Date: 20011220
Docket: T-959-00
Neutral citation: 2001 FCT 1416
BETWEEN:
MASTERFILE CORPORATION
(Plaintiff)
- and -
WORLD INTERNETT CORPORATION, NIGEL MAYNE,
TAALWOOD INTERNET MARKETING, MARCIA WOODS,
INFOBASE MARKETING INC., DEVILLE PRODUCE LIMITED,
DON MILLS OPTOMETRIC CLINIC, CANADA HOUSE ENGLISH
LANGUAGE CENTRE INC., FUN TIME TRAVEL COMPANY LTD.
PARMAC RELATIONSHIP MARKETING LTD., CAMPKIN'S
CAMPING CENTRE INC., MANSOOR ELECTRIC LTD. SACCCO
SCHOOLS LTD., CARDINAL NANNIES & COMPANIONS INC.,
CHS PHARMACY LIMITED, DR. MACLEOD EYE CLINIC,
ENTERPRISE AIR INC., GEMINI GYMNASTICS, CONSOLIDATED
GRAPHICS CANADA LIMITED, NATIONAL GOLF PARTNERS INC.,
HEALTH POWER 2000, JACK RABBIT SLIMS BAR AND EATERY INC.,
ONTARIO MOTOR SALES LIMITED, PALM BEACH TANNING
STUDIOS INC., PETLEY-HARE LIMITED, TRAIN INC. and
WESTMOUNT CORPORATE CAR SERVICES
(Defendants)
REASONS FOR ORDER
SIMPSON J.:
[1] This application is for summary judgment against 17 respondents and for default judgment against four defendants for their alleged breach of the Applicant's copyright in one hundred forty-nine images copied in the design of the respondents' websites.
The Parties
[2] The applicant, Masterfile Corporation ("Masterfile") is a Canadian company that has its head office in Toronto. It is a stock image company, and, as such, is in the business of acquiring exclusive rights to images under contracts with artists of different kinds including illustrators and photographers. The images are then licenced by Masterfile to a variety of end users including advertising agencies, designers and publishers. Masterfile's library of images is made available to prospective licensees through printed catalogues, CD-ROMs and a website. Once a client selects an image, and prior to any reproduction, a licence fee is negotiated.
[3] The respondent, World Internett Corporation ("Worldsites") is a Delaware Corporation that carries on business in Canada under the registered name Worldsites Networks. It operates a website design and hosting business which it conducts both directly and through a network of franchisees. Worldsites and its franchisees design websites for their respective customers and Worldsites then hosts the websites on its internet server. The individual defendant, Nigel Mayne, is the President of Worldsites. This motion for summary judgment has been abandoned against him and is unopposed by Worldsites.
[4] The respondent, Taalwood Internet Marketing ("Taalwood") is 1199464 Ontario Inc. It is in the business of designing websites for its customers. Taalwood entered into a franchise agreement with Worldsites on September 28, 1996. Under that agreement, the websites it designed for its customers would be hosted on Worldsites' internet server. The individual defendant, Marcia Woods ("Woods") is Taalwood's Vice-President. This motion proceeded against Taalwood and Woods. Their counsel will be described as "Respondents' Counsel".
[5] The remaining respondents are all customers of Taalwood. Taalwood designed websites for them that included Masterfile's images, and their websites are hosted on Worldsites' internet server. The following respondents have settled with the applicant and no relief is sought against them on this motion: Mansoor Electronics Ltd., Consolidated Graphics Canada Limited and Ontario Motor Sales Limited. In addition, no relief is sought against Health Power 2000 and Jack Rabbit Slims Bar and Eatery Inc. because they were not properly served.
[6] Four defendants have not defended the main action and are not represented on this motion. Accordingly, default judgment is sought against them. They are: Dr. Macleod Eye Clinic, Train Inc., Gemini Gymnastics and Deville Produce Limited.
[7] The remaining respondents on this motion, except Saccco Schools Ltd., are represented by Respondents' Counsel who, as noted above, also appears for Woods and Taalwood. Saccco Schools Ltd. retained a lawyer but he was instructed not to appear on this motion and indicated that his client would adopt the submissions made by Respondents' Counsel.
