Next, I turn to the 2013 Agreements, which were executed by Viesti and the photographers to presumably strengthen the original Copyright Assignments and Addenda. Even if collateral estoppel does not apply to the 2013 Agreements in this case, I find that the weight of case authority rejects Viesti's argument that subsequent assignments "of copyright can confer standing when the assignment of rights in place at the time the suit was filed had conferred only a bare right to sue." Minden Pictures, Inc. v. John Wiley & Sons, Inc., No. C-12-4601 EMC, 2013 WL 1995208, at *8 (N.D. Cal. May 13, 2013); Lujan v. Defenders of Wildlife, 504 U.S. 555, 571 n.4 (1992); Pearson I, No. 11-cv-01687-PAB-DW, 2014 WL 1053772, at *15; Righthaven LLC v. Allec, 2:11-CV-00532-KJD, 2012 WL 909832 (D. Nev. Mar.16, 2012); Righthaven, LLC v. Hyatt, 2:10-CV-01736-KJD, 2011 WL 3652532 (D. Nev. Aug. 19, 2011). Here, the 2013 Agreements were executed after Viesti brought suit in this matter, and consistent with Judge Brimmer's reasoning, Viesti "cannot attempt to amend jurisdictional facts once litigation has commenced."

In a series of cases analogous to the case at bar, a Nevada district court has rejected arguments that a subsequent assignment of copyright can confer standing where the assignment of rights in place at the time the suit was filed had conferred only a bare right to sue. Righthaven LLC v. Allec, 2:11-CV-00532-KJD, 2012 WL 909832 (D. Nev. Mar. 16, 2012); Righthaven, LLC v. Hyatt, 2:10-CV-01736-KJD, 2011 WL 3652532 (D. Nev. Aug. 19, 2011); Righthaven LLC v.Mostofi, 2:10-CV-1066-KJD-GWF, 2011 WL 2746315 (D. Nev. July 13, 2011). In those cases, the court had already determined that the assignment of rights that was in effect at the time the complaint was filed did not confer standing to sue because it assigned to the plaintiff only the bare right to sue.