Lessons From MMAS Research About Dispositive Pitfalls in Copyright Litigation
By David Martinez and Austin Miller
December 8, 2022
Last month, the District Court for the Central District of California confirmed longstanding Ninth Circuit law that a license granting a bare right to sue is invalid and does not confer standing to bring suit for copyright infringement. MMAS Research LLC v. Charité, No. 21-CV-1406-MWF, Dkt. 47 (CD.Cal.Nov.4,2022). As a separate grounds for dismissal, the Court further found that the accused acts of infringement occurred entirely outside of the U.S., and the Ninth Circuit has repeatedly recognized that extra-territorial acts are non-actionable.
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