Law School Case Brief
Yurman Design, Inc. v. PAJ, Inc. - 29 F. App'x 46 (2d Cir. 2002)
The trial judge has broad discretion in the matter of the admission or exclusion of expert evidence, and his action is to be sustained unless manifestly erroneous.
Plaintiff-appellant-cross-appellee Yurman Design, Inc. brought suit against PAJ, Inc. in the Southern District of New York, alleging that PAJ had intentionally infringed five of its copyrights in cable jewelry designs, that 21 of PAJ's jewelry designs (including the five copyrighted designs) intentionally infringed Yurman's trade dress in violation of the Lanham Act, and that the intentional trade dress infringements violated New York unfair competition laws. Yurman was largely successful at trial. The jury found that all five of Yurman's copyrights were valid and that four of PAJ's jewelry designs infringed the said copyrights. The jury also found that 20 of PAJ's jewelry designs (including four of the copyrighted designs) infringed Yurman's trade dress. The trade dress and copyright infringements were all found to be willful. Because the trade dress infringement was willful, the jury also found PAJ liable under New York unfair competition law. The jury awarded the following damages: (1) $275,000 in statutory damages for copyright infringement, (2) $800,000 in punitive damages on the unfair competition claim, and (3) no damages on the trade dress claim. PAJ then filed a motion for judgment as a matter of law or for a new trial, challenging most of the jury's findings. On December 12, 2000, the district court judge rejected all of PAJ's arguments, except one: the court vacated the punitive damage award. On December 13, 2000, the district court awarded Yurman $211,561.70 in attorney fees and $22,757.03 in costs pursuant to 17 U.S.C. § 505 of the Copyright Act, which allowed for the recovery of "a reasonable attorney's fee to the prevailing party." Finding that the amount awarded was too low, Yurman appealed the judgment, contending that the district court failed to consider the need for deterrence when setting the fee award amount, relied upon an inadmissible expert opinion, and failed to sufficiently explain why it awarded only 20 percent of the fees billed.
Taking into consideration the circumstances of the case at hand, did the district court award an amount that was too low?
The Second Circuit Court of Appeals found that the district court did not err in failing to consider plaintiff's willfulness and the need for deterrence when determining the amount of the fee award. According to the Court, willfulness only needed to be considered when the court was deciding whether to award any fees. As to the second argument, the Court held that the district court had broad discretion to admit or exclude expert evidence, and there was not a convincing reason to question the district court's decision to admit the testimony. Finally, the Court held that the district court was intimately familiar with the details of the case, and the appellate court had no basis to conclude the district court's finding, that only 20 percent of the time spent on the case was attributable to the copyright claims, was an abuse of discretion.
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