Global Media Network v. Pandora

Background

Global Media Network filed this action without paying the $405 in filing and administrative fees and without submitting an application to proceed without prepaying fees. William Scales signed the complaint, but the opinion identifies him as a non-party. The complaint was filed without a lawyer.

The court explained that only a natural person—not an entity such as Global Media Network—may proceed without prepaying fees under the federal fee-waiver statute. The court also explained that an entity cannot represent itself in federal court and must proceed through counsel.

Scales’s Filing History

The court described an extensive filing history involving Scales. It stated that Scales had filed 17 cases in the court since 2023 that were dismissed on the merits, for lack of jurisdiction, as deficient for failing to pay fees or request a fee waiver, or remained pending after being filed without the required payment or application. The court also identified additional cases in which Scales signed complaints listing Global Media Network or Vision Streams as plaintiffs.

The court stated that, in 16 cases filed either in Scales’s name or in the names of those companies, the complaint was submitted without payment of the fees or an application to proceed without prepayment. The court further stated that it had repeatedly directed Scales to correct that deficiency and had previously warned him that continued duplicative or non-meritorious litigation could lead to an injunction restricting future filings without a fee waiver.

Rulings

The court dismissed Global Media Network’s claims without prejudice to the entity proceeding with the action through counsel and after paying the required fees. This ruling addressed the filing requirements and representation of the entity; the opinion does not decide the underlying claims against Pandora.

The court also ordered Scales to show cause—meaning to explain why the proposed restriction should not be entered—within 30 days. He must submit a declaration stating why he should not be barred from filing future actions without prepaying fees, whether in his own name or in the names of his companies, unless he first obtains court permission. The court stated that the restriction would take effect if he failed to submit the declaration or failed to show good cause.

Judge Laura Taylor Swain certified that an appeal would not be taken in good faith and denied fee-waiver status for purposes of an appeal.