[8] As a result of the foregoing, default judgment is sought against the four defendants listed in paragraph 6 and summary judgment is sought against the following respondents: World Internett Corporation, Taalwood Internet Marketing, Marcia Woods, Infobase Marketing Inc., Don Mills Optometric Clinic, Canada House English Language Centre Inc., Fun Time Travel Company Ltd., Parmac Relationship Marketing Ltd., Campkin's Camping Centre Inc., Saccco Schools Ltd., Cardinal Nannies & Companions Inc., CHS Pharmacy Limited, Enterprise Air Inc., National Golf Partners Inc., Palm Beach Tanning Studios Inc., Petley-Hare Limited and Westmount Corporate Car Services.
The Facts
[9] Taalwood admits that, without a licence, it copied images from Masterfile's CD-ROM when it designed websites for its customers. The CD-ROM Taalwood used contained 5719 Masterfile images. When the CD-ROM is inserted in a computer, a screen appears that reads in part: "All Images Copyright© 1998 Masterfile Corporation and the Respective Artists." The viewer is advised that the images are not royalty-free images and is told that the images are protected by copyright registered in Washington D.C. The viewer is also advised that images cannot be copied unless licence fees are paid.
[10] Woods explains that Worldsites' website designer, Gary Kupecz, told her that Worldsites had made the necessary arrangements and that the images on Masterfile's CD-ROM were available for Taalwood's use. As a result, in April 1998, Taalwood began to use the Masterfile images in its website designs. It appears that Worldsites had begun to use them in February of the same year.
[11] On June 13, 1999, Masterfile discovered some of Worldsites' unauthorized use. On July 13th, it called Taalwood to complain and was referred to Worldsites. Thereafter, a Masterfile employee left a voice-mail message at Worldsites describing Masterfile's concerns and demanding that the images be removed. Woods learned of the complaint but, when she called Worldsites, she was twice assured by its Vice-President, Brian McDonald, that Taalwood was entitled to use the Masterfile images. Wood's evidence about her belief that she had a legal right to use Masterfile's images is uncontested since neither Worldsites nor Mr. Kubecz filed affidavits.
[12] Since Worldsites ignored Masterfile's voice-mail message of July 13, 1999, another voice-mail message was left on September 28, 1999. Worldsites ignored it as well. Finally, on October 1, 1999, Masterfile wrote Worldsites a letter of complaint.
[13] Eventually, Worldsites admitted to Masterfile that it had begun to copy the images in February of 1998. Masterfile then sent Worldsites three invoices dated October 21, 1999. They totalled $18,200.70 and related to twenty-one images used on the Worldsites.net and Couriersource.com websites. None of these invoices have been paid.
[14] In March of 2000, Masterfile discovered that more of its unlicenced images were in use on websites designed by Taalwood and hosted by Worldsites. Taalwood admits that it continued to copy Masterfile's images after Masterfile's initial complaint to Worldsites of July 13, 1999.
[15] Eventually, based on a schedule of use provided by Taalwood and on Masterfile's tariff , Masterfile calculated that Taalwood owes it $95,175 for the images it copied without a licence. Taalwood, on the other hand, calculated that the amount owing is $91,570.
The Issues
[16] Against this backgound, the following questions require consideration:
1. Does Masterfile have standing to bring this action? The answer will depend on whether it is an exclusive licensee or only an exclusive agent, and on the effect of the deemed assignment of copyright it has taken from many artists.
2. Is there copyright in the works? Given that no evidence of copyright has been filed by the artists who own the images, can Masterfile rely on the presumption of copyright in the Copyright Act, R.S.C. 1985, c. C-42, as amended (the "Act")?
3. Does the Federal Court have jurisdiction? The answer will depend on whether Masterfile is a Collective Society under the Act.
4. Are Masterfile's charges appropriate? The answer will depend on whether Masterfile is entitled to charge for the images based on its fee schedule for high quality images even though Taalwood copied and used only less valuable versions of the images. The appropriateness of Masterfile's charges will also depend on whether it can charge its tariff rates.
5. Is Woods personally liable?
6. Are the Respondents jointly and severally liable?
7. What is the quantum of damages and should exemplary damages be awarded?
Issue 1 - Standing
[17] Masterfile says that its contracts have always made it an exclusive licensee of the one hundred and forty-nine images in issue and it relies on the 1977 amendments to the Act that permit exclusive licensees to sue in their own names without adding the copyright owner as a party. Masterfile also relies on the deemed assignments of copyright in its contracts with forty-four of the forty-nine artists whose images are at issue[1].
