Ravazzani v. Po
- Analisa Torres
- 1:24-cv-09673
- U.S. District Court · Southern District of New York
- 5
Pablo Ravazzani v. Shop Po, LLC: Judge Willis denied Kal Rieman’s request to reconsider an order refusing to compel licenses and settlement agreements.
Defendant Kal Rieman’s request for reconsideration was denied. The order left in place the earlier refusal to compel Plaintiff Pablo Ravazzani’s licenses and the decision to withhold settlement agreements with co-defendants until after judgment.
What happened
In Pablo Ravazzani v. Shop Po, LLC, Defendant Kal Rieman asked the court to reconsider its earlier refusal to require Ravazzani to produce licenses and settlement agreements involving his copyrighted photographs.
Rieman argued that the documents were needed to evaluate Ravazzani’s damages, possible duplicate recovery, and the effect of settlements with other defendants. The court had previously found that Ravazzani’s direct licensing history was a better measure of licensing fees and that the settlement agreements did not need to be produced before judgment.
Judge Jennifer E. Willis denied Rieman’s motion for reconsideration. She found no clear error or unfairness in the earlier ruling and declined to consider Rieman’s new duplicate-recovery argument because he had not raised it in the original motion.
The detailed version
- Ravazzani v. Po · No. 1:24-cv-09673
- Analisa Torres
- Nov. 13, 2025
Background
Defendant Kal Rieman moved for reconsideration of the court’s earlier denial of his motion to compel Plaintiff Pablo Ravazzani to produce licenses for Ravazzani’s photography services and settlement agreements involving Ravazzani’s copyrighted photographs. The court had denied the motion to compel in full on October 7, 2025.
Rieman then sought reconsideration under Local Civil Rule 6.3. He argued that Second Circuit authority allowed actual and statutory damages to be measured by the market value of a copyrighted work at the time of infringement. He also argued that settlement agreements with co-defendants should be produced before judgment so he could assess their effect on Ravazzani’s damages theory, including whether Ravazzani might seek duplicate recovery or whether the agreements contained releases affecting liability or damages.
Legal standard
The court described reconsideration as an extraordinary remedy used sparingly. A party seeking it must generally identify an intervening change in controlling law, new evidence, or a clear error or manifest injustice in the earlier ruling. Reconsideration is not an opportunity to repeat arguments already rejected or raise arguments that could have been made earlier.
Court’s analysis
The court found no clear error or manifest injustice in refusing to compel all of Ravazzani’s licenses and settlement agreements. It explained that the cases Rieman cited involved situations without a direct licensing history, where past licenses or settlement agreements were needed to estimate licensing fees. Here, the parties had a direct licensing history, making Ravazzani’s personally negotiated licenses the relevant comparison.
The court also declined to reconsider its decision that settlement agreements with co-defendants did not need to be produced before judgment. It had already considered and rejected Rieman’s timing argument and had found the agreements irrelevant to liability or damages at that stage. The court further declined to consider Rieman’s duplicate-recovery argument because he raised it for the first time in the reconsideration motion and did not explain why he had not raised it earlier.
Disposition
The court denied Rieman’s motion for reconsideration and requested that the Clerk of Court close Docket No. 159. This order addressed reconsideration of a discovery ruling; it did not decide the underlying copyright claims or damages issues.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.