" Edgerton v. UPI Holdings, Inc., 2010 WL 2651304, at *5 (D. Md. July 1, 2010) (Blake, J.). "'[T]o establish copyright infringement, two elements must be proven: (1) ownership of a valid copyright, and (2) copying of constituent elements of the work that are original.'" CoStar Grp., Inc. v. LoopNet, Inc., 373 F.3d 544, 549 (4th Cir. 2004) (quoting Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340, 361 (1991)); accord Metropolitan Regional Information Systems, Inc. v. American Home Realty Network, Inc., 888 F. Supp. 2d 691, 709 (D. Md. 2012), aff'd, 722 F.3d 591 (4th Cir. 2013). In order to show ownership of a valid copyright, a plaintiff must supply "proof of originality and copyrightability."
Personal jurisdiction may be either general or specific. Tawney v. AC & R Insulation Co., Inc., No. WDQ-13-1194, 2013 WL 5887625, at *2 (D. Md. Oct. 30, 2013); see Metro. Reg'l Info. Sys., Inc. v. Am. Home Realty Network, Inc., 888 F. Supp. 2d 691, 699 (D. Md. 2012). To exercise general jurisdiction over a defendant, the defendant's activities in the state must be "continuous and systematic."
"Although the statutory and constitutional inquiries merge, the Court must address both elements in the personal jurisdiction analysis." Metro. Reg'l Info. Sys. v. Am. Home Realty Network, Inc., 888 F. Supp. 2d 691, 698 (D. Md. 2012) (citing Dring v. Sullivan, 423 F. Supp. 2d 540, 545 (D. Md. 2006)).
I. BackgroundThe relevant background is set out in the Court's August 27, 2012 opinion, Metro. Reg'l Info. Sys. v. Am. Home Realty Network, Inc., 888 F. Supp. 2d 691, 696-97 (D. Md. 2012), granting MRIS's Motion for Preliminary Injunction: MRIS facilitates real estate transactions in the mid-Atlantic region by operating and maintaining an automated database consisting of compiled property listings and related informational content.
Additionally, this Court may exercise personal jurisdiction over a corporate defendant that is neither served in Maryland nor organized under its laws and that does not maintain its principal place of business in Maryland, if its actions meet the criteria delineated in Cts. & Jud. Proc. § 6103, Maryland's long-arm statute. Cts. & Jud. Proc. § 6-103(a); see Tawney v. AC & R Insulation Co., No. WDQ-13-1194, 2013 WL 5887625, at *2 (D. Md. Oct. 30, 2013); Metro. Reg'l Info. Sys., Inc. v. Am. Home Realty Network, Inc., 888 F. Supp. 2d 691, 699 (D. Md. 2012). Maryland's statute provides:
Additionally, under Maryland's long-arm statute, Cts. & Jud. Proc. § 6-103, this Court may exercise specific jurisdiction over an individual defendant who is neither domiciled in nor served with process in Maryland if the "cause of action aris[es] from any act enumerated in [§ 6-103]." Cts. & Jud. Proc. § 6-103(a); see Tawney v. AC & R Insulation Co., No. WDQ-13-1194, at *2 (D. Md. Oct. 30, 2013); Metro. Reg'l Info. Sys., Inc. v. Am. Home Realty Network, Inc., 888 F. Supp. 2d 691, 699 (D. Md. 2012). Among other acts, § 6-103 provides for the exercise of personal jurisdiction over an individual who "[c]auses tortious injury in the State by an act or omission in the State." Cts. & Jud. Proc. § 6-103(b)(3).
Personal jurisdiction may be either general or specific. Tawney v. AC & R Insulation Co., Inc., No. WDQ–13–1194, 2013 WL 5887625, at *2 (D.Md. Oct. 30, 2013); see Metro. Reg'l Info. Sys., Inc. v. Am. Home Realty Network, Inc., 888 F.Supp.2d 691, 699 (D.Md.2012). To exercise general jurisdiction over a defendant, the defendant's activities in the state must be “continuous and systematic.
Personal jurisdiction may be either general or specific. Tawney v. AC & R Insulation Co., Inc., No. WDQ–13–1194, 2013 WL 5887625, at *2 (D.Md. Oct. 30, 2013) ; see Metro. Reg'l Info. Sys., Inc. v. Am. Home Realty Network, Inc., 888 F.Supp.2d 691, 699 (D.Md.2012).To exercise general jurisdiction over a defendant, the defendant's activities in the state must be “continuous and systematic.
"Although the statutory and constitutional inquiries merge, the Court must address both elements in the personal jurisdiction analysis." Metropolitan Reg'l Info. Sys., Inc. v. American Home Realty Network, Inc., 888 F. Supp. 2d 691, 698 (D. Md. 2012). Courts have recognized two types of personal jurisdiction: general and specific.
"Although the statutory and constitutional inquiries merge, the Court must address both elements in the personal jurisdiction analysis." Metropolitan Reg'l Info. Sys., Inc. v. American Home Realty Network, Inc., 888 F. Supp. 2d 691, 698 (D. Md. 2012). Courts have recognized two types of personal jurisdiction: general and specific jurisdiction.