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P. 1
Strick Suit Part 1

Strick Suit Part 1

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Published by SharonWaxman

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Published by: SharonWaxman on Aug 12, 2011
Copyright:Attribution Non-commercial

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03/24/2014

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EDWARDC.GREENBERG
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Edward-C
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(FF
Case
No:Attornevsfor
Plaintiff
DavidStrick
UMTED
STATES
DISTRICT
COTJRT
CENTRAL DISTRICT
OF
CALIFORIYIADAVID
STRICK.
an
individual
vs.
LOS
ANGELES TIMESCOMMLINICATIONS
LLC
dlbl
a
LATIMES.COM:
and
TRIBUNECOMPANY,
a
Di:lawareCorporation
Defendants.
COMPLAINT
JURY
TRIAL DEMANDED
ECF
CASE
COMPLAINT
Case 2:11-cv-04043-CBM -FFM Document 1 Filed 05/11/11 Page 1 of 14 Page ID #:11
 
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Plaintiff,
DAVID
STRICK,
by his
attorneys,alleges
as
follows:
JURISDICTIONANDVENUE
1.
This
is
a
civil
action
forcopyright
infringement.
2.
Jurisdiction
is
conferredupon
thisCourt
by
28
U.S.C.Section
1338.
3.
Venue
in
theCentral
District
ofCalifornia
is properpursuant
to
28
u.s.c.
1400.
PARTIES
4.
At
all
timeshereinaftermentioned,
DavidStrick
was,and
still
is,
a
highly
regarded
professional
photographer,
who
with
respect
to
matters
relevant
herein,
has
done business
inthe
formof
a sole
proprietorship.
5.
Plaintiff
DAVID
STRICK
(hereinafter
"Plaintiff'
oT
"STRICK")
is
an
individual,
residingintheCentral
District
ofCalifornia,
County
of
Los
Angeles,
State
ofCalifornia,actively
engaged
in
the
photography
business
in the
State
of
California
andelsewhere,
anddoes business
underthename
"David
Strick
Photography",
with
offices
located
within
the
Central
District
of
theCounty
of
LosAngeles,
State
of
California.
6.
Defendant
LOSANGELES
TIMES
COMMLTNICATIONS
LLC
(hereinafter
"LA
TIMES"),
is
a
foreign
business
corporation
duly
organized
and
existing
under
the laws
of
the
State
of
Delaware,
and
is
authori
zed
to
do
business
in
California,
with
an
officeto
conduct
business
located
at202
W.
First
Street,
LosAngeles,
California,
90012.
Defendant
LA
TIMES
is
a subsi
di*y
of TRIBTINE
COMPANY,
a
co{poration
duly
organizedand
existing
underthe
lawsof the
State
of
Delaware,
and
is
authorizedto
do
business
inCalifornia,
with
upon
information
and
belief,
an
officeto
conduct
business
located
at202
W. First
Street,
LosAngeles,
California,
90012.
COMPLAINT
Case 2:11-cv-04043-CBM -FFM Document 1 Filed 05/11/11 Page 2 of 14 Page ID #:12
 
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25
262728
7.
Defendant
TRIBLTNE
COMPANY
(hereinafter
"TRIBIINE"),
is
a
foreign
business
corporation
duly
organizedand
existing
under
the lawsof the
State
of Delaware,
and
is
authorizedto
dobusiness
inCalifornia,
with,
upon
information
and
belief,
an
officeto
conduct
business
located
at
202
W.First
Street.
LosAngeles,
California,
900
12.
8.
Plaintiff
is
informed
and
believes,
andbased
thereon
alleges,
that
TRIBLTNE
wholly
owns
and/or
has
a
controlling
interest
in
each
and everyone
of
the
below
listed
publications
and
websites,
and,
that
each
of
the infringements
referenced
hereinbv
TRIBTINE
subsidiaries
werecommitted
under the
control
of
TRIBTINE.
9.
Plaintiff
is
further
informed
and
believes
that
each
of
the namedDefendants
were, in
whole
or inpart,
theagents, employees,
or
representatives
of
each
of
the
other
said Defendants
and
were
acting
within
the course and
scope
of
said agency
or employment,
within
their
expressand
impliedauthority
and
that
each
of the
acts
complained
of
herein were done,
in
whole
orinpart,
on
behalfof,or
for
the
benefit
of,
said Defendants,
andeach act has
been
consented
to
and/or
ratifiedby
said
Defendantby,inter
alia,failure
to
repudiate
any
or
all
of
said
acts.
FACTS
COMMON TO
ALL
CLAIMS
10.
STRICK
is
a
professional photographer
with
many
years
of
experiencewhose
photosinclude
primarily
a
combinationof
business
and
celebrity
portraits
and
Hollywood
documentary
photography
for
clients
including
Time
Magazinq
Fortune,
Sempra
Energy, The
Gap, Paramount Pictures,Premiere
Magazine,
and
the
LA
Times,
as
well
as
countless
other
companies
and
publications.
11.
DAVID
STRICK
does
business
inthe
form
and
styleof
DavidStrick
Photography,
an
unincorporated professional
name
for his
sole
proprietorship.
12.
STRICK
is
the
sole creator
of
and
holds the
copyright
in
the subject
COMPLAINT
Case 2:11-cv-04043-CBM -FFM Document 1 Filed 05/11/11 Page 3 of 14 Page ID #:13

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