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    SUSAN WAKEEN DOLL CO v. ASHTON-DRAKE
    
    In the
    United States Court of Appeals
    For the Seventh Circuit
    
    Nos. 00-2811 & 00-3717
    
    Susan Wakeen Doll Company, Inc.,
    
    Plaintiff-Appellee,
    
    v.
    
    Ashton-Drake Galleries,
    
    Defendant-Appellant.
    
    Appeals from the United States District Court
    for the Northern District of Illinois, Eastern Division.
    No. 98 C 6777--Elaine E. Bucklo, Judge.
    
    Argued February 28, 2001--Decided November 14, 2001
    
    
    
      Before Harlington Wood, Jr., Kanne, and
    Rovner, Circuit Judges.
    
      Kanne, Circuit Judge.  Plaintiff, Susan
    Wakeen Doll Company ("Wakeen"), sculpts,
    designs, and markets collectable dolls.
    Wakeen sued Ashton-Drake Galleries ("Ash
    ton") for copyright infringement under 17
    U.S.C. sec. 501 for allegedly copying the
    head design used in one of Wakeen's most
    popular dolls, the "Love Me Tender."
    After a jury trial, the court entered
    judgment for Wakeen in the stipulated
    amount of $2.1 million and awarded Wakeen
    $203,181.92 in attorney's fees. Ashton
    appeals, alleging that 1) the district
    court erred in denying its motion for
    judgment as a matter of law or, in the
    alternative, for a new trial, 2) the
    district court submitted erroneous jury
    instructions to the jury, 3) the district
    court erred in denying its motion for a
    mistrial, and 4) the district court erred
    in awarding attorney's fees. We affirm
    the district court's denial of Ashton's
    motion for judgment as a matter of law or
    a new trial and find that the allegedly
    erroneous jury instructions did not
    prejudice Ashton. We also affirm the
    district court's denial of Ashton's
    mistrial motion. However, we vacate and
    remand the district court's award of
    attorney's fees. 
    
    I.  History 
    
      A.  The Dolls
    
      A baby head doll sculptor sculpts in a
    pliable clay called plasticine. After
    sculpting the clay, the artist puts the
    clay into a plaster mold. The artist then
    makes a porcelain model of the baby head
    by pouring liquid porcelain into the
    plaster mold and firing the head in a
    kiln. The artist paints the hardened
    porcelain head and adds hair and a body.
    Next, the artist does a wax casting of
    the plaster mold and sends it to a mold
    maker, who submerges it into a liquid of
    copper and nickel in order to create a
    metal mold. This metal mold is used to
    make a "master skin," or vinyl head. The
    best master skins become the actual
    production heads that become the dolls. 
    
      Susan Wakeen, a reputed sculptor and
    designer of baby dolls, started the Susan
    Wakeen Doll Company in 1989. That same
    year, she sculpted the original "Love Me
    Tender" ("LMT") doll head design and
    registered its copyright in 1991. The
    design received a national award of
    excellence and was a commercial success.
    As a result, it has been used in
    approximately forty different dolls
    marketed by Wakeen.
    
      In 1990, Wakeen hired Marlene Sirko
    ("Sirko") to design a head for a
    "relative" of LMT--a baby doll head that
    looked like it was in the same family as
    LMT. Susan Wakeen told Sirko that she
    would supply her with a master skin of
    LMT to use as a reference. Susan Wakeen
    claimed that she sent Sirko the LMT
    master skin via UPS, though Sirko denied
    that she ever received it. Susan Wakeen
    was not pleased with the sculpt that
    Sirko produced, calling it "cartoonish"
    and "oversized." In the fall of 1990,
    Wakeen and Sirko's relationship ended.
    
      Ashton also markets collectable dolls,
    though its dolls are created by
    independent artists. In 1993, Sirko
    supplied Ashton with a clay sculpt that
    Ashton later marketed as a doll entitled
    "The Little Drummer Boy" ("Drummer").
    Sirko was unable to produce any other
    marketable sculpts for Ashton, and,
    therefore, Ashton terminated its
    relationship with Sirko on October 21,
    1993. Despite this, Ashton began
    marketing and selling Drummer at the end
    of 1994. 
    
      The similarities between Drummer and LMT
    were brought to Susan Wakeen's attention
    by several Wakeen employees who had seen
    advertisements for Drummer and by a
    professional doll buyer who stated that
    she had seen Drummer and thought that it
    looked like LMT. As a result, Susan
    Wakeen attempted to create the Drummer
    head using the LMT master skin. She made
    a mold from the master skin, poured
    porcelain into the mold, and shrank it
    two generations to match the size of the
    Drummer head. She then modified the head
    by shaving off a small amount of
    porcelain in a few places. When she
    finished, she concluded that the shrunken
    and modified head was identical to the
    Drummer head. 
    
      Consequently, Wakeen wrote to Ashton on
    July 19, 1995 and informed it of the
    alleged copyright infringement. Ashton
    wrote to Sirko, asking her to explain the
    "extreme similarities between the two
    sculpts." Sirko responded that she had
    created the head that became Drummer
    independently, using a photo that she had
    taken at her son's nursery school as her
    reference. Ashton then wrote to Wakeen,
    assuring them that "the trail of
    development of the Little Drummer Boy is
    complete, from dated photo references of
    the child who was used as a model for the
    doll to pictures of the work in
    progress." Ashton also informed Wakeen
    that Kathy Schultz, the Program Manager
    in charge of Drummer, "worked with
    [Sirko] in the development of the
    sculpt." 
    
