JS 44C/SDNY

REV. 4/2014
CIVIL COVER SHEET "t /f I \[ Q
The JS-44 civil cover sheet and the information contained herein neither replaceJLuppledkt the filinjfana service oKJr
pleadings or other papers as required by law, except as providedby local rules of court. This form, approved by the
Judicial Conference of the UnitedStates inSeptember 1974, is required for use of the Clerkof Court for the purpose of
initiating the civil docket sheet.
091
PLAINTIFFS
ARMEN DJERRAHIAN
jot-
YVCEN
OC
DEFENDANTS
WILLIAM LEONARD ROBERTS, II. p*/a RICK ROSS an! RICKY ROZAY; MAYBACH MUSIC GROUP: DEFIAM RECORDINGS,
aUNIVERSAL MUSIC GROUP INC. company; ISLAND RECORDS, aUNIVERSAL MUSIC GROUP. INC coijpany; ATLANTIC
RECORDING CORPORATION, aWARNER MUSIC GROUP company, RICHARD MORALES, JR. p/k/a GUNPLAY; ROBERT
WILLIAMS p/k/a MEEK MILL; TORSTEN STENZEL p/k/a DJ SCREAM; CARLOS SUAREZ p/k/a SPIFF TV
ATTORNEYS (IF KNOWN)
0^
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
Edward C. Greenberg, LLC, 570 Lexington Avenue, 19th Floor, New York,
New York 10022, 212-697-8777
./ v.
ItAY 062014
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OFCAUSE)
(DONOTCITEJURISDICTIONAL STATUTES UNLESSDIVERSITY)
17 U.S.C. 501-505, Copyright Infringement
Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY atany time? NtEJVesQjudge Previously Assigned
Ifyes, was this case Vol. • Invol. • Dismissed. No • Yes • If yes, give date &Case No.
No \x\ Yes • Is THISANINTERNATIONAL ARBITRATIONCASE?
(PLACEAN[x] INONEBOXONLY)
TORTS
NATURE OF SUIT
CONTRACT PERSONAL INJURY
[ ] 310 AIRPLANE
[ ] 315 AIRPLANE PRODUCT
LIABILITY
[ J 320 ASSAULT, LIBEL &
SLANDER
[ ] 330 FEDERAL
EMPLOYERS'
LIABILITY
[ ] 340 MARINE
[ ] 345 MARINE PRODUCT
LIABILITY
[ ] 350 MOTOR VEHICLE
[ ] 355 MOTOR VEHICLE
PRODUCT LIABILITY
( ] 360 OTHER PERSONAL
INJURY
[ ] 362 PERSONAL INJURY -
MED MALPRACTICE
] 110
J120
]130
] 140
INSURANCE
MARINE
MILLER ACT
NEGOTIABLE
INSTRUMENT
RECOVERY OF
OVERPAYMENT &
ENFORCEMENT
OF JUDGMENT
MEDICARE ACT
RECOVERY OF
DEFAULTED
STUDENT LOANS
(EXCL VETERANS)
RECOVERY OF
OVERPAYMENT
OF VETERAN'S
BENEFITS
STOCKHOLDERS
SUITS
OTHER
CONTRACT
CONTRACT
PRODUCT
LIABILITY
FRANCHISE
PERSONAL INJURY FORFEITURE/PENALTY
[ ] 367 HEALTHCARE/
PHARMACEUTICAL PERSONAL , , 625DRUG RELATED
INJURY/PRODUCT LIABILITY l '
[1150
: 1151
:ns2
[ 1163
]160
]190
1195
(]196
REAL PROPERTY
]210
]220
1230
240
245
[ ]290
LAND
CONDEMNATION
FORECLOSURE
RENT LEASE 4
EJECTMENT
