Mattel, Inc. v. Mga Ent., Inc., 705 F.3d 1108 (9th Cir. 2013). · Go Syfert
Mattel, Inc. v. Mga Ent., Inc., 705 F.3d 1108 (9th Cir. 2013). Cases Citing This Book View Copy Cite
“mga's 'failure to vigorously defend against mattel's claims could have ushered in a new era of copyright litigation aimed not at promoting expression but at stifling the 'competition' upon which america thrives.”
59 citation events (59 in the last 25 years) across 16 distinct courts.
Strongest positive: Geophysical Service Incorporated v. TGS-Nopec Geophysical Company (txsd, 2020-02-19)
Treatment trajectory · 2013 → 2026 · click a year to view as-of
2013 2019 2026
Top citers, strongest first. 32 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Geophysical Service Incorporated v. TGS-Nopec Geophysical Company
S.D. Tex. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
mga's 'failure to vigorously defend against mattel's claims could have ushered in a new era of copyright litigation aimed not at promoting expression but at stifling the 'competition' upon which america thrives.
discussed Cited as authority (quoted) Oracle USA, Inc. v. Rimini St., Inc.
D. Nev. · 2018 · signal: see · quote attribution · 1 verbatim quote · confidence high
the most important factor in determining whether to award fees under the copyright act, is whether an award will further the purposes of the act.
discussed Cited as authority (rule) Burke v. Lewis Investment Company of Nevada, LLC (2×) also: Cited "see, e.g."
D. Nev. · 2025 · confidence medium
The Copyright Act’s “ultimate aim is ... to stimulate artistic creativity for the general 12 public good.” Mattel, 705 F.3d at 1111 (citation omitted). “[A] successful defense of a 13 copyright infringement action may further the policies of the Copyright Act every bit as 14 much as a successful prosecution of an infringement claim by the holder of a copyright.” 15 Fogerty, 510 U.S. at 527 .
discussed Cited as authority (rule) R&M Government Services, Inc. v. Kaman Aerospace Corp. (2×)
D.N.M. · 2025 · confidence medium
Mich. Apr. 20, 2007); Mattel, Inc. v. MGA Ent., Inc., 705 F.3d 1108, 1110 (9th Cir. 2013)).
cited Cited as authority (rule) Pacific Boat Services, Inc. v. Steinhauer
E.D. Cal. · 2024 · confidence medium
Mattel, Inc v. MGA Ent., Inc., 705 F.3d 1108, 1110 (9th Cir. 11 2013).
discussed Cited as authority (rule) Rimini Street, Inc. v. Oracle International Corporation
D. Nev. · 2024 · confidence medium
(Id.) The Court finds both parties’ arguments as to this factor somewhat 14 persuasive and accordingly finds it neutral. 15 The Copyright Act’s “ultimate aim is ... to stimulate artistic creativity for the general 16 public good.” Mattel, Inc v. MGA Ent., Inc., 705 F.3d 1108, 1111 (9th Cir. 2013) (citation 17 omitted).
discussed Cited as authority (rule) Gill v. Marsh USA, Inc.
N.D. Cal. · 2024 · confidence medium
Gill, by contrast, argues that California’s “internal affairs 9 doctrine” dictates that a breach of fiduciary duty claim such as this one is “subject to the laws of 10 the state of incorporation.” Davis & Cox v. Summa Corp., 751 F.2d 1507, 1527 (9th Cir. 1985), 11 overruled on other grounds by Mattel, Inc. v. MGA Ent., Inc., 705 F.3d 1108, 1110 (9th Cir. 12 2013). 13 “In a diversity case, federal courts apply the substantive law of the forum in which the 14 court is located, including the forum’s choice of law rules.” Downing v. Abercrombie & Fitch, 265 15 F.3d 994, 1005 (9th C…
discussed Cited as authority (rule) Incident Catering Services LLC v. Nance
W.D. Wash. · 2023 · confidence medium
