Absence of Registration Dooms Copyright Case Against Ricky Martin; 1st Cir.

CORTÉS-RAMOS V. MARTIN-MORALES No. 19-1358, 2020 WL 1847072 (1st Cir. Apr. 13, 2020)

Luis Adrian Cortes-Ramos sued Rickey Martin, alleging violations of federal copyright law and Puerto Rico laws. Plaintiff alleged that Ricky Martin’s music video was similar to Plaintiff’s. The district court dismissed Plaintiff’s claims pursuant to Fed. R. Civ. P. 12(b)(6). The First Circuit affirmed in part and vacated in part the decision of the district court. The Court held that the district court was correct in holding that the complaint did not state a proper copyright claim by not alleging registration. However, the district court erred by dismissing the complaint with prejudice because plaintiff had otherwise alleged a copyright claim and on remand the court should consider whether plaintiff could supplement his allegations concerning registration.