Catalyst Complaint Cover Page

419707

Complaint
Number 419707 Date 10/31/2012 Status Assignee Actual Savings Amount Disputed Estimated Savings Closed Granados, Elena H $0.00 $0.00 $0.00

Location Kennewick - Consumer Protection Division NAICS 541620-Legal Services- All other legal services

Complainant
Name Christopher Vallos 573 Monroe Blvd Painesville, OH 44077 Phone Day (440) 391-0435 Phone Evening Email (440) 391-0435 cvallos@hotmail.com

Respondent(s)
Name McCormack Intellectual Property Law 617 Lee St Seattle, WA 98109 Getty Images 605 5th Ave S Ste 400 Seattle, WA 98104 Contact Phone (206) 381-8888 Toll Free Email legal@mccormackl egal.com

(206) 925-6753

copyright.complianc e@gettyimages.com

Referral(s)
Name Contact Phone Contact Phone Email

Practice(s)
Code 640 Practice Fees

Activities
Date Added 11/2/2012 11/2/2012 Activity Type Email to Respondent Email to Respondent Activity R First Letter to Respondent To: copyright.compliance@gettyimages.com R First Letter to Respondent To: legal@mccormacklegal.com

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Date Added 11/2/2012 11/21/2012 11/21/2012 11/21/2012 11/21/2012 12/3/2012 12/7/2012

Activity Type Email to Complainant Email from Respondent Email to Complainant Email to Respondent Email from Complainant Email from Respondent FAX from Respondent

Activity C First Letter to Consumer To: cvallos@hotmail.com C Response from one Respondent To: cvallos@hotmail.com Rsup Closing No Adjustment (R-UNJ) To: copyright.compliance@gettyimages.com See doc 419707A and B See doc 419707C Fax from secondary R is the same as email sent on 11/19/2012. Therefore, we will not be adding to file as it is a duplicate. Csup Closing Unadjusted (C-UNJ) To: cvallos@hotmail.com Rsup Closing No Adjustment (R-UNJ) To: legal@mccormacklegal.com

12/11/2012 12/11/2012 12/11/2012 12/14/2012

Email to Complainant Email to Respondent Resolution-UNADJUSTED Email from Complainant

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Catalyst Report
Complaint Description
Description I am being harrased by Getty Images who is using Timothy B. McCormack (legal@mccormacklegal.com) as the attorney. Case number 1091514 My website is www.otcpennystockawareness.com and they "claim" I took an image that is represented by them. of a woman holding a tree and displayed this image on my website. They are wanting $1286 as a fee for this. Please help me in this matter. Chris Vallos Expected resolution details: This image is not on my website currently.

ElenaP

11/2/2012

R First Letter to Respondent To: copyright.compliance@gettyimages.com Rob McKenna ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140 November 2, 2012 Getty Images 605 5th Ave S Ste 400 Seattle, WA 98104 RE: Christopher Vallos File #: 419707 Dear Getty Images: Our office has received the enclosed complaint from Christopher Vallos regarding your business. We forward consumer complaints to businesses in order to afford the business an opportunity to respond in writing. Many businesses have found this process to be beneficial. Complaints and responses received in our office are a matter of public record. Our office informally mediates complaints as a service to consumers and businesses. We may not act as an advocate or private attorney for either party. However, complaints may indicate a pattern of unfair or deceptive trade practices warranting further attention by our office. Failure to respond to this complaint will be reflected in our public records, which are available to the public under the Public Records Act. Our office requests you reply in writing within 21 business days so that we may determine how to proceed in this matter. Please address your response to me and include our file number 419707. Thank you for your attention to this matter. ELENA H. GRANADOS CP Public Outreach Specialist Consumer Protection Division (509) 734-7143 Fax: (509) 734-7290 kencrc@atg.wa.gov Enclosure
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COMPLAINT SUMMARY Consumer Information Name: Christopher Vallos Address: 573 Monroe Blvd Painesville, OH 44077 Day Phone: (440) 391-0435 Evening Phone: (440) 391-0435 E-mail Address: cvallos@hotmail.com Age Group (optional): 59+ Do you want the Attorney General's Office to send this business a copy of your complaint Yes Names and addresses of any other complainants involved: Business Information Name of business that I am complaining about: McCormack Intellectual Property Law Address: 617 Lee St Seattle, WA 98109 Phone: (206) 381-8888 Toll-Free: Fax: E-mail:
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legal@mccormacklegal.com Name of owner or manager (if known): Tim McCormack Names and addresses of any other businesses involved in your complaint: Getty Images 605 5th Ave S Ste 400 Seattle, WA 98104 Item or service purchased: Cost of item or service: Did you sign a contract No Date of transaction: Salesperson's name: Was an advertisement involved No Date and source of advertisement: About Your Complaint Have you complained to the business No If YES, to whom (include position) What response did you receive If you have not contacted the business, explain why: Have you filed a complaint about this business with the Attorney General's Office before No If yes, list the file number assigned to that complaint: Have you contacted a private attorney No If YES, identify the name and address of the attorney: Is there a court or other legal proceeding pending 419707

