MESCHKOW & GRESHAM, P.L.C.
Jordan M. Meschkow (AZ Bar No. 007454) Lowell W. Gresham (AZ Bar No. 009702) 5727 North Seventh Street Suite 409 Phoenix, Arizona 85014-5818 (602) 274-6996 (602) 274-6970 (facsimile) Attorneys for Plaintiff
GILES LEGAL, P.L.C.
Nancy R. Giles (AZ Bar No. 020163) 733 West Willetta Street Phoenix, Arizona 85007 (602) 252-1788 Attorney for Plaintiff
UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA DAN COOGAN, doing business as COOGAN PHOTOGRAPHIC, Plaintiff, v. AVNET, INC., et al. Defendants. Case No.: CV-04-0621 PHX SRB PLAINTIFF'S [PROPOSED] SURREPLY TO AVNET'S MOTION TO WITHDRAW ADMISSION AND TO ENTER DENIALS AS TO REQUESTS TO ADMIT NOS. 15 AND 43 OF AVNET'S RESPONSES TO PLAINTIFF'S THIRD REQUESTS FOR ADMISSIONS (sic) (Oral Argument Requested) Plaintiff Dan Coogan ("Coogan") hereby makes this Surreply to Defendant Avnet's Motion and Reply to Withdraw Admission and to Enter Denials as to Requests to Admit Nos. 15 and 43 of Avnet's Responses to Plaintiff's Third Requests for Admissions (sic). In the Reply, Defendant states this Court should grant its Motion "because it will allow the Court to determine the amount of Coogan's alleged damages based on the facts rather than erroneous admissions and Plaintiff has failed to demonstrate that his ability to prove his case will be prejudiced." Reply, at 1. Under Rule 37, FED. R. CIV. P., however, Avnet cannot change its prior admissions as to home page use of Coogan's Photographs in 2002 and 2003 because 1) Avnet failed to establish the admissions were erroneous, 2) Avnet has
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not complied with discovery requests that would or would not confirm this, and 3) discovery is now closed. MEMORANDUM OF POINTS AND AUTHORITIES FACTS The paramount issues remaining in this case are damages, and individual defendants' liability. For Plaintiff to establish damages accurately, all of Avnet's uses of Coogan's Photographs must be known. Thus, as prior documents have shown, one of the very first discovery requests Plaintiff issued in the case was designed to ascertain all of Defendants' infringing uses of Coogan's photographs: · Interrogatory No. 4: State the date (month, day, and year) and circumstances concerning Defendants' first use and all subsequent uses of Plaintiff's Photographs of Roy Vallee and the manner and extent of such first and all subsequent uses, whether on an Avnet website, a third-party website, or in any report or publication. · Document Request No. 1: All documents that Defendant was required to identify or did identify in its response to Plaintiff's First Set of Interrogatories to Avnet. 1 Emphasis added. See Defendants' Responses to Plaintiff's First Set of Interrogatories to Defendant Avnet, Inc. and to Plaintiff's First Request for Production of Documents to Defendants, attached as Exhibit B to Document #108, incorporated by reference herein, served September 27, 2004. Defendants first shirked their discovery responsibilities on November 1, 2004. See Defendants' Responses to Plaintiff's First Set of Interrogatories to Defendant Avnet, Inc. and to Plaintiff's First Request for Production of Documents to Defendants, September 27, 2004, attached as Exhibit B to Document #108, incorporated by reference herein. As a result, 1) in January 2005, Plaintiff had to go to considerable expense to depose two outof-state third-party users (Supply-Chain Council and CMP Media, LLC) to continue to attempt to identify all of the third parties to whom Avnet had provided the infringing photograph 2 and 2) on 3 February 2005, Plaintiff served his Second Request for
1
Even Avnet's first answer to the use interrogatory, albeit vague or incomplete, identified web page use. 2 See discussion in document #209, at 3, incorporated by reference herein.
