Case Citator › Data General Corp. v. Grumman Systems Support Corp.

Data General Corp. v. Grumman Systems Support Corp.

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
First Circuit
Citation
36 F.3d 1147
Decided
Confirmed treatments
2
Flagged citations read
59 of 59
Citing cases (total)
59
Treatment dates
2010–2024
Overruled in part
A reviewed court has overruled part of this case’s holding. Data General Corp. v. Grumman Systems Support Corp. was overruled in part on copyright registration and later limited on prejudgment interest. The Supreme Court rejected its view that registration under § 411(a) limits federal courts' subject matter jurisdiction.
More on how this was screened

A Delaware federal court declined to extend its prejudgment interest reasoning to trebled federal antitrust damages. All 59 flagged citations have been read, and both treatments are listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

59 later cases cite Data General Corp. v. Grumman Systems Support Corp.; 59 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Data General Corp. v. Grumman Systems Support Corp.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court rejected Data General's view that copyright registration under § 411(a) is jurisdictional, listing it among the circuit decisions taking that view.

    Reed Elsevier, Inc. v. Muchnick · Supreme Court of the United States · filed

    In this case, the Court of Appeals for the Second Circuit held that a copyright holder’s failure to comply with § 411(a)’s registration requirement deprives a federal court of jurisdiction to adjudicate his copyright infringement claim. We disagree. Section 411(a)’s registration requirement is a precondition to filing a claim that does not restrict a federal court’s subject-matter jurisdiction. ... 509 F.3d, at 121 (citing “widespread agreement among the circuits that section 411(a) is jurisdictional”).2 Judge Walker dissented. ... Data Gen. Corp. v. Grumman Systems Support Corp., 36 F.3d 1147, 1163 (CA1 1994).
    Read the full opinion on CourtListener →

Limited

  • The court declined to extend Data General's prejudgment interest reasoning to an award of trebled federal antitrust damages.

    Ingevity Corporation v. BASF Corporation · District of Delaware · filed

    I do not think Data General supports awarding prejudgment interest to BASF. The First Circuit permitted Data General to recover the higher of two prejudgment interest amounts; the parties did not seem to dispute whether Data General was entitled to prejudgment interest in the first place. The Data General reasoning does not relate to antitrust damages either, unlike Kelco. The present judgment further shows that BASF is recovering trebled damages under federal law; the judgment is not ambiguous.
    Read the full opinion on CourtListener →

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