However, no such legal barrier to awarding post-judgment interest exists. See, e.g., J & J Sports Prods, 2019 WL 1339198 at 7 (awarding post-judgment interest at the federal statutory rate); J & J Sports Prod. v. Leon, 18--CV--2103 (PKC) (RML), 2019 WL 1320277 at 7-8 (E.D.N.Y. Mar. 22, 2019). Therefore, this Court respectfully recommends denying Plaintiff's request for pre-judgment interest but granting its request for post-judgment interest.

Courts in this District generally refuse requests for pre-judgment interest in FCA cases on the basis that pre-judgment interest does not serve to compensate the wronged party, but rather only serves to punish the violator. See Big Daddy's Theme Palace, 2015 WL 58606, at *5 (citing cases); J & J Sports Prods. v. Hot Shots, Inc., No. CV-09-1884 (FB) (SMG), 2010 WL 3522809, at *3 (Apr. 27, 2010) (collecting cases), adopted by, 2010 WL 3523003 (E.D.N.Y. Sept. 2, 2010); see also J & J Sports Prod. v. Leon, No. 18-CV-2103 (PKC) (RML), 2019 WL 1320277, at *7 (E.D.N.Y. Mar. 22, 2019). As such, I recommend following these cases and denying J & J Sports' request for pre-judgment interest.

Because plaintiff owned the exclusive commercial distribution rights for the Program, it is impossible for defendants to have broadcast the Program legally without having entered into a licensing agreement with plaintiff. It is undisputed that defendants did not enter into such an agreement, yet the Program was still displayed at the establishment on September 13, 2014. These undisputed facts are sufficient to establish Red Mist's liability under Section 605. See, e.g., J & J Sports Prod., Inc. v. Leon, 2019 WL 1320277, at *4 (E.D.N.Y. Mar. 22, 2019) (collecting cases). Defendants' statute of limitations argument is unavailing. Because Section 605 does not contain a statute of limitations, defendants invite the court to apply the two-year statute of limitations of the Wiretap Act, codified at 18 U.S.C. § § 2510-2522.

The Court takes judicial notice of this fact. See, e.g., J & J Sports Prod., Inc. v. Leon, No. 18-CV-2103, 2019 WL 1320277, at *3 (E.D.N.Y. Mar. 22, 2019) (taking judicial notice of entries listed in the NYSDOS Corporation and Business Entity Database, as listed on the NYSDOS website); J & J Sports Prods. Inc. v. Inga, No. 18-CV-2542, 2019 WL 1320278, at *3 (E.D.N.Y. Mar. 22, 2019) (same); Saudi v. Marine Atl., Ltd., No. 02-CV-2495, 2005 WL 8156849, at *4 (E.D.N.Y. July 1, 2005) (same).See also, e.g., Entral Grp. Int'l v. Sun Sports Bar Inc., No. 05-CV-4836(CBA), 2007 WL 2891419, at *3 (E.D.N.Y. Sept. 28, 2007) (taking "judicial notice of the fact that the Certificate of Incorporation on file with the Secretary of State for New York lists [a] 39th Avenue address for [the defendant]"); Kramer v. Time Warner Inc., 937 F.2d 767, 774 (2d Cir. 1991) (taking judicial notice of contents of corporate filings with SEC); Banks v. Consumer Home Mortgage, No. 01-CV-8058, 2003 WL 21251584, at *6 n.7 (E.D.N.Y. Mar. 28, 2003) (taking judicial notice of public record on file with Secretary of State for Georgia); Fed. R. Evid. 201.

See, e.g., Sandoval, 2018 WL 1582218; Vernot, 2017 WL 384327; see also Kropelnicki, 290 F.3d at 127 (noting "grave reservations" as to whether the FDCPA applied to misrepresentations to third parties). However, the Second Circuit has not squarely addressed the issue, see Sykes v. Mel S. Harris & Assocs. LLC, 780 F.3d 70, 97 n.6 (2d Cir. 2015) ("[The Second Circuit] has not ruled on whether an FDCPA claim may be brought for misrepresentations made to third parties."), and district courts are, of course, not bound by the decisions of other district courts, see J & J Sports Prod., Inc. v. Leon, No. 18-CV-2103 (PKC) (RML), 2019 WL 1320277, at *6 (E.D.N.Y. Mar. 22, 2019) (noting that the district court is "not bound by the decisions of any other district court in the nation, nor by the decisions of any circuit court other than the Second") (internal quotations and citation omitted). "[C]ourts generally decline to impose sanctions where the purported sanctionable conduct boils down to the advancement of a novel legal theory."