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Production of Documents to All Defendants (Avnet, Inc., Roy Vallee, and Allen Maag). See Exhibit A, attached hereto. Plaintiff's Second Request for Production sought in particular the following: · YOUR COMPUTER SOFTWARE products and ANY AND ALL DOCUMENTATION RELATING TO them that were used to use, contain, incorporate, or point to ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS from the time YOU obtained possession of them (estimated before the July/August 2001 issue of Avnet Global Perspective magazine) to when all use by YOU of ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS ceased. · ANY AND ALL DOCUMENTS AND/OR DATA FILES stored on ANY COMPUTER that IDENTIFY ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS, or RELATING TO ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS. · ANY AND ALL ARCHIVE AND/OR BACKUP FILES stored on MEDIA that IDENTIFY ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS. · ANY AND ALL COMPUTER, COMPUTER SYSTEM or COMPUTER NETWORK that IDENTIFY ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS. · ANY AND ALL COMPUTER, COMPUTER SYSTEM or COMPUTER NETWORK that formerly carried FILES RELATING TO ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS. · ANY AND ALL COMPUTER, COMPUTER SYSTEM or COMPUTER NETWORK that IDENTIFY ANY AND ALL ACTIVE FILE, DELETED FILE or FILE FRAGMENT RELATING TO ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS. · ANY AND ALL COMPUTER, COMPUTER SYSTEM or COMPUTER NETWORK that IDENTIFY ANY AND ALL AVNET WEBSITES that carries, uses, or displays ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS. · ANY AND ALL COMPUTER, COMPUTER SYSTEM or COMPUTER NETWORK that IDENTIFY ANY AND ALL AVNET WEBSITES that carried, used, or displayed ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS from the time YOU obtained possession of ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS (estimated to be before the July/August 2001 issue of Avnet Global Perspective magazine) to when all use by YOU of ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS ceased. · ALL FILES, COMPUTER SOFTWARE, COMPUTER PROGRAMS AND DOCUMENTATION RELATING TO ANY AND ALL of YOUR COMPUTER SOFTWARE, to make any article displaying or showing ANY AND ALL OF PLAINTIFF'S PHOTOGRAPHS. · All DOCUMENTS that YOU IDENTIFY in YOUR Responses to Plaintiff's First Interrogatories to all Defendants (Avnet, Inc., Roy Vallee, and Allen Maag). The initial and following specific document requests, at a minimum encompassed all of the web pages used by Avnet and attached to Coogan's Complaint as Exhibits. It also
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encompassed earlier Avnet web pages containing Coogan's Photographs.
Despite
Defendants' service of their 30 March 2005 Supplemental Responses to Plaintiff's First Set of Interrogatories to Defendant Avnet, Inc. (including the obtuse and incomplete answer to Interrogatory No. 4), the entire Supplemental Responses attached as Exhibit E to document 108 (and dated March 30, 2004 (sic), but served under document 53, dated 3/30/2005), and Avnet's 1st Supplemental Disclosure Statement, dated March 25, 2005 (document 60, Exhibit 18, tab #3), Avnet did not then, and has not yet produced even ONE of its web pages. Despite numerous letters, meetings, and telephone calls between counsel concerning the lack of answers to the above discovery requests, defense counsel maintained a steadfast refusal to answer, even offering a letter as a "meet and confer" on the issue. See C. Houston July 1, 2005 letter, attached as Exhibit B. Ultimately, this Court heard this discovery dispute, and October 3, 2005, this Court ordered: IT IS ORDERED within two weeks of this date defense counsel shall make a good faith effort to provide plaintiff better production of requested documents. If plaintiff can cite specific items defendant has admitted to using which have not been produced, the Court will reconsider plaintiff's request to allow him access to defendant Avnet's computers. After the Court's Order, on October 17, 2005, defense counsel produced a letter, spreadsheet and CD. See Exhibit C, attached hereto. Defendants' October 17, 2005 letter also identified that (1) the file vallee_r_small.jpg graced www.avnet.com (the home page) when Avnet was first caught infringing in February 2004 on its home page; and (2) the file roy_vallee_board_big.jpg "no longer exists. It was changed and deleted from the active web server on February 25, 2004 as a result of the February 24, 2004 letter from counsel informing Avnet of possible copyright infringement." See Avnet Supplemental Production, RFA Response Chart, Coogan v Avnet, attached to October 17, 2005 letter, at 1; see also Complaint Paragraph reference 23. Prior to this, Avnet identified transferring a file named
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Exhibit D, wherein in AVN0040, Michelle Gorel, Director of Marketing Communications Avnet Technology Solutions send this file, indicated by name
