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Copyright Lessons from the Fourth Circuit

By William M. Bryner and Kristin G. Garris
November 23, 2010

The U.S. Court of Appeals for the Fourth Circuit recently affirmed a judgment in excess of $11 million entered against a furniture manufacturer found liable for copyright infringement. Universal Furniture International, Inc. v. Collezione Europa USA, Inc., 618 F.3d 417 (4th Cir. 2010). Following a bench trial in 2007, Collezione Europa USA, Inc. (“Collezione”) was found liable for, among other things, infringing the copyrighted furniture designs of Universal Furniture International, Inc. (“Universal”). See Universal Furniture Int'l, Inc. v. Collezione Europa USA, Inc., 2007 WL 2712926 (M.D.N.C. 2007). Subsequently, Collezione was ordered to pay Universal its entire gross revenues from sales of the infringing furniture ' a remedy provided for by the Copyright Act. See Universal Furniture Int'l, Inc. v. Collezione Europa USA, Inc., 2009 WL 367538 (M.D.N.C. 2009). Although the Fourth Circuit's judgment has not yet become final, unless it is reversed or overruled this opinion establishes, for the first time in that Circuit, certain significant principles of copyright law, as discussed below.

History of the Litigation

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