This Court has original subject matter jurisdiction over this copyrightinfringement action pursuant to 28 U.S.C. § 1331 and 28 U.S.C. § 1338(a).12.
Righthaven is the owner of the copyright in the literary work entitled:
Slain storeclerk, 77, mourned
the “Work”), attached hereto as Exhibit
At all times relevant to this lawsuit, the Work has depicted and depicts theoriginal source publication as the Las Vegas
The Defendants willfully copied, on an unauthorized basis, the Work from asource emanating from Nevada.15.
On or about May 20, 2010, the Defendants displayed, and continue to display, anunauthorized reproduction of the Work
”), attached hereto as Exhibit
2, on theWebsite.16.
The subject matter, at least in part, of the Work and the Infringement, is themurder of a Las Vegas, Nevada-based convenience store clerk.17.
At all times relevant to this lawsuit, the Defendants knew that the Work wasoriginally published in the Las Vegas
At all times relevant to this lawsuit, the Defendants knew that the Infringementwas and is of specific interest to Nevada residents.19.
The Defendants’ display of the Infringement was and is purposefully directed at
The Defendants willfully copied, on an unauthorized basis, the literary work
entitled: “Man shaken after fatal shooting” (the “Fatal Shooting Article”), attached hereto as
Exhibit 3, from a source emanating from Nevada.21.
On or about January 20, 2010, the Defendants displayed, and continue to display,the Fatal Shooting Article on the Website.22.
The Defendants’ display of the
Fatal Shooting Article was and is purposefullydirected at Nevada residents.
Case 2:10-cv-01200-RLH-RJJ Document 1 Filed 07/20/10 Page 3 of 9