Mr. Hennen is, and has been at all times relevant to this lawsuit, identified as the
President and CEO of Freedom Force Communications,
as evidenced by content accessiblethrough Mr.
ofile webpage located at the Internet domain <freedomforcesus.com>,attached hereto as Exhibit 1.13.
Mr. Port is, and has been at all times relevant to this lawsuit, identified as a
of the Website, as evidenced by content accessible through
Mr. Port’s Facebook profile
webpage, attached hereto as Exhibit 2.14.
reproduced an unauthorized copy of the photograph entitled: “TSA
Agent performs enhanced pat-
downs” (the “Work”), attached hereto as Exhibit
3, and displayed
said unauthorized copy (the “Infringement”), attached hereto as Exhibit
4, on the Website.
This Court has jurisdiction over the subject matter and the parties under thecopyright laws of the United States, 17 U.S.C. § 101 et seq., as well as jurisdictional provisionsof 28 U.S.C. § 1331 and 28 U.S.C. § 1338(a).16.
Righthaven is the owner of the copyright in and to Work.17.
On or about November 20, 2010, Mr. Port willfully reproduced the Work on anunauthorized basis, from a source emanating from Colorado.18.
On or about November 20, 2010, the Defendants displayed, and continue todisplay, the Infringement on the Website.19.
The composition, at least in part, of the Work and the Infringement, is aTransportation Security Administration Agent performing an enhanced pat-down search in theDenver, Colorado airport.20.
The focal point of the Infringement is Denver, Colorado.21.
The only geographic location that is associated with, and related to, the Work isDenver, Colorado.