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`Jeffrey A. LeVee (State Bar No. 125863)
`Brent D. Sokol (State Bar No. 167537)
`jlevee@jonesday.com
`JONES DAY
`555 South Flower Street
`Fiftieth Floor
`Los Angeles, CA 90071.2452
`Telephone: +1.213.489.3939
`Facsimile: +1.213.243.2539
`Attorneys for Defendant and Counterclaimant
`ENTRAVISION COMMUNICATIONS
`CORPORATION
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`GLOBAL MUSIC RIGHTS, LLC,
`Plaintiff,
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`v.
`ENTRAVISION
`COMMUNICATIONS
`CORPORATION,
`Defendant.
`
`Case No. 2:19-cv-08535-TJH (ASx)
`
`DEFENDANT AND
`COUNTERCLAIMANT
`ENTRAVISION
`COMMUNICATIONS
`CORPORATION’S REPLY TO
`GMR’S OPPOSITION TO MOTION
`TO STAY
`Date: March 2, 2020
`Time: Taken Under Submission
`Judge: Hon. Terry J. Hatter, Jr.
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`Case No. 2:19-cv-08535-TJH (ASx)
`ENTRAVISION'S REPLY TO GMR’S
`OPPOSITION TO MOTION TO STAY
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 2 of 14 Page ID #:276
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`TABLE OF CONTENTS
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`
`INTRODUCTION ........................................................................................... 5
`I.
`II. ARGUMENT .................................................................................................. 6
`A.
`This Action and the RMLC Action Involve the Same Claims ............. 6
`B. GMR’s Antitrust Violations Arise From Its Leverage of
`Copyright Ownership To Control Areas Outside Its Limited
`Monopoly And These Misuse Issues Are Before the Court in the
`RMLC Action ....................................................................................... 8
`C. A Stay Will Not Prejudice GMR ........................................................ 12
`III. CONCLUSION ............................................................................................. 13
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`Case No. 2:19-cv-08535-TJH (ASx)
`ENTRAVISION'S REPLY TO GMR’S
`OPPOSITION TO MOTION TO STAY
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 3 of 14 Page ID #:277
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`TABLE OF AUTHORITIES
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`Page
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`
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`CASES
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`A & M Records v. Napster,
`239 F.3d 1004 (9th Cir. 2001) ......................................................................... 9, 10
`
`Altera Corp. v. Clear Logic, Inc.,
`424 F.3d 1079 (9th Cir. 2005) ............................................................................. 11
`
`Apple Inc. v. Psystar Corp.,
`658 F.3d 1150 (9th Cir. 2011) ............................................................................. 11
`
`Broad. Music, Inc. v. Hearst/ABC Viacom,
`746 F. Supp. 320 (S.D.N.Y. 1990) .................................................................... 8, 9
`
`Clark v. Amica Mutual Ins. Co.,
`2013 WL 12171876 (E.D. Wash. May 21, 2013) ................................................. 8
`
`Hangarter v. Provident Life and Accident Ins. Co.,
`373 F.3d 998 (9th Cir. 2004) ................................................................................. 7
`
`Landmark Tech., LLC v. iRobot Corp.,
`2014 WL 486836 (E.D. Tex. Jan. 24, 2014) ......................................................... 6
`
`Lasercomb Am. v. Reynolds,
`911 F. 2d 970 (4th Cir. 1990) ................................................................................ 9
`
`Levya v. Certified Grocers of CA, Ltd.,
`593 F.2d 857 (9th Cir. 1979) ............................................................................... 13
`
`Omega v. Costco Wholesale Corp.,
`776 F.3d 692 (9th Cir. 2015) ....................................................................... 8, 9, 11
`
`Practice Mgmt. Info. Corp. v. The Am. Med. Ass’n,
`121 F.3d (9th Cir. 1997) ........................................................................................ 8
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`Case No. 2:19-cv-08535-TJH (ASx)
`ENTRAVISION'S REPLY TO GMR’S
`OPPOSITION TO MOTION TO STAY
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 4 of 14 Page ID #:278
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`Radio Music License Committee, Inc. v. Global Music Rights,
`LLC, No. 2:16-cv-06076, ECF No. 64-1 ............................................................ 10
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`Stebbins v. Geico Ins. Agency,
`2019 WL 281281 (D. Nev. Jan. 22, 2019) ............................................................ 7
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`Tavakoli v. Allstate Property & Cas. Ins. Co.,
`2012 WL 1903666 (W.D. Wash. May 25, 2012) .................................................. 7
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`Wi-LAN Inc. v. LG Elecs. Inc.,
`382 F. Supp. 3d 1012 (S.D. Cal. Apr. 12, 2019) ................................................... 7
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`ZeniMax Media, Inc. v. Samsung Elecs. Co., Ltd.,
`2017 WL 4805524 (N.D. Tex. Oct. 25, 2017) .................................................... 13
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 5 of 14 Page ID #:279
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`I.
