A Landmark Verdict
In our October 2025 Client Advisory, we discussed the significance of the federal court’s summary judgment rulings in Post University Inc. v. Learneo, Inc., which allowed key Digital Millennium Copyright Act (“DMCA”) and Lanham Act claims to proceed to trial against Course Hero’s parent company. On March 4, 2026, a Connecticut federal jury delivered a verdict: $75.3 million in damages against Learneo Inc., finding that it violated the DMCA more than 3,000 times when it manipulated documents coming from Post University.
The Trial and Verdict
The nine-day trial, which began on February 17, 2026, focused on claims for direct, contributory, and vicarious copyright infringement as well as removal or alteration of copyright management information (“CMI”) in violation of the DMCA. Post University alleged that when users uploaded its course materials (e.g., syllabi, assignments, quizzes, exams, and student essays) to Learneo’s Course Hero, the platform removed original CMI, such as author, title, and copyright owner information, and replaced it with its own CMI, including Course Hero’s own copyright notice, logos, banners, prompts, footers, and watermarks. These allegations were consistent with the evidence the court had credited at summary judgment regarding the platform’s staged lifecycle of uploading, previewing, unlocking, and downloading documents.
After nearly 14 hours of deliberations over the course of three days, the jury found Learneo liable for removing Post University’s CMI and replacing it with Course Hero’s own. Statutory damages under the DMCA range from $2,500 to $25,000 per violation, and the jury assessed the maximum amount of $25,000 for each of the 3,015 violations found against Learneo, resulting in a $75.3 million award. While only a fraction of Post University’s multi-billion-dollar projected awards figure, the jury award remains a meaningful result.
Learneo has indicated that it plans to appeal as it “strongly” disagrees with the verdict.
What This Means for Educational Institutions
The verdict underscores the practical advice we offered in our prior advisory. Institutions that invest in copyright registration, clear branding, consistent metadata practices, and robust enforcement protocols stand to benefit not only from deterrence but from meaningful remedies when violations occur. Notably, only five of the documents at issue were registered with the U.S. Copyright Office, and copyright infringement damages for those works totaled just $114.85 based on Course Hero’s per-document revenue. The majority of the $75.3 million verdict arose from DMCA statutory damages for CMI removal and alteration—reinforcing the independent importance of DMCA claims when CMI is manipulated by a platform.
Educational institutions should revisit and, where necessary, strengthen the measures we outlined previously: registering copyrights in important instructional materials before infringement occurs, confirming institutional ownership through employment agreements and academic policies, prominently branding all teaching documents with institutional names and logos, and adopting clear policies prohibiting unauthorized uploading or sharing of course materials. The Post University verdict makes clear that these steps are not merely prudent—they can form the evidentiary foundation for substantial recoveries.
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Carter Ledyard & Milburn LLP uses Client Advisories to inform clients and other interested parties of noteworthy issues, decisions and legislation which may affect them or their businesses. A Client Advisory does not constitute legal advice or an opinion.