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    THREE BOYS MUSIC v BOLTON, 9755150

    U.S. 9th Circuit Court of Appeals

    THREE BOYS MUSIC v BOLTON
    9755150

    THREE BOYS MUSIC CORPORATION,
    Plaintiff-Appellee,
    
    v.
    Nos. 97-55150
    MICHAEL BOLTON, individually and
    97-55154
    d/b/a MR. BOLTON'S MUSIC, INC.;
    ANDREW GOLDMARK; NON-PAREIL
    D.C. No.
    MUSIC, INC.; WARNER-CHAPPELL
    CV-92-01177 LGB
    MUSIC LIMITED; WARNER-
    OPINION
    TAMERLANE PUBLISHING CORP.; WB
    MUSIC CORP.; and SONY MUSIC
    ENTERTAINMENT, INC.,
    Defendants-Appellants.
    
    
    Appeals from the United States District Court
    for the Central District of California
    Lourdes G. Baird, District Judge, Presiding
    
    Argued and Submitted
    October 5, 1999--Pasadena, California
    
    Filed May 9, 2000
    
    Before: Betty B. Fletcher, Dorothy W. Nelson, and
    Melvin Brunetti, Circuit Judges.
    
    Opinion by D.W. Nelson
    
    _________________________________________________________________
    
    COUNSEL
    
    Robert G. Sugarman, Weil, Gotshal & Manges, New York,
    New York, for the defendants-appellants.
    
    Russell J. Frackman, Mitchell, Silberberg & Knupp, Los
    Angeles, California, for the defendant-appellant.
    
    Pierce O'Donnell, O'Donnell & Shaeffer, Los Angeles, Cali-
    fornia, for the plaintiff-appellee.
    
    John P. McNicholas, McNicholas & McNicholas, Los Ange-
    les, California, for the plaintiff-appellee.
    
    Louis Petrich, Leopold, Petrich, & Smith, Los Angeles, Cali-
    fornia, for amici, Recording Industry Association of America,
    Inc. and Motion Picture Association of America, Inc.
    
    _________________________________________________________________
    
    OPINION
    
    D.W. NELSON, Circuit Judge:
    
    In 1994, a jury found that Michael Bolton's 1991 pop hit,
    "Love Is a Wonderful Thing," infringed on the copyright of
    a 1964 Isley Brothers' song of the same name. The district
    court denied Bolton's motion for a new trial and affirmed the
    jury's award of $5.4 million.
    
    Bolton, his co-author, Andrew Goldmark, and their record
    companies ("Sony Music") appeal, arguing that the district
    court erred in finding that: (1) sufficient evidence supported
    the jury's finding that the appellants had access to the Isley
    Brothers' song; (2) sufficient evidence supported the jury's
    finding that the songs were substantially similar; (3) subject
    matter jurisdiction existed based on the Isley Brothers regis-
    tering a complete copy of the song; (4) sufficient evidence
    supported the jury's attribution of profits to the infringing ele-
    ments of the song; (5) Sony Music could not deduct its tax lia-
    bility; and (6) the appellants' motion for a new trial based on
    newly discovered evidence was unwarranted.
    
    We affirm.
    
    I. BACKGROUND
    
    The Isley Brothers, one of this country's most well-known
    rhythm and blues groups, have been inducted into the Rock
    and Roll Hall of Fame. They helped define the soul sound of
    the 1960s with songs such as "Shout," "Twist and Shout," and
    "This Old Heart of Mine," and they mastered the funky beats
    of the 1970s with songs such as "Who's That Lady, " "Fight
    the Power," and "It's Your Thing." In 1964, the Isley Broth-
    ers wrote and recorded "Love is a Wonderful Thing " for
    United Artists. The Isley Brothers received a copyright for
    "Love is a Wonderful Thing" from the Register of Copyrights
    on February 6, 1964. The following year, they switched to the
    famous Motown label and had three top-100 hits including
    "This Old Heart of Mine."
    
    Hoping to benefit from the Isley Brothers' Motown suc-
    cess, United Artists released "Love is a Wonderful Thing" in
    1966. The song was not released on an album, only on a 45-
    record as a single. Several industry publications predicted that
    "Love is a Wonderful Thing" would be a hit -- "Cash Box"
    on August 27, 1966, "Gavin Report" on August 26, 1966, and
    "Billboard" on September 10, 1966. On September 17, 1966,
    Billboard listed "Love is a Wonderful Thing" at number 110
    in a chart titled "Bubbling Under the Hot 100. " The song was
    never listed on any other Top 100 charts. In 1991, the Isley
    Brothers' "Love is a Wonderful Thing" was released on com-
    pact disc. See Isley Brothers, The Isley Brothers -- The Com-
    plete UA Sessions, (EMI 1991).
    
