UIRC-GSA Holdings, LLC v. William Blair & Company, L.L.C., No. 23-1527 (7th Cir. 2024)
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The case involves UIRC-GSA Holdings, a company that acquires and manages properties used by the U.S. government, and William Blair, a financial services company. UIRC filed a lawsuit against Blair for copyright infringement, alleging that Blair copied original portions of their bond offering documents during a similar offering with a third party. The District Court granted Blair's summary judgment motion, ruling that UIRC's documents lacked the requisite originality for valid copyrights and awarded Blair attorney’s fees under the Copyright Act.
The United States Court of Appeals for the Seventh Circuit affirmed the judgment of the District Court. The Court of Appeals agreed with the District Court that much of the language in UIRC's documents was copied from documents created by another entity, the Idaho Housing and Finance Association. The court also determined that the language UIRC did draft lacked the creative expression required for copyright protection, as it consisted of facts, fragmented phrases, or language dictated solely by functional considerations. As such, UIRC did not have a valid copyright in the bond documents it alleges Blair copied.
The Court of Appeals further affirmed the District Court's decision to award attorney’s fees to Blair. The District Court had weighed several factors in making this decision, including the frivolousness of the suit, the losing party’s motivation, the objective unreasonableness of the claims advanced by the losing party, and the need to advance considerations of compensation and deterrence.
The court issued a subsequent related opinion or order on March 19, 2024.
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