No If YES, please explain: Explain your complaint in detail: I am being harrased by Getty Images who is using Timothy B. McCormack (legal@mccormacklegal.com) as the attorney. Case number 1091514 My website is www.otcpennystockawareness.com and they "claim" I took an image that is represented by them. of a woman holding a tree and displayed this image on my website. They are wanting $1286 as a fee for this. Please help me in this matter. Chris Vallos Expected resolution details: This image is not on my website currently. What do you think the business should do to resolve your complaint - (circle one) Other Explain if you have circled 'Other': SIGNATURE I understand that by submitting this complaint to the Washington State Attorney General's Office my complaint and any response from the business and all communications with Attorney General’s Office will become public records under state law. Public records are subject to public records disclosure requests and as a public record, my complaint and all related documents may be seen by other people. I declare, under penalty of perjury under the laws of the State of Washington, that the information contained in this complaint is true and accurate, and that any documents attached are true and accurate copies of the originals. I understand that the Washington State Attorney General's Office will contact the party(ies) against which I have filed a complaint in an effort to reach an amicable resolution. I authorize the party(ies) against which I have filed a complaint to communicate with and provide information related to my complaint to the Washington State Attorney General's Office. Signature Christopher Vallos Date 10/29/2012 Received via the Internet City and State where signed Painesville, OHIO

419707

ElenaP

11/2/2012

R First Letter to Respondent To: legal@mccormacklegal.com Rob McKenna ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140 November 2, 2012 McCormack Intellectual Property Law 617 Lee St Seattle, WA 98109 RE: Christopher Vallos File #: 419707 Dear McCormack Intellectual Property Law: Our office has received the enclosed complaint from Christopher Vallos regarding your business. We forward consumer complaints to businesses in order to afford the business an opportunity to respond in writing. Many businesses have found this process to be beneficial. Complaints and responses received in our office are a matter of public record. Our office informally mediates complaints as a service to consumers and businesses. We may not act as an advocate or private attorney for either party. However, complaints may indicate a pattern of unfair or deceptive trade practices warranting further attention by our office. Failure to respond to this complaint will be reflected in our public records, which are available to the public under the Public Records Act. Our office requests you reply in writing within 21 business days so that we may determine how to proceed in this matter. Please address your response to me and include our file number 419707. Thank you for your attention to this matter. ELENA H. GRANADOS CP Public Outreach Specialist Consumer Protection Division (509) 734-7143 Fax: (509) 734-7290 kencrc@atg.wa.gov Enclosure
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COMPLAINT SUMMARY Consumer Information Name: Christopher Vallos Address: 573 Monroe Blvd Painesville, OH 44077 Day Phone: (440) 391-0435 Evening Phone: (440) 391-0435 E-mail Address: cvallos@hotmail.com Age Group (optional): 59+ Do you want the Attorney General's Office to send this business a copy of your complaint Yes Names and addresses of any other complainants involved: Business Information Name of business that I am complaining about: McCormack Intellectual Property Law Address: 617 Lee St Seattle, WA 98109 Phone: (206) 381-8888 Toll-Free: Fax: E-mail:
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legal@mccormacklegal.com Name of owner or manager (if known): Tim McCormack Names and addresses of any other businesses involved in your complaint: Getty Images 605 5th Ave S Ste 400 Seattle, WA 98104 Item or service purchased: Cost of item or service: Did you sign a contract No Date of transaction: Salesperson's name: Was an advertisement involved No Date and source of advertisement: About Your Complaint Have you complained to the business No If YES, to whom (include position) What response did you receive If you have not contacted the business, explain why: Have you filed a complaint about this business with the Attorney General's Office before No If yes, list the file number assigned to that complaint: Have you contacted a private attorney No If YES, identify the name and address of the attorney: Is there a court or other legal proceeding pending 419707

