However, it appears that Zalewski's initial conduct might warrant an award of attorney's fees under the Copyright Act based on other factors. See, e.g., Matthew Bender, 240 F.3d at 126 (“Misconduct before or during litigation can, in appropriate cases, provide the basis for an award of fees.”). The district court may also be able to explain why in its view the first three complaints were so obtuse, abusive, and otherwise different from the Third Amended Complaint that its award is justified. Therefore, we vacate the district court's award of attorney's fees to T.P. and DeRaven and remand for reconsideration of whether an award of attorney's fees is appropriate in light of this order.