In United States v. Rajaratnam, a jury convicted the defendant of five counts of conspiracy to commit securities fraud and nine counts of securities fraud arising from insider trading. Rajaratnam renewed his motion under Federal Rule of Criminal Procedure 29 for a judgment of acquittal on all counts, contending that the evidence was insufficient. The district court denied the motion in full, applying the Rule 29 standard that requires viewing the evidence in the light most favorable to the prosecution and drawing all reasonable inferences in the government's favor, and concluding that a rational jury could find guilt beyond a reasonable doubt. The court reasoned that circumstantial evidence, including testimony and trading records, adequately established the elements of conspiracy agreements to share material nonpublic information and the execution of trades based on that information.
This case involved a trademark licensee, AB Sciex, seeking to enjoin arbitration proceedings initiated by its licensors, Life Technologies and Applied Biosystems, over the use of trademarks transferred in connection with the sale of a mass spectrometry business. The Purchase Agreement governing the sale contained an arbitration clause for disputes arising from it or related transaction documents, but the separate License Agreement granting AB Sciex the trademark rights did not. AB Sciex argued it was not bound by the arbitration clause as a non-signatory to the Purchase Agreement and that its trademark use was governed solely by the License Agreement. The court denied the motion to enjoin arbitration, holding that AB Sciex was estopped from avoiding arbitration because it knowingly exploited direct benefits of the Purchase Agreement through the licenses obtained via the License Agreement, which was an ancillary agreement required by the Purchase Agreement.
The case involved Canal + Image UK Ltd. suing lyricist and songwriter defendants for copyright infringement and breach of contract, alleging that their musical adaptation of the 1949 film Kind Hearts and Coronets exceeded the scope of a time-limited licensing agreement that had expired after Canal + declined to produce the work. The court had previously dismissed the copyright claim for lack of substantial similarity between the works and the contract claim as preempted by the Copyright Act. Defendants then moved for attorney’s fees under 17 U.S.C. § 505, but the court denied the motion, holding that Canal + had not litigated in bad faith and that the circumstances did not otherwise justify a fee award to the prevailing defendants.
This case involves current and former employees of Thalassa Restaurant suing the restaurant operator, its owners and managers (the Makris family), and a related food importer for alleged violations of the Fair Labor Standards Act, New York Labor Law, and related state and city laws concerning wages, overtime, tips, and employment practices. The court ruled on cross-motions for partial summary judgment and a motion to dismiss certain plaintiffs, granting and denying each in part. It applied the economic realities test to determine employer status, finding that certain individual defendants exercised sufficient control over employees to qualify as employers while others did not, and resolved disputes over specific wage claims, willfulness for statute of limitations purposes, and liability for related entities based on the degree of operational involvement and ownership.
This case concerns an appeal from a bankruptcy court order holding that state-law apparent manufacturer claims against Pfizer (parent of debtor Quigley) were barred by the § 524(g) channeling injunction issued in Quigley's Chapter 11 asbestos bankruptcy. The district court reversed, ruling that the claims—based on Pfizer's use of its logo on Quigley asbestos products—fell outside the injunction's scope because they did not allege liability arising from Pfizer's ownership of, management of, insurance to, or corporate transactions with Quigley. The court further noted that related-to jurisdiction was doubtful under precedents like Pacor and Combustion Engineering but rested its decision on the injunction's limited statutory reach, allowing the claims to proceed in Pennsylvania state court.
The case involved FR8 Singapore Pte. Ltd. seeking to compel Albacore Maritime Inc. and related Prime Defendants to arbitrate claims in London by treating the Prime Defendants as alter egos of Albacore under a contract with an English choice-of-law clause. The court had previously ruled that English law governed the alter-ego analysis and allowed defendants to renew their motion to dismiss after further briefing. On reconsideration, the court rejected FR8's arguments that federal common law should instead apply to the veil-piercing question. Applying English law, the court found the complaint insufficient because it did not allege that Albacore was incorporated to evade existing liabilities at the time of the transaction. The court therefore denied reconsideration and the request for a certificate of appealability, granted the motion to dismiss, and closed the cases.