Humanmade v. SFMade

Background

Humanmade alleged that it developed and authored the Next Generation Manufacturing Training Program between 2018 and 2021 and applied for copyright registration in 2021. The program allegedly included copyrighted materials, training curricula, and other intellectual property. Humanmade and SFMade collaborated on job-training programs, with Humanmade developing the training materials and providing the manufacturing training while SFMade primarily provided placement services.

Humanmade alleged that, after Humanmade, SFMade, and Goodwill Silicon Valley entered a memorandum of understanding to implement a manufacturing-training program, SFMade and its affiliate, Manufacture: San Jose, cut Humanmade out of the project. Humanmade further alleged that SFMade and Manufacture: San Jose then reproduced, distributed, and created derivative works of the program without authorization, while representing that SFMade had developed and owned it.

SFMade’s Motion

SFMade moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which concerns subject-matter jurisdiction, arguing that Humanmade lacked standing because it did not own the copyright. The court rejected that argument. It explained that copyright ownership is part of statutory standing—the question whether a plaintiff has a claim under the relevant statute—not Article III standing, which concerns the Constitution’s requirements for a federal court to hear a dispute. The court stated that copyright ownership could instead be challenged under Rule 12(b)(6), which tests whether a complaint states a legally sufficient claim.

SFMade also moved under Rule 12(b)(6), relying on an application for funding and a master consulting agreement that SFMade argued showed the program was created as a work for hire and that rights were assigned to the City and County of San Francisco. The court declined to consider those documents under the incorporation-by-reference doctrine. That doctrine can allow a court to consider a document outside the complaint when the complaint extensively refers to it or the document forms the basis of the claim. The court found that Humanmade’s complaint did not explicitly mention either document and that the documents did not form the basis of the copyright-infringement claim. The court noted that the documents might relate to an affirmative defense, but that did not make them part of the complaint’s basis.

Court’s Analysis

The court concluded that Humanmade stated a copyright-infringement claim. A copyright-infringement claim requires allegations that the plaintiff owns a valid copyright and that the defendant copied original expression from the copyrighted work. Humanmade alleged that it developed and authored the program, that the program had never been owned by SFMade or anyone other than Humanmade, and that SFMade infringed the program’s materials. Humanmade also attached a Copyright Office registration certificate listing it as the sole author and copyright claimant. The court stated that the certificate was prima facie evidence of copyright ownership and that Humanmade’s allegations plausibly addressed infringement.

Disposition

The court DENIED SFMade’s motion to dismiss. The opinion did not decide whether SFMade actually infringed Humanmade’s copyright; it decided only that the claim could proceed at the pleading stage. The court also set a case management conference for March 12, 2024.