Minden Pictures, Inc. v. Complex Media, Inc.

Background

On November 28, 2023, the court stayed Complex Media’s motion to dismiss Minden Pictures’ second amended complaint. The stay continued while the Second Circuit considered an appeal in a related copyright case. On August 16, 2024, the Second Circuit held that there is no “sophisticated plaintiff” exception to the discovery rule or to a defendant’s burden to plead and prove a statute-of-limitations defense.

Ruling

The court stated that Complex Media’s motion was based largely on arguments that Minden Pictures was a sophisticated litigant that should have known about the alleged copyright breach and that the discovery rule does not apply in copyright cases without fraud. In light of the Second Circuit’s decision, the court denied the pending motion to dismiss, with leave to amend.

Further proceedings

The parties were ordered to file a joint letter by August 30, 2024, addressing the next steps in the litigation. If Complex Media planned to file another motion to dismiss, the parties had to include a proposed briefing schedule. The Clerk of Court was directed to lift the stay and close the motion pending at ECF No. 37.

Classification

This is a procedural order because it ruled on a motion to dismiss, a threshold pleading motion, rather than deciding the underlying copyright dispute on the merits.