    Michael Bolton is a singer/songwriter who gained popular-
    ity in the late 1980s and early 1990s by reviving the soul
    sound of the 1960s. Bolton has orchestrated this soul-music
    revival in part by covering old songs such as Percy Sledge's
    "When a Man Love a Woman" and Otis Redding's"(Sittin'
    on the) Dock of the Bay." Bolton also has written his own hit
    songs. In early 1990, Bolton and Goldmark wrote a song cal-
    led "Love Is a Wonderful Thing." Bolton released it as a sin-
    gle in April 1991, and as part of Bolton's album,"Time, Love
    and Tenderness." Bolton's "Love Is a Wonderful Thing" fin-
    ished 1991 at number 49 on Billboard's year-end pop chart.
    
    On February 24, 1992, Three Boys Music Corporation filed
    a copyright infringement action for damages against the
    appellants under 17 U.S.C. SS 101 et seq.  (1988). The parties
    agreed to a trifurcated trial. On April 25, 1994, in the first
    phase, the jury determined that the appellants had infringed
    the Isley Brothers' copyright. At the end of second phase five
    days later, the jury decided that Bolton's "Love Is a Wonder-
    ful Thing" accounted for 28 percent of the profits from
    "Time, Love and Tenderness." The jury also found that 66
    percent of the profits from commercial uses of the song could
    be attributed to the inclusion of infringing elements. On May
    9, 1994, the district court entered judgment in favor of the
    Isley Brothers based on the first two phases.
    
    The deadline for post-trial motions was May 25, 1994. On
    that day, the appellants filed a motion for judgment as a mat-
    ter of law and a motion for new trial. The district court denied
    the motions on August 11, 1994. On June 8, 1994, the appel-
    lants filed a second motion for new trial based on newly dis-
    covered evidence on the issue of copyright ownership. The
    district court dismissed this motion as untimely.
    
    On December 5, 1996, the district court adopted the find-
    ings of the Special Master's Amended Report about the allo-
    cation of damages (third phase). In the final judgment entered
    against the appellants, the district court ordered Sony Music
    to pay $4,218,838; Bolton to pay $932,924; Goldmark to pay
    $220,785; and their music publishing companies to pay
    $75,900. They timely appealed.
    
    II. DISCUSSION
    
    Proof of copyright infringement is often highly circumstan-
    tial, particularly in cases involving music. A copyright plain-
    tiff must prove (1) ownership of the copyright; and (2)
    infringement -- that the defendant copied protected elements
    of the plaintiff's work. See Smith v. Jackson , 84 F.3d 1213,
    1218 (9th Cir. 1996) (citation omitted). Absent direct evi-
    dence of copying, proof of infringement involves fact-based
    showings that the defendant had "access" to the plaintiff's
    work and that the two works are "substantially similar." Id.
    
    Given the difficulty of proving access and substantial simi-
    larity, appellate courts have been reluctant to reverse jury ver-
    dicts in music cases. See, e.g., id. at 1221 (affirming a jury's
    verdict for the defendants in a copyright infringement case
    involving Michael Jackson and other musicians); Gaste v.
    Kaiserman, 863 F.2d 1061, 1071 (2d Cir. 1988) (affirming a
    jury's damages award against a defendant in a music copy-
    right infringement case). Judge Newman's opinion in Gaste
    nicely articulated the proper role for an appeals court in
    reviewing a jury verdict:
    
           The guiding principle in deciding whether to over-
           turn a jury verdict for insufficiency of the evidence
           is whether the evidence is such that, without weigh-
           ing the credibility of the witnesses or otherwise con-
           sidering the weight of the evidence, there can be but
           one conclusion as to the verdict that reasonable men
           could have reached.
    
    Id. at 1066 (internal quotations omitted). In Arnstein v. Por-
    ter, the seminal case about musical copyright infringement,
    Judge Jerome Frank wrote:
    
           Each of these two issues -- copying and improper
           appropriation -- is an issue of fact. If there is a trial,
           the conclusions on those issues of the trier of the
           facts -- of the judge if he sat without a jury, or of
           the jury if there was a jury trial -- bind this court on
           appeal, provided the evidence supports those find-
           ings, regardless of whether we would ourselves have
           reached the same conclusions.
    
    Arnstein v. Porter, 154 F.2d 464, 469 (2d Cir. 1946).
    
    As a general matter, the standard for reviewing jury ver-
    dicts is whether they are supported by "substantial evidence"
    -- that is, such relevant evidence as reasonable minds might
    accept as adequate to support a conclusion. See Poppell v.
    City of San Diego, 149 F.3d 951, 962 (9th Cir. 1998). The
    credibility of witnesses is an issue for the jury and is generally
    not subject to appellate review. See Gilbrook v. City of West-
    minster, 177 F.3d 839, 856 (9th Cir.), cert. denied, 120 S. Ct.
    614 (1999).
    