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`INTRODUCTION
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`The logic of a modest stay of this action is unassailable: there is a prior
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`related case—the RMLC Action—in which the complex antitrust claims raised in
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`this action are already being litigated, discovery is active and ongoing, and the
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`Court has set a discovery cutoff date and pretrial conference. By contrast, in this
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`action, discovery has not yet begun, and the Court has not even scheduled the Rule
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`26 conference.
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`Once the Court has resolved the antitrust claims in the RMLC Action, this
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`lawsuit literally may be over because a finding that GMR has violated the antitrust
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`laws in the RMLC Action would necessarily carry over to this action and bar
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`GMR’s affirmative claims. Likewise, Entravision has agreed that a finding in favor
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`of GMR on the facts presented in RMLC’s antitrust claims would bind Entravision
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`in this action. What is the logic of forcing Entravision—one of thousands of
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`members of RMLC—to actively litigate its antitrust claims in this action while the
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`RMLC Action is heading towards a resolution? GMR never explains, beyond the
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`implied fact that GMR wants Entravision to have to spend a lot of money on legal
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`fees to put pressure on Entravision to settle.
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`GMR will not suffer any prejudice if a stay of the case is issued, whereas
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`Entravision would be prejudiced if a stay is not issued. For all these reasons,
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`Entravision urges the Court to grant this motion.
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`Case No. 2:19-cv-08535-TJH (ASx)
`ENTRAVISION'S REPLY TO GMR’S
`OPPOSITION TO MOTION TO STAY
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 6 of 14 Page ID #:280
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`II. ARGUMENT
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`A. This Action and the RMLC Action Involve the Same Claims.
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`GMR argues that “[t]he RMLC action does not overlap at all with GMR’s
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`copyright infringement claims.” Opp. at 7. The Court has already rejected this
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`assertion. See ECF No. 25 at 1 (finding two actions related because there are
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`“substantially related or similar questions of law and fact” and “would entail
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`substantial duplication of labor if heard by different judges”).
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`Nor does Entravision “seek[] to use the deliberately engineered similarities
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`between [Entravision’s antitrust counterclaims and RMLC’s antitrust claims] to
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`stall GMR’s prosecution of this action.” Opp. at 7. The resolution of the antitrust
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`claims in the RMLC Action will be outcome determinative to this action. If this
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`Court determines that GMR has violated the antitrust laws as alleged in the RMLC
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`Action, then GMR will also be barred from enforcing a copyright claim against
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`Entravision. Since Entravision has agreed to be bound by the determination in the
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`RMLC Action, proceeding with this case would lead to duplicative and unnecessary
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`litigation. As such, judicial efficiency warrants a stay. See Landmark Tech., LLC
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`v. iRobot Corp., 2014 WL 486836, at *3 (E.D. Tex. Jan. 24, 2014) (“Staying a case
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`at an early juncture can advance judicial efficiency and maximize the likelihood
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`that neither the [c]ourt nor the parties expend their assets addressing invalid
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`claims.”) (internal quotation marks omitted).
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`GMR asks that the Court bifurcate the antitrust and copyright infringement
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`claims, a decision “committed to the sound discretion of the court.” Hangarter v.