      During the following two years, Wakeen
    repeatedly asked Ashton to send it the
    work-in-progress photos and the original
    clay that Sirko submitted to Ashton. In
    response, Ashton told Wakeen that it had
    concluded that the original sculpt of
    Drummer and the final version of LMT were
    very different, and that the two works
    only appeared similar after the reduced
    LMT head had been modified. Ashton did
    not make the original clay sculpt
    available to Wakeen or produce any
    photographs of the work-in-progress until
    court proceedings commenced. Throughout
    its dispute with Wakeen, Ashton continued
    to sell and profit from dolls using the
    Drummer head. 
    
    B.  The Trial
    
      In October, 1998, Wakeen filed suit
    under 17 U.S.C. sec. 501, claiming that
    Ashton infringed its copyright by
    producing and marketing Drummer. Susan
    Wakeen asserted that she had sent Sirko
    an LMT master skin, thus giving Sirko an
    opportunity to copy the doll head. Susan
    Wakeen produced a UPS receipt that
    indicated that she had sent a package to
    Sirko on the day that she claimed to have
    sent the master skin to Sirko. Wakeen
    also presented evidence that LMT and
    Drummer were substantially similar.
    Wakeen's witness, doll-expert Jeanne
    Singer, opined that the external
    structures of the doll heads were
    identical. Susan Wakeen and Singer both
    testified that they had compared the
    Sirko head to a plaster-filled master
    skin of LMT and concluded that the
    dimensions and placement of the dolls'
    facial features were virtually identical.
    Singer also testified that although some
    of the features were different between
    the two dolls, Sirko had most likely made
    minor modifications to the LMT master
    skin in order to disguise her copying.
    Susan Wakeen demonstrated to the jury how
    quickly Drummer could be created from a
    reduced LMT head. Finally, Wakeen claimed
    that Sirko did not have the skill to
    independently create a doll head like
    Drummer's. 
    
      Ashton challenged each aspect of
    Wakeen's case. Initially, Ashton
    attempted to show that Sirko could not
    have copied LMT. Sirko denied receiving a
    master skin from Wakeen, and Ashton
    argued that the evidence was insufficient
    to prove that Wakeen had sent Sirko the
    LMT master skin, or that Sirko had
    received it. Ashton highlighted that
    Wakeen could not produce any records from
    its shipping department or a transmittal
    letter to support its claim that it sent
    the master skin to Sirko. Ashton also
    claimed that the UPS receipt from the
    package that Wakeen sent to Sirko did not
    describe the package's contents. 
    
      Ashton next attempted to rebut Wakeen's
    contention that the dolls were
    substantially similar by calling a doll-
    expert, Erik Blome, who claimed that
    there were overwhelming dissimilarities
    between the two dolls. Blome testified
    that Drummers' features--specifically,
    its nose, cheeks, and lips--were
    different than LMT's. Blome testified
    that he measured the distances between
    facial features on the LMT plaster-filled
    skin and on the Drummer plaster, and that
    the distances were "extremely different"
    between the two. Ashton also argued that
    Susan Wakeen's modification demonstration
    was misleading because she was using a
    head made from porcelain, while Sirko
    would have had to have modified an LMT
    head made out of vinyl.
    
      Finally, Ashton claimed that Drummer's
    head was the independent creation of
    Sirko. Sirko explained, via deposition,
    that she began sculpting her doll head in
    early 1993. She said that she sculpted
    freehand from a block of plasticine clay,
    using photographs of a toddler boy taken
    at her son's nursery school in 1990 as
    her model. Sirko testified that others
    witnessed her work-in-progress, although
    Ashton was unable to produce any
    photographs of Sirko's work-in-progress. 
    
      Ashton called several witnesses to
    support Sirko's assertions. Tania Honeck,
    who lived with Sirko for several months,
    testified that she watched Sirko create
    the Drummer head. Honeck saw Sirko warm
    the clay and mount it to a sculpting
    pole. Honeck also helped select reference
    photographs of the toddler claimed to
    have been the model for Sirko's head and
    said that the photos were constantly
    present in Sirko's studio during the
    sculpting process. Further, she never saw
    an LMT master skin in Sirko's home or
    studio. Ashton then called Sandra
    Gianini, an artist friend of Sirko's.
    Gianini testified that she visited
    Sirko's studio in 1993 and that she
    helped paint eyes on and add hair to the
    Drummer head. Gianini stated that she was
    not present when Sirko sculpted the
    Drummer head, though she also said that
    if she saw the head prior to its
    completion, she probably would not have
    remembered it because of its unfinished
    state. She also testified that she did
    not see an LMT master skin in Sirko's
    studio. Honeck and Gianini both testified
    that Sirko sculpted Drummer in late 1992
    or early 1993, right after Christmas. 
    
      Sirko's husband Yuri testified via
    deposition. Yuri stated that Sirko
    started Drummer's head from a block of
    clay and that he saw Sirko using the
    reference photographs of the toddler boy
    while she was sculpting. He also stated
    that he never saw an LMT doll, master
    skin, or photograph in Sirko's studio.
    Both Yuri and Marlene Sirko testified
    that Sirko sculpted Drummer's head before
    she had any contact with Ashton. They
    claimed that after completing Drummer's
    head in March, 1993, Sirko sent Ashton
    photographs of the finished sculpt, and
    that Ashton suggested a few minor
    changes, such as making the mouth more
    pouty. They also claimed that after
    Ashton approved Sirko's work, it made the
    plaster molds used in the production
    process. Finally, Ashton presented
    evidence showing that Sirko had the
    talent and experience necessary to create
    Drummer's head.
    