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content, and the use of one photograph of Mr. Vallee on an infinitesimally small percentage of space of the website's pages. The burden and expense of conducting a massive search for materials peripherally related to the Stevie Award far outweighs any potential benefit those materials might provide to either party, See Fed. R. Civ. P. 26(b)(2). See J. Green May 19, 2006 letter, Exhibit G, attached hereto. Even after a meet and confer on June 1, 2006 at 2:00 PM on this issue, certified by the undersigned, Defendants' counsel remained intransigent, refusing to provide a notice that Avnet won, the web pages submitted, or any other related documents. Avnet has now served Avnet's Third Supplemental Response to Plaintiff's First Set of Interrogatories to Defendant Avnet, Inc. - Interrogatory No. 4, attached hereto as Exhibit D. This supplement purports to change "Avnet.com - The photograph was used between January 24, 2004 and February 25, 2004 on the homepage of Avnet.com for public relations. Between August 28, 2002 and February 25, 2004 the picture of Vallee appeared on a secondary page of the website for public relations." 3 to: The photograph was posted on a secondary page (the Press Room) at Avnet.com between August 28, 2002 and February 25, 2004. In January 2004, Bryan Carter was asked to add a "What's New" item on the homepage of Avnet.com. On January 21, 2004 he began working on the photograph for its inclusion in the "What's New" item. The photograph was available for view by the public on the main page at Avnet.com for the first time on February 5, 2004, where it remained until removed on February 25, 2004. The data regarding the dates of placement and removal of the photograph is contained on the CD disclosed on October 17, 2005. See Exhibit H at 2. This change is also erroneous because it omits the Roy Vallee bio pages where Plaintiff's Photograph appeared redundantly on three pages or more (www.avnet.com, www.avnet.de, and www.ir.avnet.com), with links to downloadable copies. See Exhibits to the Complaint/Amended Complaint, incorporated by reference herein. ARGUMENT I. Defendants did not Disprove Admissions, and are, Therefore, Barred under Rule 37 from Altering Such Prior Admissions.
Even assuming what Avnet says is true in Avnet's Second or Third Supplemental See Exhibit D to document 180, incorporated by reference, herein, at 3. ¶5; note the error, here, because it is clear Plaintiff's Photograph of Roy Vallee did not appear "on a secondary page", but rather on secondary pages.
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Response to Plaintiff's First Set of Interrogatories to Defendant Avnet, Inc. - Interrogatory No. 4, this being that the log file for the one file vallee_r_small.jpg proves home page use only for January to February 2004 or early February to late February 2004, this is wholly consistent, and does not repudiate either of Requests to Admit Nos. 15 and 43 of Avnet's Responses to Plaintiff's Third Requests for Admissions. With at least 15 files containing of these photographs 4 , Avnet has not and should not now be able to establish that another file did not grace www.avnet.com as admitted in Requests to Admit Nos. 15 and 43 of Avnet's Responses to Plaintiff's Third Requests for Admissions. A positive identification of the file vallee_r_small.jpg on the home page for the January-February 2004 or February 2004 time-frame cannot disprove earlier 2002 or 2003 use. Therefore, Avnet has produced only evidence consistent with its earlier Admissions. For example, any one of the other at least 15 files may have graced the home page of www.avnet.com either in 2002, or when "Avnet won the Stevie Award" as Requests to Admit Nos. 15 and 43 specify. Moreover, since: 1) Avnet provided no web pages or other related documents in answering Plaintiff's First Request for Production of Documents to Defendant Avnet, Inc., 2) Avnet provided no web pages or other related documents in answering Plaintiff's Second Request for Production of Documents to All Defendants (Avnet, Inc., Roy Vallee, and Allen Maag), and 3) Avnet still refuses to provide relevant web pages or other related documents to its winning a Stevie Award, in response to answering Plaintiff's Fourth Request for Production of Documents to Avnet, Inc., Request No. 28, all of the Defendants cannot use any such evidence at trial, or otherwise in this case: A party that without substantial justification fails to disclose information required by Rule 26(a) or 26(e)(1), or to amend a prior response to discovery as required by Rule 26(e)(2), is not, unless such failure is harmless, permitted to use as evidence at a trial, at a hearing, or on a motion any witness or information not so disclosed. In addition to or in lieu of this sanction, the court, on motion and after affording an opportunity to be heard, may impose other appropriate sanctions. In addition to requiring payment of reasonable expenses, including attorney's fees, caused by the failure, these sanctions may include any of the actions authorized under Rule 37(b)(2)(A), (B), and (C) and may include informing the jury of the failure to make the disclosure.