“A logical relationship exists when the 4 counterclaim arises from the same aggregate set of operative facts as the initial claim, in that the 5 same operative facts serve as the basis of both claims or the aggregate core of facts upon which 6 the claim rests activates additional legal rights otherwise dormant in the defendant.” Mattel, Inc 7 v. MGA Ent., Inc., 705 F.3d 1108, 1110 (9th Cir. 2013) (internal quotation marks omitted).
discussed Cited as authority (rule) Medimpact Healthcare Systems, Inc. v. IQVIA Holdings Inc.
S.D. Cal. · 2022 · confidence medium
See Nedlloyd 12 Lines B.V. v. Superior Ct., 3 Cal. 4th 459, 471 (1992) (“even in the absence of a choice- 13 of-law clause, Hong Kong's overriding interest in the internal affairs of corporations 14 domiciled there would in most cases require application of its law.”); Davis & Cox v. 15 Summa Corp., 751 F.2d 1507, 1527 (9th Cir. 1985) superseded on other grounds as 16 stated in Mattel, Inc. v. MGA Entm't, Inc., 705 F.3d 1108, 1110 (9th Cir. 2013) 17 (“[i]ndemnification of corporate directors” similar to breach of fiduciary duty, involves 18 internal affairs of corporation); see also Va…
discussed Cited as authority (rule) Lynwood Investments CY Limited v. Konovalov
N.D. Cal. · 2022 · confidence medium
Courts should “giv[e] substantial weight to the reasonableness of 2 [the losing party’s] litigating position, but also tak[e] into account all other relevant 3 factors,” see Kirtsaeng v. John Wiley & Sons, Inc., 579 U.S. 197, 210 (2016), “[t]he most 4 important factor” being “whether an award will further the purposes of the Act,” see 5 Mattel, Inc v. MGA Ent., Inc., 705 F.3d 1108, 1111 (9th Cir. 2013) (citation omitted).
discussed Cited as authority (rule) Lynwood Investments CY Limited v. Konovalov
N.D. Cal. · 2022 · confidence medium
Courts should “giv[e] substantial weight to the reasonableness of 2 [the losing party’s] litigating position, but also tak[e] into account all other relevant 3 factors,” see Kirtsaeng v. John Wiley & Sons, Inc., 579 U.S. 197, 210 (2016), “[t]he most 4 important factor” being “whether an award will further the purposes of the Act,” see 5 Mattel, Inc v. MGA Ent., Inc., 705 F.3d 1108, 1111 (9th Cir. 2013) (citation omitted).
cited Cited as authority (rule) Philadelphia Indemnity Insurance Company v. Olympia Early Learning Center
W.D. Wash. · 2022 · confidence medium
MGA Ent., 20 Inc., 705 F.3d 1108, 1110 (9th Cir. 2013).
discussed Cited as authority (rule) Northern Hospitality Group, Inc. v. Poynter
D. Alaska · 2022 · confidence medium
Cal. Jan. 5, 2021). 36 Mattel, Inc v. MGA Ent., Inc., 705 F.3d 1108, 1110 (9th Cir. 2013). 37 Blaisdell v. Frappiea, 729 F.3d 1237, 1241 (9th Cir. 2013) (“Courts in this circuit have an obligation to give a liberal construction to the filings of pro se litigants . . . .); see also Sparrow v. Mazda Am.
discussed Cited as authority (rule) Estavilla v. The Goodman Group, LLC
D. Mont. · 2022 · confidence medium
The Ninth Circuit also applies “the logical relationship test for compulsory counterclaims.” Mattel, Inc. v. MGA Entertainment, Inc., 705 F.3d 1108, 1110 (9th Cir. 2013) (quoting In re Pegasus Gold Corp., 394 F.3d 1189, 1195-96 (9th Cir. 2005)).
cited Cited as authority (rule) LeBarron v. Interstate Group, LLC
D. Nev. · 2021 · confidence medium
Mattel, Inc. 20 v. MGA Entm’t, Inc., 705 F.3d 1108, 1110 (9th Cir. 2013); Pochiro v. Prudential Ins.
discussed Cited as authority (rule) Greg Young Publishing, Inc. v. Zazzle, Inc.
C.D. Cal. · 2020 · confidence medium
The Goals of the Copyright Act Lastly, courts analyze whether awarding fees would “further the purposes of the Copyright Act.” Glacier Films, 896 F.3d at 1040 (quoting Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir. 2013)).
discussed Cited as authority (rule) Outlaw Laboratory, LP v. DG in PB, LLC
S.D. Cal. · 2020 · confidence medium
