Louis Vuitton Malletier, S.A. v. Akanoc Solutions, Inc.

Louis Vuitton Malletier, S.A., sued Managed Solutions Group, Inc. (“MSG”), Akanoc Solutions, Inc., and Steven Chen (collectively “Defendants”) for contributory copyright and trademark infringement, contending that Defendants were liable for their role in hosting websites that directly infringed Louis Vuitton’s trademarks and copyrights. After a trial, a jury found Defendants liable and awarded damages against each defendant. In response to Defendants’ motion for judgment as a matter of law, the district court set aside the jury’s verdict and award against MSG. The district court otherwise denied the motion.

Appellants Akanoc and Chen appeal the jury verdict, contending that the district court erred in instructing the jury and in denying their post-trial motion for judgment as a matter of law. Louis Vuitton cross-appeals the district court’s order granting judgment as a matter of law in favor of MSG. We have appellate jurisdiction under 28 U.S.C. § 1291 . Among other questions, we must decide whether the district court properly instructed the jury on awarding damages as to each defendant. Concluding that there was error, we vacate the damage awards and remand to the…