4
See Exhibit C with 13, Exhibit D with another, and there others not shown in either.
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Rule 37(c), FED. R. CIV. P. All of the instant Defendants must be so barred. II. Avnet's New or Different Information (disproving Admissions 15 and 43) is Not New or Different.
Avnet's "investigation" into home page use that it cited in its Motion to Withdraw Admission and to Enter Denials as to Requests to Admit Nos. 15 and 43 of Avnet's Responses to Plaintiff's Third Requests for Admissions is not based on new or different information. As the October 17, 2005 letter shows, Bryan Carter was actively involved in making and reporting on the logs, and this information was not new or different. Moreover, the October 17, 2005 letter and its prior investigation were completed nearly two months before the December 5, 2005 verification of Avnet's Responses to Plaintiff's Third Requests for Admissions. And, since Defendant in its Reply conveniently ignored the test under Rule 36, Fed. R. Civ. P. as laid out in the case cited by Plaintiff in the Response at Page 8, Victory Carriers, Inc. v. Stockton Stevedoring Co., 388 F.2d 955, 959 (9th Cir. 1968), Avnet's Motion must be refused. Even in its Reply, Defendant's failure to counter its holdings, whatsoever, is poignant: An answer to an interrogatory is comparable to answers, which may be mistaken, given in deposition testimony or during the course of the trial itself. Answers to interrogatories must often be supplied before investigation is completed and can rest only upon knowledge which is available at the time. When there is conflict between answers supplied in response to interrogatories and answers obtained through other questioning, either in deposition or trial, the finder of fact must weigh all of the answers and resolve the conflict. On the other hand, if a party makes a crucial admission in his formal pleading, or in response to a formal request for admissions, then the admitted fact is to be taken as established... (emphasis added) (citations omitted). See document #204. Moreover, the very review it was alleged to have been recently conducted could have been conducted prior to the 5 December 2005 verification of Avnet's Responses to Plaintiff's Third Requests for Admissions. This review is based on personnel and data that were available and more fresh then. To grant Defendant's Motion based entirely on this old data would render the verification meaningless, as well as prejudice Plaintiff, who has relied on the admissions since 5 December 2005 and through the end of discovery.
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Plaintiff also points out that Avnet clearly misrepresented to this Court the basis for its Motion. Defendant's vague allegation that the Motion was based on new evidence and information was a material misrepresentation. Only after Motion, Response, and Reply had been filed did Defendant then reveal that the true basis of the review was information that had been collected and reviewed well before Avnet's Responses to Plaintiff's Third Requests for Admissions and its verification. Nor is this Avnet's first misrepresentation. The Court is reminded that in defending Coogan's Motion for Summary Judgment, Avnet claimed since the suit was filed, it ceased all use (distribution, display, reproduction) of Plaintiff's Photographs, and this was in June of 2005. As noted in Avnet's Second Supplemental Response to Plaintiff's First Set of Interrogatories to Defendant Avnet, Inc. - Interrogatory No. 4, however, Avnet distributed infringing printed 2002 and 2003 Annual Reports through October 2005. Avnet's Motion should be denied because it is based on a material misrepresentation that, if allowed to stand, leads to a corruption of the judicial process. III. Avnet's Reference That "Plaintiff Will Have the Opportunity to CrossExamine Avnet's Employees at Trial" is Untrue.
With Plaintiff having no documents related to Avnet's web pages other than those attached to the Complaint, with Avnet having not disproved what its 2002 home page looked like, and what its home page looked like when Avnet submitted its Stevie Award nomination, and with Avnet barred from doing so under Rule 37, FED. R. CIV. P., there will be no documents to use at trial for cross-examination or otherwise. This not only greatly prejudices Plaintiff now; it forecloses a defense against this change at trial, even using cross-examination. Competent cross-examination is based on evidence. Evidence useful in such a cross-examination was not collected because such collection was unnecessary to Plaintiff, due to Avnet's admission. Now, discovery is closed and Plaintiff is prevented from collecting evidence for use in cross-examination on this point. Accordingly, Plaintiff will be prejudiced if Defendant's motion is granted, because effective cross-examination cannot be done without the evidence that is denied to Plaintiff now that discovery is closed. As stated in Hadley v. United States, 45 F.3d 1345, 1348
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(9th Cir. 1995) "The prejudice contemplated by Rule 36(b) is `not simply that the party who obtained the admission will now have to convince the fact finder of its truth. Rather, it relates to the difficulty a party may face in proving its case, e.g., caused by the unavailability of key witnesses, because of the sudden need to obtain evidence' with respect to the questions previously deemed admitted." Hadley, 45 F.3d at 1348.. Here, without these admissions, there is no other evidence available to Plaintiff, documentary or otherwise, of 2002 or Stevie Award home page use. Moreover, these Admissions are material because they go to damages, the principal remaining issue in this case. Since under the copyright act, damages are "actual damages suffered by him or her as a result of the infringement, and any profits of the infringer that are attributable to the infringement and are not taken into account in computing the actual damages", this admission, or its withdrawal, affects a profits calculation as well as a damages one. See Title 17 U.S.C. § 504(b). IV. Avnet's Statement that "Avnet is the only source of information regarding when the photograph was used on the homepage and when it was not" is Disingenuous, at Best.