    We affirm the jury's verdict in this case in light of the stan-
    dard of review and copyright law's "guiding principles."
    Although we will address each of the appellant's arguments
    in turn, we focus on access because it is the most difficult
    issue in this case. Our decision is predicated on judicial defer-
    ence -- finding that the law has been properly applied in this
    case, viewing the facts most favorably to the appellees, and
    not substituting our judgment for that of the jury.
    
    A. Access
    
    [1] Proof of access requires "an opportunity to view or to
    copy plaintiff's work." Sid and Marty Krofft Television
    Prods., Inc. v. McDonald's Corp., 562 F.2d 1157, 1172 (9th
    Cir. 1977). This is often described as providing a "reasonable
    opportunity" or "reasonable possibility" of viewing the plain-
    tiff's work. 4 Melville B. Nimmer & David Nimmer, Nimmer
    on Copyright, S 13.02[A], at 13-19 (1999); Jason v. Fonda,
    526 F. Supp. 774, 775 (C.D. Cal. 1981), aff'd , 698 F.2d 966
    (9th Cir. 1983). We have defined reasonable access as "more
    than a `bare possibility.' " Jason, 698 F.2d at 967. Nimmer
    has elaborated on our definition: "Of course, reasonable
    opportunity as here used, does not encompass any bare possi-
    bility in the sense that anything is possible. Access may not
    be inferred through mere speculation or conjecture. There
    must be a reasonable possibility of viewing the plaintiff's
    work -- not a bare possibility." 4 Nimmer,S 13.02[A], at 13-
    19. "At times, distinguishing a `bare' possibility from a `rea-
    sonable' possibility will present a close question. " Id. at 13-
    20.
    
    [2] Circumstantial evidence of reasonable access is proven
    in one of two ways: (1) a particular chain of events is estab-
    lished between the plaintiff's work and the defendant's access
    to that work (such as through dealings with a publisher or
    record company), or (2) the plaintiff's work has been widely
    disseminated. See 4 Nimmer, S 13.02[A], at 13-20-13-21; 2
    Paul Goldstein, Copyright: Principles, Law, and Practice
    S 8.3.1.1., at 90-91 (1989). Goldstein remarks that in music
    cases the "typically more successful route to proving access
    requires the plaintiff to show that its work was widely dissem-
    inated through sales of sheet music, records, and radio perfor-
    mances." 2 Goldstein, S 8.3.1.1, at 91. Nimmer, however,
    cautioned that "[c]oncrete cases will pose difficult judgments
    as to where along the access spectrum a given exploitation
    falls." 4 Nimmer, S 13.02[A], at 13-22.
    
    [3] Proof of widespread dissemination is sometimes accom-
    panied by a theory that copyright infringement of a popular
    song was subconscious. Subconscious copying has been
    accepted since Learned Hand embraced it in a 1924 music
    infringement case: "Everything registers somewhere in our
    memories, and no one can tell what may evoke it . . . . Once
    it appears that another has in fact used the copyright as the
    source of this production, he has invaded the author's rights.
    It is no excuse that in so doing his memory has played him
    a trick." Fred Fisher, Inc. v. Dillingham, 298 F. 145, 147-48
    (S.D.N.Y. 1924). In Fred Fisher, Judge Hand found that the
    similarities between the songs "amount[ed] to identity" and
    that the infringement had occurred "probably unconsciously,
    what he had certainly often heard only a short time before."
    Id. at 147.
    
    [4] In modern cases, however, the theory of subconscious
    copying has been applied to songs that are more remote in
    time. ABKCO Music, Inc v. Harrisongs Music, Ltd. , 722 F.2d
    988 (2d Cir. 1983) is the most prominent example. In
    ABKCO, the Second Circuit affirmed a jury's verdict that for-
    mer Beatle George Harrison, in writing the song "My Sweet
    Lord," subconsciously copied The Chiffons' "He's So Fine,"
    which was released six years earlier. See id.  at 997, 999. Har-
    rison admitted hearing "He's So Fine" in 1963, when it was
    number one on the Billboard charts in the United States for
    five weeks and one of the top 30 hits in England for seven
    weeks. See id. at 998. The court found:"the evidence, stand-
    ing alone, `by no means compels the conclusion that there
    was access . . . it does not compel the conclusion that there
    was not.' " Id. (quoting Heim v. Universal Pictures Co., 154
    F.2d 480, 487 (2d Cir. 1946)). In ABKCO, however, the court
    found that "the similarity was so striking and where access
    was found, the remoteness of that access provides no basis for
    reversal." Id. Furthermore, "the mere lapse of a considerable
    period of time between the moment of access and the creation
    of defendant's work does not preclude a finding of copying."
    4 Nimmer, S 13.02[A], at 13-20 (citing ABKCO, 722 F.2d at
    997-98).
    
