John Labatt Ltd. v. Anheuser-Busch, Inc.

How later courts describe this case

• holding that “costs” under the Clean Air Act only include attorneys’ fees for Rule 68 purposes if the action is unreasonable
• acknowledging silence and inaction may induce justifiable reliance by defendant in copyright infringement action that plaintiff would not pursue an infringement claim
• ownership or co-ownership claims accrue when the claim knows or has reason to know of injury caused by competing claim
• “[Plaintiffs claiming to be coauthors are time-barred three years after accrual of their claim from seeking a declaration of copyright co-ownership rights and any remedies that would flow from such a declaration.”