Accordingly, this Court will follow “the majority approach within this jurisdiction,” Urbont, 863 F.Supp.2d at 282, and apply the injury rule to Plaintiff's copyright infringement claim. Thus, Plaintiff's claim of copyright infringement based on acts prior to March 20, 2010—three years prior to the filing of the Complaint—is time-barred. Plaintiff's Complaint may proceed, however, to the extent it alleges a claim for copyright infringement based on alleged acts by Defendants subsequent to March 20, 2010.
Cael Technologies (Pvt.) Ltd. v. Precise Voting, LLC, CV 13-1470, 2014 WL 541933 (E.D.N.Y. Feb. 12, 2014)
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