    The Isley Brothers' access argument was based on a theory
    of widespread dissemination and subconscious copying. They
    presented evidence supporting four principal ways that Bolton
    and Goldmark could have had access to the Isley Brothers'
    "Love is a Wonderful Thing":
    
    (1) Bolton grew up listening to groups such as the Isley
    Brothers and singing their songs. In 1966, Bolton and Gold-
    mark were 13 and 15, respectively, growing up in Connecti-
    cut. Bolton testified that he had been listening to rhythm and
    blues music by black singers since he was 10 or 11,"appreci-
    ated a lot of Black singers," and as a youth was the lead singer
    in a band that performed "covers" of popular songs by black
    singers. Bolton also testified that his brother had a "pretty
    good record collection."
    
    (2) Three disk jockeys testified that the Isley Brothers'
    song was widely disseminated on radio and television stations
    where Bolton and Goldmark grew up. First, Jerry Blavitt testi-
    fied that the Isley Brothers' "Love is a Wonderful Thing" was
    played five or six times during a 13-week period on the televi-
    sion show, "The Discophonic Scene," which he said aired in
    Philadelphia, New York, and Hartford-New Haven. Blavitt
    also testified that he played the song two to three times a
    week as a disk jockey in Philadelphia and that the station is
    still playing the song today. Second, Earl Rodney Jones testi-
    fied that he played the song a minimum of four times a day
    during an eight to 14 to 24 week period on WVON radio in
    Chicago, and that the station is still playing the song today.
    Finally, Jerry Bledsoe testified that he played the song on
    WUFO radio in Buffalo, and WWRL radio in New York was
    playing the song in New York in 1967 when he went there.
    Bledsoe also testified that he played the song twice on a tele-
    vision show, "Soul," which aired in New York and probably
    in New Haven, Connecticut, where Bolton lived.
    
    (3) Bolton confessed to being a huge fan of the Isley
    Brothers and a collector of their music. Ronald Isley testified
    that when Bolton saw Isley at the Lou Rawls United Negro
    College Fund Benefit concert in 1988, Bolton said,"I know
    this guy. I go back with him. I have all his stuff. " Angela
    Winbush, Isley's wife, testified about that meeting that Bolton
    said, "This man needs no introduction. I know everything he's
    done." 
    
    (4) Bolton wondered if he and Goldmark were copying a
    song by another famous soul singer. Bolton produced a work
    tape attempting to show that he and Goldmark independently
    created their version of "Love Is a Wonderful Thing." On that
    tape of their recording session, Bolton asked Goldmark if the
    song they were composing was Marvin Gaye's "Some Kind
    of Wonderful."1 The district court, in affirming the jury's ver-
    dict, wrote about Bolton's Marvin Gaye remark:
    
           This statement suggests that Bolton was contemplat-
           ing the possibility that the work he and Goldmark
           were creating, or at least a portion of it, belonged to
           someone else, but that Bolton wasn't sure who it
           belonged to. A reasonable jury can infer that Bolton
           mistakenly attributed the work to Marvin Gaye,
           when in reality Bolton was subconsciously drawing
           on Plaintiff's song.
    
    The appellants contend that the Isley Brothers' theory of
    access amounts to a "twenty-five-years-after-the-fact-
    subconscious copying claim." Indeed, this is a more attenu-
    ated case of reasonable access and subconscious copying than
    ABKCO. In this case, the appellants never admitted hearing
    the Isley Brothers' "Love is a Wonderful Thing. " That song
    never topped the Billboard charts or even made the top 100
    for a single week. The song was not released on an album or
    compact disc until 1991, a year after Bolton and Goldmark
    wrote their song. Nor did the Isley Brothers ever claim that
    Bolton's and Goldmark's song is so "strikingly similar" to the
    Isley Brothers' that proof of access is presumed and need not
    be proven.
    
    [5] Despite the weaknesses of the Isley Brothers' theory of
    reasonable access, the appellants had a full opportunity to
    present their case to the jury. Three rhythm and blues experts
    (including legendary Motown songwriter Lamont Dozier of
    Holland-Dozier-Holland fame) testified that they never heard
    of the Isley Brothers' "Love is a Wonderful Thing." Further-
    more, Bolton produced copies of "TV Guide" from 1966 sug-
    gesting that the television shows playing the song never aired
    in Connecticut. Bolton also pointed out that 129 songs called
    "Love is a Wonderful Thing" are registered with the Copy-
    right Office, 85 of them before 1964.
    