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`Provident Life and Accident Ins. Co., 373 F.3d 998, 1021 (9th Cir. 2004) (affirming
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`district court’s refusal to bifurcate where there was a substantial overlap in evidence
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`between the claims at issue). “Nonetheless [bifurcation is] the exception, not the
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`rule.” Tavakoli v. Allstate Property & Cas. Ins. Co., 2012 WL 1903666, at *7
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`(W.D. Wash. May 25, 2012). Id. at *9 (declining to bifurcate trial or discovery
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`because “[b]ifurcation is not likely to make the resolution of this matter more
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`economical or more expedient”). Given the need for the Court to center its judicial
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`resources around the antitrust counterclaims and the related misuse defense,
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`bifurcation is not the exception here.
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`GMR’s position that bifurcation of the two claims would somehow keep the
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`focus on the “real issue” undermines the seriousness of the antitrust claims lodged
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`against it. Entravision’s antitrust claims are not the tail wagging the proverbial
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`“copyright infringement dog”. It is in fact the other way around. GMR’s antitrust
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`violations are at the forefront of this litigation and the RMLC Action. Courts do not
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`separate claims when they are so intertwined, particularly in the beginning stages of
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`litigation. See Stebbins v. Geico Ins. Agency, 2019 WL 281281, at *4 (D. Nev. Jan.
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`22, 2019) (declining bifurcation to avoid “wast[ing] judicial resources” where the
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`claims are intertwined such that it would “require the parties to present much of the
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`same evidence twice, have witnesses testify twice, make many of the same
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 8 of 14 Page ID #:282
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`arguments twice, and pay the cost of litigation twice”); see also Wi-LAN Inc. v. LG
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`Elecs. Inc., 382 F. Supp. 3d 1012, 1026 (S.D. Cal. Apr. 12, 2019) (declining to
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`bifurcate defendant’s antitrust counterclaims because the case is in its initial
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`stages); Clark v. Amica Mutual Ins. Co., 2013 WL 12171876 (E.D. Wash. May 21,
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`2013) (finding that “bifurcation of these claims would not be convenient,
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`expeditious, or economical” . . . because “[t]here is likely to be significant factual
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`overlap”). Based on sound principles of judicial efficiency, Entravision reaffirms
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`its request to stay the case.
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`B. GMR’s Antitrust Violations Arise From Its Leverage of Copyright
`Ownership To Control Areas Outside Its Limited Monopoly and
`These Misuse Issues Are Before the Court in the RMLC Action.
`Copyright misuse precludes enforcement of the copyright for the period of
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`misuse. Practice Mgmt. Info. Corp. v. The Am. Med. Ass’n, 121 F.3d at 516, 520
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`n.9 (9th Cir. 1997). Therefore, GMR may not avail itself of the Court to enforce its
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`copyrights in this case while its present misuse continues.
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`GMR spends large portions of its opposition to the stay motion arguing about
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`the scope of the copyright misuse defense. But this misses the point. Antitrust
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`violations, such as those alleged in the RMLC Action, may form the basis of
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`copyright misuse. As Judge Wardlaw has noted, “the defense is often applied when
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`a defendant can prove either: (1) a violation of the antitrust laws; (2) that the
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`copyright owner otherwise illegally extended its monopoly; or (3) that the
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`copyright owner violated the public policies underlying the copyright laws. Omega
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 9 of 14 Page ID #:283
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`v. Costco Wholesale Corp., 776 F.3d 692, 700 (9th Cir. 2015); see also Broad.
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`Music, Inc. v. Hearst/ABC Viacom, 746 F. Supp. 320, 327-28 (S.D.N.Y. 1990)
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`(holding that forced blanket licensing could give rise to both misuse and antitrust
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`violations); Lasercomb Am. v. Reynolds, 911 F. 2d 970, 977-78 (4th Cir. 1990)
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`(“A patent or copyright is often regarded as a limited monopoly—an exception to
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`the general public policy against restraints of trade. Since antitrust law is the
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`statutory embodiment of that public policy, there is an understandable association
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`of antitrust law with the misuse.”). The Ninth Circuit has even suggested that under
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`certain circumstances a “unilateral refusal to license a copyright may constitute
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`wrongful exclusionary conduct giving rise to a claim of misuse….” A & M
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`Records v. Napster, 239 F.3d 1004, 1027 n.8 (9th Cir. 2001). Of course, the factual
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`underpinnings of the anticompetitive behavior don’t need to rise to the level of an
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`antitrust violation to constitute misuse. Omega, 776 F.3d at 700. But if they do, as
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`alleged here and in the RMLC Action, they may constitute copyright misuse.
