Copyright Law Updates | New Judicial Opinions

May 24, 2007

Troll Co. v. Uneeda Doll Co.

05-6487 CV, 2007 WL 1097082, 2d Cir., 4/13/2007

Troll Co. v. Uneeda Doll Co.

Holding:

Pursuant to section 104A of the Copyright Act, a party can be considered a "reliance party" only where the infringement is ongoing and without more than a trivial interruption.

Detailed Summary:

The district court preliminarily enjoined defendant from manufacturing, selling or distributing “wish-nik” troll dolls, since plaintiff claims the copyright had been restored pursuant to the Uruguay Round Agreements Act (URAA). The URAA restores copyrights for various foreign works that had previously entered the public domain in the US because of noncompliance with certain formalities, especially notice of copyright. The Plaintiff’s copyright was automatically restored. But defendant argues that it is a “reliance party”—one who may continue to exploit the work until the owner makes known its intent to enforce the copyright—and thus may sell off its inventory of the dolls during a one year sell-off. The court held that defendant was not a reliance party because the statute requires continuous infringement, whereas defendant had voluntarily ceased exploitation for 9 or 10 years.

Also See:

FCC Adopts New Rules Permitting TV Channel Sharing by Broadcasters; Enacts First Step Towards Freeing UP Spectrum under Incentive Auction

FCC Modernizes Broadcast Television Public Inspection Files to Give the Public Online Access to Information Previously Available Only at TV Stations

Copyright Office Conducts Proceedings on Exemption to Prohibition on Circumvention of Copyright Protection Systems

Legislation to Deregulate Television Market Introduced in House and Senate

Copyright Office Proposes New Fee Schedule

Companies Mentioned

Copyright Law

The following companies are mentioned in Copyright Law Updates:

MGA Entertainment (HK) Ltd.

Mattel, Inc.

MGA Entertainment Inc.

UMG Recordings, Inc.

American Society of Composers, Authors, and Publishers

Litecubes, LLC

Poof Apparel Corp.

Derek Andrew, Inc.

Metro-Goldwyn-Mayer Pictures, Inc.

Geoffrey Productions, Inc.

Universal City Studios LLLP

Twentieth Century Fox Film Corp.

Turner Network Television LP, LLLP

Simon & Schuster, Inc.

Turner Network Sales, Inc.

Turner Classic Movies, LP, LLLP

Turner Broadcasting System, Inc.

The Cartoon Network LP, LLP

Paramount Pictures Corp.

NBC Studios, Inc.

Veoh Networks, Inc.

Disney Enterprises, Inc.

CSC Holdings, Inc.

CBS Broadcasting Inc.

Cablevision Systems Corp.

Cable News Network LP, LLLP

American Broadcasting Companies, Inc.

Kamind Associates, Inc. a.k.a. KAM Industries

Westbound Records, Inc.

All Headline News Corp.

Janice Combs Publishing, Inc. d.b.a. Justin Combs Publishing

American Software Development Company, Inc.

Bad Boy Records LLC

Affordable Video Systems, Ltd.

Bad Boy Entertainment, Inc. d.b.a. Bad Boy Records

Dream Games of Arizona, Inc.

Yahoo! Inc.

Frank Diana City Entertainment

Television Music License Committee

PC Onsite

SESAC, Inc.

RealNetworks, Inc.

AOL LLC f.k.a. America Online, Inc.

Northern Lights Products, Inc. d.b.a. GlowProducts.com

Nicotext A.B.

Dezer Development, LLC

John Wiley & Sons, Inc.

Home Shopping Network, Inc.

Miramax Film Corp.

J.D. Salinger Trust

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