Gilbreath

Laura Gilbreath, Lee Zimmerman, Randi Briggs, John Herold, and the California non-profit mutual benefit association known as the Traditional Cat Association (the “defendants”) appeal the district court’s order denying their request for attorney’s fees under the Copyright Act. They contend that the district court erred when it limited their recovery to fees attributable to copyright claims, without first considering whether the copyright and non-copyright claims were related. They also contend that the district court abused its discretion when it denied their fee request altogether for lack of adequate documentation. We have jurisdiction pursuant to 28 U.S.C. § 1291 . As both of the defendants’ claims are meritorious, we reverse and remand.

I. BACKGROUND

This case arose out of dispute over who owns the right to use the name “Traditional Cat Association,” and who owns the right to use, copy and disseminate certain documents (a constitution and by-laws, a registry, and “breed standards”) developed by the original Traditional Cat Association. The plaintiffs are the Traditional Cat Association incorporated in the State of Washington and Diana L. Finer-an, its head and also…