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American Home Realty Network (“AHRN”), based in California, operates a website that displays photos of residential home for sale and that facilitates real estate agent referrals and home sales. Metropolitan Regional Information Systems (“MRIS”), based in Maryland. MRIS facilitates real estate transactions in the mid-Atlantic region by operating and maintaining an automated database consisting of compiled
property listings and related informational content including home photos. Without permission, AHRN included in its website home photos from the MRIS website. MRIS sued AHRN, and AHRN’s CEO in his personal capacity, in U.S. District Court in Maryland on various copyright infringement claims. AHRN and its CEO filed motions to dismiss the case for lack of personal jurisdiction, improper venue, and failure to state a claim.
The court found that there were insufficient specific factual allegations against AHRN’s CEO to support personal jurisdiction under Maryland’s long-arm statute. However, the court found the allegations against AHRN were sufficient for both personal jurisdiction and venue in Maryland, and denied AHRN’s motion to dismiss. The court also found that MRIS was likely to succeed on the merits of its copyright infringement claim, that errors in AHRN’s copies of MRIS data included errors that could cause imminent irreparable harm to MRIS’s credibility in the real estate market, including MRIS’s relationship with its subscribers, that on balance MRIS would suffer more from the lack of a temporary injunction than AHRN would suffer from being temporarily enjoined, and that the public interest is served by issuing a temporary injunction protecting MRIS’s copyrights.
Date: August 27, 2012
Jurisdiction: United States District Court for the District of Maryland
Case Type: Copyright Infringement, Database, Personal Jurisdiction, Long-arm Statute, Venue, Temporary Injunction
Case Status: Trial court decision
Trial Court: Dismissed case against CEO in his individual capacity for lack of personal jurisdiction, denied corporation’s motion to dismiss for lack of personal jurisdiction, granted plaintiff’s motion for temporary injunction against defendant’s infringing conduct.
On Appeal: Not applicable