Case Explained: EQUINE LEGAL SOLUTIONS, PC V. FIRELINE FARMS, INC., ET AL.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-13

Docket: 3:22-cv-01850-AN

The ninth-circuit vacated the district court’s judgment awarding $400 in statutory damages and remanded the case with instructions to enter judgment in favor of the plaintiff-appellant in the amount of $1,500. The court held that the district court clearly erred in finding that the defendant was not aware its acts constituted copyright infringement under 17 U.S.C. § 504(c)(2). Applying the standard of review for clear error, the panel determined that because the plaintiff had complied with the notice requirements of 17 U.S.C. § 401(b), the defendant’s claim of innocent infringement was precluded by 17 U.S.C. § 401(d). Furthermore, the court found that the defendant indisputably knew that posting the copyrighted forms online constituted an infringement after being repeatedly notified to remove them, thereby negating any argument for a lower damage tier based on lack of knowledge. Consequently, the statutory minimum award of $750 per infringement applied to the two infringements at issue, resulting in a total of $1,500. The court affirmed that the district court acted within its wide discretion in determining the final amount of statutory damages based on factors such as deterrence and the nature of the conduct, but corrected the legal error regarding the defendant’s state of mind to mandate the higher minimum award.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.