    C.  The Instruction Conference
    
      Both parties met with the district court
    judge before closing arguments in order
    to discuss the jury instructions each
    party had previously submitted to the
    court. Rather than using the parties'
    proposed instructions, the court tendered
    a two-page instruction on copyright law
    at the start of the instruction
    conference and gave the parties a
    fewminutes to look it over. The
    instruction informed the jury that Wakeen
    should prevail if it proved that Sirko
    had access to LMT and that Drummer and
    LMT were substantially similar. Ashton
    objected to this instruction because it
    did not address independent creation,
    which would rebut Wakeen's copyright
    infringement claim. Ashton argued that
    even if Wakeen proved access and
    substantial similarity, Ashton should
    prevail if Sirko independently created
    her work. Ashton requested that another
    line be added to the jury instructions
    addressing independent creation. The
    district court judge did not consider
    such an instruction necessary and stated
    that once Wakeen proved access and
    substantial similarity, then there could
    be no independent creation. The district
    court judge and Ashton debated this area
    of copyright law for a few hours, but
    Ashton failed to convince the judge that
    its position was correct. The district
    court judge submitted the original jury
    instructions to the jury, adding one line
    that stated that Ashton claimed that
    Sirko independently created her work. 
    
      At this conference, both parties also
    tendered interrogatories covering access,
    substantial similarity, and independent
    creation that they proposed should be
    used if the court chose to submit a
    special verdict form to the jury. Wakeen
    also submitted a proposed general verdict
    form. The court opted for a special
    verdict, but prepared its own form that
    did not utilize the parties' proposed
    questions. The court's special verdict
    form asked the jury to answer two
    questions--one dealing with access and
    one dealing with substantial similarity.
    Because the court's verdict form did not
    include Ashton's proposed question
    dealing with independent creation, Ashton
    asked for a general verdict form. When
    the court refused, Ashton proffered a
    second question dealing with independent
    creation and suggested that the court
    include it on its special verdict form.
    The court refused this suggestion, and
    the conference ended.
    
    D.  Closing Arguments
    
      During closing arguments, Ashton
    repeatedly told the jury that it should
    find that Ashton did not infringe
    Wakeen's copyright because Sirko had
    independently created her work. Ashton
    explained to the jury that if Sirko inde
    pendently created her work, then that
    meant that she did not copy LMT and that
    there was no infringement. Ashton also
    told the jury that if it found that Sirko
    independently created her work, then it
    should mark "no" on the special verdict
    form asking whether the two heads were
    substantially similar. Although Wakeen
    did not object to this comment, the
    district court judge reprimanded Ashton
    in front of the jury indicating that this
    comment improperly stated the law.
    
    E.  Jury Deliberations
    
      The original jury verdict form posed two
    questions to the jury: "1) Do you find
    that Marlene Sirko had access to
    plaintiff's copyrighted sculpture?" and
    "2) Do you find that there exists a
    substantial similarity between the
    sculpture that became Ashton Drake
    Galleries' 'Little Drummer Boy' and
    plaintiff Susan Wakeen Doll Company's
    copyrighted sculpture?" The morning after
    the jurors began deliberating, the
    district court decided that it needed to
    ask a separate question dealing with
    independent creation. Wakeen opposed
    submitting the supplemental verdict form
    without also submitting clarifying
    instructions to the jury. Ashton agreed
    that the court needed to submit the
    supplemental verdict form, but argued
    against submitting clarifying
    instructions. Neither party objected to
    the court's decision to submit the
    supplemental verdict form after the jury
    returned its verdict with respect to the
    original two questions. Therefore, after
    the jury answered "yes" to both of these
    questions, the district court judge gave
    the jury a supplemental verdict form
    containing the following question: "Do
    you find that Marlene Sirko copied
    plaintiff's copyrighted sculpture to
    create the sculpture that became
    defendant Ashton-Drake Galleries' 'Little
    Drummer Boy?'" Ashton moved for a
    mistrial after the supplemental verdict
    form was submitted to the jury on the
    grounds that the deliberative process had
    been impaired. The court denied Ashton's
    mistrial motion.
    
      The jurors answered "yes" to this third
    question, and the court entered a verdict
    for Wakeen. The court awarded Wakeen $2.1
    million in damages, an amount to which
    both parties had stipulated before trial.
    Ashton moved for judgment as a matter of
    law ("JMOL") or, alternatively, for a new
    trial under Federal Rules of Civil
    Procedure 50(b) and 59(a). The district
    court denied Ashton's motion. The
    district court then awarded Wakeen
    attorney's fees in the amount of
    $203,181.92. 
    
    II.  Analysis
    
    A. Standard of Review
    
      We review a district court's denial of
    a motion for JMOL de novo. See Palmquist
    v. Selvik, 111 F.3d 1332, 1343 (7th Cir.
    1997). Our inquiry, however, is limited
    to "whether the evidence presented,
    combined with all reasonable inferences
    permissibly drawn therefrom, is
    sufficient to support the verdict when
    viewed in the light most favorable to the
    party against whom the motion is
    directed." Goodwin v. MTD Prods., Inc.,
    232 F.3d 600, 606 (7th Cir. 2000). In
    other words, we reverse only if we find
    that no rational juror could have found
    for the prevailing party. See Emmel v.
    Coca-Cola Bottling Co. of Chicago, 95
    F.3d 627, 629 (7th Cir. 1996). We review
    a district court's denial of a motion for
    a new trial to see whether the district
    court judge abused her discretion in
    ruling that the jury verdict was not
    against the clear weight of the evidence.
    See Robinson v. Burlington N. R.R., 131
    F.3d 648, 656 (7th Cir. 1997). This means
    that we will not overturn a jury verdict
    if there is a reasonable basis in the
    record to support it. See id.
    