When Plaintiff's first letter notifying Avnet of its instant copyright infringement was sent to Avnet on 24 February 2004, all of Avnet's web pages could be accessed at www.archive.org (the Internet Archive website). Immediately thereafter, those web pages were not available because Avnet locked up its server (named "aux") from being "spidered" by the Internet Archive website at www.archive.org. See February 25, 2004 email of Rachel SantaCruz "And as I understand it James has set aux up so it can no longer be spidered. I have already gone in there and started cleaning up but that gives up more time", attached as Exhibit I. Additional emails exist showing Ms. SantaCruz very busily moving the image files of Plaintiff's Photographs then. Now, Avnet claims "Avnet is the only source of information regarding when the photograph was used on the homepage and when it was not". If this is so, then it should have produced its homepages throughout the years, in discovery, and/or attached to its Motion, it should have been able to produce its homepages throughout the years, in
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discovery, and/or attached to its Motion, or it should have allowed Plaintiff to do so during discovery on the well-known Internet Archive website. Avnet either could not or would not produce its homepages, and Avnet's robot.txt file on its server prevents the Plaintiff from obtaining them. Since Avnet refused to produce web page evidence that might have proven or refuted Avnet's more recently preferred stand on these Admissions, and since Avnet has ensured its former websites cannot be obtained on www.archive.org (the Internet Archive website) Avnet should not be rewarded for its failure to produce requested documents by having its motion granted. CONCLUSION With Plaintiff fully compromised to show use or non-use of one of his many images on the Avnet home page in 2002 and in 2003, when Avnet submitted it in 2004 for a Stevie Award, now or at trial, the prejudice is incalculably high. Also, since Defendant Avnet filed their Motion under the guise of a new investigation, when such investigation predated the Admissions by two months, Defendants Motion and Reply to Withdraw Admission and to Enter Denials as to Requests to Admit Nos. 15 and 43 of Avnet's Responses to Plaintiff's Third Requests for Admissions must be denied. Moreover, Avnet itself should be barred from disproving Admissions 15 or 43, by its bad dealings in discovery. This is only fair under Rule 37, Fed. R. Civ. P.
Respectfully submitted this 2nd day of June, 2006,
s/Jordan M. Meschkow Jordan M. Meschkow MESCHKOW & GRESHAM, P.L.C. 5727 North Seventh Street Suite 409 Phoenix, Arizona 85014 Telephone: (602) 274-6996 Facsimile (602) 274-6970 ATTORNEYS FOR PLAINTIFF
Nancy R. Giles GILES LEGAL, P.L.C. 733 West Willetta Street Phoenix, Arizona 85007 Telephone: (602) 252-1788 ATTORNEY FOR PLAINTIFF
Case 2:04-cv-00621-SRB 8050-0131-216-2
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Case 2:04-cv-00621-SRB 8050-0131-216-2
CERTIFICATE OF SERVICE I hereby certify that on 2 June 2006 I electronically transmitted the attached document and its Exhibits to the Clerk's Office using the ECF System for filing and transmittal of a Notice of Electronic Filing to the following ECF registrants: Jordan Green Lawrence Palles FENNEMORE CRAIG 3003 North Central Avenue, Suite 2600 Phoenix, Arizona 85012-2913 Attorneys for Defendants and Nancy R. Giles Giles Legal, P.L.C. 733 West Willetta Street Phoenix, Arizona 85007-1920 Attorneys for Plaintiff
s/Jordan M. Meschkow
Document 216-312 Filed 06/02/2006
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