TORTS TO LAND
TORT PRODUCT
LIABILITY
ALL OTHER
REAL PROPERTY
ACTIONS UNDER STATUTES
CIVIL RIGHTS
[]440 OTHER CIVIL RIGHTS
(Non-Prisoner)
[ ]441 VOTING
[ ]442 EMPLOYMENT
[ ]443 HOUSING/
ACCOMMODATIONS
[ ]445 AMERICANS WITH
DISABILITIES -
EMPLOYMENT
[ ] 446 AMERICANS WITH
DISABILITIES -OTHER
[ ] 448 EDUCATION
Checkifdemandedincomplaint:
CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
I ] 365 PERSONAL INJURY
PRODUCT LIABILITY
[ ) 368 ASBESTOS PERSONAL
INJURY PRODUCT
LIABILITY
PERSONAL PROPERTY
[ ] 370 OTHER FRAUD
[ ] 371 TRUTH IN LENDING
SEIZURE OF PROPERTY
21 USC 881
[ J690 OTHER
[ ] 380 OTHER PERSONAL
PROPERTY DAMAGE
[ ] 385 PROPERTY DAMAGE
PRODUCT LIABILITY
PRISONER PETITIONS
[ ]463 ALIEN DETAINEE
[ ]510 MOTIONS TO
VACATE SENTENCE
28 USC 2255
[ ] 530 HABEAS CORPUS
[ J535 DEATH PENALTY
[ ] 540 MANDAMUS &OTHER
LABOR
[ ] 710 FAIR LABOR
STANDARDS ACT
[ ] 720 LABOR/MGMT
RELATIONS
[ ]740 RAILWAY LABOR ACT
[ 1 751 FAMILY MEDICAL
LEAVE ACT (FMLA)
[ ] 790 OTHER LABOR
LITIGATION
[ ] 791 EMPL RET INC
SECURITY ACT
IMMIGRATION
[ ]462 NATURALIZATION
APPLICATION
[ ] 465 OTHER IMMIGRATION
ACTIONS
PRISONER CML RIGHTS
[ I 550 CIVIL RIGHTS
[ ] 555 PRISON CONDITION
[ ] 560 CML DETAINEE
CONDITIONS OF CONFINEMENT
ACTIONS UNDER STATUTES
BANKRUPTCY OTHER STATUTES
I 1375 FALSE CLAIMS
(1400 STATE ( ]422 APPEAL
28 USC 158 REAPPORTIONMENT
[ ]423 WITHDRAWAL [ ]410 ANTITRUST
28 USC 157 [ ]430 BANKS & BANKING
[ ]450 COMMERCE
[ ]460 DEPORTATION
PROPERTY RIGHTS [ ]470 RACKETEER INFLU
ENCED & CORRUPT
M 820 COPYRIGHTS ORGANIZATION ACT
[ ] 830 PATENT (RICO)
[ ] 840 TRADEMARK [ ) 480 CONSUMER CREDIT
[ ]490 CABLE/SATELLITE TV
SOCIAL SECURITY I ] 850 SECURITIES/
COMMODITIES/
[ ]861HIA(1395ff) EXCHANGE
[ ] 862 BLACK LUNG (923)
[ ] 863 DIWC/DIWW (405(g))
[ ] 864 SSID TITLE XVI
[ ]865 RSI (405(g)) [ ] 890 OTHER STATUTORY
ACTIONS
[ ] 891 AGRICULTURAL ACTS
FEDERAL TAX SUITS
[ ]870 TAXES (U.S. Plaintiff or
Defendant)
[ ) 871 IRS-THIRD PARTY
26 USC 7609
[ ] 893 ENVIRONMENTAL
MATTERS
[ ] 895 FREEDOM OF
INFORMATION ACT
[ ] 896 ARBITRATION
[ ] 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR
APPEAL OF AGENCY DECISION
[ ]950 CONSTITUTIONALITY OF
STATE STATUTES

DEMAND $_ OTHER
iJPgQ0^LCL^M THIS CASE IS RELATED TO ACIVIL CASE NOW PENDING IN S.D.N.Y.?
JUDGE DOCKETNUMBER
Check YES onlyifdemandedincomplaint
JURY DEMAND: S YES CjNO
NOTE: You must also submit at the timeoffiling the Statement of Relatedness form (Form IH-32).
