Equine Legal Solutions, PC v. Fireline Farms, Inc.
July 13, 2026·3:22-cv-01850-AN·Unpublished·By Maria Santos
The Ninth Circuit vacated a district court judgment awarding four hundred dollars in statutory damages for copyright infringement. The appellate court ordered the lower court to enter judgment in the plaintiff's favor for one thousand five hundred dollars instead.
Plaintiff Equine Legal Solutions, PC appealed a district court judgment awarding four hundred dollars in a copyright action against Defendant Fireline Farms, Inc. The district court had found the defendant’s acts were not willful and awarded the statutory minimum.
The court’s reasoning
The Ninth Circuit held that the district court clearly erred in determining the defendant was unaware of the infringement. The license agreement did not permit online posting, and the plaintiff repeatedly requested removal. Consequently, the defendant knew the acts constituted infringement. The court also affirmed that the district court had wide discretion in setting the award amount, noting the infringements were unintentional in the ordinary sense and caused no discernible harm.
What it means going forward
Defendants in copyright cases cannot claim innocent infringement as a defense if the plaintiff has met the notice requirements of Section four zero one, subsection B, even if the violation was negligent.