    [6] The Isley Brothers' reasonable access arguments are not
    without merit. Teenagers are generally avid music listeners. It
    is entirely plausible that two Connecticut teenagers obsessed
    with rhythm and blues music could remember an Isley Broth-
    ers' song that was played on the radio and television for a few
    weeks, and subconsciously copy it twenty years later. Further-
    more, Ronald Isley testified that when they met, Bolton said,
    "I have all his stuff." Finally, as the district court pointed out,
    Bolton's remark about Marvin Gaye and "Some Kind of
    Wonderful" indicates that Bolton believed he may have been
    copying someone else's song.
    
    [7] Finally, with regard to access, we are mindful of Judge
    Frank's words of caution in Arnstein v. Porter : "The judge
    characterized plaintiff's story as `fantastic'; and in the light of
    the references in his opinion to defendant's deposition, the
    judge obviously accepted the defendant's denial of access and
    copying . . . . [Y]et plaintiff's credibility, even as to those
    improbabilities, should be left to the jury." Arnstein, 154 F.2d
    at 469. In this case, Judge Baird heeded Judge Frank's admo-
    nition:
    
           [T]his Court is not in a position to find that the only
           conclusion that a reasonable jury could have reached
           is that Defendants did not have access to Plaintiff's
           song. One must remember that the issue this Court
           must address is not whether Plaintiff has proven
           access by a preponderance of evidence, but whether
           reasonable minds could find that Defendants had a
           reasonable opportunity to have heard Plaintiff's
           song before they created their own song.
    
    Although we might not reach the same conclusion as the jury
    regarding access, we find that the jury's conclusion about
    access is supported by substantial evidence. We are not estab-
    lishing a new standard for access in copyright cases; we are
    merely saying that we will not disturb the jury's factual and
    credibility determinations on this issue.
    
    B. Substantial Similarity
    
    [8] Under our case law, substantial similarity is inextricably
    linked to the issue of access. In what is known as the "inverse
    ratio rule," we "require a lower standard of proof of substan-
    tial similarity when a high degree of access is shown." Smith,
    84 F.3d at 1218 (citing Shaw v. Lindheim, 919 F.2d 1353,
    1361-62 (9th Cir. 1990); Krofft, 562 F.2d at 1172). Further-
    more, in the absence of any proof of access, a copyright plain-
    tiff can still make out a case of infringement by showing that
    the songs were "strikingly similar." See Smith, 84 F.3d at
    1220; Baxter v. MCA, Inc., 812 F.2d 421, 423, 424 n.2 (9th
    Cir. 1987).
    
    [9] Proof of the substantial similarity is satisfied by a two-
    part test of extrinsic similarity and intrinsic similarity. See
    Krofft, 562 F.2d at 1164. Initially, the extrinsic test requires
    that the plaintiff identify concrete elements based on objective
    criteria. See Smith, 84 F.3d at 1218; Shaw, 919 F.2d at 1356.
    The extrinsic test often requires analytical dissection of a
    work and expert testimony. See Apple Computer, Inc v.
    Microsoft Corp., 35 F.3d 1435, 1442 (9th Cir. 1994). Once
    the extrinsic test is satisfied, the factfinder applies the intrinsic
    test. The intrinsic test is subjective and asks "whether the
    ordinary, reasonable person would find the total concept and
    feel of the works to be substantially similar." Pasillas v.
    McDonald's Corp., 927 F.2d 440, 442 (9th Cir. 1991) (inter-
    nal quotations omitted).
    
    [10] We will not second-guess the jury's application of the
    intrinsic test. See Krofft 562 F.3d at 1166 ("Since the intrinsic
    test for expression is uniquely suited for determination by the
    trier of fact, this court must be reluctant to reverse it.") (cita-
    tions omitted). Furthermore, we will not reverse factual deter-
    minations regarding the extrinsic test absent a clearly
    erroneous application of the law. See id. It is well settled that
    a jury may find a combination of unprotectible elements to be
    protectible under the extrinsic test because " `the over-all
    impact and effect indicate substantial appropriation.' " Id. at
    1169 (quoting Malkin v. Dubinsky, 146 F. Supp. 111, 114
    (S.D.N.Y. 1956)).
    
    1. Evidence of Substantial Similarity
    
    [11] Bolton and Goldmark argue that there was insufficient
    evidence of substantial similarity because the Isley Brothers'
    expert musicologist, Dr. Gerald Eskelin, failed to show that
    there was copying of a combination of unprotectible elements.
    On the contrary, Eskelin testified that the two songs shared a
    combination of five unprotectible elements: (1) the title hook
    phrase (including the lyric, rhythm, and pitch); (2) the shifted
    cadence; (3) the instrumental figures; (4) the verse/chorus
    relationship; and (5) the fade ending. Although the appellants
    presented testimony from their own expert musicologist,
    Anthony Ricigliano, he conceded that there were similarities
    between the two songs and that he had not found the combi-
    nation of unprotectible elements in the Isley Brothers' song
    "anywhere in the prior art." The jury heard testimony from
    both of these experts and "found infringement based on a
    unique compilation of those elements." We refuse to interfere
    with the jury's credibility determination, nor do we find that
    the jury's finding of substantial similarity was clearly errone-
    ous.
    