    B.  Sufficiency of the Evidence
    
      Ashton's first argument is that the
    evidence at trial was insufficient for
    Wakeen to establish a claim of copyright
    infringement against it, and therefore,
    that the district court erred in not
    granting its motion for JMOL or a new
    trial. To establish copyright
    infringement, a plaintiff must prove two
    elements: "1) ownership of a valid
    copyright, and 2) copying of constituent
    elements of the work that are original."
    Feist Publ'ns, Inc. v. Rural Tel. Serv.
    Co., Inc., 499 U.S. 340, 361, 111 S. Ct.
    1282, 113 L. Ed. 2d 358 (1991). The
    parties do not dispute that Wakeen owns a
    valid copyright in LMT, but disagree
    about whether Sirko copied LMT to create
    the head that Ashton marketed as Drummer.
    Given that direct evidence of copying is
    normally unavailable, "copying may be
    inferred where the defendant had access
    to the copyrighted work and the accused
    work is substantially similar to the
    copyrighted work." Atari, Inc. v. N. Am.
    Phillips Consumer Elecs. Corp., 672 F.2d
    607, 614 (7th Cir. 1982). Thus, Wakeen
    could establish a prima facie case of
    copyright infringement by showing that
    Ashton had access to its copyrighted LMT
    doll and that Drummer was substantially
    similar to LMT. See, e.g., Ty, Inc. v.
    GMA Accessories, Inc., 132 F.3d 1167,
    1169-70 (7th Cir. 1997). However, the
    inference of copying that is drawn from
    proof of access and substantial
    similarity can be rebutted by the
    defendant's showing that it independently
    created the allegedly infringing work.
    See id. at 1171.
    
      As a practical matter, if "two works are
    so similar as to make it highly probable
    that the later one is a copy of the
    earlier one, the issue of access need not
    be addressed separately, since if the
    later work was a copy its creator must
    have had access to the original." Id. at
    1170. Thus, if the works resemble each
    other so closely as to make it highly
    unlikely that the challenged work was "an
    accident of independent creation," then
    the similarity "is evidence of access."
    Id. "The more a work is both like an
    already copyrighted work and--for this is
    equally important--unlike anything that
    is in the public domain, the less likely
    it is to be an independent creation." Id.
    at 1169. Thus, a strong showing of
    substantial similarity can operate to
    infer that the defendant had access to
    the plaintiff's work and that the
    defendant copied the plaintiff's work
    rather than independently created its own
    work. However, the presumption of copying
    that arises from a showing of substantial
    similarity can be rebutted by proof of
    independent creation. Id. ("[I]f
    independent creation results in an
    identical work, the creator of that work
    is free to sell it."). A defendant
    independently created a work if it
    created its own work without copying
    anything or if it copied something other
    than the plaintiff's copyrighted work.
    See 3 Melville B. Nimmer & David Nimmer,
    Nimmer on Copyright sec. 12.11[D], at 12-
    175 (2001).
    
      We now turn to the evidence in this case
    to determine if it was sufficient to
    support the jury's findings that: 1)
    Ashton had access to LMT, 2) there were
    substantial similarities between LMT and
    Drummer, and 3) Ashton did not
    independently create Drummer. Viewing the
    facts in the light most favorable to
    Wakeen, as we must, we find that there
    was sufficient evidence to support the
    jury's findings. 
    
      Wakeen could prove access by showing
    that "the defendant had an opportunity to
    view the protected item." Wildlife
    Express Corp. v. Carol Wright Sales,
    Inc., 18 F.3d 502, 508 n.5 (7th Cir.
    1994). Susan Wakeen testified that based
    on a previous working relationship, she
    sent a master skin of the LMT head to
    Sirko via UPS on July 16, 1990. Wakeen
    also introduced a UPS receipt into
    evidence to corroborate this testimony,
    which showed that UPS picked up a package
    addressed to Sirko from Wakeen on that
    day. While Sirko claimed that she never
    received the UPS package, the jury
    rejected this testimony and determined
    that she did receive it--thereby
    inferring that she saw the master skin.
    The jury was presented with conflicting
    stories--that Sirko received the package
    containing the master skin or that she
    did not receive the package. Because
    arational juror could have believed Susan
    Wakeen's testimony that she sent the LMT
    master skin to Sirko via UPS, as
    reflected by the UPS receipt, the jury's
    finding that Sirko had access to LMT was
    not clearly erroneous. See Coca-Cola
    Bottling, 95 F.3d at 629; cf. Anderson v.
    City of Bessemer City, 470 U.S. 564, 574,
    105 S. Ct. 1504, 84 L. Ed. 2d 518 (1985)
    ("[W]here there are two permissible views
    of the evidence, the fact finder's choice
    between them cannot be clearly
    erroneous.").
    
      The jury's access finding is further
    supported by the striking similarity
    between the LMT head and Sirko's doll
    head that provided the basis for Drummer.
    See Ty, 132 F.3d at 1170. This court
    applies the "ordinary observer" test to
    determine whether a substantial
    similarity existed between the two dolls'
    heads. Wildlife Express, 18 F.3d at 508-
    09. The inquiry under this test is
    "whether the accused work is so similar
    to the plaintiff's work that an ordinary
    reasonable person would conclude that the
    defendant unlawfully appropriated the
    plaintiff's protectible expression by
    taking material of substance and value."
    Id. at 509 (quoting Atari, 672 F.2d at
    614). Because the works at issue deal
    with the reproduction of a lifelike
    object--a toddler--Wakeen must prove that
    Drummer is substantially similar "to
    those few aspects of the work that are
    expression not required by the idea."
    Wildlife Express, 18 F.3d at 508.
    
      The "idea" in this case was a depiction
    of a toddler's face. The artistic
    "expression" of LMT according to Wakeen
    was an idealized child's face that
    reflected the essence of a baby's beauty
    and innocence. Wakeen presented
    demonstrative exhibits and expert
    testimony at trial that supported the
    jury's factual determination that LMT and
    Drummer were substantially similar. The
    jury compared the two heads themselves,
    saw photographs of the two heads,
    examined porcelains of the heads, and
    looked at an LMT head with Drummer hair
    in order to assess the similarities
    between the two works. In addition, the
    jury heard testimony from Singer,
    Wakeen's expert, saying that the two
    heads' facial features were virtually
    identical. For example, both heads
    portrayed a toddler with pouty lips that
    were lower on the right side of the
    mouth. 
    
