DEA Lookup.com, Inc. v. Solstice Benefits, Inc. and UnitedHealthcare, Inc.; DEA Lookup.com, Inc. v. PharmaScript, LLC

Summary

The District of Delaware denied motions by Solstice Benefits, Inc., UnitedHealthcare, Inc., and PharmaScript, LLC, challenging copyright and contract claims brought by DEA Lookup.com, Inc. The court held that alleged use beyond the scope of software licenses could support copyright infringement claims and establish federal subject-matter jurisdiction. The court also found that DEA plausibly alleged breach of contract, including contract formation, breaches involving unauthorized software use and audit compliance, and damages.

Holdings

1. Solstice's motion for judgment on the pleadings was timely because objections to subject matter jurisdiction may be raised at any time and the motion was filed early enough not to delay trial.
2. The alleged existence of license agreements did not eliminate federal subject matter jurisdiction because a copyright infringement claim may proceed when the licensee allegedly uses the copyrighted material beyond the scope of the license.
3. DEA plausibly stated a copyright infringement claim against PharmaScript by alleging ownership of valid copyrights and unauthorized copying of original elements of its software.
4. DEA plausibly stated a breach-of-contract claim against PharmaScript by alleging contract formation, breach of contractual obligations, and damages.

Questions Presented

1. Whether the alleged existence of license agreements converted DEA's copyright claims into state-law contract disputes and eliminated federal subject matter jurisdiction.
2. Whether Solstice's Rule 12(c) motion was timely.
3. Whether DEA plausibly alleged copyright infringement against PharmaScript.
4. Whether DEA plausibly alleged the existence of a contract, breach, and damages for its breach-of-contract claim against PharmaScript.

Disposition

other