A jury award of $22,500 per song, resulting in a total award of $675,000 in statutory damages against an individual who downloaded copyrighted music files on a peer-to-peer network, violated the individual's due process rights, where he reaped no pecuniary reward from the infringement and the infringement caused the plaintiffs "minimal harm," a district court ruled. The court referenced the "plainly legitimate reasons" underlying statutory damages provisions in copyright actions, which seek to insure that copyright owners are adequately compensated where actual damages are difficult to prove, to deter copyright infringement, and to encourage licensed access to works. The court noted, however, that the U.S. Supreme Court has constrained punitive damage awards under the due process clause, and found that the jury's award was "far greater than necessary to serve the government’s legitimate interests in compensating copyright owners and deterring infringement."

Sony BMG Music Entertainment v. Tenenbaum, 2010 U.S. Dist. LEXIS 68642 (D. Mass. July 9, 2010) DownloadPDF