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
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.
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
“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.
Case 2:10-cv-01281 Document 1 Filed 07/29/10 Page 2 of 7