Pro Se Success Rate?

A case filed late last month by a pro se plaintiff in the Southern District of New York for copyright (and patent) infringement against media giant Viacom Int'l and affiliated company VH1 raised OTCS's eyebrows a bit: how successful are pro se plaintiffs in copyright infringement cases?

Professor Patry has noted in his blog the perils (and annoyances) of proceeding pro se, but does anyone have hard numbers? This is potentially an interesting topic for a law review note or article to explore.

[Jincea Butler v. Viacom Int'l.; VH1; Lee Rolantz; Jack Benson; Louis Horvitz; Tim Cohen; filed 1/23/2008; case no. CV-0557]