No If YES, please explain: Explain your complaint in detail: I am being harrased by Getty Images who is using Timothy B. McCormack (legal@mccormacklegal.com) as the attorney. Case number 1091514 My website is www.otcpennystockawareness.com and they "claim" I took an image that is represented by them. of a woman holding a tree and displayed this image on my website. They are wanting $1286 as a fee for this. Please help me in this matter. Chris Vallos Expected resolution details: This image is not on my website currently. What do you think the business should do to resolve your complaint - (circle one) Other Explain if you have circled 'Other': SIGNATURE I understand that by submitting this complaint to the Washington State Attorney General's Office my complaint and any response from the business and all communications with Attorney General’s Office will become public records under state law. Public records are subject to public records disclosure requests and as a public record, my complaint and all related documents may be seen by other people. I declare, under penalty of perjury under the laws of the State of Washington, that the information contained in this complaint is true and accurate, and that any documents attached are true and accurate copies of the originals. I understand that the Washington State Attorney General's Office will contact the party(ies) against which I have filed a complaint in an effort to reach an amicable resolution. I authorize the party(ies) against which I have filed a complaint to communicate with and provide information related to my complaint to the Washington State Attorney General's Office. Signature Christopher Vallos Date 10/29/2012 Received via the Internet City and State where signed Painesville, OHIO

419707

ElenaP

11/2/2012

C First Letter to Consumer To: cvallos@hotmail.com Rob McKenna ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140 November 2, 2012 Christopher Vallos 573 Monroe Blvd Painesville, OH 44077 RE: McCormack Intellectual Property Law and Getty Images File #: 419707 Dear Christopher Vallos: The complaint you submitted to our office has been assigned to me. I have provided a copy of your complaint to McCormack Intellectual Property Law and Getty Images and requested a response within 21 business days. I will notify you when a response is received regarding your complaint. Our informal mediation service takes approximately 6-8 weeks. Your patience during this process is appreciated. Our office brings lawsuits in the name of the State of Washington, rather than on behalf of private individuals. If a business does not respond or declines to adjust your complaint, this office cannot require it to do so. The Consumer Protection Act does not give us authority to act as your private attorney. Our office obtains valuable information from individual consumer complaints. Your complaint will become part of our public record of business practices. We maintain complaint files of business practices that may be useful if enforcement action on behalf of the State of Washington is warranted in the future. If a response is not received or if your complaint is not resolved, we will inform you of alternatives if you wish to pursue this matter further. If you need to contact me, please have your complaint number available for reference. Thank you for contacting our office. ELENA H. GRANADOS CP Public Outreach Specialist
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Consumer Protection Division (509) 734-7143 Fax: (509) 734-7290 kencrc@atg.wa.gov

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ElenaP

11/21/2012

From: Copyright Compliance [mailto:Copyright.Compliance@gettyimages.com] Sent: Monday, November 19, 2012 1:02 PM To: ATG MI Kennewick CRC Subject: RE: 419707 : A notice from the Washington State Attorney General'sOffice