      On appeal, Ashton argues that to the
    extent there is a resemblance between LMT
    and Drummer, this similarity is
    unavoidable. Ashton argues that babies'
    faces all have similar features such as
    large eyes, puffy cheeks, and doubled
    chins. Ashton also claims that there are,
    in fact, marked differences between the
    two dolls. For example, it notes the
    small differences in size between the
    features of the two heads. Even if we
    would have weighed the evidence
    differently than the jury, we cannot
    reverse unless we find that there was no
    rational basis for the jury's finding.
    See Goodwin, 232 F.3d at 606. Here, there
    was testimony showing the similarities
    between the two heads, and these
    similarities related to features that
    were not necessary to capture the essence
    of a baby--such as a pouty expression
    rather than a smile and lips that were
    lower on the right side. Thus, there was
    a rational basis for the jury's
    conclusion that LMT and Drummer were
    substantially similar. See Coca-Cola
    Bottling, 95 F.3d at 629.
    
      Having found that Wakeen successfully
    presented a prima facie case of copyright
    infringement, the jury next considered
    whether Sirko copied LMT in designing the
    head that became Ashton's Drummer, or
    whether Sirko independently created her
    work. In support of its claim that Sirko
    independently created Drummer, Ashton
    presented testimony from Sirko's friends.
    These friends claimed that they saw Sirko
    referring to the photograph of the
    toddler while working on Drummer.
    Further, none of these witnesses saw the
    LMT master skin in Sirko's studio. Wakeen
    countered that Sirko had seen the master
    skin of the LMT, that this skin could
    easily be modified to produce Drummer,
    and that Sirko lacked the skill to
    independently create a head like Drummer
    without copying. Further, Wakeen's
    expert, Singer, testified that Drummer's
    features indicated that Sirko made slight
    modifications to the LMT master skin. On
    appeal, Wakeen also identifies
    inconsistencies in the testimony of
    Sirko's friends. The jury evaluated all
    of this evidence and found that Sirko
    copied LMT in producing the head that
    became Drummer. Because there were facts
    supporting the jury's conclusion, this
    finding is not clearly erroneous. See
    Wildlife Express, 18 F.3d at 506 n.1. 
    
      The record supports the jury's findings
    that Sirko had access to the LMT master
    skin, that LMT and Drummer were
    substantially similar, and that Sirko
    copied LMT in designing the head that
    became Drummer. Therefore, these findings
    were not clearly erroneous, and the
    district court did not abuse its
    discretion in denying Ashton's motion for
    JMOL or for a new trial.
    
    C.  Jury Instructions
    
      Ashton's next contention is that the
    district court's instructions to the jury
    were erroneous, and that these errors
    were prejudicial, requiring that Ashton
    be granted a new trial. To win a new
    trial based on an erroneous jury instruc
    tion, Ashton must show that: 1) the
    instructions did not adequately state
    Seventh Circuit law and 2) it was
    prejudiced by the error because the jury
    was likely confused or misled. See Gile
    v. United Airlines, Inc., 213 F.3d 365,
    375 (7th Cir. 2000). An erroneous jury
    instruction could not prejudice Ashton
    unless considering the instructions as a
    whole, along with all of the evidence and
    arguments, the jury was misinformed about
    the applicable law. See EEOC v. AIC Sec.
    Investigations, Ltd., 55 F.3d 1276, 1283
    (7th Cir. 1995). In other words, even if
    the jury instructions in this case were
    erroneous, if the applicable principles
    of law were communicated to the jury--
    through the arguments or evidence, for
    example--then Ashton does not deserve a
    new trial. See id.
    
      The jury instructions in this case did
    not accurately present the relationship
    between access, substantial similarity,
    and independent creation as explained by
    this court in Ty, 132 F.3d at 1171.
    Specifically, the jury instruction on
    proving copyright infringement failed to
    convey to the jury that Wakeen could not
    prevail if Sirko independently created
    Drummer./1 In Ty, 132 F.3d at 1171
    (emphasis added), we held that:
    
    Access (and copying) may be inferred when
    two works are so similar to each other
    and not to anything in the public domain
    that it is likely that the creator of the
    second work copied the first, but the
    inference can be rebutted by disproving
    access or otherwise showing independent
    creation.
    
    However, the jury instructions in this
    case omitted crucial information and
    stated: "Access (as well as copying) may
    be inferred when a defendant's sculpture
    is so similar to plaintiff's sculpture
    that it is likely that the creator of
    defendant's sculpture copied plaintiff's
    sculpture." At oral argument, Ashton
    conceded that it did not object to this
    clause during the instruction conference.
    Therefore, Ashton has waived any argument
    with respect to this clause. See Deppe v.
    Tripp, 863 F.2d 1356, 1361 (7th Cir.
    1988) (holding that Federal Rule of Civil
    Procedure 51 means "that in civil cases a
    plain error doctrine is not available to
    protect parties from erroneous jury
    instructions to which no objection was
    made at trial.").
    
      Further, the district court instructed
    the jury that: "If you conclude that Ms.
    Sirko had access to plaintiff's
    copyrighted sculpture you should find in
    favor of plaintiff Susan Wakeen Doll
    Company if you find that defendant's
    sculpture is substantially similar to
    plaintiff's copyright." The problem with
    this jury instruction was that it
    suggested that Wakeen could prevail on
    its copyright infringement claim if it
    proved access and substantial similarity
    regardless of whether Sirko independently
    created her work. However, this
    suggestion was not true under Seventh
    Circuit precedent, as Ashton could rebut
    the inference of copying stemming from a
    finding of access and substantial
    similarity by showing that Sirko
    independently created her work. See Ty,
    132 F.3d at 1171. Therefore, Ashton has
    proved half of what it needs to prove in
    order to prevail on this claim--that the
    jury instructions did not adequately
    state the law of this Circuit. 
    
