12345678910111213141516171819202122232425262728property matters, BuzzFeed has, on information and belief, violated federal law by willfullyinfringing Mavrix copyrights to at least 9 different photographs on BuzzFeed.com.10.
In the marketplace, celebrity photos such as those at issue in this case carrytremendous monetary value. Mavrix procures images of celebrities at a significant cost andlicenses these images to various third parties to create highly sought after feature spreads,among other things, on television, print, and online.11.
Defendants herein have driven massive traffic to BuzzFeed.com—includingmillions of visitors monthly across the United States and California—in part due to thepresence of the sought after and searched-for celebrity images that frame this dispute. Allof this traffic translates into significant ill-gotten commercial advantage and revenuegeneration for Defendants as a direct consequence of their infringing actions.
The Photos Forming the Subject Matter of This Dispute
Mavrix is a prominent celebrity photography agency that licenses itsphotographs on an exclusive and non-exclusive basis to a multitude of top-tier mediaoutlets, including the world’s leading newspapers, television programs, and magazines,such as,
, People and US Weekly.13.
BuzzFeed has reproduced, publicly distributed, and publicly displayedcopyright-protected photographs belonging to Mavrix on numerous occasions via itswebsite without Mavrix’s permission, consent, or license.14.
Despite having no permission, consent, or license to do so, on or around June6, 2011, and other subsequent dates including but not limited to September 28, 2012,BuzzFeed reproduced, publicly distributed, and publicly displayed certain images of superstar singer Katy Perry on a rooftop in Miami belonging to Mavrix (the “Perry RooftopPhotos”). True and correct copies of BuzzFeed’s website demonstrating its unauthorizeduse of these photos is attached hereto as Exhibit 1. Mavrix sought a copyright registrationfor these photos within 90 days of their first publication, and the copyright registration forthese photos is attached hereto as Exhibit 4.15.
Despite having no permission, consent, or license to do so, on or around June
Case 2:12-cv-08715-CAS-RZ Document 1 Filed 10/11/12 Page 3 of 24 Page ID #:6