S ilberberg &
Plaintiffs Warner Bros. Records Inc., Elektra Entertainment Group Inc.
Atlantic Recording Corporation, Bad Boy Records LLC, Asylum Records LLC,Tommy Boy Music, Inc., Rhino Entertainment Company, WB Music Corp.,Warner-Tamerlane Publishing Corp., Unichappell Music Inc., and W.B.M. Music
Corp., (collectively "Plaintiffs") aver as follows:
Plaintiffs are record companies and music publishing companies
affiliated with Warner Music Group Corp. Collectively, Plaintiffs own and/or
administer some of the most popular sound recordings and musical compositions inthe world, including sound recordings by Madonna, Flo Rida, Gnarls Barkley,Sean Paul, and Red Hot Chili Peppers, and musical compositions written or co-written by Michael Jackson, T.I., Katy Perry, Timbaland, Dr. Dre, and Lil Wayne.
By this action, Plaintiffs seek to put an immediate stop to, and seek redress for,
Defendants' deliberate and brazen exploitation of Plaintiffs' sound recordings andmusical compositions in hundreds of extreme hardcore pornographic videos,
without any consent or authorization from Plaintiffs.
In no uncertain terms, Defendants' are engaged in copyrightinfringement of the most blatant and offensive kind. Defendants own and operate
a network of subscription-based Internet websites that make millions of dollarsfrom performing and distributing to their members (who pay a monthly fee to
watch and download these videos) an ever-growing library of explicitpornographic videos. Defendants also license their videos to satellite television
broadcasters such as Dish Network and DirecTV, which in turn broadcast them to
millions of subscribers. Defendants know that major record labels, recording
artists, and music publishers do not license their works for use in such
Case 2:10-cv-04991-CBM -JEM Document 1 Filed 07/07/10 Page 2 of 44 Page ID #:2