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`By any definition, GMR’s blanket licensing structure is classic copyright
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`misuse and violates the antitrust laws. See BMI, 746 F. Supp. 320 (finding both
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`antitrust and misuse properly alleged and, if proven, would constitute misuse).
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`RMLC has challenged the anticompetitive nature of GMR’s actions, including
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`GMR’s leveraging of control beyond the copyrights it owns through its blanket
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`licensing scheme, and these issues will be resolved in the RMLC Action. RMLC
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`Action, ECF 163 at ¶ 37-43. GMR’s conduct has raised significant concerns. The
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 10 of 14 Page ID #:284
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`United States Department of Justice has voiced objection to these practices in cases
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`where the blanket licensor was not even leveraging its ownership of works. Id. at ¶
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`40. As discovery in the RMLC Action will show, GMR’s license scheme and
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`demands give rise to copyright misuse and involve the leveraging of a limited
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`monopoly in rights it owns to control areas outside the monopoly. Therefore,
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`resolution of the RMLC Action, and Entravision’s agreement to abide by the
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`decision therein on those facts, will bar or otherwise resolve GMR’s enforcement of
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`its copyright in this action.
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`GMR’s copyright misuse goes beyond anything an aggregator has done
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`before, as is indicated by documents in the judicial record. See e.g., Radio Music
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`License Committee, Inc. v. Global Music Rights, LLC, No. 2:16-cv-06076, ECF
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`No. 64-1 at Exh. A (Interim License) (“GMR controls the right to license alone or
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`in combination with third party(ies)….”). GMR “controls” works it doesn’t own in
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`a variety of ways. GMR’s catalog contains tens of thousands of works. As RMLC
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`has alleged “many, if not a majority of the works in GMR’s repertory, are in fact
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`only fractional interests in works.” RMLC Action, ECF 163 at ¶ 40. Further, many
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`of these works are subject to agreements between the co-owners, including
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`agreements not to independently enter into licenses without the consent of all co-
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`owners. Thus, by tying up GMR co-owners “fractional license” rights with the
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`works that GMR itself owns, and mandating that they be licensed together or not at
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`all, GMR effectively uses its blanket license to control areas outside GMR’s grant
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 11 of 14 Page ID #:285
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`of monopoly See Napster, 239 F. 3d at 1027 (“The misuse defense prevents
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`copyright holders from leveraging their limited monopoly to allow them control of
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`areas outside the monopoly.”) (citations omitted). This reduces competition, hurts
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`the broadcasters and in turn reduces the availability of works to the public. See
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`Apple Inc. v. Psystar Corp., 658 F.3d 1150, 1157 (9th Cir. 2011) (emphasis added)
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`(holding that “[t]he copyright misuse doctrine does not prohibit using conditions to
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`control use of copyrighted material, but it does prevent copyright holders from
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`using conditions to stifle competition”).
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`GMR is thus leveraging a limited monopoly in works which it purports to
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`exclusively own to control competition in works it doesn’t own. This also supports
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`Entravision’s unclean hands defense, as the Ninth Circuit has recognized,
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`“copyright misuse is an unclean hands defense.” See Omega, 776 F.3d at 700 (J.
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`Wardlaw concurrence) (citing rationale with approval); see also Altera Corp. v.
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`Clear Logic, Inc., 424 F.3d 1079, 1090 (9th Cir. 2005) (copyright misuse is “an
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`unclean hands defense which forbids the use of the copyright to secure an exclusive
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`right or limited monopoly not granted by the Copyright Office and which is
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`contrary to public policy of the grant.”).