605 Fifth Avenue South, Suite 400, Seattle, Washington 98104 Tel 206 925 5000 Fax 206 925 5001 www.gettyimages.com November 19, 2012 Elena H. Granados CP Outreach Specialist Attorney General of Washington Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 Via e-mail to kencrc@atg.wa.gov and Fax to (509) 734-7290 Re: Christopher Vallos Your File # 419707 Our File # 1091514 Dear Ms. Granados: We are in receipt of the complaint filed by Christopher Vallos that you forwarded to us on November 2, 2012. We appreciate the opportunity to respond to Mr. Vallos’s concerns. By way of introduction, Getty Images is the leading creator and distributor of still and moving images. More than 4,000 images per day are licensed on our website, www.gettyimages.com, which features wholly-owned content (i.e., images to which we own the copyright), as well as exclusively licensed content (i.e., third-party contributor images which are licensed exclusively through us). Customers such as graphic designers, advertising agencies, and publishers license our imagery for a variety of purposes, including but not limited to print advertising, billboards, newspaper and magazine articles, brochures and websites. Our license information is clearly available from each page of our website, and we do not permit the use of our imagery without a license. Notwithstanding the license requirement, like other digital media companies, Getty Images does fall victim to individuals pirating its intellectual property. To combat this, Getty Images uses both employees and digital image recognition software to locate entities that have used Getty Images’ imagery without paying a license fee. One such entity recently identified as having used unlicensed imagery from our collections is OTC Penny Stock Awareness (“OTC”).
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On July 7, 2011, and again on September 9, 2011, we sent OTC a letter with notification that we had found unauthorized use of one of our images on its website, www.OTCPennyStockAwareness.com. The image is part of Getty Images’ Rights-Managed “Photographer’s Choice” collection, # sb10066918j-001 (the “Image”), and can be found on our web site at http://www.gettyimages.com/detail/sb10066918j-001/Photographers-Choice. We informed OTC that use of the Image without a license constitutes copyright infringement, and that OTC must either: (i) provide evidence that a license was issued, or (ii) pay a fee for use of the Image. In this instance, the fee was $780.00, and we provided an invoice in that amount, which featured a thumbnail of the Image and its image number along with a “screenshot” of the Image on OTC’s website. The amount invoiced is in line with what typically would be charged for a license of the Image under these circumstances. Mr. Vallos states that he has removed the Image from the OTC website. While we appreciate the removal, the Image is protected by copyright, and was previously displayed on that website. Copyright law holds responsible anyone who publicly displays an image without authorization of the copyright holder. Mr. Vallos’s use of the Image without a license constitutes copyright infringement, for which we are entitled to seek damages. At this time, Mr. Vallos has not raised any valid defenses. Getty Images has acted appropriately and in good faith in pursuing the unauthorized use of our intellectual property. Should you require any additional information about this matter, please do not hesitate to contact us. Regards, Getty Images – Copyright Compliance

419707

ElenaP

11/21/2012

C Response from one Respondent To: cvallos@hotmail.com Rob McKenna ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140 November 21, 2012 Christopher Vallos 573 Monroe Blvd Painesville, OH 44077 RE: McCormack Intellectual Property Law and Getty Images File #: 419707 Dear Christopher Vallos: Our office has received a response from Getty Images regarding your complaint. Attached is a copy for your records. When we receive a response from McCormack Intellectual Property Law we will contact you again. If the business response does not resolve the complaint, we will inform you of other alternatives including private legal remedies. ELENA H. GRANADOS CP Public Outreach Specialist Consumer Protection Division (509) 734-7143 Fax: (509) 734-7290 kencrc@atg.wa.gov Enclosure From: Copyright Compliance [mailto:Copyright.Compliance@gettyimages.com] Sent: Monday, November 19, 2012 1:02 PM To: ATG MI Kennewick CRC Subject: RE: 419707 : A notice from the Washington State Attorney General'sOffice

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605 Fifth Avenue South, Suite 400, Seattle, Washington 98104 Tel 206 925 5000 Fax 206 925 5001 www.gettyimages.com November 19, 2012 Elena H. Granados CP Outreach Specialist Attorney General of Washington Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 Via e-mail to kencrc@atg.wa.gov and Fax to (509) 734-7290 Re: Christopher Vallos Your File # 419707 Our File # 1091514 Dear Ms. Granados: We are in receipt of the complaint filed by Christopher Vallos that you forwarded to us on November 2, 2012. We appreciate the opportunity to respond to Mr. Vallos’s concerns. By way of introduction, Getty Images is the leading creator and distributor of still and moving images. More than 4,000 images per day are licensed on our website, www.gettyimages.com, which features wholly-owned content (i.e., images to which we own the copyright), as well as exclusively licensed content (i.e., third-party contributor images which are licensed exclusively through us). Customers such as graphic designers, advertising agencies, and publishers license our imagery for a variety of purposes, including but not limited to print advertising, billboards, newspaper and magazine articles, brochures and websites. Our license information is clearly available from each page of our website, and we do not permit the use of our imagery without a license. Notwithstanding the license requirement, like other digital media companies, Getty Images does fall victim to individuals pirating its intellectual property. To combat this, Getty Images uses both employees and digital image recognition software to locate entities that have used Getty Images’ imagery without paying a license fee. One such entity recently identified as having used unlicensed imagery from our collections is OTC Penny Stock Awareness (“OTC”). On July 7, 2011, and again on September 9, 2011, we sent OTC a letter with notification that we had found unauthorized use of one of our images on its website, www.OTCPennyStockAwareness.com. The image is part of Getty Images’ Rights-Managed “Photographer’s Choice” collection, # sb10066918j-001 (the “Image”), and can be found on our web site at http://www.gettyimages.com/detail/sb10066918j-001/Photographers-Choice. We informed OTC that use of the Image without a license constitutes copyright infringement, and that OTC must either: (i) provide evidence that a license was issued, or (ii) pay a fee for use of the Image. In this instance, the fee was $780.00, and we provided an invoice in that amount,
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which featured a thumbnail of the Image and its image number along with a “screenshot” of the Image on OTC’s website. The amount invoiced is in line with what typically would be charged for a license of the Image under these circumstances. Mr. Vallos states that he has removed the Image from the OTC website. While we appreciate the removal, the Image is protected by copyright, and was previously displayed on that website. Copyright law holds responsible anyone who publicly displays an image without authorization of the copyright holder. Mr. Vallos’s use of the Image without a license constitutes copyright infringement, for which we are entitled to seek damages. At this time, Mr. Vallos has not raised any valid defenses. Getty Images has acted appropriately and in good faith in pursuing the unauthorized use of our intellectual property. Should you require any additional information about this matter, please do not hesitate to contact us. Regards, Getty Images – Copyright Compliance

