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Capitol Records, Inc. v. Thomas

United States District Court for the District of Minnesota
579 F. Supp. 2d 1210 (2008)


Facts

Jammie Thomas (defendant) downloaded and distributed copyright-protected songs, using the peer-to-peer file-sharing program Kazaa. Capitol Records, Incorporated and other recording companies (plaintiffs) held exclusive copyrights in 24 sound recordings. The plaintiffs sued Thomas, seeking injunctive relief and statutory damages. During the trial, jury instruction 15 stated that the copyright holder’s exclusive-distribution right was infringed if recordings of copyrighted works were made available on a peer-to-peer network without licenses, regardless of whether the copyright holder showed that the works were actually distributed. The jury was also instructed about the plaintiff’s exclusive right to reproduce copyright-protected works. The jury found Thomas liable and awarded damages of $9,250 per infringement. The jury’s special-verdict form did not specify the basis on which liability was found or the rationale for damages. The district court determined sua sponte that it was necessary to reevaluate jury instruction 15, specifically whether actual distribution was a necessary element for infringement of distribution rights.

Rule of Law

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Issue

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Holding and Reasoning (Davis, C.J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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