(PLACEAN x INONEBOXONLY) ORIGIN
H1 Original • 2 Removed from • 3 Remanded • 4 Reinstated or Q 5 Transferred from Q6 Multidistrict Q 7Appeal to District
Proceeding stateCourt from Opened (Specify District) Litigaton iJ^Ejudge
Q a. all parties represented Appellate Judgment
I | b. Atleast one
party is pro se.
(PLACEAN x INONEBOXONLY) BASIS OF JURISDICTION
• 1 U.S. PLAINTIFF • 2 U.S. DEFENDANT • 3 FEDERAL QUESTION Q4 DIVERSITY
(U.S. NOT A PARTY)
IFDIVERSITY, INDICATE
CITIZENSHIP BELOW.
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITYCASES ONLY)
(Place an [X] inone box for Plaintiff andone box for Defendant)
PTF DEF
CITIZEN OFTHIS STATE [ ] 1 [ ] 1 CITIZEN OR SUBJECT OFA
FOREIGN COUNTRY
PTF DEF PTF DEF
[ ]3 [ ]3 INCORPORATED and PRINCIPAL PLACE [ ]5 [ ]5
OF BUSINESS IN ANOTHER STATE
CITIZEN OFANOTHER STATE []2 []2 INCORPORATED or PRINCIPAL PLACE []4[]4 FOREIGN NATION
OF BUSINESS IN THIS STATE
PLAINTIFF(S)ADDRESS(ES) AND COUNTY(IES)
ARMEN DJERRAHIAN, 164 Russell Street, Brooklyn, NY 11222
_DEFENDANT(S) ADDRESS(ES) ANDCOUNTY(IES)
[]6 []6
WILLIAMLEONARDROBERTS, II, p/k/a RICK ROSS and RICKYROZAY, 10398 Laurel Rd, Davie, FL 33328, Broward County;
MAYBACH MUSIC GROUP, 10398 Laurel Rd, Davie, FL 33328, Broward County;
DEF JAM RECORDINGS, a UNIVERSAL MUSIC GROUP INC. Company, 150 Fifth Avenue, New York, New York 10011, New York County;
ISLANDRECORDS, a UNIVERSAL MUSICGROUP, INC. Company, 150 Fifth Avenue, New York, New York 10011, New York County;
ATLANTIC RECORDING CORPORATION, a WARNER MUSIC GROUP CORP. Company, 75Rockefeller Plaza, 31st Floor, NewYork, NY
10019, New York County
DEFENDANT(S) ADDRESS UNKNOWN
REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
RE9IBENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
RICHARD MORALES, JR. p/k/a GUNPLAY
ROBERT WILLIAMS, p/k/a MEEK MILL
TORSTEN STENZEL p/k/a DJ SCREAM
CARLOS SUAREZ p/k/a SPIFF TV
Check one: THIS ACTION SHOULD BEASSIGNED TO: Q WHITE PLAINS [x] MANHATTAN
(DONOT check either box if this a PRISONER PETITION/PRISONERCIVIL RIGHTS
COMPLAINT.)
DATE 5/6/14 ^NATURE OFATTORNEYJ3£*ECORD ADMITTED TOPRACTICE IN THISDISTRICT
[] NO
M YES (DATE ADMITTED Mo. 10 Yr. 1982 )
RECEIPT #y^^7 // / ^sy _ Attorney Bar Code # EG 5553
Maj
Magistrate Judge
Ruby J. Krajick, Clerk of Court by. . Deputy Clerk, DATED.
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
Clear Form Save
is so Designated.
