U.S. Auto Parts Network, Inc. v. Parts Geek, LLC

U.S. Auto Parts Network (USAP) brought suit against Parts, Geek, LLC and various individuals alleging, among other things, copyright infringement in certain e-commerce software. The district court granted summary judgment against USAP on its claim of copyright infringement because it concluded that USAP did not own the allegedly infringed copyright. Because there are genuine issues of material fact as to whether USAP owns a copyright in all or part of the software at issue, we reverse in part, vacate in part, and remand.

I

The story starts in 1996, when Richard Pine and Todd Daugherty founded Benz-Bin, a website that sold Mercedes-Benz car parts. By 2000, Pine and Daugherty met two more internet entrepreneurs, Brian Tinari and Lowell Mann. Together they began to work on what had by then become Partsbin, a website selling replacement parts for cars of all makes. Partsbin needed software to help it process customer orders over the internet (e-commerce software) and so Tinari entered into discussions with a computer programmer, Lucas Thomason, to license an order processing program of Thomason’s called Manager 2000. Thomason wrote the program in “late 1999 or early 2000,”…