IP Law Daily, COPYRIGHT—1st Cir.: Songwriter’s copyright lawsuit against Ricky Martin over the song 'Vida' revived on appeal, (Jun 15, 2026)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

The district court prematurely resolved disputed copyright ownership issues and invalidated the copyright registration without affording the songwriter a fair opportunity to obtain evidence.

A songwriter secured the revival of his copyright infringement lawsuit against singer Ricky Martin after the U.S. Court of Appeals for the First Circuit vacated a summary judgment ruling and an order invalidating the songwriter’s copyright registration. The appellate court found that the district court granted summary judgment without allowing meaningful discovery, even though key evidence was controlled by Ricky Martin and the contest co-sponsor, Sony. Because the plaintiff had not received a full and fair opportunity to obtain evidence concerning the ownership of the disputed copyrights, the case had to be remanded for further proceedings (Cortés-Ramos v. Martin-Morales, No. 24-1805 (1st Cir. Jun. 12, 2026)).

The dispute arose between songwriter Luis Adrián Cortés-Ramos and Ricky Martin (Martin), the Puerto Rican recording artist. Their relationship stemmed from the 2013 SuperSong contest, which Martin and Sony co-sponsored to select an original song for possible inclusion on the official album of the 2014 FIFA World Cup. Cortés entered the contest, advanced to the finals, and later accused Martin of copying his work.

Cortés claimed copyrights in a song and accompanying music video that he submitted to the contest in January 2014. He alleged that Martin’s later-released song and music video, “Vida,” unlawfully copied protectable elements of his submission. Martin responded that the contest documents transferred any copyright interests Cortés possessed to Sony, depriving him of standing to pursue infringement claims.

The litigation had already generated multiple appeals before the First Circuit. Following an earlier remand regarding copyright registration issues, Cortés filed the present action alleging copyright infringement and fraudulent inducement. The district court dismissed the fraudulent-inducement claim but allowed the copyright claim to proceed. Martin subsequently argued that contest rules and related agreements established that Cortés had assigned all relevant copyrights to Sony. A magistrate judge recommended summary judgment in Martin’s favor, finding that Cortés had assented to the contest rules and transferred his rights. The district court adopted that recommendation, entered summary judgment for Martin, and declared Cortés’s 2017 copyright registration invalid because he allegedly lacked any rights to register. Cortés appealed.

Jurisdiction. The court first rejected Cortés’s argument that an arbitration agreement between him and Sony deprived the federal courts of jurisdiction. Relying on Skirchak v. Dynamics Research Corp., 508 F.3d 49 (1st Cir. 2007), and DiMercurio v. Sphere Drake Insurance PLC, 202 F.3d 71 (1st Cir. 2000), the court reiterated that arbitration agreements do not divest courts of jurisdiction. Moreover, Martin was not a party to the arbitration agreement, and Cortés failed to identify any legal basis for arbitrating his dispute with Martin. The court therefore found no jurisdictional defect and no reason to abstain from hearing the case.

Discovery. The appeal turned on discovery. Cortés repeatedly argued that he had never been allowed to conduct discovery despite years of litigation and that Sony and Martin controlled the documents necessary to challenge the claimed copyright assignment. Although he requested a scheduling conference and sought an opportunity to obtain evidence, the district court denied those requests and directed the parties to proceed to summary judgment.

The First Circuit concluded that the district court improperly resolved the case without giving Cortés a meaningful opportunity to obtain evidence. Applying Rule 56(d), the court relied on Emigrant Residential LLC v. Pinti, 37 F.4th 717 (1st Cir. 2022), which instructs courts to apply the rule liberally when a party needs discovery to oppose summary judgment. Although Cortés did not file a Rule 56(d) motion, the court found that his repeated discovery requests sufficiently alerted the district court to the problem.

No fair opportunity. The court next found that Cortés acted diligently. He sought discovery as soon as the district court signaled that it intended to bypass ordinary case-management procedures and proceed directly toward summary judgment. According to the court, Rule 56(d) is designed to protect litigants who promptly seek evidence necessary to oppose dispositive motions, and Cortés consistently pressed the issue.

More importantly, the court determined that Cortés never received a full and fair opportunity to conduct discovery. Unlike the typical Rule 56(d) case, where parties dispute whether additional discovery is necessary, no discovery occurred at all. The court emphasized that Martin relied on affidavits and documents obtained through Sony while Cortés lacked any meaningful opportunity to test that evidence through depositions or document requests. Citing In re PHC, Inc. Shareholder Litigation, 762 F.3d 138 (1st Cir. 2014), the court explained that denying discovery is particularly problematic when the relevant information lies within the control of the opposing side.

The court further observed that discovery exists to permit parties to verify the completeness and accuracy of the evidence presented against them. Quoting principles discussed in United States v. Procter & Gamble Co., 356 U.S. 677 (1958), the court stressed that modern discovery procedures are intended to transform litigation into a fair contest rather than a game of surprise. Here, Martin effectively asked the courts to accept that all relevant documents had already been produced, while Cortés had no practical mechanism to confirm that assertion.

Remand. Because the discovery error affected the entire summary judgment proceeding, the court declined to address the merits of the copyright-assignment issue. It likewise declined to determine whether Cortés’s copyright registration was actually invalid. Instead, it vacated both the summary judgment ruling and the registration-invalidity order and directed the district court to permit discovery before reconsidering the merits of the dispute.

Partial dissent. Chief Judge David J. Barron dissented in part and would have affirmed. He concluded that Cortés failed to preserve a viable Rule 56(d) challenge and did not adequately address the district court’s findings regarding discovery. Barron also noted that Cortés did not meaningfully challenge the determination that he accepted the contest rules through a clickwrap agreement, which provided an independent basis for affirmance.

The Case is No. 24-1805.

Judge: Thompson, O.

Attorneys: Juan Ramon Rodriguez Lopez (Rodriguez Lopez Law Offices PSC) for Luis Adrian Cortes-Ramos. Benjamin Stewart Akley (Pryor Cashman LLP) for Enrique Martin-Morales.

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