Pay Attorney Fees or Face Trial: Court Brushes Off Dentist's Request to Dismiss Suit
Chief U.S. District Judge Mark E. Walker found that the plaintiff in a copyright lawsuit over before-and-after dentistry photos had withheld important evidence in the case.
November 05, 2019 at 05:07 PM
5 minute read
A plaintiff dentist who elected to toss his own copyright infringement lawsuit weeks before trial, after the defense produced damaging evidence, faces a choice from Chief U.S. District Judge Mark E. Walker in the Northern District of Florida.
The judge agreed to dismiss the case without prejudice on one condition: the plaintiff would have to pay the defendant's attorney fees and costs for two and a half years of litigation.
"The plaintiff, therefore, has two options," the ruling said. "He can either decline to dismiss, decline to pay and take his chances at trial; or he can accept the dismissal with the condition set forth in this order."
The ruling didn't offer much to smile about for Boca Raton cosmetic dentist Mitchel Pohl, who sued an internet media company in April 2018 after discovering that before-and-after shots of one of his patients, referred to as "Belinda," appeared on multiple websites without his permission.
Walker's ruling is the latest twist in a case that was dismissed in June 2018 and revived in May.
While Walker had ruled the photos of Belinda's teeth weren't creative or original enough to merit copyright protection, the U.S. Court of Appeals for the Eleventh Circuit found that that was a question for jurors to answer.
A trial was scheduled for October, but in the weeks before, defense attorneys Matthew Nelles and Adriana Kostencki of Nelles Kostencki in Fort Lauderdale acquired some crucial information from the U.S. Copyright Office: a string of emails that were game-changing for his client, MH SUB I LLC, known as Internet Brands.
The plaintiff's attorney, William Hollimon of Hollimon P.A. in Tallahassee, did not respond to requests for comment by deadline.
According to Monday's ruling, the dentist had previously claimed that he'd mistakenly entered the wrong year on a copyright registration form for his website in 2005. He alleged that he wrote 2000 instead because he'd innocently misinterpreted of the application form, an explanation Walker had accepted.
But Walker found Pohl's team had failed to disclose email evidence that showed an examiner from the Copyright Office had asked him whether he wanted to change the date to 2005, but he chose to keep it at 2000.
"In sum, plaintiff failed to provide relevant evidence to defendant, despite defendant's request, which was in their possession and which could have resolved this case on summary judgment," Walker wrote.
The revelation bolsters Nelles long-held argument that because the teeth photos were taken in 2004, they didn't fall under Pohl's 2000 copyright protection.
"Obviously, in the year 2000, these 2004 photographs didn't exist," Nelles said. "So whatever website he had in the year 2000 for sure did not contain these photographs."
When the plaintiff then moved to dismiss without prejudice, Walker made "a reasonable inference that plaintiff seeks dismissal to avoid an expected adverse ruling."
"Strikingly, plaintiff offers no reasons for seeking voluntary dismissal of this lawsuit, claiming only that he seeks dismissal 'for a variety of reasons that are not relevant to this motion,'" the order said.
|'We live for these types of issues'
Nelles said he discovered the emails in October after independently asking the Copyright Office for documents.
"We never envisioned that we would come across such an important document as those emails," Nelles said.
The ruling could be significant for the copyright arena, according to Nelles, as the case touches on somewhat novel and unexplored areas of law, including whether or not the information on a registration certificate holds more authority than the actual work submitted to the copyright office.
"The case for us has been a highly intriguing case because of such core, important copyright issues," he said. "This is sort of what we litigate IP and copyright cases for. We live for these types of issues to arise and to have to deal with them."
Also unusual is that the Copyright Office didn't simply accept the deposited material, but actually asked Pohl questions about it to clarify his intentions.
"He wrote an email back saying, 'This is exactly what I want, I want the 2000.' It was deliberate," Nelles said.
It's been an unusually expensive case for the defense, mottled with discovery, motions, appellate work and trial preparation.
"The attorney fees substantially outweigh any potential damages," Nelles said.
The plaintiff has until Nov. 12 to make a decision.
Read the court order:
Read more: How to Lose a Copyright Case: Court Finds Photos of Teeth Lack Sufficient Bite
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllBenworth Accused of Predatory Tactics in Foreclosure Dispute as Elderly Defendant's Health Deteriorates
4 minute read'Get Rid of the Men': Employer Accused of Discrimination
Trending Stories
- 1US Magistrate Judge Embry Kidd Confirmed to 11th Circuit
- 2Shaq Signs $11 Million Settlement to Resolve Astrals Investor Claims
- 3McCormick Consolidates Two Tesla Chancery Cases
- 4Amazon, SpaceX Press Constitutional Challenges to NLRB at 5th Circuit
- 5Schools Win Again: Social Media Fails to Strike Public Nuisance Claims
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250