Print
H^jp
EdwardC. Greenberg, Esq. (ECG5553)
Tamara L. Lannin, Esq. (TL 3784)
EDWARD C. GREENBERG, LLC
570 Lexington Ave., 19th Floor
New York, NY 10022
Tel: (212) 697-8777
Fax:(212)697-2528
Attorneysfor Plaintiff
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ARMEN DJERRAHIAN,
JUDGE OETKBMntiff,
- against -
WILLIAM LEONARD ROBERTS, II, p/k/a RICK
ROSS and RICKY ROZAY; MAYBACH MUSIC
GROUP; DEF JAM RECORDINGS a UNIVERSAL
MUSIC GROUP INC. Company; ISLAND
RECORDS, a UNIVERSAL MUSIC GROUP, INC.
Company; ATLANTIC RECORDING
CORPORATION, a WARNER MUSIC GROUP
Company; RICHARD MORALES, JR. p/k/a
GUNPLAY; ROBERT WILLIAMS p/k/a MEEK
MILL; TORSTEN STENZEL p/k/a DJ SCREAM;
CARLOS SUAREZ p/k/a SPIFF TV,
Defendants.
14 CV
COMPLAINT
ECF CASE
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Plaintiff, ARMENDJERRAHIAN, by his attorneys, EDWARDC. GREENBERG, LLC,
alleges as follows:
PARTIES
1. At all times hereinafter mentioned, ARMEN DJERRAHIAN was, and still is, a noted
and respected professional photographer, who with respect to matters relevant herein, has done
business in the form of a sole proprietorship.
2. Plaintiff ARMEN DJERRAHIAN (hereinafter "Plaintiff or "DJERRAHIAN") is an
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individual citizen ofFrance, who is actively engaged in the photography business in the State of
NewYork andelsewhere, andwho resides in Brooklyn, NewYork 11222.
3. Defendant WILLIAM LEONARD ROBERTS, II (hereinafter "ROSS") is an
individual, who upon information and belief resides in Davie, Florida, and who is aworld
renowned musical performer who does business under the names of"Ricky Rozay", "Rick Ross",
and "Rick Ro$$". That upon information and belief, ROSS works under contract for defendant
DEF JAM RECORDINGS. That ROSS is thefounder, CEO, and creator of therecord label
MAYBACH MUSIC GROUP.
4. Defendant MAYBACH MUSIC GROUP (hereinafter "MMG") is a recordlabel
imprint, founded by ROSS, which was has been distributed by DEF JAM RECORDINGS, Warner
Brothers Records, and ATLANTIC RECORDING CORPORATION. Upon information and
belief, MMG isbased inthe Miami suburb ofDavie, Florida. Upon information and belief, MMG
is an unincorporated business entity.
5. Defendant DEF JAM RECORDINGS (hereinafter "DEFJAM"), is uponinformation
and belief a Delaware Corporation, that regularly conducts business and has anoffice intheState,
City and County ofNew York, with an office at 150 Fifth Ave., New York, NY 10011, and which
is a subsidiary of Universal Music Group Inc. That upon information and belief DEF JAM
RECORDINGS was formerly part of theUniversal Music Group Inc. subsidiary Island DefJam
Music Group.
6. Defendant ISLANDRECORDS (hereinafter "ISLAND"), is upon informationand
belief a Delaware Corporation, that regularly conducts business and has anoffice inthe State, City
and County ofNew York, with anoffice at 150 Fifth Ave., New York, NY 10011, and which isa
subsidiary of Universal Music Group Inc. That upon information and belief ISLAND RECORDS
was formerly part of theUniversal Music Group Inc. subsidiary Island Def JamMusic Group.
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7. That upon information and belief, Universal Music Group Inc. previously had an
affiliate and/or subsidiary group entitled "Island Def Jam Music Group", which was comprised of
both ISLAND RECORDS and DEF JAM RECORDINGS. That upon information and belief, in
April 2014, Universal Music Group, Inc. announced that it would be breaking up the "Island Def
Jam Music Group Inc." such that ISLAND RECORDS and DEF JAM RECORDINGS could be
two separate entities. Defendants DEF JAM. and ISLAND (hereinafter "ISLAND DEF JAM")
appear to be inextricably intertwined to make it difficult to determine when one is acting as DEF
JAM or ISLAND such that for the purposes of this Complaint, they will both bereferred toas
"ISLAND DEF JAM.
