Utopia Provider Systems, Inc. v. Pro-Med Clinical Systems, L.L.C., 2009 WL 1210998 (S.D. Fla. 2009)

On May 1, Chief Judge William J. Zloch of the Southern District of Florida issued a final judgment on attorneys’ fees in Utopia Provider Systems.  We discussed this case a couple of months ago.  Utopia brought suit alleging infringement of a series of medical charts.  The Court found that the charts didn’t merit exclusive rights due to the merger doctrine and a lack of originality.  The Court’s analysis in the judgment on attorneys’ fees is relatively straight forward.  Towards the end of the analysis, however, the Court made the following observation on registration:

Moreover, the copyright claim that Plaintiff was suing over had the benefit of a facially valid copyright registration. This registration was, of course, issued by the one body that had the authority to issue the registration and the one body, other than the Court, that is considered expert in this area of the law-the United States Copyright Office. Though the Court invalidated the copyright (a decision that remains pending on appeal), Plaintiff’s reliance on its registration was not frivolous or unreasonable.