Sony Music Entertainment v. Cox Communications, Incorporated

Court: US Court of Appeals for the Fourth Circuit

Docket: 21-1168

Opinion Date: February 20, 2024

Judge: Rushing

Areas of Law: Civil Procedure, Copyright, Intellectual Property

In this case, Sony Music Entertainment and numerous other record companies and music publishers sued Cox Communications, alleging that Cox's customers used its internet service to infringe their copyrights. The plaintiffs argued that Cox should be held accountable for its customers' copyright infringement. A jury found Cox liable for both willful contributory and vicarious infringement of over 10,000 copyrighted works owned by the plaintiffs and awarded $1 billion in statutory damages.

The United States Court of Appeals for the Fourth Circuit held that Cox was not vicariously liable for its customers' copyright infringement because Cox did not profit from its subscribers’ acts of infringement, a legal prerequisite for vicarious liability. However, the court affirmed the jury’s finding of willful contributory infringement because Cox knew of the infringing activity and materially contributed to it.

The court vacated the $1 billion damages award and remanded the case for a new trial on damages, holding that the jury’s finding of vicarious liability could have influenced its assessment of statutory damages. The court did not vacate the contributory infringement verdict.

PROMPTU SYSTEMS CORPORATION v. COMCAST CORPORATION

Court: US Court of Appeals for the Federal Circuit

Docket: 22-1939

Opinion Date: February 16, 2024

Judge: TARANTO

Areas of Law: Intellectual Property, Patents

Promptu Systems Corp. sued Comcast Corp. alleging that Comcast infringed on its U.S. Patent Nos. 7,047,196 and 7,260,538. The patents cover a method of using speech recognition services in combination with cable television or video delivery. The case was litigated in the United States District Court for the Eastern District of Pennsylvania. The district court adopted claim constructions that were mostly in line with Comcast's proposals. As a result, Promptu and Comcast agreed to dismiss Promptu's patent-infringement claim and state-law claims with prejudice. Promptu also agreed to a final judgment of no infringement by Comcast of the ’196 and ’538 patents, based on the claim constructions adopted by the district court.

Promptu appealed the judgment, challenging several of the underlying claim constructions. The United States Court of Appeals for the Federal Circuit found that the district court incorrectly construed certain claim terms and therefore vacated the judgment and remanded the case for further proceedings. The court held that the district court's constructions of the terms "back channel," "multiplicity of received identified speech channels," "speech recognition system coupled to a wireline node," and "centralized processing station" were not accurate. The court provided detailed analysis and reasoning for these conclusions. The court did not rule on the merits of the infringement claims, but instead remanded the case for further proceedings based on the corrected claim constructions.

Justia CLE & Webinars: Understanding Loan Transactions for the Non-Finance Attorney

Justia Team

As a lawyer, you may come across loan transactions even if you are not a finance attorney. What do you need to do, and what do all these documents in a loan document package even mean? Now is the time to demystify it all so you can elevate your law firm practice and ensure quality legal representation for all your clients!

Read More