Title Co., 2014 WL 1883939 , at 14 *5 (quoting Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1110 (9th Cir. 2013)). 15 Shell’s claim arises from a settlement agreement executed in Michigan, on some date 16 between February 21, 2018 and September 13, 2019, and negotiated between Shell and 17 Outlaw’s counsel acting in Michigan, Boss Law PLLC – a firm whose alleged 18 misconduct continues today.
cited Cited as authority (rule) Michael Cutts v. Richland Holdings, Inc.
9th Cir. · 2019 · confidence medium
Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1110 (9th Cir. 2013) (quoting In re Pegasus Gold Corp., 394 F.3d 1189, 1196 (9th Cir. 2005)). 12 CUTTS V.
discussed Cited as authority (rule) Antonio White v. Calvin Broadus, Jr.
9th Cir. · 2019 · confidence medium
"The most important factor in determining whether to award fees under the Copyright Act" is whether the award furthers the Copyright Act’s aim of "stimulat[ing] artistic creativity for the general public good." Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir. 2013) (internal quotation marks omitted).
discussed Cited as authority (rule) Glacier Films (Usa), Inc. v. Andrey Turchin
9th Cir. · 2018 · confidence medium
THE GOALS OF THE COPYRIGHT ACT Finally, the district court erred in its assessment of whether awarding fees in this case would “further the purposes of the [Copyright] Act.” Mattel, Inc v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir. 2013).
discussed Cited as authority (rule) Core Techs, Inc. v. Advanced Fraud Sols., LLC
N.C. Bus. Ct. · 2018 · confidence medium
“A logical relationship exists when the counterclaim arises from the same aggregate set of operative facts as the initial claim, in that the same operative facts serve as the basis of both claims or the aggregate core of facts upon which the claim rests activates additional legal rights otherwise dormant in the defendant.” Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1110 (9th Cir. 2013).
cited Cited as authority (rule) Bikram's Yoga College of India, L.P. v. Evolation Yoga, LLC
9th Cir. · 2015 · confidence medium
Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir.2013) (quoting Twentieth Century Music Corp. v. Aiken, 422 U.S. 151, 156 , 95 S.Ct. 2040 , 45 L.Ed.2d 84 (1975)).
discussed Cited as authority (rule) SOFA Entertainment, Inc. v. Dodger Productions, Inc.
9th Cir. · 2013 · confidence medium
III A. Fair Use The Copyright Act exists “ ‘to stimulate artistic creativity for the general public good.’ ” Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir. 2013) (quoting Twentieth Century Music Corp. v. Aiken, 422 U.S. 151, 156 , 95 S.Ct. 2040 , 45 L.Ed.2d 84 (1975)).
discussed Cited "see" Teradata Corporation v. Sap Se
Fed. Cir. · 2023 · signal: see · confidence high
See Mattel, Inc. v. MGA Entertainment, Inc., 705 F.3d 1108 (9th Cir. 2013) (holding trade-secret counterclaim not com- pulsory where plaintiff’s claim was also a trade-secret claim and the accused products—Barbie and Bratz dolls— were competing products).
discussed Cited "see" ResCap Liquidating Trust v. Primary Residential Mortgage
8th Cir. · 2023 · signal: accord · confidence high
Like the Tenth Circuit, “[w]e review the district court’s discovery decisions for abuse of discretion and will reverse only if [PRMI] makes a clear showing that the denial of discovery resulted in actual and substantial prejudice.” Garcia v. Tyson Foods, Inc., 770 F.3d 1300, 1309 (10th Cir. 2014) (cleaned up); see Minnesota Supply Co. v. Raymond Corp., 472 F.3d 524 , 545 n.14 (8th Cir.2006); accord Mattel, Inc. v. MGA Ent., Inc., 705 F.3d 1108, 1111 (9th Cir. 2013).
discussed Cited "see" Vashisht-Rota v. Howell Management Services
S.D. Cal. · 2020 · signal: see · confidence high
