Columbia had licensed television series to stations owned through Feltner's corporation, but terminated the licenses after the stations became delinquent in royalty payments and negotiations failed. Despite termination, the stations continued broadcasting the programs, and Columbia sued for copyright infringement. Columbia elected to seek statutory damages under 17 U.S.C. § 504(c) instead of actual damages. The district court denied Feltner's request for a jury trial on statutory damages and, after a bench trial, found 440 acts of infringement, found willfulness, and awarded $8.8 million in statutory damages.
Issue
Does 17 U.S.C. § 504(c) itself grant a right to a jury trial when a copyright owner elects statutory damages, and if not, does the Seventh Amendment require a jury trial on statutory damages, including the amount awarded?
Rule
Section 504(c) does not itself grant a statutory right to a jury trial, but the Seventh Amendment preserves a right to a jury trial on all issues pertinent to an award of statutory damages under that section, including the amount of statutory damages. In deciding whether the Seventh Amendment applies to a statutory action, courts examine the historical analogy of the action and the nature of the remedy sought, with monetary relief generally treated as legal rather than equitable.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
North Shore Media, a fictional production company in Seattle, sued Daniel Price in federal court for infringing several registered television scripts. North Shore elected statutory damages under 17 U.S.C. § 504(c), and Daniel demanded a jury on both liability and damages. The judge denied the request, reasoning that the statute says damages are awarded in an amount "the court considers just."
Which is the strongest objection to the judge's ruling?
Explanation. The majority held that § 504(c) does not itself create a statutory jury-trial right. But the Seventh Amendment applies because copyright infringement actions seeking monetary relief are analogous to actions at law, and statutory damages are legal rather than equitable relief. That jury-trial right extends to all issues pertinent to statutory damages, including the amount. (Derived from Feltner v. Columbia Pictures Television, Inc. (1998).)