Rockefeller Photos, LLC v. Obaid Partners, Inc. — Court Grants Default Judgment but Reduces Statutory Damages from $630,000 to $15,750

Background

Rockefeller Photos, LLC filed a motion for default judgment against Obaid Partners, Inc., doing business as Sam's Foods Supermarket, on August 19, 2026 (Doc. 15). The matter was referred to a United States Magistrate Judge under 28 U.S.C. § 636(b)(1)(B) and Local Rule 302(c)(19). On September 8, 2026, the assigned magistrate judge issued findings and recommendations recommending that plaintiff's motion be granted (Doc. 17). The court ordered plaintiff to serve the findings and recommendations on defendant at its last known address, and no objections were filed.

The dispute concerns twenty-one stock photographs of fruits and vegetables used by a single grocery store. Plaintiff sought maximum statutory damages of $30,000 per infringed image, totaling $630,000, while also noting that its annual license fees to license its entire library of images over the two-year period of the infringement would have been only $23,976 (Doc. 15 at 18).

Because no objections were filed, the district court conducted a de novo review of the case under 28 U.S.C. § 636(b)(1) before acting on the magistrate judge's findings and recommendations.

The Court’s Holding

After de novo review, the court concluded that the finding and recommendation that plaintiff is entitled to a default judgment against defendant is supported by the record, and it adopted the September 8, 2026 findings and recommendations in part and granted the motion for default judgment. The court nevertheless rejected the recommended damages of $630,000, finding that maximum statutory damages of $30,000 per image for each of the 21 images was excessive and unsupported, citing Corson v. Wylde Group, Inc., which observed that such a request 'appears to be far beyond the upper range of many statutory damage awards throughout the country.'

The court contrasted VHT v. Zillow Group, Inc., 69 F.4th 983 (9th Cir. 2023), where the Ninth Circuit affirmed a post-trial award of $800 per image for over 2,000 images that had not been innocently infringed, with this case's single grocery store using 21 stock photos of fruits and vegetables. Finding persuasive the reasoning of the District of Massachusetts in Rockefeller Photos, LLC v. Bston Pizza, Inc., which held that the statutory minimum of $750 per work was adequate in similar circumstances, the court adopted that reasoning here.

The court entered judgment in plaintiff's favor against Obaid Partners, Inc., granted injunctive relief enjoining defendant from further unauthorized infringement of the twenty-one copyrighted images, awarded statutory damages of $15,750 (the $750-per-image minimum) with post-judgment interest under federal law, awarded attorney's fees of $2,437.50 and costs of $536.50, and directed the Clerk of Court to close the case.

Key Takeaways

• A court may grant default judgment on liability while independently reducing a recommended statutory damages award it finds excessive and unsupported by the record.
• Maximum statutory damages of $30,000 per work are not automatic; courts compare the request to awards in comparable cases and to the plaintiff's own evidence of actual licensing fees.
• The statutory minimum of $750 per work can be found adequate to protect a copyright and remedy infringement where a small business uses a limited number of stock images.
• A copyright default judgment can include injunctive relief, statutory damages, post-judgment interest, attorney's fees, and costs even when the defendant does not appear or object.
• De novo review under 28 U.S.C. § 636(b)(1) allows the district court to adopt a magistrate judge's liability recommendation while modifying the recommended damages.

Why It Matters

The decision illustrates how courts calibrate statutory damages in copyright default cases, relying on the plaintiff's own licensing-fee evidence and comparable awards rather than the requested maximum. It shows that the statutory minimum can suffice where the infringement is modest, balancing copyright protection against proportionality to actual harm.

For copyright owners and small-business defendants alike, the order confirms that default judgment does not guarantee maximum statutory damages, and that courts will scrutinize per-image maximum requests against real-world licensing values and peer awards.