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STEVEN A. GIBSON, ESQ.Nevada Bar No. 6656sgibson@righthaven.com JODI DONETTA LOWRY, ESQ.Nevada Bar No. 7798 jlowry@righthaven.com J. CHARLES COONS, ESQ.Nevada Bar No. 10553 jcoons@righthaven.com Righthaven LLC9960 West Cheyenne Avenue, Suite 210Las Vegas, Nevada 89129-7701Attorneys for Plaintiff
UNITED STATES DISTRICT COURTDISTRICT OF NEVADA
RIGHTHAVEN LLC, a Nevada limited-liability company,Plaintiff,v.MONEYREIGN, INC., a New Jersey domesticprofit corporation,Defendant.Case No.: 2:10-CV-0350
COMPLAINT AND DEMAND FOR JURYTRIAL
Righthaven LLC (“Righthaven”) complains as follows against
MoneyReign, Inc.(
“
MoneyReign
”
), on information and belief:
NATURE OF ACTION
1.
This is an action for copyright infringement pursuant to 17 U.S.C. §501.
PARTIES
2.
Righthaven is, and has been at all times relevant to this lawsuit, a Nevada limited-liabilitycompany with its principal place of business in Nevada.
Case 2:10-cv-00350-PMP-RJJ Document 1 Filed 03/13/10 Page 1 of 9
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3.
Righthaven is, and has been at all times relevant to this lawsuit, in good standing with theSecretary of State of Nevada.4.
MoneyReign is, and has been at all times relevant to this lawsuit, a New Jersey domesticprofit corporation with its principal place of business in New Jersey.
JURISDICTION
5.
This Court has original subject matter jurisdiction over this copyright infringement actionpursuant to 28 U.S.C. §1331 and §1338(a).6.
This Court has original subject matter jurisdiction over this action pursuant to 28 U.S.C.§1332(a)(1) and §1332(c) because this is a civil action between parties with completediversity of citizenship and the amount in controversy, exclusive of interest and costs,exceeds $75,000.00.7.
MoneyReign purposefully directs activities at Nevada residents, which activities haveresulted in the copyright infringement alleged herein.8.
MoneyReign purposefully directs and effectuates the unauthorized reproduction of Righthaven-owned copyrighted works at www.casinoreign.com
(“MoneyReign‟sWebsite”).
9.
MoneyReign‟s unauthorized reproduction of Righthav
en-owned copyrighted works
found on MoneyReign‟s Website
is purposefully targeted to Nevada residents and toactual and potential visitors to Nevada.10.
MoneyReign copied, on an unauthorized basis, the literary work entitled
“MGM Mirage,
chamber reconcile to battle budget,
”
attached hereto as Exhibit 1
(the “MGM MirageArticle”),
from a source emanating from Nevada.11.
MoneyReign displayed and displays the MGM Mirage Article on
MoneyReign‟s
Website.12.
MoneyReign‟s
display of the MGM Mirage Article was and is purposefully directed atNevada residents.
Case 2:10-cv-00350-PMP-RJJ Document 1 Filed 03/13/10 Page 2 of 9
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13.
MoneyReign copied, on an unauthorized basis, the literary work entitled
“
The Strip:
Icahn lands Las Vegas bargain; what next?”
attached hereto as Exhibit 2
(the “IcahnArticle”),
from a source emanating from Nevada.14.
Mone
yReign displayed and displays the Icahn Article on MoneyReign‟s Website.
15.
MoneyReign‟s display of the Icahn Article was and is purposefully directed at Nevada
residents.16.
MoneyReign copied, on an unauthorized basis, the literary work entitled
“Chi
nese New
Year: Year of the Tiger revelers will find festive scenery, entertainment in Las Vegas,”
attached hereto as Exhibit 3
(the “Chinese New Year Article”),
from a source emanatingfrom Nevada.17.
MoneyReign displayed and displays the Chinese New Year A
rticle on MoneyReign‟s
Website.18.
MoneyReign‟s display of the Chinese New Year Article was and is purposefully directed
at Nevada residents.19.
Mone
yReign copied, on an unauthorized basis, the literary work entitled “
Hawaii gamingbill finds traction but still
a long shot,”
attached hereto as Exhibit 4
(the “HawaiiArticle”),
from a source emanating from Nevada.20.
Mone
yReign displayed and displays the Hawaii Article on MoneyReign‟s Website.
21.
MoneyReign‟s display of the Hawaii Article was and is purposefully directed at Nevada
residents.22.
Mone
yReign copied, on an unauthorized basis, the literary work entitled “Everyone likes
to start New Y
ear here,”
attached hereto as Exhibit 5
(the “Everyone Likes Article”),
from a source emanating from Nevada.23.
Mone
yReign displayed and displays the Everyone Likes Article on MoneyReign‟s
Website.24.
MoneyReign‟s display of the Everyone Likes Article was and is purposefully directed at
Nevada residents.
Case 2:10-cv-00350-PMP-RJJ Document 1 Filed 03/13/10 Page 3 of 9
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Righthaven Copyright Infringement Complaint against MoneyReign, Inc., Case No. 10-cv-00350 (Filed March 13, 2010)
Complaint filed in Righthaven, LLC v. MoneyReign, Inc., Case No. 10-cv-00350 (Filed March 13, 2010)
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