Mattel, Inc., et al v. MGA Entertainment, Inc., et al, No. 11-56357 (9th Cir. 2013)Annotate this Case
Mattel filed suit against MGA, claiming that MGA infringed Mattel's copyrights by producing Bratz dolls. On appeal, Mattel challenged the jury's verdict that Mattel misappropriated MGA's trade secrets and the district court's award of attorneys fees and costs to MGA under the Copyright Act, 17 U.S.C. 505. The court held that MGA's claim of trade-secret misappropriation was not logically related to Mattel's counterclaim and therefore, the court reversed the district court's holding that MGA's counterclaim-in-reply was compulsory. Because the district court did not abuse its discretion in awarding fees and costs under the Act, the court affirmed that award.
Court Description: Copyright. The panel affirmed in part and reversed the district court’s judgment, after a new jury trial on remand from this court, in an action under the Copyright Act. On remand, the jury rejected the claim of Mattel, Inc., that MGA Entertainment, Inc., infringed Mattel’s copyrights by producing Bratz dolls. The jury also found that Mattel misappropriated MGA’s trade secrets, and the district court awarded attorneys’ fees and costs to MGA under the Copyright Act. The panel held that MGA’s counterclaim-in-reply for misappropriation of trade secrets under California law was not compulsory and thus was not properly permitted because it did not rest on the same aggregate core of facts as Mattel’s trade secret misappropriation counterclaim. The panel vacated the jury’s verdict on MGA’s claim, as well as related damages, fees, and costs. The panel held that the district court did not abuse its discretion in awarding attorneys’ fees under the Copyright Act to MGA, the prevailing party on the copyright infringement claim.