I. INTRODUCTION Frederick Bouchat, an amateur artist, was so excited that an NFL team was moving to Baltimore that he created drawings and designs for the team in his free time. (1) Initially willing to provide one of his drawings in exchange for only a "letter of recognition" and an autographed helmet, he later filed suit after discovering that the Baltimore Ravens and National Football League Properties ("NFLP") had used his drawing in their team logo without authorization or acknowledgement. (2) A jury returned a verdict of copyright infringement against the Ravens and NFLP, and the Fourth Circuit affirmed in an interlocutory appeal in Bouchat v. Baltimore Ravens, Inc. (Bouchat I). (3) In the damages phase of the trial, however, the jury found that none of the Ravens' or NFLP's profits were attributable to their infringing acts, and the Fourth Circuit affirmed in Bouchat v. Baltimore Ravens, Inc. (Bouchat II). (4)
