Radio Television Espanola S.A. v. New World Entertainment, Ltd.

Radio Television Española sued New World Entertainment for breach of contract, claiming that New World failed to honor a contract granting Radio Television an exclusive license to broadcast two of New World’s television programs. The district court granted summary judgment for New World because the parties had not complied with 17 U.S.C. § 204 (a)’s requirement that transfers of copyright be in writing. On appeal, we affirm on the merits but reverse the district court’s subsequent determination that New World’s application for costs was untimely.

I. BACKGROUND

New World Entertainment is an American company that produces and distributes *925 television programs. Television Española is a Spanish company owned by Radio Television Española, a company owned by the country of Spain. Television Española acquires rights to broadcast television programs for its principal, Radio Television, and then broadcasts those programs throughout Spain. New World and Television Española had conducted business with each other since at least 1988.

In April 1994, the two companies met at a television market in Cannes, France, where Television Española alleges there was an oral agreement for an…