8. Defendant ATLANTIC RECORDING CORPORATION, is uponinformation and
belief aDelaware Corporation, that regularly does business and has an office in the State, City and
County ofNew York, with an office at 75 Rockefeller Plaza, 31st FL, New York, NY 10019, and
which is a subsidiary of Warner Music Group.
9. Defendant RICHARD MORALES, JR. (hereinafter "GUNPLAY") is an individual,
who upon information and belief resides in Miami, Florida, and who isaperformer who does
business under thename of "Gunplay". That upon information and beliefGUNPLAY works under
contract for defendant DEF JAM, which serves as his agent.
10. Defendant ROBERT WILLIAMS (hereinafter "MEEKMILL") is an individual, who
upon information and belief resides Philadelphia, Pennsylvania, and who isaperformer who does
business under the name of "Meek Mill". That, upon information and belief, MeekMill works
under contract for ATLANTIC, which serves as his agent.
11. Defendant TORSTEN STENZEL (hereinafter "DJ SCREAM") is an individual, who
upon information and belief resides Atlanta, Georgia and who isaperformer who does business
under the name of DJ SCREAM.
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12. CARLOS SUAREZ (hereinafter "SPIFF") is an individual, who upon information and
belief resides in the City and State ofNew York, and who is an artist who does business under the
name ofSPIFF TV. Upon information and belief, SPIFF is amember ofand/or works for MMG
and/or ROSS.
13. All individual defendants regularly employ pseudonyms inconnection with their
music, branding of their personae andrelated business endeavors.
JURISDICTION AND VENUE
14. This is a civil action for copyright infringement.
15. Jurisdiction is conferred uponthis Court by 28 U.S.C. Section 1338.
16. Venue in the Southern District of NewYorkis properpursuant to 28 U.S.C. 1400.
FACTS COMMON TO ALL CLAIMS
17. That Plaintiff DJERRAHIAN is a successful professional photographer with many
years of experience and a considerable reputation.
18. DJERRAHIAN is well known in the hiphopmusic business, as he has worked with
major artists including Jay-Z, Usher, 50 Cent, Eminem, Kanye West, Rick Ross and director Spike
Lee. DJERRAHIAN's work has been featured on the covers of several issues of Vibe Magazine,
and onThe Wild Magazine, XXL Magazine, and numerous international publications.
19. DJERRAHIAN has also shot and directed music videos and commercials, including a
music video featuring R&B recording artist Melanie Fiona, which received a nomination for [Best]
"Video of the Year" at the 2010 BET Awards.
20. DJERRAHIAN is also a successful fashionphotographer who has shot photos for
Shinola, Cazal Eyewear, Nike, Fila, Reebok, Marc Ecko, and commercials for Elle Magazine,
Revlon, Van Cleef & Arpels, and Piaget.
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THE IMAGES
21. On May 17, 2010, DJERRAHIAN shot images of ROSS for XXL Magazine, which
were published in the July/August 2010 issue of XXL Magazine (a copy of such images are
annexed hereto as Exhibit "A". DJERRAHIAN submitted an application for the registration of
such images with the United States Copyright Office on April 4, 2014 (registration pending, case #
1-1338622681).
22. On June 27, 2012, DJERRAHIAN shot images ofROSS and other members of
MAYBACH MUSIC GROUP, GUNPLAY, MEEK MILL, Omarion, Stalley, and Wale. Aportion
ofsuch images were published in the August/September 2012 issue ofVibe Magazine (said images
published in Vibe Magazine are annexed hereto as Exhibit "B").
23. DJERRAHIAN granted alimited license to VIBE Magazine to use his images on the
cover and inthe contents ofthe August/September 2012 issue ofVibe Magazine, only. No other
rights were granted by plaintiff. Vibe is not a defendant herein.
24. DJERRAHIAN duly registered such images with the United States Copyright Office
on December 25, 2013, Registration No. VA 1-899-797 (acopy ofsaid registration isincluded
within Exhibit "B" hereto).
