The National Academy of Television Arts and Sciences v. Multimedia System Design

Background

The National Academy of Television Arts and Sciences and the Academy of Television Arts & Sciences sued Multimedia System Design, Inc., doing business as “Crowdsource the Truth,” for alleged copyright and trademark violations involving the Emmy statuette and for defamation. After MSDI’s initial attorney was allowed to withdraw, MSDI failed to hire another attorney. The Court then entered a default judgment against MSDI on February 22, 2022.

Jason Goodman, MSDI’s sole shareholder and employee, filed the motion at issue while representing himself. Goodman was not a party to the case at that time. His earlier counterclaims had been dismissed, which removed him from the case, and the Court had previously denied his request to intervene because his interests were adequately represented by MSDI.

Motion and arguments

Goodman sought relief under Federal Rule of Civil Procedure 60(b)(3) and (6). Rule 60 allows a court to change a final judgment in limited circumstances, including because of an opposing party’s fraud or misconduct or for another reason that justifies relief. Goodman asked the Court to vacate the judgment against MSDI, allow him to intervene, and substitute him as the defendant.

Goodman argued that the company named as MSDI was a fictional or separate entity and that the Academies had sued it based on his “Crowdsource the Truth” activities. He also repeated allegations of conspiracy, fraud, and misconduct involving the Academies, their attorneys, and the Court. The Court noted that MSDI’s earlier answer had admitted that a company named Multimedia System Design, Inc. existed and was owned by Goodman, although the answer disputed that “Crowdsource the Truth” was MSDI’s assumed business name.

Goodman’s motion was too late under the court’s local rule governing reconsideration motions, but the Court treated it as timely under Rule 60 because it was filed within one year of the judgment. The Court explained that Rule 60 relief is extraordinary and requires exceptional circumstances.

Ruling

The Court denied Goodman’s motion for reconsideration. It identified several problems with the request: Goodman was not a party and cited no authority supporting his ability to bring a Rule 60 motion; he identified no overlooked controlling law or evidence; and he did not show exceptional circumstances, fraud, or misconduct that could justify relief.

The Court also observed that Goodman’s position was difficult to reconcile with MSDI’s earlier admissions and that, if MSDI were actually defunct and unrelated to his video programs, it was unclear how the judgment against MSDI harmed him. The Clerk was directed to close the motion and mail a copy of the order to Goodman. The opinion does not separately state a disposition of Goodman’s requests to intervene or substitute himself beyond denying the motion for reconsideration.