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Sony BMG Music Entertainment v. Tenenbaum

United States Court of Appeals for the First Circuit

660 F.3d 487 (2011)

Facts

Sony BMG Music Entertainment, Warner Brothers Records, Inc., Arista Records, LLC, Atlantic Recording Corporation, and UMG Recordings, Inc. (collectively, the record companies) (plaintiffs) brought an action for statutory damages and injunctive relief against Joel Tenenbaum (defendant), a connoisseur of peer-to-peer file sharing. The record companies alleged that Tenenbaum had violated the Copyright Act by downloading and distributing 30 musical recordings without the consent of the copyright owners. The district court found in favor of the record companies, and the jury assessed damages against Tenenbaum at $22,500 per recording. Tenenbaum moved for a new trial or remittitur. The court avoided the question of remittitur, instead opting to reduce the damage award as having been excessive on constitutional due-process grounds. The record companies appealed the reduction. Tenenbaum also appealed, challenging the constitutionality of the Copyright Act. The United States intervened to defend the constitutionality of the Copyright Act. The United States Court of Appeals for the First Circuit granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Lynch, C.J.)

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The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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