      Ashton must lose on this claim, however,
    because the erroneous jury instructions
    did not prejudice it. The fact that the
    district court recognized its error and
    eventually submitted the crucial third
    question to the jury meant that the jury
    was fully informed of the applicable
    legal principles, albeit in a less than
    ideal manner. After finding that Ashton
    had access to LMT and that Drummer was
    substantially similar to LMT, the jury
    was given a supplemental verdict form
    that asked it to answer a third question:
    "Do you find that Marlene Sirko copied
    plaintiff's copyrighted sculpture to
    create the sculpture that became
    defendant Ashton-Drake Galleries' Little
    Drummer Boy?" This question squarely
    addressed the independent creation
    defense because copying is the opposite
    of independent creation. See, e.g.,
    Eisenschiml v. Fawcett Publ'ns, Inc., 246
    F.2d 598, 603 (7th Cir. 1957). If the
    jury answered "no" to this question,
    Ashton would have prevailed. Therefore,
    although the jury instructions did not
    address independent creation, this
    principle was communicated to the jury
    via the supplemental verdict form, and
    the jury specifically found that Sirko
    did not independently create her work. 
    
      The evidence at trial and defense
    counsel's closing arguments also notified
    the jury that Ashton should prevail if
    Sirko independently created Drummer. See
    AIC Sec. Investigations, 55 F.3d at 1283.
    The majority of Ashton's case focused on
    independent creation. For example, it
    presented evidence that Sirko was an
    accomplished sculptor and that she used a
    1990 photograph of a toddler as the model
    for her head that became Drummer.
    Further, three defense witnesses claimed
    that they saw Sirko using the photograph
    as her model, that they never saw the
    master skin of LMT in Sirko's studio,
    that they conferred with Sirko about
    certain features of her work, and that
    the likeness between Sirko's work and the
    photograph was obvious. This evidence
    helped notify the jury that Ashton's
    defense was that Sirko did not copy LMT,
    but rather, that she independently
    created her work.
    
      During closing arguments, defense
    counsel argued: "If the Little Drummer
    Boy is an original creation of Marlene
    Sirko, the inquiry ends right there. If
    you find Marlene Sirko created,
    independently created the Little Drummer
    Boy, you can go home, the case is over .
    . . ." Further, he stated: "Was this
    copy? Is this copyright infringement? The
    answer is no. Marlene Sirko created this
    doll. She created this with the
    inspiration of this child, a child she
    photographed in her son's nursery school
    in Germantown, Pennsylvania." These two
    comments conveyed to the jury that Ashton
    was relying, in part, on the independent
    creation defense and that if Sirko
    independently created her work, then she
    did not copy LMT. 
    
      In sum, the jury instructions were
    erroneous in that they failed to explain
    that even if Wakeen proved access and
    substantial similarity, Ashton should
    prevail if Sirko independently created
    her work. However, the error in the
    instructions was cured by the fact that
    the evidence and arguments conveyed the
    independent creation defense to the jury
    and by the fact that the jury
    specifically found that Sirko did not
    independently create her work. Therefore,
    Ashton's "speculation that the jury might
    have decided the case differently if
    given the proper instruction is
    insufficient to establish prejudice."
    Gile, 213 F.3d at 375.
    
      On appeal, Ashton claims that the error
    in the jury instructions was compounded
    by events that occurred during closing
    arguments. During its closing argument,
    Ashton's counsel told the jury: 
    
    In fact, you are going to see a verdict
    form that says, "Do you find these heads
    substantially similar?" Well, if you
    believe, if you find that there was no
    copying done by Marlene Sirko, you are
    going to answer that question "No." I'm
    going to repeat that again to you before
    we are done, but if you should find that
    Marlene Sirko's work is an original
    creation of Marlene Sirko, that she did
    not copy Love Me Tender, that question in
    your jury form that says "Is there a
    substantial similarity," you have got to
    answer, you must answer that "No."
    
    At that point, the district court judge
    interrupted and commented in the jury's
    presence: "Counsel, that's an incorrect
    statement, and I believe you know that,
    so I'll give them the law."
    
      Ashton claims that the district court
    judge's comment was reversible error
    because it made its counsel seem
    deceitful and that its counsel was only
    trying to comply with the district
    court's erroneous instructions. In order
    to obtain a reversal, Ashton must show
    that the district court abused its
    discretion in supervising the closing
    arguments. See Trytko v. Hubbell, Inc.,
    28 F.3d 715, 727 (7th Cir. 1994). Whether
    LMT and Drummer were substantially
    similar and whether Sirko independently
    created her work were different
    propositions, see Ty, 132 F.3d at 1171,
    and it was not true that the jury should
    mark "no" to the substantial similarity
    question if it found that Sirko
    independently created her work.
    Therefore, the district court did not
    abuse its discretion by interrupting
    counsel because of this incorrect
    statement. See United States v. Briggs,
    700 F.2d 408, 414 (7th Cir. 1983)
    (stating that a "federal judge has the
    right, and often the obligation, to
    interrupt the presentation of counsel in
    order to clarify misunderstandings").
    Furthermore, the district court did not
    abuse its discretion by stating that
    Ashton's counsel knew it was misstating
    the law. See, e.g., Piepenburg v. Cutler,
    649 F.2d 783, 792-93 (10th Cir. 1981)
    (declining to reverse where district
    court interrupted counsel's closing
    arguments and inferred that counsel
    intentionally misstated the law).
    