25. DJERRAHIAN further registered the other images shot of MMG members, ROSS,
GUNPLAY, MEEK MILL, Omarion, Stalley, and Wale, which were not published inVibe
Magazine, with the United States Copyright Office, Registration No. VAu 1-160-975 (a copy of
said images and the corresponding registration are annexed hereto as Exhibit "C".
26. Each of the images included within Exhibits "A", "B" and "C"hereto shall hereinafter
be referred to individually andcollectively as applicable as the 'Tmage(s)".
27. MMG is a record label imprint, which was founded bytherapper and mogul ROSS.
28. MMGis home to artists such as ROSS, Omarion, Wale, Stalley, MEEKMILL, and
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GUNPLAY.
29. MMG has released at least six solo and two compilation albums, including three
certified Gold albums. MMG is, upon information and belief, based in the State ofFlorida, but
regularly does business inthe State ofNew York.
30. ROSS has sold millions ofalbums and has had at least five (5) albums reach #1 on the
Billboard music charts.
31. Defendants or one or more of them, have employed one or more of the Image(s) onat
least tour posters, tour promotional advertisements, internet banners, advertisements, mixtape
covers, promotional materials, album/cd covers, as well as on various Internet websites including
MMG's website, Twitter page, Facebook page, and other websites.
32. Defendants, or one or more ofthem, have utilized the Images in wide spread marketing
to promote MMG and its members, including but not limited to Gunplay, Ross, and Meek Mill.
33. That Plaintiffs images ofMMG and its members were/are valuable to the Defendants,
or one or more of them.
34. That plaintiffs Image(s) ofMMG and its members creatively capture the personalities
of members of MMG.
35. The images ofGUNPLAY in particular are upon information and belief, the definitive
images ofhim and have been used in numerous promotional materials for GUNPLAY and on the
cover of at least five mixtapes.
36. That MMG and the Images of same are important elements of hiphopmusic culture.
That various blogs referring toMMG feature at least one ofthe Image(s) created by
DJERRAHIAN.
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THE OFFENDING USES OF THE IMAGES
Tour Advertisements
37. Defendants, or one or more of them, have utilized at least two ("2") of plaintiffs
Images invarious advertisements for an MMG tour (copies ofa sampling of such various
advertisements, as described hereinbelow, are annexed hereto as Exhibit "D", hereinafter the
"TOURAD(S)").
38. The TOUR ADS have been published in various media, including but not limited to as
internet posters and image files, internet website banners, physical print posters, and ininternet
promotional videos.
39. Said TOUR AD(S) includes plaintiffs photographs of MEEK MILL, andWale (see
Exhibit "B"), without plaintiffs license, authorizationor consent.
40. TheTOUR AD(S) employs two("2") separate images of plaintiffs (see Exhibit "B"
hereto), and is anunauthorized derivative work of such two ("2") of plaintiffs images.
41. The TOUR AD(S) includes text at the topof the page which states "TheUntouchable
Maybach Music Empire Presents" and then belowplaintiffs images of MEEK MILL, ROSS, and
Wale, states "THEMMGTOURFEATURING MEEKMILL, RICKRO$$ Wale".
42. Different versions of the TOURAD(S) were posted by or at the direction or control of
defendants, or one or more of them, on MMG's Facebookpage on its "timeline".
43. The TOURAD(S) was posted by or at the direction or control of defendants, or one or
more of them, on MMG's Facebook page as one of its "Profile Pictures".
44. The TOURAD(S) were postedby or at the directionor control of defendants, or one or
more of them, on DJ Scream's Facebook and Twitter pages, including in his FacebookTimeline.
45. That, upon informationand belief, DJ Screamis the "official DJ" of MMG.
46. One version of the TOUR ADS includes the website and twitter handle for ROSS, to
wit, www.rozavraw.com, and @rickyrozay. Said version of the TOUR ADS further includes logos
for the following: MMG, Def Jam Recordings, Warner Brothers, DatPiff, Ciroc, and others.
