Supreme Court sanctioned limits on punitive damages do not apply to statutory damages in copyright infringement actions.

The US District Court for the District of Maryland, Northern Division, held that the Supreme Court's recommended bruits on punitive damages, enunciated in State Farm Mutual v. Campbell [538 U.S. 408 (2003)] and BMW of North America v. Gore [517 U.S. 559 (1996)], do not apply to statutory damages in copyright infringement actions. [Lowry's Reports, Inc. v. Legg Mason, Inc., 302 F. Supp. 2d 455 (D. Md. Feb. 11, 2004.]

This issue arose in the context of an action brought by Lowry's Reports, Inc., alleging copyright infringement and breach of contract resulting from the use by Legg Mason, Inc., of Lowry's New York Stock Exchange Market Trend Analysis. On October 3, 2003, …