    D.  Mistrial Motion  
    
      Ashton also argues that the erroneous
    jury instructions infected the process by
    which the jury considered the
    supplemental verdict form. It complains
    that the district court erred by failing
    to declare a mistrial because of the
    wording of the question on the
    supplemental verdict form, because of the
    timing of when the court gave the
    supplemental verdict form to the jury,
    and because the supplemental verdict form
    was not accompanied by clarifying
    instructions. Ashton bases its mistrial
    motion on the contention that "the
    deliberative process has been severely
    disrupted by reason of the piecemeal
    instruction to the jury." We review a
    denial of a mistrial motion for an abuse
    of discretion. See Raybestos Prods. Co.
    v. Younger, 54 F.3d 1234, 1239 (7th Cir.
    1995).
    
      Ashton complains that the language of
    the supplemental verdict form did not
    adequately notify the jury that the third
    question had to do with independent
    creation. The supplemental verdict form
    asked the jury: "Do you find that Marlene
    Sirko copied plaintiff's copyrighted
    sculpture to create the sculpture that
    became Ashton Drake Galleries' Little
    Drummer Boy?" Ashton argues that because
    this question did not mention the words
    "independent creation" and since it
    required a "no" answer to support Ashton,
    this question favored Wakeen. Ashton's
    argument is without merit because it
    drafted this very question and proffered
    it as a third interrogatory that the
    court should ask the jury. The district
    court chose to submit Ashton's
    interrogatory to the jury, and Ashton is
    in no position to challenge its adequacy.
    Moreover, Ashton told the jury during
    closing arguments that copying was the
    converse of independent creation. 
    
      Ashton also claims that the timing of
    the submission of the supplemental
    verdict form and the fact that it was not
    accompanied by clarifying instructions
    constitute reversible error. After the
    district court decided to submit a
    supplemental verdict form, it sought
    guidance with respect to when it should
    submit the third question to the jury--
    before or after the jury had decided the
    first two questions. Neither party
    addressed this point, but Wakeen argued
    that the district court should accompany
    the supplemental verdict form with
    clarifying instructions telling the jury
    that it could infer copying from the same
    evidence that supported its findings of
    access and substantial similarity. Ashton
    responded to Wakeen's argument by stating
    that clarifying instructions were
    unnecessary because the jury instructions
    already mentioned that the jury could
    infer copying from proof of access and
    substantial similarity. The district
    court agreed with Ashton on this point
    and stated that it thought the best
    course of action would be to wait to
    submit the supplemental verdict form
    until the jury had returned its verdict
    with respect to the other two
    questions./2
    
      Ashton claims that the manner in which
    the supplemental verdict was submitted to
    the jury was reversible error because the
    jury did not know all of the issues that
    needed to be addressed from the outset.
    Ashton claims that the jurors were misled
    by the jury instruction that told the
    jury to find for Wakeen if it found
    access and substantial similarity.
    Therefore, it argues, by the time the
    jury had decided access and substantial
    similarity, the jury thought it had
    already decided the case in Wakeen's
    favor, and the supplemental verdict form
    was meaningless. While Ashton's proffered
    scenario is possible, it is also possible
    that the jury thought that the submission
    of the supplemental verdict form meant
    that the court was displeased with its
    answers to the first two questions. See
    Bonner v. Guccione, 178 F.3d 581, 591 (2d
    Cir. 1999) (stating that post-verdict
    interrogatory may lead "jury to infer
    that judge is conveying her unhappiness
    with the verdict"). However, Ashton's
    reliance on juror confusion is ill-
    founded given that it argued to the
    district court that clarifying
    instructions were not necessary. 
    
      The district court's denial of Ashton's
    mistrial motion was not an abuse of
    discretion. Ashton had the opportunity to
    advise the court on how to submit the
    supplemental verdict form to the jury,
    and the court did what Ashton asked it to
    do. Ashton drafted the third question,
    argued against clarifying instructions,
    and remained silent as to the timing
    issue. Further, on appeal, it has done
    nothing more than speculate that the jury
    was confused. The record, however, does
    not reveal that the jury was confused.
    The jury heard evidence and arguments
    pertaining to the two elements of the
    copyright infringement claim--access and
    substantial similarity--and to the issue
    of independent creation. The district
    court submitted three special
    interrogatories pertaining to each of
    these issues, and the jury deliberated
    for hours on each question before
    returning a verdict in Wakeen's favor on
    all three issues. While it was
    unfortunate that the district court erred
    in initially drafting the jury
    instructions, Ashton has not shown that
    any step of the deliberative process was
    reversible error.
    
    E.  Attorney's Fees
    
      Ashton's final argument is that the
    district court erred in awarding
    attorney's fees. The Copyright Act
    provides that "in its discretion," a
    district court may "award a reasonable
    attorney's fee to the prevailing party as
    part of the costs." 17 U.S.C. sec. 505.
    In utilizing its discretion to award
    attorney's fees under 17 U.S.C. sec. 505,
    a court should consider such non-
    exclusive factors as "frivolousness,
    motivation, objective unreasonableness
    (both in the factual and in the legal
    components of the case) and the need in
    particular circumstances to advance
    considerations of compensation and
    deterrence." Harris Custom Builders, Inc.
    v. Hoffmeyer, 140 F.3d 728, 730 (7th Cir.
    1998) (quoting Fogerty v. Fantasy, Inc.,
    510 U.S. 517, 534 n.19, 114 S. Ct. 1023,
    127 L. Ed. 2d 455 (1994)). Under this
    test, there is no precise rule or
    formula, but courts should apply the test
    in an even-handed manner, treating
    prevailing plaintiffs and prevailing
    defendants alike. Harris Custom Builders,
    140 F.3d at 730 (quoting Fogerty, 510
    U.S. at 534). A showing of bad faith or
    frivolousness is no longer required in
    order to receive attorney's fees. See
    Budget Cinema, Inc. v. Watertower
    Assocs., 81 F.3d 729, 731 (7th Cir.
    1996). We will reverse a court's award of
    attorney's fees under 17 U.S.C. sec. 505
    if the district court applied the wrong
    legal standard or abused its discretion.
    See id. 
    