47. Upon information and belief, one or more versions ofthe TOUR AD(S) were
distributed by defendants, or one or more ofthem, to third parties to be displayed by same.
48. The TOUR AD(S) were published, displayed, and disseminated, by or atthe direction
orcontrol ofdefendants, orone ormore ofthem, on MMG's YouTube page inseveral different
videos promoting the MMG tour and the purchase oftickets through LiveNation.com.
49. That the YouTube videos promoting the MMG tour also include another ofPlaintiffs
Images ofWale, ROSS, and MEEK MILL (a copy ofsaid image is annexed hereto as Exhibit
"E", hereinafterthe "SECONDTOUR AD").
50. The SECOND TOUR AD hasbeen published, displayed, and disseminated, byor at
thedirection or control of defendants, or one or more of them, onMMG'sYouTube page in
several different videos promoting the MMG tour and the purchase oftickets through
LiveNation.com.
51. Upon information and belief, both the TOUR AD(S) and the SECOND TOUR AD
were distributed by or atthe direction or control ofdefendants, or one ormore ofthem, to third
parties to display, distribute, and/or disseminate, so as to maximize the publicity for the tour.
2013 Takeover
52. Defendants, orone or more of them, have utilized at least twelve ("12") of plaintiffs
Images in various advertisements for MMG's mixtape entitled "Takeover" (copies ofasampling
of suchvarious advertisements, as described hereinbelow, are annexed heretoas Exhibit "F",
hereinafter the "TAKOVER AD(S)").
53. TheTAKEOVER ADS have beenpublished in various media, including but not
limited toas internet posters and image files, physical print posters, mixtape cover(s) and in
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internet videos.
54. Said TAKEOVER AD(S) includes plaintiffs photographs ofOmarion, MEEK MILL,
ROSS, Staley, Wale and Gunplay (see Exhibit "C", specifically "Staley_021", "Omarion_001",
"Meek Mil_038", "Rick_033", "Wale_016", "Gunplay_018", "Omarion_212", "Meek Mil_278",
"Rick_081", "Stalley__086", "Wale_026", and "Gunplay_108"), without plaintiffs license,
authorization or consent.
55. The TAKEOVER AD(S) employ twelve ("12") separate images ofplaintiffs, and is an
unauthorized derivative workof suchtwelve ("12") of plaintiff s images.
56. At the bottom ofat least one ofthe versions ofthe TAKEOVER AD(S) states a credit
in print to each of the following: MAYBACH MUSIC GROUP, RICK ROSS, MEEK MILL,
WALE, OMARION, STALLEY, GUNPLAY, DEF JAM RECORDINGS, and ATLANTIC
RECORDS, among others.
57. That at the bottom of at least one of theversions of theTAKEOVER AD(S) includes
the logos for ATLANTIC, MMG and DEF JAM RECORDINGS.
58. Different versions of the TAKEOVER AD(S) were postedby or at the direction or
control of defendants, or oneor more of them, onMMG's Instagram andFacebook pages.
59. Different versions of the TAKEOVER AD(S) werepostedby or at the direction or
control of defendants, or one or more of them, on MMG's Twitter account.
60. The TAKEOVER AD(S), aspublished ina video asdisplayed onMMG's Facebook
Page, by, or at the direction or control ofdefendants, or one or more ofthem, with alink to
MMG's page at soundcloud.com.
61. The TAKEOVER AD(S), were published by, or at the direction or control of
defendants, or one or more of them on ROSS' website www.rozayraw.com.
62. Upon information and belief, one ormore versions ofthe TAKEOVER AD(S) were
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distributed by defendants, or one or more of them, to third parties to be displayed by same.
63. The TAKEOVER AD(S) have been used by defendants, orone ormore ofthem, as
cover for several mixtape songs, including but not limited to "Ball Freestyle (ft. Gunplay)", "Ball
Freestyle", "Ball", "Ball (Remix) Ft. Gunplay", "Ball (Remix").