419707

ElenaP

11/21/2012

Rsup Closing No Adjustment (R-UNJ) To: copyright.compliance@gettyimages.com Rob McKenna ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140 November 21, 2012 Getty Images 605 5th Ave S Ste 400 Seattle, WA 98104 RE: Christopher Vallos File #: 419707 Dear Getty Images: Thank you for your recent communication in response to the complaint from Christopher Vallos. Christopher Vallos has been informed of your response and that we have closed this complaint with regard to our informal mediation service. We have notified the complainant of the availability of private legal remedies in the event the complainant wishes to pursue this matter further. Although this was not resolved to the parties’ mutual satisfaction, we appreciate your response. This complaint will remain in our public records. Please be advised even though we are closing this complaint, we may open a formal investigation or take future action pursuant to the Consumer Protection Act at any time if the facts and circumstances indicate that further action is warranted. ELENA H. GRANADOS CP Public Outreach Specialist Consumer Protection Division (509) 734-7143 Fax: (509) 734-7290 kencrc@atg.wa.gov

419707

ElenaP

11/21/2012

From: Chris Vallos [mailto:cvallos@hotmail.com] Sent: Wednesday, November 21, 2012 9:42 AM To: ATG MI Kennewick CRC Subject: RE: 419707 : A notice from the Washington State Attorney General'sOffice Mr. Mckenna, I also filed a grievance with the WSBA office of Disceplinary Counsel against (Timothy McCormack) the attorney handling the claim with Getty Images. WSBA File no 12-03039 I am attaching the WSBA letter requesting information from Timothy McCormack and Getty Images on this matter. According to the WSBA letter, Mr. McCormack and Getty Images has 30 days from the date the letter was sent (November 1, 2012) The amount that they are demanding ($1286) is ridiculous. Chris Vallos

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ElenaP

12/3/2012

From: Lauren Kingston [mailto:Lauren@McCormackLegal.com] Sent: Thursday, November 29, 2012 10:36 AM To: ATG MI Kennewick CRC Cc: McCormack Legal Subject: RE: 419707 : A notice from the Washington State Attorney General'sOffice Dear Ms. Granados, Attached is our response to the complaint referenced below, your file number 419707. A hard copy will follow by mail. Please contact me if you have any questions. Sincerely, Lauren Kingston Attorney at Law McCormack Intellectual Property Law Business Law PS Mailing Address 617 Lee Street Seattle, WA 98109 Tel: 206-381-8888 Direct: 206-330-0108 Fax: 206-381-1988 Internet Address www.McCormackLegal.com <www.McCormackLegal.com> E: attorney@McCormackLegal.com This e-mail may contain confidential information which is legally privileged. The information is solely for the use of the addressee named above. If you are not the intended recipient, any disclosure, copying, distribution or other use of the contents of this information is strictly prohibited. If you have received this e-mail in error, please notify us by return e-mail and delete this message. Thank you.