[18] Masterfile says it has the sole right to reproduce an image that is the subject of a contract and that this demonstrates its status as an exclusive licensee. Masterfile also says that it is an exclusive licensee because its contracts enable it to grant exclusive licences for the images. It notes that its contracts provide that artists are not to reproduce the image or make similar images during the life of the contracts, and says that this further demonstrates its status as an exclusive licensee.
[19] Respondents' counsel submits that Masterfile's contracts only appoint it to be an exclusive agent. She says that the contracts do not make Masterfile an exclusive licensee and that the deemed assignments on which Masterfile relies are not valid in Canada. She also says that Masterfile does not have a true right to copy the images and that it grants licenses as an agent. Finally, she submits that the artists' agreement not to reproduce the images has nothing to do with an exclusive license granted to Masterfile. Rather, it protects the value of the images which are the subject of exclusive licenses to end users.
[20] Five Masterfile contracts with various artists were reviewed in connection with these submissions. They are: a Memorandum of Agreement dated April 19, 1985 between Masterfile and Daryl Benson (the "First Contract"); a Memorandum of Agreement dated September 1, 1988 between Masterfile and Wilhelm Schmidt (the "Second Contract"); a Memorandum of Agreement dated July 1, 1989 between Masterfile Corporation and Bruce Rowell (the "Third Contract"); a Memorandum of Agreement of May 1, 1994 between Masterfile and Paul Chen (the "Fourth Contract"); and a Memorandum of Agreement dated June 1, 1999 between Masterfile and Bruce Rowell (the "Fifth Contract").
[21] In the First Contract, the artist appoints Masterfile his sole and exclusive agent worldwide for the sale and licensing of all defined images. Provision 2.02 of the First Contract makes it clear that, in future, the photographer will execute any assignments or licences of copyright needed to give effect to a sale or licence of an image. Respondents' Counsel says that, if Masterfile was to be an exclusive licensee, the First Contract would so provide and there would be no need to involve the photographer in future copyright assignments.
[22] Respondents' Counsel also refers to provision 4.03 of the First Contract. Masterfile relies on its sole right to reproduce the images as proof of its status as a licensee but Respondents' Counsel notes that provision 1.01(a) states that the copies Masterfile makes must be clearly distinguishable from the originals. Respondents' Counsel submits that, since no licence is required to make a distinguishable image, Masterfile's right to reproduce a distinguishable image does not support a finding that it is an exclusive licensee.
[23] Furthermore, provision 5.01 of the First Contract makes it clear that the artist and not Masterfile retains all present and future copyright.
[24] Provision 7.03 of the First Contract deals with litigation and states in part that:
The Photographer grants Masterfile full and complete authority to make those claims and take such action as may be necessary (in the opinion of Masterfile) if there occurs any damage to, destruction or loss of any Material, or the unauthorized use of Agency Images by any third party. All amounts recovered by Masterfile in connection with any claims or action shall be apportioned and paid equally to the Photographer and Masterfile...
[25] Although it appears from this provision that the artist agrees that Masterfile will litigate alone over unauthorized use of an image, it is my view that, because copyright stays with the artist, this provision is not sufficient to appoint Masterfile an exclusive licensee of the artist's copyright in the image.
[26] The Second Contract also appoints Masterfile as the artist's agent and entitles it to make distinguishable reproductions of the images. As well, in provision 5.01, the artist states that he is the sole holder of the copyright in the images. Again, Masterfile can litigate about unauthorized use but there is no provision for a copyright assignment for litigation and no reference to Masterfile as an exclusive licensee. Accordingly, it is my conclusion that this contract does not make Masterfile an exclusive licensee.
[27] The significant provisions of the Third Contract are similar to those in the First and Second Contracts and my conclusion about Masterfile's status is the same.
[28] In provision 2.01(a) of the Fourth Contract, the artist warrants that he is the sole and exclusive copyright owner. In provision 3.05(a), the artist agrees that copyright may be transferred to Masterfile if it pursues claims under provision 7.04. That provision gives Masterfile authority to litigate claims dealing with the unauthorized use of images.
[29] The second paragraph of provision 7.04 is the first version of Masterfile's deemed assignment clause. It reads as follows: "This section 7.04 will be deemed an assignment of copyright to the extent that such assignment is necessary in any jurisdiction to permit Masterfile to pursue claims on behalf of Chen [the artist]."