See Mattel, Inc. v. MGA 17 Entertainment, Inc., 705 F. 3d 1108, 1110 (9th Cir. 2013). 18 In the Utah litigation, HMS asserts several causes of action Plaintiff and AEG, 19 including defamation and injurious falsehood.
discussed Cited "see" Oracle USA, Inc. v. Rimini Street, Inc.
D. Nev. · 2016 · signal: see · confidence high
See Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir.2012) (“The most important factor in determining whether to award fees under the Copyright Act, is whether an award will further the purposes of the Act.”).
discussed Cited "see" Garcia v. Tyson Foods, Inc.
10th Cir. · 2014 · signal: see · confidence high
See Mattel, Inc. v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir.2013) (upholding the district court’s in camera review of unredacted attorney invoices because they would constitute work product and the parties had other ongoing litigation).
discussed Cited "see, e.g." Jane Doe v. Daniel Fitzgerald
9th Cir. · 2024 · signal: see, e.g. · confidence medium
See, e.g., Mattel, Inc. v. MGA Ent., Inc., 705 F.3d 1108, 1110 (9th Cir. 2013) (comparing allegations in a complaint with allegations in a counterclaim to determine whether claims arose out of “same transaction or occurrence” for purposes of Rule 13 of the Federal Rules of Civil Procedure).
discussed Cited "see, e.g." Ditech Financal LLC v. Northgate Homeowners Association
D. Nev. · 2023 · signal: see also · confidence medium
See id. at 1097-98 (declining to interpret the 7 operative pleading to contain a request for damages after the pertinent party had made 8 various representations to the effect that it was only seeking declaratory and injunctive 9 relief); see also Mattel, Inc v. MGA Ent., Inc., 705 F.3d 1108, 1110-11 (9th Cir. 2013) 10 (vacating jury verdict where the theory upon which the jury found liability was not borne 11 out by the pleadings). 12 Regardless, and alternatively, Plaintiff concedes in reply that it “must foreclose first, 13 and then if necessary sue for any deficiency and rents from Tibon…
cited Cited "see, e.g." Olson v. Armada Corp
W.D. Wash. · 2021 · signal: see also · confidence low
Co., 7 726 P.2d 1, 6 (Wash. 1986); see also Mattel, Inc v. MGA Ent., Inc., 705 F.3d 1108 , 1110 8 (9th Cir. 2013) (applying the “logical relationship test”).
cited Cited "see, e.g." Nutrivita Laboratories, Inc. v. VBS Distribution Inc.
C.D. Cal. · 2016 · signal: see also · confidence medium
Fogerty v. Fantasy, Inc., 510 U.S. 517 , 534 & n. 19, 114 S.Ct. 1023 , 127 L.Ed.2d 455 (1994) (Fogerty I); see also Mattel, Inc v. MGA Entm’t, Inc., 705 F.3d 1108, 1111 (9th Cir.2013).
Retrieving the full opinion text from the archive…
MATTEL, INC., a Delaware Corporation; Mattel De Mexico S.A. De C
v.
Plaintiffs-Appellants, v. MGA ENTERTAINMENT, INC., a California Corporation; MGA Entertainment (HK) Limited, a Hong Kong Special Administrative Region Business Entity; MGAE De Mexico, S.R.L. De C v. a Mexico Business Entity; Isaac Larian; Carlos Gustavo MacHado Gomez; Omni 808 Investors, LLC; IGWT 826 Investments, LLC, Defendants-Appellees
11-56357.
Court of Appeals for the Ninth Circuit.
Jan 24, 2013.
705 F.3d 1108
Kathleen M. Sullivan (argued), Quinn Emanuel Urquhart & Sullivan, LLP, New York, NY; John B. Quinn, Susan R. Est-rich and Michael T. Zeller, Quinn Emanuel Urquhart & Sullivan, LLP, Los Angeles, CA, for Plaintiffs-Appellants., Clifford M. Sloan (argued), Allon Kedem and David W. Foster, Skadden, Arps, Slate, Meagher & Flom LLP, Washington, D.C.; Thomas J. Nolan, Jason D. Russell and Hillary A. Hamilton, Skadden, Arps, Slate, Meagher & Flom LLP, Los Angeles, CA, for Defendants-Appellees.
Kozinski, Trott, Wardlaw.
Cited by 36 opinions  |  Published
1 passage pin-cited by 1 case
Pinpoint authority: bottom 61%
Citer courts: D. Nevada (1)