419707

ElenaP

12/11/2012

Csup Closing Unadjusted (C-UNJ) To: cvallos@hotmail.com Rob McKenna ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140 December 11, 2012 Christopher Vallos 573 Monroe Blvd Painesville, OH 44077 RE: McCormack Intellectual Property Law and Getty Images File #: 419707 Dear Christopher Vallos: Our office has received a response from McCormack Intellectual Property Law declining to adjust your complaint for the reasons outlined in the response. We realize you may disagree with McCormack Intellectual Property Law and Getty Images’s position. However, our office does not have the legal authority to force the parties to resolve their dispute. We regret that we are unable to provide further assistance to you in this situation. We do not have the legal authority to act as an attorney for private individuals, nor may we act as a judge or arbitrator in individual disputes. If you would like to pursue the matter, you may wish to contact Small Claims Court in your County. General information about Small Claims Court, including contact information, can be found by visiting the following website: https://www.courts.wa.gov/newsinfo/resources/ - fa=newsinfo_jury.scc&altMenu=smal For referrals to attorneys in your area, you may call one of the following numbers: Clark County: 360-695-0599 King County: 206-623-2551 or 211 Lewis County: 360-748-0430 Pierce County: 253-383-3432 Snohomish County: 425-388-3018 Spokane County: http://www.spokanebar.org/ (Telephone number not available) Thurston County: http://thurstoncountybar.com/ (Telephone number not available) If you cannot afford an attorney, and have a non-criminal legal problem, you may qualify for assistance from the NW Justice Project’s CLEAR Coordinated Legal Advice, which can be
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reached Toll Free at 1-888-201-1014 or online at the following website: http://www.nwjustice.org/about_njp/clear.html. In addition, if you are 60 or over, you may call CLEAR SENIOR at 1-888-387-7111 regardless of income. You may also wish to contact the Washington State Dispute Resolution Center nearest you to see if they can assist in mediating your dispute. You can obtain additional information about the Dispute Resolution Centers at these websites: <http://www.courts.wa.gov/court_dir/ - fa=court_dir.dispute> <http://www.resolutionwa.org/>. Please be aware that the Dispute Resolution Centers do not provide attorney referrals or legal advice. We appreciate your bringing this matter to our attention. Your complaint will remain a part of our public record of this firm’s business practices. ELENA H. GRANADOS CP Public Outreach Specialist Consumer Protection Division (509) 734-7143 Fax: (509) 734-7290 kencrc@atg.wa.gov Enclosure

419707

ElenaP

12/11/2012

Rsup Closing No Adjustment (R-UNJ) To: legal@mccormacklegal.com Rob McKenna ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140 December 11, 2012 McCormack Intellectual Property Law 617 Lee St Seattle, WA 98109 RE: Christopher Vallos File #: 419707 Dear McCormack Intellectual Property Law: Thank you for your recent communication in response to the complaint from Christopher Vallos. Christopher Vallos has been informed of your response and that we have closed this complaint with regard to our informal mediation service. We have notified the complainant of the availability of private legal remedies in the event the complainant wishes to pursue this matter further. Although this was not resolved to the parties’ mutual satisfaction, we appreciate your response. This complaint will remain in our public records. Please be advised even though we are closing this complaint, we may open a formal investigation or take future action pursuant to the Consumer Protection Act at any time if the facts and circumstances indicate that further action is warranted. ELENA H. GRANADOS CP Public Outreach Specialist Consumer Protection Division (509) 734-7143 Fax: (509) 734-7290 kencrc@atg.wa.gov

419707

ElenaP

12/14/2012

From: Chris Vallos [mailto:cvallos@hotmail.com] Sent: Tuesday, December 11, 2012 8:37 PM To: ATG MI Kennewick CRC Subject: RE: 419707 : A notice from the Washington State Attorney General'sOffice Mr. McKenna, I am still waiting for Mr. McCormack to respond to the questions from Washington State Bar Association Office of Disciplinary Counsel (WSBA File No. 12-02039) dated November 1, 2012 (see attached letter from WSBA) This issue is being resolved by the Washington State Bar Association. Until Getty Images and/or Mr. McCormack provides detailed answers to the below, I will no longer have communications with Getty Images and/or Mr. McCormack 1. Who is the "author" of the work - Provide a brief description of the work. 2. Who is the original copyright claimant 3. provide proof that Getty is the "author" and copyright claimant in the cited work. If Getty is not the author and original copyright claimant, provide documentation that shows when Getty acquired any exclusive rights in the work, from whom the right were acquired, and whether the rights include the right to enforce alleged copyright violations. 4. Was the work registered - If so, provide proof of any registration from the United States Register of Copyrights. 5. provide the date(s) of Mr. Vallos's alleged infringement of the work. Provide proof that an alleged infringement occurred on that date. If not included above, provide proof that Getty held exclusive right to enforce an infringement claim on the date(s) of the alleged infringement. 6. List any copyright infringement actions you filed for Getty in the last five years' Chris Vallos

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