[30] Reading provisions 3.05(a) and 7.04 together, it appears that, in the future, two events are possible. Firstly, copyright may actually be transferred to Masterfile. Secondly, it may be deemed to have been assigned, so that Masterfile can litigate on an artist's behalf. The clear implication, in my view, is that the artist will not be a party to Masterfile's litigation. If Masterfile does not sue, copyright remains with the artist. If Masterfile does sue, the deemed assignment only takes effect in jurisdictions in which, without the assignment, the artist would be a necessary party to an action.
[31] Masterfile takes the position that, because it is the artist's exclusive licensee, it does not need to rely on the deemed assignment. It submits in the alternative that, if it is not an exclusive licensee, the deemed assignment gives it standing to sue for breach of copyright without making the artist a plaintiff in this litigation.
[32] I have concluded that, under the Fourth Contract, Masterfile has not been made an exclusive licensee. Therefore, it becomes necessary to consider the validity of the deemed assignment. This will be done in the context of the Fifth Contract.
[33] The Fifth Contract was a new form of contract that Masterfile asked its existing and new artists to sign as of June of 1999. However, only forty-four of the forty-nine artists whose images are at issue in this case have given Masterfile a deemed assignment of copyright. Some of the forty-four only gave the deemed assignment after Worldsites and Taalwood began to copy the images. As well, the following five artists never had deemed assignment of copyright clauses in their contracts with Masterfile:
Paul Terpanjian
Larry Williams
Kerry Hayes
Bill Brooks
Wilhelm Schmidt
[34] In provision 3 of the Fifth Contract, Masterfile is appointed as an agent, not a licensee. In provision 4, Masterfile acknowledges that copyright will remain exclusively with the artist. However, the artist agrees that at a future date he or she will assign copyright to Masterfile in certain circumstances that include litigation. In provision 4.5, Masterfile is authorized to execute on the artist's behalf any documents required to assure and confirm Masterfile's copyright.
[35] The assignment clause in the Fifth Contract reads as follows:
Masterfile agrees and acknowledges that the copyright in all images is, and will remain, the exclusive property of Artist. Recognizing this irrevocable right of ownership, Artist agrees to assign copyright in the File Images to Masterfile in the following circumstances:
4.1 in the pursuit of Claims by Masterfile as per Section 13.5;
4.2 Artist authorizes Masterfile, in its sole discretion, to register the copyright in any File Images in the name of Masterfile in any jurisdiction in the world where Masterfile determines that such registration will allow Masterfile to better exercise its rights to reproduce and licence or sell any File Image and protect the interests of the Parties;
4.3 Masterfile will register copyright in the U.S.A. as a matter of course for any File Images which appear in Promotional Media. This registration empowers Masterfile to sue copyright infringers for "statutory damages" in the U.S.A..
4.4 The copyright in any File Image so assigned or registered will immediately and automatically revert to Artist upon the later of:
4.4.1 termination of this Agreement, or
4.4.2 termination of any period of extension of this Agreement regarding specific File Images.
4.5 Artist and Masterfile will execute and deliver any additional documents which may reasonably be required to assure and confirm Masterfile's copyright in File Images and the subsequent reassignment of this copyright to Artist. To facilitate such execution and delivery, Artist hereby appoints Masterfile as his/her attorney-in-fact to execute and deliver any such documentation on Artist's behalf.
[my emphasis]
[36] Provision 13.5 of the Fifth Contract contains the deemed assignment of copyright. It reads:
13.5 Notwithstanding Section 7.6 [regarding loss or damage by Masterfile], Artist grants Masterfile full authority to make Claims and take such action as may be necessary (in the opinion of Masterfile) for the loss of or damage to any Material, or the unauthorized use of any File Image by any third party.
13.5.1 All amounts recovered by Masterfile in connection with Claims will be shared and paid as per Section 13.2, after deducting all collection, legal and other reasonable costs incurred by Masterfile in this regard. If such costs in aggregate exceed the total amount collected, or if no amounts are collected, then Masterfile will be solely responsible for the excess costs. Nothing herein will prevent Artist from making Claims if Masterfile declines to do so, in which event Masterfile would not be entitled to share in any amounts collected by Artist in respect of such Claims.
