Judgment Collection and Copyright Preemption

Bone-Martin v. Moss addressed federal copyright preemption in the context of a judgment-collection action. The Fifth Court held that the the trial court lacked jurisdiction to divest the appellants of their federal copyrights and transfer ownership of certain copyrighted videos to the appellees.

The Court emphasized that the Copyright Act grants exclusive jurisdiction to federal courts over matters related to copyright ownership and transfer. Therefore, “the trial court had no jurisdiction to determine the ownership of the videos and whether the purported transfer of videos to Google or another virtual platform was a ‘voluntary transfer’ under the Copyright Act.” No. 05-22-00439-CV (Feb. 13, 2025) (mem. op.).