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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David Martinez


Member of the Executive Board;
Member of the Firm's Diversity Committee;
Pro Bono Chair, Los Angeles Office

Austin B. Miller

Former Associate

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