13.5.2 This Section 13.5 will be deemed to effect an assignment of copyright to the extent that such assignment is necessary in any jurisdiction to permit Masterfile to pursue Claims on behalf of Artist.
[37] The difficulty with the deemed assignment in provision 13.5.2 is that it contradicts provisions 4.1 and 4.5, which suggest that, when litigation is undertaken under 13.5 in jurisdictions which require an executed assignment, an actual, not a deemed, assignment of copyright is to occur.
[38] Based on the Fifth Contract, it is again my conclusion that Masterfile is not an exclusive licensee. Further, although it could have taken an actual assignment of copyright in order to litigate without making the artist a party to the litigation, and although it could have executed such an assignment itself, Masterfile has not done so pursuant to provision 4.5.
[39] Respondent's Counsel submits that the deemed assignments in the Fourth and Fifth Contracts are not recognized by section 13(4) of the Act, which says:
(4) Assignments and licences.-The owner of the copyright in any work may assign the right, either wholly or partially, and either generally or subject to limitations relating to territory, medium or sector of the market or other limitations relating to the scope of the assignment, and either for the whole term of the copyright or for any other part thereof, and may grant any interest in the right by licence, but no assignment or grant is valid unless it is in writing signed by the owner of the right in respect of which the assignment or grant is made, or by the owner's duly authorized agent.
[my emphasis]
[40] Based on this provision, I accept Respondents' Counsel's submission that Masterfile's deemed assignments are not valid under Canadian law. Although section 13(4) of the Act gives copyright owners considerable flexibility in the assignment of their rights, it does not contemplate assignments that may take effect at a future date. Assignments can be limited in a variety of ways but, in my view, some certainty is required. At a minimum, an assignment must actually exist and must be signed.
[41] Finally, I should note that both provision 3.05(d) of the Fourth Contract and provision 4.5 of the Fifth Contract specifically refer to the possibility of an express written assignment in the event of future litigation. No such assignments have been taken from any of the artists in this case.
[42] Having concluded that Masterfile has neither an exclusive licence nor an assignment of copyright for the images at issue in this case, it is my further conclusion that Masterfile has no standing to prosecute this action. Accordingly, this motion for summary judgment will be dismissed.
[43] Although it would have been logical to dismiss the Plaintiff's action as a result of my conclusion that it has no standing, I am not persuaded that I have jurisdiction to grant that relief in the absence of a defendant's motion for summary judgment pursuant to Federal Court Rule 2(3)(2).
Additional Conclusions
[44] In the hope that these comments may narrow the issues or facilitate settlement, I offer the following brief conclusions on the balance of the issues by way of obiter dicta:
Issue 2
[45] With regard to the applicability of the presumption of copyright under section 34.1(2) of the Act, I would have concluded that the Copyright Notice[2] found on Masterfile's CD-ROM did not entitle it to the benefit of the presumption because the artists' names were not shown. Further, I would have disagreed with the applicant's submission that section 34.1(1)(a) of the Act applies. In my view, once copyright is challenged in the absence of registration, as was the case here, the requirements of section 34.1(2) of the Act must be satisfied.
Issue 3
[46] Although I accepted that Masterfile operates for profit in a competitive environment and offers promotional services, I would have sent this issue to trial because I did not have any evidence about how collective societies actually operate in Canada.
Issue 4
[47] In my view, the respondents used Masterfile's images in a format different from the one in which they were offered for sale. Masterfile and the artists it represented were offering to sell only high quality distinctive images. They should not be penalized because the respondents illegally used versions of lesser quality. As well, the respondents would have been ordered to reimburse Masterfile according to its tariff. In view of their infringement, the respondents are not now entitled to the benefit of negotiated prices that they might have obtained had they sought licences to use the images.
Issue 5
[48] I would have concluded that Woods is not personally liable on the basis that she was not indifferent to the issue of infringement.
Issue 6
[49] Worldsites would have been liable for both its infringements and all of the Taalwood infringements. Taalwood, in turn, would have been liable for all of its infringing uses but not those of Worldsites. Finally, the customers of Worldsites and Taalwood would have been liable only for the fees for the images used on their individual websites.
Issue 7
[50] Even if the deemed assignments had been valid to give Masterfile standing, they did not exist for sixty-six of the one hundred forty-nine images when the infringements began in early 1998. Accordingly, the question of whether fees could be claimed for infringements that predated the deemed assignments would have been sent to trial. Finally, exemplary damages
would have been awarded against Worldsites but would not have been awarded against any of the other respondents.
