SUPPLEMENTAL MEMORANDUM
DeMASCIO, District Judge.
On May 1, 1987, the court entered Findings of Fact and Conclusions of Law holding defendants liable for willful infringements of plaintiffs' copyrights in the T.A. Survey and E.S. Survey, written tests designed to detect honesty and emotional status, respectively, in the workplace. In the memorandum I awarded $50,000 in statutory damages and $25,000 in punitive damages.
Defendants have filed a motion...
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