Copyright Protection Extended to Database Content

Monday, January 22, 2018

U.S. District Judge Paula Xinis granted in part and denied in part the defendants’ motion to dismiss in a lawsuit in which the plaintiff asserted claims of copyright infringement, false advertising, and misappropriation of trade secrets.  The complaint alleged unauthorized downloading of the plaintiff’s customer list and proprietary database content,. With respect to the copyright infringement claim, Judge Xinis denied the motion to dismiss based on her conclusion that the Copyright Act extended to protection of content of a database.  Although the database included non-copyright eligible SEC content, that same content was also analyzed and copy-edited, and included unique descriptions of facts and technology original to the plaintiff, making it copyright eligible.  RoyaltyStat, LLC v. IntangibleSpring Corp., No. PX 153940, 2018 WL 348151 (D. Md. Jan. 10, 2018).