Victory! Court Enters Default Against Trubow and MMAS Research — Ownership of the Morisky Widget Now Resolved in Favor of Dr. Morisky
April 21, 2026 — Today the United States District Court for the Western District of Washington entered default against Defendants MMAS Research LLC and Steven Trubow in Case No. C21-1301-RSM.
In a clear and decisive ruling (Dkt. #324), the Honorable Ricardo S. Martinez found that Defendants’ long pattern of discovery violations, unpaid sanctions, local-rule violations, and repeated delay tactics left the case unprepared for trial and warranted the severe sanction of default. The Clerk of Court has now been directed to enter default against the Defendants.
What This Means for the Morisky Widget
Because default has been entered, all well-pleaded allegations in Plaintiff Dr. Donald E. Morisky’s complaint are now taken as true. This includes Dr. Morisky’s claims of ownership and control of the Morisky Widget and the underlying MMAS-4 / MMAS-8 intellectual property.
The default judgment phase that follows will formalize the Court’s ruling that:
• Dr. Morisky / MMAR LLC is the rightful owner of the Morisky Widget copyright.
• Any licenses, assignments, or authorizations purportedly granted by Steven Trubow or MMAS Research LLC are unauthorized and without legal effect.
• Use of the Morisky Widget (or any derivative MMAS-8 scoring tool) pursuant to a Trubow-issued license constitutes copyright infringement.
Practical Impact for Licensees and Researchers
Any party that obtained a “Morisky Widget” license from Trubow or MMAS Research is now on notice that those licenses were issued without authority. Continuing to use the Widget under such a license exposes the user to copyright infringement liability.
Dr. Morisky and MMAR LLC remain the sole authorized source for valid, enforceable licenses. All researchers, universities, hospitals, and pharmaceutical companies should immediately confirm the legitimacy of their licensing arrangements directly with MMAR LLC dba adherence at moriskyscale.com.
Next Steps
Plaintiff has been directed to file a motion for default judgment no later than June 5, 2026. In that motion, Dr. Morisky will seek:
• A final judgment confirming ownership of the Morisky Widget copyright.
• An order directing the U.S. Copyright Office to assign the Widget copyright to MMAR LLC.
• Damages (including negative-inference damages for spoliation and statutory damages for willful infringement).
• A permanent injunction and other appropriate relief.
We will provide updates as the default judgment process moves forward.
A Long-Overdue Resolution
This default is the direct result of years of Defendants’ refusal to comply with court orders, pay sanctioned amounts, and litigate in good faith. The Court’s ruling vindicates Dr. Morisky’s position that he never relinquished ownership or control of the Morisky Widget.
We thank the Court for its careful stewardship of this matter and look forward to the final judgment that will bring certainty and clarity to the entire research and clinical community that relies on the Morisky Medication Adherence Scales.
Stay tuned.
Valid licensing and authorized use of the Morisky Widget remain available exclusively through MMAR LLC dba adherence at www.moriskyscale.com.
Donald E. Morisky, PhSc
April 21, 2026 — Today the United States District Court for the Western District of Washington entered default against Defendants MMAS Research LLC and Steven Trubow in Case No. C21-1301-RSM.
In a clear and decisive ruling (Dkt. #324), the Honorable Ricardo S. Martinez found that Defendants’ long pattern of discovery violations, unpaid sanctions, local-rule violations, and repeated delay tactics left the case unprepared for trial and warranted the severe sanction of default. The Clerk of Court has now been directed to enter default against the Defendants.
What This Means for the Morisky Widget
Because default has been entered, all well-pleaded allegations in Plaintiff Dr. Donald E. Morisky’s complaint are now taken as true. This includes Dr. Morisky’s claims of ownership and control of the Morisky Widget and the underlying MMAS-4 / MMAS-8 intellectual property.
The default judgment phase that follows will formalize the Court’s ruling that:
• Dr. Morisky / MMAR LLC is the rightful owner of the Morisky Widget copyright.
• Any licenses, assignments, or authorizations purportedly granted by Steven Trubow or MMAS Research LLC are unauthorized and without legal effect.
• Use of the Morisky Widget (or any derivative MMAS-8 scoring tool) pursuant to a Trubow-issued license constitutes copyright infringement.
Practical Impact for Licensees and Researchers
Any party that obtained a “Morisky Widget” license from Trubow or MMAS Research is now on notice that those licenses were issued without authority. Continuing to use the Widget under such a license exposes the user to copyright infringement liability.
Dr. Morisky and MMAR LLC remain the sole authorized source for valid, enforceable licenses. All researchers, universities, hospitals, and pharmaceutical companies should immediately confirm the legitimacy of their licensing arrangements directly with MMAR LLC dba adherence at moriskyscale.com.
Next Steps
Plaintiff has been directed to file a motion for default judgment no later than June 5, 2026. In that motion, Dr. Morisky will seek:
• A final judgment confirming ownership of the Morisky Widget copyright.
• An order directing the U.S. Copyright Office to assign the Widget copyright to MMAR LLC.
• Damages (including negative-inference damages for spoliation and statutory damages for willful infringement).
• A permanent injunction and other appropriate relief.
We will provide updates as the default judgment process moves forward.
A Long-Overdue Resolution
This default is the direct result of years of Defendants’ refusal to comply with court orders, pay sanctioned amounts, and litigate in good faith. The Court’s ruling vindicates Dr. Morisky’s position that he never relinquished ownership or control of the Morisky Widget.
We thank the Court for its careful stewardship of this matter and look forward to the final judgment that will bring certainty and clarity to the entire research and clinical community that relies on the Morisky Medication Adherence Scales.
Stay tuned.
Valid licensing and authorized use of the Morisky Widget remain available exclusively through MMAR LLC dba adherence at www.moriskyscale.com.
Donald E. Morisky, PhSc
Morisky owns the Morisky Widget copyright. Therefore, MMAS Research lacks standing to assert a claim of copyright infringement. See 3 Nimmer on Copyright § 12.02[B][1]. In any event, because ownership of the copyright is an element of the claim, see Airframe Sys. v. L-3 Communs. Corp., 658 F.3d 100, 105 (1st Cir. 2011), the outcome of the Washington case provides additional grounds for finding the copyright claim would be futile.