LADS Network Solutions Inc. v. Agilis Systems LLC et al.

Summary

The United States District Court for the Eastern District of Missouri grants Plaintiff’s motion for leave to amend the complaint based on a newly obtained supplemental copyright registration. The court denies Plaintiff’s motion to reopen discovery for lack of diligence and good cause. It also grants Defendants’ motion to reinstate counterclaims because the prior dismissal of those counterclaims was based on a judgment that the Eighth Circuit later reversed.

Holdings

1. Plaintiff satisfied Rule 16(b)'s good-cause standard because the supplemental copyright registration did not exist before the amendment deadline and was analogous to newly discovered evidence; leave to amend was therefore granted.
2. Plaintiff failed to establish Rule 16(b) good cause to reopen discovery because it identified no change in law, newly discovered fact, or changed circumstance and did not demonstrate diligence in pursuing the proposed depositions before discovery closed.
3. The counterclaims should be reinstated under Rule 60(b)(5) because their dismissal without prejudice resulted from the earlier judgment dismissing Plaintiff's claims, and that judgment was subsequently reversed.

Questions Presented

1. Whether Plaintiff showed good cause under Federal Rule of Civil Procedure 16(b) to amend its complaint after the scheduling-order deadline based on a supplemental copyright registration obtained after the deadline.
2. Whether Plaintiff showed good cause under Rule 16(b) to reopen discovery for depositions that it did not pursue before the original discovery deadline.
3. Whether Defendants' counterclaims should be reinstated under Federal Rule of Civil Procedure 60(b)(5) after the judgment underlying their dismissal was reversed.

Disposition

other