Cortes-Ramos v. Sony Corp. of America, No. 16-2441 (1st Cir. 2018)Annotate this Case
The district court erred in awarding attorney’s fees to Defendants in this case alleging various claims under Puerto Rico and federal law, including claims under the Copyright Act, 17 U.S.C. 505.
Plaintiff sued Sony Corporation of America and other related defendants in connection with a songwriting contest that Sony had co-sponsored. The district court dismissed the claims with prejudice on the grounds that they were subject to mandatory arbitration under an agreement that Plaintiff had signed upon entering the contest and that his claims were subject to dismissal under Fed. R. Civ. P. 12(b)(6). The First Circuit affirmed. Thereafter, Defendants moved for attorney’s fees under section 505 of the Copyright Act, which provides for attorney’s fees to the prevailing party. The district court granted the motion and awarded attorney’s fees. The First Circuit reversed, holding that Defendants did not qualify as prevailing parties under section 505.