Capitol Records, LLC v. VideoEgg, Inc.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that “[t]he ‘sheer availability’ of allegedly infringing video files on [defendant’s] website” was “insufficient to support jurisdiction under Section 302(a)(1),” where “videos were available free of charge and irrespective of the viewer’s locale”
• noting that “New York has a substantial interest in protecting the intellectual property rights of copyright owners in the state”
• first quoting Ehrenfeld v. Bin Mahfouz, 881 N.E.2d 830, 834 (N.Y. 2007), then quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985)
• “The alleged tort caused injury in New York because the tort of copyright infringement ‘cause[s] injury in the state where the allegedly infringed intellectual property is held.’ ”
• “[Sjome evidence of volitional activities directed at the forum is required” and similar allegations of web activity insufficient because “it is neither volitional nor distinguishable from [defendants’] interaction with users located in any other jurisdiction”
• “Much of Hi5’s interaction with its New York users, however, lacks the traditional indicia of ‘purposeful availment’ because it is neither volitional nor distinguishable from its interaction with users located in any other jurisdiction.”

Source: CourtListener parenthetical corpus (CC0).