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Righthaven Copyright Infringement Complaint against Silver Matrix, LLC, et al.

Righthaven Copyright Infringement Complaint against Silver Matrix, LLC, et al.

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Righthaven LLC v. Silver Matrix LLC and Justin Beech , Case No. 10-cv-01281 (Filed July 29, 2010)
Righthaven LLC v. Silver Matrix LLC and Justin Beech , Case No. 10-cv-01281 (Filed July 29, 2010)

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Published by: www.righthavenlawsuits.com on Aug 05, 2010
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09/13/2010

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STEVEN A. GIBSON, ESQ.Nevada Bar No. 6656sgibson@righthaven.com J. CHARLES COONS, ESQ.Nevada Bar No. 10553ccoons@righthaven.com JOSEPH C. CHU, ESQ.Nevada Bar No. 11082 jchu@righthaven.com Righthaven LLC9960 West Cheyenne Avenue, Suite 210Las Vegas, Nevada 89129-7701(702) 527-5900Attorneys for Plaintiff 
UNITED STATES DISTRICT COURTDISTRICT OF NEVADA
RIGHTHAVEN LLC, a Nevada limited-liability company,Plaintiff,v.SILVER MATRIX LLC, a Delaware limitedliability company; and JUSTIN BEECH, anindividual,Defendants.Case No.: 2:10-cv-01281
COMPLAINT AND DEMANDFOR JURY TRIAL
Righthaven LLC (“Righthaven”) c
omplains as follows against Silver Matrix LLC
(“
Silver Matrix
”)
and Justin Beech (
“Mr. Beech”;
collectively with Silver Matrix known hereinas the
“Defendants”)
, on information and belief:
NATURE OF ACTION
1.
 
This is an action for copyright infringement pursuant to 17 U.S.C. § 501.
Case 2:10-cv-01281 Document 1 Filed 07/29/10 Page 1 of 7
 
 
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PARTIES
2.
 
Righthaven is, and has been at all times relevant to this lawsuit, a Nevada limited-liability company with its principal place of business in Nevada.3.
 
Righthaven is, and has been at all times relevant to this lawsuit, in good standingwith the Nevada Secretary of State.4.
 
Silver Matrix is, and has been at all times relevant to this lawsuit, a Delawarelimited liability company.5.
 
Silver Matrix is, and has been at all times relevant to this lawsuit, an owner of the
Internet domain found at <dslreports.com> (the “Domain”), as identified by the content
accessible through the Domain (said content accessible through the Domain known herein as the
“Website”).
 6.
 
Mr. Beech is, and has been at all times relevant to this lawsuit, identified by Mr.
Beech’s LinkedIn page as
an owner and operator of the Domain, evidence of which is attachedhereto as Exhibit 1.7.
 
The Defendants are, and have been at all times relevant to this lawsuit, the self-proclaimed owners of the copyright(s) in the work(s) posted on the Website, as evidenced by a
copyright notice displayed on the Website: “
© 1999-2010 dslreports.com.
 
JURISDICTION
8.
 
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).9.
 
Righthaven is the owner of the copyright in the literary work entitled:
Telecomgroups run out of cash
(the
“Work”), attached hereto as Exhibit
2.10.
 
At all times relevant to this lawsuit, the Work has depicted and depicts theoriginal source publication as the Las Vegas
 Review-Journal
.11.
 
The Defendants willfully copied, on an unauthorized basis, the Work from asource emanating from Nevada.
Case 2:10-cv-01281 Document 1 Filed 07/29/10 Page 2 of 7
 
 
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12.
 
On or about June 16, 2010, the Defendants displayed, and continue to display, anunauthorized reproduction of the Work 
(the “
Infringement
”), attached hereto as Exhibit
3, on theWebsite.13.
 
The subject matter, at least in part, of the Work and the Infringement, is thebankruptcy filings of four Nevada-based telecommunications companies.14.
 
At all times relevant to this lawsuit, the Defendants knew that the Work wasoriginally published in the Las Vegas
 Review-Journal
.15.
 
At all times relevant to this lawsuit, the Defendants knew that the Infringementwas and is of specific interest to Nevada residents.16.
 
The Defendants’ display of the Infringement was and is purposefully directed at
Nevada residents.17.
 
The Defendants knew, or reasonably should have known, that websites, such asthe Website, are and were at all times relevant to this lawsuit, the habitual subject of postings byothers of copyright-infringing content.18.
 
At all times relevant to this lawsuit, the Defendants did not institute any proactivepolicy of precluding or attempting to preclude the posting by others of copyright-infringingcontent on the Website.19.
 
At all times relevant to this lawsuit, the Defendants did not institute any proactivepolicy of monitoring or attempting to monitor the posting by others of copyright-infringingcontent on the Website.20.
 
At all times relevant to this lawsuit, the Defendants did not institute any proactivepolicy of deleting or attempting to delete the posting by others of copyright-infringing content onthe Website.21.
 
At all times relevant to this lawsuit, the Defendants’ failure to institute any
proactive policies intended to address the posting by others of copyright-infringing content onthe Website constituted and constitutes the Defenda
nts’ willful blindness to copyright
infringements occurring on the Website.
Case 2:10-cv-01281 Document 1 Filed 07/29/10 Page 3 of 7

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