MGM Studios, Inc. v. Grokster, Ltd.

United States District Court for the Central District of California · Property

PropertyCopyrightPermanent InjunctionsInducement LiabilityEquitable Remediescopyrightinducementpermanent injunction

Facts

StreamCast distributed and operated the Morpheus peer-to-peer system and had already been held liable by this court for distributing Morpheus with the intent to induce copyright infringement. After summary judgment, StreamCast began distributing a filtered version of Morpheus and encouraging some users of legacy versions to upgrade, but only about one-third of downloading sessions used the filtered software and plaintiffs submitted evidence that copyrighted works remained downloadable. Plaintiffs sought a broad permanent injunction requiring exhaustive prevention of infringement and extensive filtering and successor obligations. StreamCast argued that filtering was legally improper, that its current efforts were sufficient, and that any injunction should be limited because Morpheus was capable of substantial noninfringing uses.

Issue

Whether plaintiffs were entitled to a permanent injunction against StreamCast after a finding of inducement liability, and if so, how broad and specific that injunction could be. The court also had to decide whether StreamCast could be required to implement effective filtering and take steps to move users away from unfiltered legacy software.

Rule

Under 17 U.S.C. § 502(a), a copyright plaintiff seeking a permanent injunction must satisfy the traditional four-factor equitable test stated in eBay: irreparable injury, inadequacy of legal remedies, balance of hardships favoring equity, and consistency with the public interest. There is no presumption of irreparable harm. Any injunction must be specific under Rule 65(d), narrowly tailored to the proven theory of liability, and in this inducement context may regulate continued distribution of the product when that distribution remains connected to past promotion of infringement; however, the injunction should preserve substantial noninfringing uses as feasible and generally requires notice from plaintiffs before filtering duties are triggered for particular works.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A federal court in Seattle finds that Harborlight Media intentionally induced large-scale infringement by marketing its file-sharing app to users seeking unauthorized songs. The copyright owners then seek a permanent injunction and argue that once infringement liability is established, injunctions ordinarily follow without any further equitable showing.

How should the court evaluate the request for a permanent injunction?

Explanation. The majority opinion held that copyright plaintiffs seeking a permanent injunction must satisfy the traditional four-factor eBay test: irreparable injury, inadequacy of legal remedies, balance of hardships, and public interest. It rejected any automatic rule that injunctions follow infringement and found no room for a separate simplified copyright rule that circumvents that analysis.