OPINION

KOZINSKI, Chief Judge:

The last time Mattel and MGA were here, we predicted that “the entire case will probably need to be retried.” Mattel, Inc. v. MGA Entm’t Inc., 616 F.3d 904, 918 (9th Cir.2010). On remand, the district court agreed and ordered a new trial. The jury rejected Mattel’s claim that MGA infringed Mattel’s copyrights by producing Bratz dolls. While Mattel doesn’t challenge that result, it does challenge the jury’s verdict that Mattel misappropriated MGA’s trade secrets, and the district court’s award of attorneys’ fees and costs to MGA'under the Copyright Act.

I. BACKGROUND

In late 2006, Mattel sought leave to amend its complaint by adding a claim that MGA had stolen its trade secrets. The district court allowed Mattel to plead the claim, but only as a counterclaim. Then, in 2010, after we had decided the first appeal, MGA filed a new claim against Mattel for misappropriating its trade secrets. See Cal. Uniform Trade Secrets Act, Cal. Civ.Code § 3426 et seq. Mattel moved to dismiss MGA’s claim, arguing that the statute of limitations had run because the events at issue happened more than three years earlier. See Cal. Civ. Code § 3426.6. The district court denied Mattel’s motion, concluding that “Mattel’s trade secret misappropriation counterclaim and MGA’s trade secret misappropriation counterclaim-in-reply are logically related.” Thus, MGA’s counterclaim-in-reply was compulsory and therefore permissible.

[*1110] The jury found for MGA, and awarded more than $80 million in damages. The district court then awarded MGA an equal amount in exemplary damages under the California Uniform Trade Secrets Act, which authorizes exemplary damages if the misappropriation was “willful and malicious.” Cal. Civ.Code § 3426.3(c). The court also awarded trade-secret attorneys’ fees and costs. In addition, because the jury found for MGA on Mattel’s copyright claim, the district court awarded attorneys’ fees and costs to MGA under the Copyright Act. See 17 U.S.C. § 505.

Mattel appeals both the district court’s decision that MGA’s trade-secret counterclaim was compulsory and the award of fees under the Copyright Act.

II. ANALYSIS

A. MGA’s trade-secret claim

Counterclaims-in-reply are permitted only if they are compulsory. See Davis & Cox v. Summa Corp., 751 F.2d 1507, 1525 (9th Cir.1985), superseded on other grounds by 28 U.S.C. § 1961. To be compulsory, a counterclaim must “arise[] out of the transaction or occurrence that is the subject matter of the opposing party’s claim.” Fed. R. Civ. P. 13(a)(1)(A). We apply “the logical relationship test for compulsory counterclaims.” In re Pegasus Gold Corp., 394 F.3d 1189, 1195-96 (9th Cir.2005) (internal quotation marks omitted). “A logical relationship exists when the counterclaim arises from the same aggregate set of operative facts as the initial claim, in that the same operative facts serve as the basis of both claims or the aggregate core of facts upon which the claim rests activates additional legal rights otherwise dormant in the defendant.” Id. at 1196 (internal quotation marks omitted); see also Moore v. N.Y. Cotton Exch., 270 U.S. 593, 610, 46 S.Ct. 367, 70 L.Ed. 750 (1926).

MGA’s claim did not rest on the same “aggregate core of facts” as Mattel’s claim. While Mattel asserted many claims that covered numerous interactions between Mattel and MGA, Mattel’s specific allegations regarding trade secrets were that several of their employees, including Gustavo Machado and Ron Brawer, defected to MGA and disclosed Mattel’s trade secrets. By contrast, MGA’s trade-secret claim rested on allegations that Mattel’s employees stole MGA trade secrets by engaging in chicanery (such as masquerading as buyers) at toy fairs. That both Mattel and MGA claimed they stole each other’s trade secrets isn’t enough to render MGA’s counterclaim compulsory. In re Pegasus, 394 F.3d at 1196. What matters is not the legal theory but the facts. “[E]ven the most liberal construction of [‘transaction’] cannot operate to make a counterclaim that arises out of an entirely different or independent transaction or occurrence compulsory under Rule 13(a).” 6 Charles A. Wright & Arthur R. Miller, Federal Practice & Procedure § 1410, at 52 (3d ed.2010).

