi-Era Art Restitution Legal Update NYSBA EASL Jan 24 2011



On Monday January 24, 2011 I will be part of a panel organized by the New York State Bar Association' Entertainment Arts and Sports Law Section, flyer above, direct link and program description below.

http://www.nysba.org/AM/Template.cfm?Section=Event_List&TEMPLATE=/CM/ContentDisplay.cfm&CONTENTID=45158

1:35-3:30 p.m. NAZI-ERA ART RESTITUTION: RECENT CASE DEVELOPMENTS


This program will address recent cases brought by heirs of Holocaust victims concerning the ownership of
artworks claimed to have been looted or sold under duress during the Nazi era. When the art resurfaced –
often decades later – in the hands of museums, collectors, galleries and auction houses, ownership disputes
have raised complex procedural, substantive, and policy issues. This panel includes lawyers representing
both sides of several high-profile cases, including the eleven-year battle which resulted in a $19 million
settlement with the Leopold Museum in Vienna in the Egon Schiele - Portrait of Wally case and the
seven-year battle with the Republic of Austria, which resulted in the restitution to the family of Holocaust
victims of a number of important works by Gustav Klimt, valued, in the aggregate, in excess of $300
million. The esteemed panelists will also discuss cases involving the Museum of Fine Arts in Boston, the
Norton Simon Museum in Pasadena, and descendants of families who are laying claim to works by Picasso,
Pissarro, Schiele, Kokoschka, Klimt, and Lucas Cranach the Elder

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Art Law & Beer - SDNY Federal Bar Association Jan 26 at Gallery Henoch - Free Networking Event

Art Law & Beer - Federal Bar Association The Younger Lawyers Division of the Federal Bar Association Southern District of New York Chapter

presents

ART LAW & BEER
Free Event
January 26th
6:30 - 8:30 PM
at
GALLERY HENOCH
555 W. 25th Street

Featuring:
DAVID KASSAN, Figurative Artist
LILLIAN LASERSON, Copyright and Entertainment Lawyer and Former General Counsel of DC Comics
DANIEL FISHER, Beer Blogger and Craft Beer Advocate



RSVP to Michael Zussman mjzussman@yahoo.com

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