    2. Independent Creation
    
    [12] Bolton and Goldmark also contend that their witnesses
    rebutted the Isley Brothers' prima facie case of copyright
    infringement with evidence of independent creation. By estab-
    lishing reasonable access and substantial similarity, a copy-
    right plaintiff creates a presumption of copying. The burden
    shifts to the defendant to rebut that presumption through proof
    of independent creation. See Granite Music Corp. v. United
    Artists Corp., 532 F.2d 718, 721 (9th Cir. 1976).
    
    [13] The appellants' case of independent creation hinges on
    three factors: the work tape demonstrating how Bolton and
    Goldmark created their song, Bolton and Goldmark's history
    of songwriting, and testimony that their arranger, Walter
    Afanasieff, contributed two of five unprotectible elements that
    they allegedly copied. The jury, however, heard the testimony
    of Bolton, Goldmark, Afanasieff, and Ricigliano about inde-
    pendent creation. The work tape revealed evidence that Bol-
    ton may have subconsciously copied a song that he believed
    to be written by Marvin Gaye. Bolton and Goldmark's history
    of songwriting presents no direct evidence about this case.
    And Afanasieff's contributions to Bolton and Goldmark's
    song were described by the appellants' own expert as "very
    common." Once again, we refuse to disturb the jury's deter-
    mination about independent creation. The substantial evi-
    dence of copying based on access and substantial similarity
    was such that a reasonable juror could reject this defense.
    
    3. Inverse-Ratio Rule
    
    Although this may be a weak case of access and a circum-
    stantial case of substantial similarity, neither issue warrants
    reversal of the jury's verdict. An amicus brief on behalf of the
    recording and motion picture industries warns against water-
    ing down the requirements for musical copyright infringe-
    ment. This case presents no such danger. The Ninth Circuit's
    inverse-ratio rule requires a lesser showing of substantial sim-
    ilarity if there is a strong showing of access. See Smith, 84
    F.3d at 1218. In this case, there was a weak showing of
    access. We have never held, however, that the inverse ratio
    rule says a weak showing of access requires a stronger show-
    ing of substantial similarity. Nor are we redefining the test of
    substantial similarity here; we merely find that there was sub-
    stantial evidence from which the jury could find access and
    substantial similarity in this case.
    
    C. Sufficiency of the Deposit Copy
    
    The appellants argue that the district court did not have
    jurisdiction over this case because the Isley Brothers failed to
    register a complete copy of the song upon which the lawsuit
    was based. Although the 1909 Copyright Act requires the
    owner to deposit a "complete copy" of the work with the
    copyright office, our definition of a "complete copy" is broad
    and deferential: "Absent intent to defraud and prejudice, inac-
    curacies in copyright registrations do not bar actions for
    infringement." Harris v. Emus Records Corp. , 734 F.2d 1329,
    1335 (9th Cir. 1984) (citations omitted).
    
    Bolton and Goldmark argue that in 1964 the Isley Brothers
    deposited sheet music ("deposit copy") of "Love is a Wonder-
    ful Thing" that differed from the recorded version of the song.
    Furthermore, they claimed that the deposit copy does not
    include the majority of the musical elements that were part of
    the infringement claim. At trial, the Isley Brothers' expert, Dr.
    Eskelin, testified that the deposit copy included all of the
    song's essential elements such as the title hook, chorus, and
    pitches. Dr. Eskelin even played the deposit copy for the jury
    on the keyboard. We refuse to disturb the jury's finding that
    the Isley Brothers deposited a "complete copy " because (1)
    there was no intent to defraud and prejudice and (2) any inac-
    curacies in the deposit copy were minor and do not bar the
    infringement action.
    
    D. Attribution of Profits
    
    [14] Sony Music claims that the district court improperly
    applied an assumption that all profits from Bolton and Gold-
    mark's song go to the Isley Brothers, and that no evidence
    supported the jury's apportionment of profits. A successful
    copyright plaintiff is allowed to recover only those profits that
    are "attributable to infringement." 17 U.S.C.S 504(b) (1994).
    "In establishing the infringer's profits, the copyright owner is
    required to present proof only of the infringer's gross revenue,
    and the infringer is required to prove his or her deductible
    expenses and the elements of profit attributable to factors
    other than the copyrighted work." Id. See also Cream
    Records, Inc. v. Jos. Schlitz Brewing Co., 754 F.2d 826, 828
    (9th Cir. 1985) (holding that when all profits do not clearly
    derive from the infringing material, the copyright owner is not
    entitled to recover all of the profits); Gaste , 863 F.2d at 1070
    (finding that where there is "imprecision in the computation
    of expenses, a court should err on the side of guaranteeing the
    plaintiff a full recovery"). Thus, the statutory burden of proof
    lies with Sony Music to prove what percentage of their profits
    were not attributable to copying the Isley Brothers'"Love is
    a Wonderful Thing."
    