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`In the RMLC Action, the Court will also be presented with GMR’s
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`agreements with its licensors that remove “GMR composers” as competitive license
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`sources as to their co-owned works, but without any providing a right to perform
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`these works. These practices and agreements, including the fractionalization of
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`rights in a way not contemplated by the copyright grant, are another form of
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`misuse. There are serious issues to be resolved in the RMLC Action about GMR’s
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`ownership and licensing structure before it can proceed to enforce its copyrights.
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`These are so substantial as to warrant stay of this case, which is “just about a small
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`amount of money” and for which over which the “sky will not fall in” until they are
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`resolved.
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`C. A Stay Will Not Prejudice GMR.
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`GMR’s assertion that a stay would “seriously prejudice GMR,” Opp. at 14, is
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`100% inconsistent with its prior representations in the RMLC Action. In the RMLC
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`Action, lead counsel for GMR admitted in open court that “[t]here is no urgency”
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`here. Specifically, in trying to put off a preliminary injunction hearing against it—
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`notwithstanding its allegation of ongoing infringement by the entire industry—
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`GMR’s counsel represented to the Court as follows:
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`My point is simply this. There is no urgency. There is no dire thing
`that’s going to happen . . . So this problem can be readily solved by
`the parties simply entering into an interim license . . . And we hear
`this, you know, within 90 days thereafter, or some reasonable time
`frame which would take us presumably, you know, into the spring of
`next year. And I can assure Your Honor that, you know, the sky is not
`going to fall between now and then . . . This is all about money. And
`frankly, it’s all about an extraordinary small amount of money.
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`RMLC Action, ECF No. 64-1 at 24-26 (emphasis added). In addition, GMR
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`conceded a lack of urgency where the “extraordinary small amount of money”
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`amounted to $3 million, which hardly justifies a race to trial in this case.
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 13 of 14 Page ID #:287
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`Further, Entravision has stipulated to an interim license with GMR during
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`pendency of the action—the solution GMR proposed to the Court. Therefore,
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`GMR has manifestly expressed its comfort on the record with “wait[ing] . . . to be
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`vindicated” even on an industry wide basis. Opp. at 15. Significantly, time has
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`already been spent briefing and conducting discovery in the RMLC Action, with a
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`pre-trial conference date set to move the litigation along. Thus, the stay requested
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`by Entravision is “within a reasonable time in relation to the urgency of the claims
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`presented to the court.” Levya v. Certified Grocers of CA, Ltd., 593 F.2d 857, 864
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`(9th Cir. 1979).
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`Finally, GMR waited over two years to file this lawsuit against Entravision
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`for alleged copyright infringement. See ZeniMax Media, Inc. v. Samsung Elecs.
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`Co., Ltd., 2017 WL 4805524, at *5 n.11 (N.D. Tex. Oct. 25, 2017) (finding that a
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`stay would not unduly prejudice plaintiff who waited three years to enforce its
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`intellectual property rights). As such, GMR will not be prejudiced by a stay until
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`adjudication of the RMLC Action because “the sky is not going to fall between now
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`and then.” RMLC Action, ECF No. 64-1 at 26.
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`III. CONCLUSION
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`For the reasons stated above and in Entravision’s opening brief, the Court
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`should stay the case until adjudication of the RMLC Action.
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`Case 2:19-cv-08535-TJH-AS Document 33 Filed 02/18/20 Page 14 of 14 Page ID #:288
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`Dated: February 14, 2020
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`JONES DAY
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`By: /s/ Brent D. Sokol
`Brent D. Sokol
`Jeffrey A. LeVee (State Bar No. 125863)
`jlevee@jonesday.com
`Brent D. Sokol (State Bar No. 167537)
`bdsokol@jonesday.com
`JONES DAY
`555 South Flower Street
`Fiftieth Floor
`Los Angeles, CA 90071.2452
`Telephone: +1.213.489.3939
`Facsimile: +1.213.243.2539
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`Attorneys for Defendant and
`Counterclaimant ENTRAVISION
`COMMUNICATIONS CORPORATION
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