Los Angeles News Service v. Reuters Television International, Ltd.
United States Court of Appeals for the Ninth Circuit
340 F.3d 926 (2003)
LANS (plaintiff) licensed footage of a notorious 1992 Los Angeles riot incident to NBC, which under a separate agreement sent a copy of its broadcast to Visnews (defendant) in New York, which then transmitted it to European and African subscribers and also sent it to Reuters (defendant) in London via another New York-based organization; after LANS sued for infringement, the courts held no liability arose for infringement occurring outside the United States and, on remand, limited LANS to profit-based damages (finding none had actually accrued to the defendants) and $60,000 in statutory damages. LANS appealed the ruling barring actual damages for the extraterritorial infringement.
Whether, in calculating damages for copyright infringement occurring outside of the United States, courts may include only profits, not actual damages, attributable to domestic acts of infringement.