    Sony Music presented evidence that Bolton's "Love Is a
    Wonderful Thing" produced only 5-10% of the profits from
    his album, "Time, Love and Tenderness," and that the song's
    infringing elements resulted in only 10-15% of the profits
    from the song. The Isley Brothers, however, attacked the
    credibility of one of Sony Music's experts. Furthermore, they
    presented evidence that Bolton's infringing song was the
    album's lead single, that it was released 19 days before the
    album, and that Bolton engaged in telephone promotion of the
    song. The jury found that 28% of the album's profits derived
    from the song, and that 66% of the song's profits resulted
    from infringing elements.
    
    [15] We affirm the jury's apportionment of the profits for
    several reasons. First, the jury instructions adequately con-
    veyed the burden of proof. Second, the burden of proof was
    on Sony Music, and the jury chose not to believe Sony
    Music's experts. Finally, a jury verdict apportioning less than
    100% of the profits but more than the percentage estimates of
    Sony Music's experts does not represent clear error.
    
    E. Deduction of Tax Liability
    
    Sony Music also argues that the district court erred in
    allowing Bolton and Goldmark, but not Sony Music, to
    deduct income taxes due to profits from the album. Whether
    income taxes are considered "deductible expenses " under
    S 504(b) is an issue of first impression in this circuit. The
    Supreme Court held that willful infringers could not deduct
    income taxes, but it left open the possibility that non-willful
    infringers could deduct their income taxes from the infringing
    profits. See L.P. Larson, Jr., Co. v. Wm. Wrigley, Jr., Co., 277
    U.S. 97, 99-100 (1928). The circuits are split over whether
    non-willful infringers such as Bolton, Goldmark, and Sony
    Music can deduct income taxes from their infringing profits.
    Compare In Design v. K-Mart Apparel Corp., 13 F.3d 559,
    567 (2d Cir. 1994) (allowing the deduction of income taxes)
    with Schnadig Corp. v. Gaines Mfg. Co., Inc., 620 F.2d 1166,
    1169-70 (6th Cir. 1980) (not allowing the deduction of
    income taxes).
    
    The Second Circuit allowed the deduction of income taxes
    because if infringers are liable for pre-tax profits, they may
    end up paying more money than they ever received. See In
    Design, 13 F.3d at 567. Under the Second Circuit's rule, the
    infringer receives a windfall by (1) paying a smaller damages
    award and (2) deducting the entire, pre-tax award from gross
    income on a subsequent tax return. The Sixth Circuit rejected
    the deduction of income taxes because the increased pre-tax
    profits paid to the copyright holder will be balanced out by an
    eventual tax refund based on the pre-tax award. See Schnadig,
    620 F.2d at 1169-70. Under the Sixth Circuit's rule, the copy-
    right holder receives a windfall by receiving a larger, pre-tax
    award.
    
    During the third phase of this trial, the district court
    adopted the findings of the special master's report regarding
    the deduction of income taxes. The district court followed the
    Second Circuit rule and allowed Bolton and Goldmark, as
    non-willful infringers, to deduct the income taxes and man-
    agement fees that they paid relating to the infringing song.
    The district court, however, refused to allow Sony Music to
    deduct its Net Operating Loss Carry-forward (NOL) because
    the NOL did not have a "concrete financial impact."
    
    We uphold the district court's decision to allow non-willful
    infringers to deduct income taxes, but not NOL. In this case,
    Bolton and Goldmark actually paid income taxes and manage-
    ment fees on the infringing profits. Sony Music, however,
    never actually paid income taxes on its infringing profits.
    Rather, Sony Music claimed it offset nearly $1.7 million in
    taxes on the infringing profits against its parent company's
    NOL. No court has ever found that NOL is a deductible
    expense under S 504(b). Furthermore, we find that the district
    court's distinctions between taxes actually paid and taxes not
    actually paid was a fair one. Thus, we affirm the district
    court's calculation of a $4,218,838 damages award against
    Sony Music.
    
    F. Second New Trial Motion
    
    Finally, Bolton and Goldmark claim that the district court
    erred in rejecting their second motion for new trial. The dis-
    trict court's denial of a motion for a new trial pursuant to Fed-
    eral Rule of Civil Procedure 60(b) is reviewed for an abuse
    of discretion. See Browning-Ferris Indus. v. Kelco Disposal,
    Inc., 492 U.S. 257, 278  (1989); Scott v. Ross, 140 F.3d 1275,
    1281 (9th Cir. 1998). The abuse of discretion standard applies
    particularly when the district court's denial is based on the
    motion's untimeliness. See E. & J. Gallo Winery v. Gallo Cat-
    tle Co., 967 F.2d 1280, 1294-96 (9th Cir. 1992).
    
