United States Golf Ass'n v. Arroyo Software Corp.

Arroyo Software Corporation (Arroyo) appeals from a judgment enjoining it from misappropriating golf handicap formulas and service marks developed and owned by the United States Golf Association (USGA). Arroyo contends the trial court erred in (a) refusing to bar USGA’s lawsuit on the ground it was collaterally estopped by an earlier decision of the United States Court of Appeal for the Third Circuit involving USGA and a different defendant (United States Golf Ass’n v. St. Andrews Systems (3d Cir. 1984) 749 F.2d 1028 (St. Andrews)); (b) rejecting Arroyo’s argument USGA’s lawsuit is preempted by federal copyright law; and (c) granting summary adjudication for USGA on Arroyo’s cross-complaint against USGA for unfair competition, tortious interference with prospective economic advantage, and violation of California antitrust laws. In a cross-appeal, USGA argues that the trial court committed reversible error by declining to award it costs. We affirm the judgment in all respects.

I. Factual and Procedural Background

The USGA was founded in 1894. One of its chief contributions to the game of golf in the United States has been its development and maintenance since 1911 of the…