The district court ruled that it was “more than reasonable to conclude at least some of the trade secret information allegedly misappropriated by Machado and Brawer incorporated trade secret information” that Mattel had stolen from MGA. But this is not borne out by the pleadings, as the district court recognized: “MGA does not expressly allege that Machado and/or Brawer brought market intelligence group information to MGA from Mattel.” Nor would it matter if they had. That the same information may have shuttled back and forth between Mattel and MGA isn’t a sufficient nexus to support a compulsory counterclaim.

Because MGA’s trade-secret claim should not have reached this jury, we vacate the verdict along with the related[*1111] damages, fees and costs. See Cal. Civ. Code §§ 3426.3(c), 3426.4. On remand, the district court shall dismiss MGA’s trade-secret claim without prejudice.

B. Copyright attorneys’ fees

Whether or not a prevailing party is entitled to attorneys’ fees under the Copyright Act “is reposed in the sound discretion of the district courts.” Fantasy v. Fogerty, 94 F.3d 553, 555 (9th Cir.1996) (Fogerty II); see also 17 U.S.C. § 505. The most important factor in determining whether to award fees under the Copyright Act, is whether an award will further the purposes of the Act. Fogerty II, 94 F.3d at 558. The Act’s “ultimate aim is ... to stimulate artistic creativity for the general public good.” Twentieth Century Music Corp. v. Aiken, 422 U.S. 151, 156, 95 S.Ct. 2040, 45 L.Ed.2d 84 (1975). That aim is furthered when defendants “advance a variety of meritorious copyright defenses.” Fogerty v. Fantasy, 510 U.S. 517, 527, 114 S.Ct. 1023, 127 L.Ed.2d 455 (1994) (Fogerty I).

Here, the district court explained, “MGA [has] secured the public’s interest in a robust market for trendy fashion dolls populated by multiple toy companies.” MGA’s “contribution to the state of the law in the field of copyright in a case of this magnitude and notoriety” was important because MGA’s “failure to vigorously defend against Mattel’s claims could have ushered in a new era of copyright litigation aimed not at promoting expression but at stifling the ‘competition’ upon which America thrives.” The district court did not abuse its discretion in awarding MGA fees for fighting against Mattel’s claim “that was stunning in scope and unreasonable in the relief it requested.”

Mattel argues that, because its claim was objectively reasonable, MGA is not entitled to fees. This argument seeks to resurrect the long-rejected requirements of frivolousness and bad faith. See Apple Computer, Inc. v. Microsoft Corp., 35 F.3d 1435, 1448 (9th Cir.1994). At one point, a copyright defendant had to show that the plaintiffs claim was frivolous or made in bad faith in order to .be entitled to fees; but no longer. Id. Even assuming Mattel’s claim was objectively reasonable, the district court didn’t abuse its discretion in awarding MGA fees.

Mattel also maintains that it should have been provided with unredacted copies of MGA’s legal invoices. But the sort of information Mattel seeks is attorney work product. See MGIC Indem. Corp. v. Weisman, 803 F.2d 500, 505 (9th Cir.1986). Protecting MGA’s work product was particularly important here, because MGA was still engaged in litigation with Mattel. In any event, the district judge reviewed unredacted invoices in camera, which is a sufficient safeguard against unreasonable bills.

Mattel’s remaining arguments about apportionment and calculation are equally unconvincing. The district court properly exercised its discretion in awarding and calculating attorneys’ fees and costs. See Entm’t Research Group, Inc. v. Genesis Creative Group, Inc., 122 F.3d 1211, 1216-17 (9th Cir.1997).

III. CONCLUSION

MGA’s claim of trade-secret misappropriation was not logically related to Mattel’s counterclaim; we therefore reverse the district court’s holding that MGA’s counterclaim-in-reply was compulsory. Because the district court did not abuse its discretion in awarding fees and costs under the Copyright Act, we affirm that award.

While this may not be the last word on the subject, perhaps Mattel and MGA can take a lesson from their target demographic: Play nice.

[*1112] AFFIRMED IN PART, REVERSED IN PART AND REMANDED.

NO COSTS.