"Sandra J. Simpson"
JUDGE
Toronto, Ontario
December 20, 2001
FEDERAL COURT OF CANADA
Names of Counsel and Solicitors of Record
COURT NO: T-959-00
STYLE OF CAUSE: MASTERFILE CORPORATION
(Plaintiff)
- and -
WORLD INTERNETT CORPORATION, NIGEL MAYNE, TAALWOOD INTERNET MARKETING, MARCIA WOODS, INFOBASE MARKETING INC., DEVILLE PRODUCE LIMITED, DON MILLS OPTOMETRIC CLINIC, CANADA HOUSE ENGLISH
LANGUAGE CENTRE INC., FUN TIME TRAVEL COMPANY LTD., PARMAC RELATIONSHIP MARKETING LTD., CAMPKIN'S CAMPING CENTRE INC., MANSOOR ELECTRIC LTD. SACCCO SCHOOLS LTD., CARDINAL NANNIES & COMPANIONS INC., CHS PHARMACY LIMITED, DR. MACLEOD EYE CLINIC, ENTERPRISE AIR INC., GEMINI GYMNASTICS, CONSOLIDATED
GRAPHICS CANADA LIMITED, NATIONAL GOLF PARTNERS INC., HEALTH POWER 2000, JACK RABBIT SLIMS BAR AND EATERY INC., ONTARIO MOTOR SALES LIMITED, PALM BEACH TANNING STUDIOS INC., PETLEY-HARE LIMITED, TRAIN INC. and WESTMOUNT CORPORATE CAR SERVICES
(Defendants)
DATE OF HEARING: TUESDAY, MAY 15, 2001
PLACE OF HEARING: TORONTO, ONTARIO
REASONS FOR ORDER BY: SIMPSON J.
DATED: THURSDAY, DECEMBER 20, 2001
APPEARANCES: Mr. R. Adam Bobker
For the Plaintiff
Ms. May Cheng
For the Defendants
SOLICITORS OF RECORD: Bereskin & Parr
Barristers & Solicitors
Patent and Trademark Agents
Box 401, 40 King Street West
Toronto, Ontario
M5H 3Y2
For the Plaintiff
Fasken Martineau Dumoulin
TD Bank Tower, Suite 4200
Toronto, Ontario
M5K 1N6
For the Defendants (Taalwood Defendants)
FEDERAL COURT OF CANADA
Date: 2001220
Docket: T-959-00
Between:
MASTERFILE CORPORATION
(Plaintiff)
- and -
WORLD INTERNETT CORPORATION, NIGEL MAYNE, TAALWOOD INTERNET MARKETING, MARCIA WOODS, INFOBASE MARKETING INC., DEVILLE PRODUCE LIMITED, DON MILLS OPTOMETRIC CLINIC, CANADA HOUSE ENGLISH LANGUAGE CENTRE INC., FUN TIME TRAVEL COMPANY LTD., PARMAC RELATIONSHIP MARKETING LTD., CAMPKIN'S CAMPING CENTRE INC., MANSOOR ELECTRIC LTD. SACCCO SCHOOLS LTD., CARDINAL NANNIES & COMPANIONS INC., CHS PHARMACY LIMITED, DR. MACLEOD EYE CLINIC, ENTERPRISE AIR INC., GEMINI GYMNASTICS, CONSOLIDATED GRAPHICS CANADA LIMITED, NATIONAL GOLF PARTNERS INC., HEALTH POWER 2000, JACK RABBIT SLIMS BAR AND EATERY INC., ONTARIO MOTOR SALES LIMITED, PALM BEACH TANNING STUDIOS INC., PETLEY-HARE LIMITED, TRAIN INC. and WESTMOUNT CORPORATE CAR SERVICES
(Defendants)
REASONS FOR ORDER
[1]Seventeen images are not covered by deemed assignments. They bear Masterfile's Image Code Numbers 21-01171, 22-00640, 19-00465, 20-00235, 22-00118, 19-00510, 19-00579, 20-00271, 22-00450, 22-00987, 20-00275, 20-00537, 21-01022, 19-00625, 21-00573, 21-00998 and 20-00212.
[2]Tab 13 of the Document Compendium used on this motion.
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