Manatt Represents Iglesia Ni Cristo (Church of Christ) in Copyright Infringement Case

Manatt Entertainment Partner Nathaniel Bach and Litigation Associate Thomas Worger successfully represented Iglesia Ni Cristo (INC) (Church of Christ), a nonprofit religious organization based in the Philippines with branches in the United States, in a copyright infringement lawsuit filed against former church minister Isaias T. Samson Jr. INC alleged that Samson broadcast unaffiliated religious services via Zoom during which he unlawfully displayed and publicly performed INC’s copyrighted hymns to his viewing audience.

On May 12, 2022, following Bach’s argument, Judge Jon S. Tigar of the U.S. District Court for the Northern District of California denied Samson’s motion to dismiss and granted our client’s motion for a preliminary injunction, enjoining Samson from infringing Iglesia Ni Cristo’s copyrighted hymns, including those in its copyrighted Hymnals. The Court agreed with our client’s argument that the Copyright Act’s religious services exemption in 17 U.S.C. § 110(3) does not apply to broadcasts of religious services or transmissions to the public at large. The Court wrote that “[t]o hold otherwise would effectively deprive religious organizations of the right to safeguard their intellectual property rights from infringers who broadcast their services online.” The Court also found that “the equities [] easily favor Iglesia Ni Cristo” and that “a preliminary injunction is in the public interest.” In the wake of the preliminary injunction, INC settled the matter, with the Court entering a consent decree and permanent injunction against Samson.



pursuant to New York DR 2-101(f)

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