Sadowski v. Primera Plana NY, Inc.
- George Daniels
- 1:18-cv-10072
- U.S. District Court · Southern District of New York
- 2
In Sadowski v. Primera Plana NY, Inc., Judge Daniels adopted default damages and awarded Sadowski $11,900, including attorney’s fees and costs.
Christopher Sadowski and Primera Plana NY, Inc.; the judgment awarded Sadowski $11,900 and closed the case.
What happened
Christopher Sadowski sued Primera Plana NY, Inc. for copyright infringement. The company did not respond, and Sadowski obtained a clerk’s certificate of default. The court had already granted default judgment and asked Magistrate Judge Wang to determine damages.
Judge Wang recommended awarding Sadowski $11,900: $10,500 in statutory damages and $1,400 in attorney’s fees and costs. No party objected to that recommendation, so the court reviewed it for clear error, meaning an obvious mistake.
Judge George B. Daniels found no error and adopted the recommendation in full. The court directed entry of final judgment for Sadowski for $11,900 and directed the Clerk of Court to close the case.
The detailed version
- Sadowski v. Primera Plana NY, Inc. · No. 1:18-cv-10072
- George Daniels
- Dec. 14, 2021
Background
Christopher Sadowski filed a copyright-infringement lawsuit against Primera Plana NY, Inc. on October 31, 2018. The defendant did not respond to the complaint, so Sadowski obtained a clerk’s certificate of default on February 7, 2019. The court then granted Sadowski’s motion for default judgment and referred the question of damages to Magistrate Judge Wang.
Sadowski also sued unidentified defendants referred to as Does 1–10, but he never amended the complaint to identify them.
Damages Recommendation
After conducting an inquest—a proceeding to determine the amount of damages—Magistrate Judge Wang issued a report recommending a total award of $11,900. The recommendation allocated $10,500 to statutory damages, which are damages set by law, and $1,400 to attorney’s fees and costs. The parties were warned that failing to object on time would waive objections on appeal, but no objections were filed.
Court’s Ruling
Because no objections were filed, Judge George B. Daniels reviewed the report for clear error, meaning an obvious mistake. He found no error, clear or otherwise, in Magistrate Judge Wang’s analysis. The court adopted the report in its entirety, directed that final judgment be entered for Sadowski in the amount of $11,900, and directed the Clerk of Court to close the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.