      In its order, the district court found
    that the "deterrence" factor alone
    created a basis for awarding attorney's
    fees under 17 U.S.C. sec. 505, and
    awarded Wakeen $203,181.92 in fees.
    However, it offered no explanation of how
    this factor supported an award of
    attorney's fees. In fact, all that the
    district court's order said on this
    matter was, "[a]s to deterrence, the
    defendant says that it had stopped the
    infringement before trial and so did not
    need to be deterred, but this confuses
    specific deterrence--deterring this
    wrongdoer from its malfeasance--with
    general deterrence--deterring other
    potential wrongdoers from theirs." Then
    the district court concluded that it
    "would award attorney's fees to the
    plaintiff on deterrence grounds under
    Fogerty." The district court did not
    indicate what behavior it was trying to
    deter, or how the "particular
    circumstances" in this case weighed in
    favor of awarding attorney's fees.
    Fogerty, 510 U.S. at 534 n.19.
    
      Although we are aware that a district
    court may use its discretion to award
    fees under 17 U.S.C. sec. 505, we cannot
    determine how that discretion was
    exercised in this case. In Harris Custom
    Builders, 140 F.3d at 730-31, the court
    vacated and remanded an award of
    attorney's fees where the district court
    judge did not adequately explain the rea
    sons for granting the award. The court
    remanded the case to the district court
    judge for "his comments, which need not
    be extensive, on how his discretion [was]
    being exercised." Id. at 731; see Fasa
    Corp. v. Playmates Toys, Inc., 108 F.3d
    140, 144 (7th Cir. 1997) (refusing to
    "read between the lines" of the judge's
    award of attorney's fees and vacating
    award and remanding case to district
    court so that it could elucidate the
    standard it was applying). While we make
    no judgment on whether the deterrence
    factor alone can support an award for
    attorney's fees--especially given that
    the district court's order was
    unpublished--we note that some
    explanation by the district court about
    its decision is necessary. If the
    district court purports to deter others
    from behaving as Ashton did, then it must
    explain what Ashton did that led to its
    award of attorney's fees. 
    
      The district court also purported to
    award attorney's fees as part of the
    costs under 28 U.S.C. sec. 1920. That
    statute lists six categories of "costs"
    that may be provided to the prevailing
    party as a matter of course, but
    attorney's fees are not a category that
    the statute lists. 28 U.S.C. sec. 1920.
    In a copyright action, fees are governed
    by 17 U.S.C. sec. 505, and any award of
    fees and non-taxable costs must come
    through it, and not through the general
    costs provisions of 28 U.S.C. sec. 1920.
    Cf. Fasa Corp., 108 F.3d at 144 (holding
    that the word "costs" is a term of art
    that does not normally encompass
    attorney's fees). Therefore, the district
    court erred in awarding attorney's fees
    as "costs" under 28 U.S.C. sec. 1920. 
    
    III.  Conclusion
    
      We AFFIRM the district court's denial of
    Ashton's motion for judgment as a matter
    of law; denial of Ashton's motion for a
    new trial; and denial of Ashton's motion
    for mistrial. We VACATE the district
    court's award of attorney's fees and
    REMAND the issue for further action.
    
    FOOTNOTES
    
    /1 The instructions, as read to the jury, stated:
    
    This is a copyright infringement case. The plain-
    tiff Susan Wakeen Doll Company, Inc., claims that
    the defendant Ashton Drake Galleries infringed
    its copyright on a baby doll head sculpted by
    Susan Wakeen which the plaintiff named "Love Me
    Tender." The defendant denies infringing the
    copyright and claims that the sculpture is the
    independent, original creation of Marlene Sirko.
    
    Copyright infringement exists when a defendant
    copies a work to which the plaintiff owns the
    copyright . . . . In order to determine whether
    defendant copied plaintiff's sculpture, you must
    determine whether Marlene Sirko had access to
    plaintiff's copyrighted sculpture. Access (as
    well as copying) may be inferred when a defen-
    dant's sculpture is so similar to plaintiff's
    sculpture that it is likely that the creator of
    defendant's sculpture copied plaintiff's sculp-
    ture. You may also conclude that Ms. Sirko had
    access to plaintiff's copyrighted sculpture if
    you find that plaintiff sent Ms. Sirko a copy of
    that sculpture and believe that Ms. Sirko saw
    plaintiff's sculpture.
    
    If you conclude that Ms. Sirko had access to
    plaintiff's copyrighted sculpture you should find
    in favor of plaintiff Susan Wakeen Doll Company
    if you find that defendant's sculpture is sub-
    stantially similar to plaintiff's copyright.
    Defendant's sculpture is "substantially similar"
    to plaintiff's copyright if an ordinary reason-
    able person, unless he or she set out to detect
    disparities between the plaintiff's and defen-
    dant's sculptures, would be disposed to overlook
    the disparities and regard their aesthetic appeal
    as the same. The two sculptures need not be
    identical for defendant's sculpture to infringe
    plaintiff's copyright. Differences in size,
    shape, color, or feel are not important if there
    are [sic] substantial similarity in the overall
    artistic expression.
    
    /2 The court wanted to wait to submit the supplemen-
    tal verdict form because if the jury answered
    "no" to either of the first two questions--indi-
    cating that Sirko did not have access to LMT or
    that the two heads were not substantially simi-
    lar--then Wakeen would have failed to prove its
    prima facie case, and Ashton would have pre-
    vailed. Therefore, it would have been moot wheth-
    er Sirko had independently created her work.
    
    

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