Brighton Collectibles, Inc. v. Pedre Watch Co.

A permanent injunction was not granted when the plaintiff was unable to prove (i) it has suffered irreparable injury; (ii) remedies available at law are inadequate; (iii) a remedy in equity is warranted; and (iv) the public interest would not be disserved by a permanent injunction.

Opinion (Battaglia): Brighton Collectibles, Inc. ("Brighton") commenced a copyright action two years ago against Pedre Watch Co. ("Pedre") alleging that Pedre’s watch design infringed on a registered copyright owned by Brighton. After lengthy litigation, the jury returned a verdict finding for Brighton. Specifically, the jury found that Brighton owned a valid copyright on the disputed watch design, Pedre’s watch design copied the original watch design, and that Pedre’s infringement was not-willful. Brighton then sought a permanent injunction against Pedre to permanent enjoin Pedre from future infringement of a large selection of Brighton’s watch designs. The Copyright Act states that a court may grant temporary and final injunctions, as an equitable remedy, on such terms as it may deem reasonable to prevent or restrain infringement of a copyright. An injunction should issue only where the intervention of a court of equity is essential in order effectually to protect property rights against injuries otherwise irremediable. In order to prove that a permanent injunction is appropriate, Brighton must meet a four part test. First, it must prove that it has suffered an irreparable injury. Brighton's argument that the knockoffs were diluting the market did not prove that there was a tangible threat of future infringement, and thus the irreparable injury element was not satisfied. Second, it must prove that remedies available at law are inadequate: here, Pedre was put on notice and infringement following the suit had not happened. Third, it must prove that a remedy in equity is warranted based on a balance of hardships between the parties. Here, because there was no substantial likelihood of future infringement, an injunction would be an unnecessary trade restriction on Pedre. Lastly, it must prove that the public interest would not be disserved by a permanent injunction. Because Brighton's designs were a combination of common design element, the court determined that an injunction would discourage innovation and stifle fair competition. Accordingly, the court DENIED Brighton’s Motion for Permanent Injunction.