    Bolton and Goldmark's second motion for a new trial was
    based on the discovery of new evidence that disputed the Isley
    Brothers' claim of authorship. A day before the deadline for
    post-trial motions, the appellees discovered evidence alleging
    that the Turkcords, a group that played with the Isley Brothers
    in the mid-1960s, claimed to have written the 1964 song,
    "Love is a Wonderful Thing." Bolton and Goldmark did not
    immediately notify the district court of this new evidence.
    Instead, fourteen days after the deadline for post-trial motions
    had passed, they filed an additional motion for new trial. The
    district court rejected the second motion for new trial as
    untimely filed. 
    
    We affirm the district court's denial of the second motion
    for new trial because the evidence, if true, goes at most to the
    weight and credibility of the evidence before the jury. At trial,
    Ronald Isley claimed to have written the song with the
    deceased guitar legend, Jimi Hendrix. (As a young man, Hen-
    drix played in the Isley Brothers' band.) The Turkcords'
    claims of authorship are dubious for several reasons. The
    Turkcords knew about the re-release of "Love is a Wonderful
    Thing" by United Artists in 1991, yet they claimed that the
    Isley Brothers had agreed to share the song's royalties with
    them only after hearing about the damages award in this case
    on "Inside Edition." Furthermore, Bolton and Goldmark knew
    about this new evidence before the deadline for the post-trial
    motions, yet they did not immediately notify the district court.
    
    Even if the Turkcords' claims of authorship are true, a new
    trial is not warranted in the interests of justice because the
    Isley Brothers' copyright ownership is not jeopardized. Regis-
    tration is prima facie evidence of the validity of a copyright.
    See 17 U.S.C. S 410(c) (1994). This presumption can be
    rebutted by the defendant's showing that the plaintiff's work
    is not original. See North Coast Indus. v. Jason Maxwell, Inc.,
    972 F.2d 1031, 1033 (9th Cir. 1992). North Coast 's definition
    of originality is broad: " `All that is needed to satisfy both the
    Constitution and the statute is that the "author " contributed
    something more than a "merely trivial" variation, something
    recognizably "his own." Originality in this context means "lit-
    tle more than a prohibition of actual copying." ' " Id. (quoting
    Krofft, 562 F.2d at 1163 n.5 (quoting Alfred Bell & Co. v.
    Catalda Fine Arts, 191 F.2d 99, 102-03 (2d Cir. 1951))). See
    also Kamar Int'l Inc. v. Russ Berrie and Co., 657 F.2d 1059,
    1061 (9th Cir. 1981) (employing a broad definition of origi-
    nality relating to toy stuffed animals).
    
    In this case, the Isley Brothers undoubtedly contributed
    something original to "Love is a Wonderful Thing. " Their
    proteges, the Turkcords, purportedly wrote the song, then
    gave the Isley Brothers' permission to record it after the voice
    of the Turkcords' lead singer allegedly "cracked. " Members
    of the Turkcords allegedly sang back-up on the record. Yet
    the Turkcords never copyrighted their song. They relied on
    the Isley Brothers' alleged promise to share the royalties with
    them.
    
    The district court did not abuse its discretion in rejecting
    Bolton and Goldmark's second motion for a new trial based
    on this evidence. The Turkcords' claims of authorship would
    not have affected the outcome of the case and at most go to
    the weight and credibility of the evidence. Bolton and Gold-
    mark's second motion was a last-ditch attempt to discredit the
    jury's verdict. The district court heard all of the evidence in
    this case, instructed the jury on the applicable law, yet refused
    to reverse the jury's verdict pursuant to motion for a judgment
    as a matter of law. Having found that the law was properly
    applied in this case, we leave the district court's decisions and
    the jury's credibility determinations undisturbed.
    
    AFFIRMED./dcs/programs/www/cgi-prod/getfile.sh[51]: rmove:  not found
    /dcs/programs/www/cgi-prod/getfile.sh[52]: rmove:  not found
    /dcs/programs/www/cgi-prod/getfile.sh[53]: rmove:  not found
    
    _______________________________________________________________
    
    FOOTNOTES
    
    1 Gaye recorded "Some Kind of Wonderful" after it had been made
    famous by The Drifters. See Marvin Gaye, Some Kind of Wonderful, on
    In the Groove (Motown 1968). Marvin Gaye also referred to the song's
    chorus, "She's some kind of wonderful," in his song, "Too Busy Thinking
    About My Baby." See Marvin Gaye, Too Busy Thinking About My Baby,
    on MPG, (Motown 1969).
    

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