IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF OHIO

AMERICAN GLOBAL UNIVERSITY : Case No.:SCHOOL OF MEDICINE :Belmopan / San Pedro Belize : Hon. Judge:U.S. Mailing Address :2602 Oakstone Dr. Suite 6 :

COMPLAINT FOR COPYRIGHT

Columbus, OH 43231 :

INFRINGEMENT AND

INTELLECTUAL PROPERTY

Med Serve International, LLC :

INFRINGEMENT

118 Graceland Blvd. Ste. 311 :Columbus, OH 43214 ::Malik J. Soudah :8065 Reynoldswood Dr. :Reynoldsburg, OH 43068 ::Plaintiffs, ::v. ::RADOSLAW LEWKOWSKI :18 East Old Willow Road :Suite 519 :Prospect Heights, IL 60070 ::American Global University, LLC :5600 N. River Road, Suite 800 :Chicago, IL 60018 ::Defendants. ::

COMPLAINT FOR COPYRIGHT INFRINGEMENT,INTELLECTUAL PROPERTY INFRINGEMENT,DAMAGE TO REPUTATION AND LOSS OF WEBSITE TRAFFIC

Plaintiff American Global University School of Medicine (“AGUSM”) for its complaintagainst defendant Radoslaw Lewkowski (“Lewkowski”) states as follows:

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NATURE OF THE ACTION

This is an action for copyright infringement under 17 U.S.C. § 501, trademark infringement under 15 U.S.C. § 1114 and unfair competition, false designation of origin,infringement and misleading representation of facts arising under 15 U.S.C. §1125(a).

THE PARTIES

AGUSM is a medical school organized under the laws of the Country of Belizeand the State of Ohio. Its principal place of business is located at Manatee Drive, San PedroTown, Ambergris Caye, Belize, C.A., and its U.S. office is located at 118 Graceland Boulevard,Suite 311, Columbus, OH 43214.3.

AGUSM owns and operates its website, agusm.org, and owns all of thetrademarks, website codes, and files associated with it.4.

Lewkowski, upon information and belief, is an individual residing at 18 East OldWillow Road, Prospect Heights, IL 60070.5.

Upon information and belief, Lewkowski knowingly and willfully directed,oversaw and actively engaged in the infringing activities complained of herein.

JURISDICTION AND VENUE

This is an action for copyright infringement under the Copyright Act, 17 U.S.C. §101

et seq

., trademark infringement under 15 U.S.C. § 1114 and unfair competition, falsedesignation of origin, infringement and misleading representation of facts under 15 U.S.C. §1125(a).7.

This court has jurisdiction over this matter under 28 U.S.C. §§ 1132(a), 1331 and1338(a). Venue is proper in this Court under 28 U.S.C. § 1391(b)(2) and/or (3).

BACKGROUND FACTS

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38.

AGUSM is a medical school established under the name “American GlobalUniversity School of Medicine” in Belize.9.

AGUSM has been accredited as such with the Government of Belize’s Ministry of Education. The Government of Belize issued a charter to AGUSM on November 2, 2005, andAGUSM has also been certified in Belize under the Companies Act (CAP 250, Section 17).10.

AGUSM does not have a campus in Netherlands Antilles. American GlobalUniversity (“AGU”), AGUSM’s parent university, does not have authorizing agent who hasleased or taken occupancy of classrooms, offices, dormitories, etc. to facilitate a medical schoolcurriculum in Netherlands Antilles.11.

Malik J. Soudah (“Soudah”) is the president of AGUSM and is one of twomanaging member of Med-Serve International, LLC (“Med-Serve International”). The U.S.Government has issued Med-Serve International an Employer Identification Number (“EIN”) tooperate AGUSM’s U.S. offices in Ohio.12.

Peggy J. Allen (“Allen”) is the Registrar and Director of Admissions andAdministration at AGUSM.13.

Soudah and Allen are the only two persons authorized to sign documentation onbehalf of AGUSM.14.

AGUSM has been issued a listing under the International Medical EducationDirectory (“IMED”), an affiliation that is needed for medical schools to prove accreditation.15.

AGUSM operates its official website atwww.agusm.org.16.

Lewkowski is a former AGU employee.

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