Summary
This federal district court order dismisses a copyright infringement complaint sua sponte due to the plaintiff's failure to establish standing. The court determined that the purported copyright registrations attached to the amended complaint could not be verified in the official Copyright Office database, raising doubts about the plaintiff's ownership of the alleged works. While granting the plaintiff one final opportunity to amend within 21 days to concretely demonstrate copyright ownership, the court denied his renewed motion for early discovery as moot.
Topics
Practice areas
Questions Presented
- Whether the district court has subject‑matter jurisdiction over Brown's copyright infringement claims given his lack of standing.
Holdings
- The court lacks subject‑matter jurisdiction because Brown has failed to establish standing; the complaint is dismissed.
Key quotations
“Because Mr. Brown has failed to establish standing, the Court DISMISSES his complaint but grants him one final opportunity to amend to concretely demonstrate that he holds the copyright for each of the relevant works.” (at 12)
Factual background
Plaintiff Patrick Brown alleged that unknown defendants (Does 1‑20) infringed his copyrighted works and attached twenty certificates of registration for 376 works. The court could not locate any of the alleged registrations in the Copyright Office public records, raising doubts about Brown's ownership and standing.
Procedural history
The court denied Brown's motion for early discovery on May 19, 2024, finding lack of standing. Brown filed an amended complaint on June 6, 2025, attaching certificates of registration. The court again could not locate any registrations and determined it lacked subject‑matter jurisdiction, dismissing the complaint and denying the renewed discovery motion.
Remand instructions
The amended complaint must be filed within 21 days of the date of this Order.