Copyright Law – The One Satisfaction Rule’s Use in Copyright Cases May Get a Test

Karaoke hardware and software distributor, KTS Karaoke, is in a legal rumble with Sony/ATV Music Publishing about whether KTS’ distribution of karaoke recordings constitutes copyright infringement and the extent of such infringement, as described in this Hollywood Reporter article (click here and here for copies of the lawsuits KTS and Sony/ATV have filed against each other).

Sony claims KTS sold unlicensed karaoke recordings.  KTS apparently did not manufacturing any of these recordings.  One issue that may be determined in these lawsuits is KTS’ contention that Sony should not be entitled to damages from KTS if Sony has already received damages for the distribution of the same unlicensed recordings from someone else, such as KTS’ suppliers (to be more precise, if Sony is entitled to damages from KTS, KTS contends the damages it owes should be reduced by the amount of damages paid by other companies that have paid damages for the same infringement).

The “one satisfaction rule” is a general legal principle wherein an injured party is entitled to one payment for a single injury.  The one satisfaction rule has been applied in at least one copyright case (detailed here in a blogpost from renown copyright commentator, William Patry).

Sony contends the one satisfaction rule does not apply as they consider the upstream manufacturer (KTS’ suppliers) to be unrelated to and not jointly and severally liable with distributors such as KTS.  To the extent both parties infringe, Sony considers this to be separate infringements and therefore Sony should be able to recover damages from both parties.  It will be interesting to see if the court rules on whether the one satisfaction rule applies to this case.


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