Gunplay Acquitted
64. Defendants, or one or more ofthem, have utilized one ("1") ofplaintiffs Images of
GUNPLAY invarious advertisements for GUNPLAY'S mixtape entitled "Acquitted"(copies ofa
sampling of such various advertisements, as described hereinbelow, are annexed hereto as Exhibit
"G", hereinafter the "ACQUITTED AD(S)").
65. The ACQUITTED ADS have been published invarious media, including but not
limited to as internet posters and image files, internet background image, mixtape cover and
mixtape backside.
66. Said ACQUITTED AD(S) includes plaintiffs photograph ofGUNPLAY (see Exhibit
"C", specifically "Gunplay_108"), without plaintiffs license, authorization orconsent.
67. The ACQUITTED AD(S) employ plaintiffs image of GUNPLAY edited and
"photoshopped" in such amanner as to create an unauthorized derivative work ofplaintiffs Image.
68. In the foreground ofthe ACQUITTED ADS are several microphones, on which are the
logos for MMG, and ISLAND DEF JAM, among others.
69. The backside tothe Mixtape (an ACQUITTED AD) includes plaintiffs Image, and
logos for MMG, andISLAND DEF JAM, among others.
70. The backside totheMixtape (an ACQUITTED AD) further includes a credit for the
"artwork" to "Kideight.com".
71. The ACQUITTED AD was published by, or under the direction or control of
GUNPLAY on his Facebook page as the "Cover Photo".
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72. Different versions ofthe ACQUITTED AD(S) were published by, or under the
direction orcontrol of GUNPLAY onhis Facebook page inhis timeline.
73. Upon information and belief, the ACQUITTED ADS were published by, or under the
direction or control ofGUNPLAY and/or ROSS on the Twitter page for "gunplaymmg".
74. The Twitter page for "gunplaymmg" lists ROSS' website www.rozavraw.com instead
of Gunplay's website ofwww.gunplayallday.com.
75. Upon information and belief, one or more versions of the ACQUITTED AD(S) were
distributed by defendants, or one or more ofthem, to third parties to be displayed by same.
76. That Gunplay's mixtape "Acquitted" has been reported by an authoritative music
magazine, Spin Magazine, as one ofthe "40 Best Hip-Hop Albums of2013".
Group Photo AdolfSniffler
77. Defendants, orone or more ofthem, have utilized one ("1") ofplaintiffs Images ofa
group photo of MMG members Wale, MEEK MILL, ROSS, Stalley, Omarion and GUNPLAY at
least at the top ofthe twitter page for @gunplaymmg (a copy ofsuch offending use is annexed
hereto as Exhibit "H", hereinafter the "GROUP PHOTO").
78. Plaintiffcreated the GROUP PHOTO (see Exhibit "C", specifically "MMG09").
79. Upon information and belief, the GROUP PHOTO was published by, or under the
direction or control of GUNPLAY and/orROSS on the Twitter page for "gunplaymmg".
80. Upon information and belief, the GROUP PHOTO has been distributed by defendants,
or one or more of them, to third parties to be displayed by same.
Gunplay Sunshine State ofMind
81. Defendants, or one or more of them, have utilized one ("1") of plaintiffs Images of
GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled"Gunshine State of
Mind"(copies ofasampling ofsuch various advertisements, as described hereinbelow, are annexed
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hereto asExhibit "I", hereinafter the "GUNSHINE AD(S)").
82. The GUNSHINE ADS have been published in various media, including but not limited
to asinternet posters, image files, and as a mixtape cover.
83. Said GUNSHINE AD(S) includes plaintiffs photograph ofGUNPLAY (see Exhibit
"B"), without plaintiffs license, authorization orconsent.
84. The GUNSHINE AD(S) employ plaintiffs image ofGUNPLAY edited and
"photoshopped" in such amanner as to create an unauthorized derivative work of plaintiffsImage.
85. The color ofthe jacket worn by GUNPLAY in the GUNSHINE AD(S) has been color
edited from the original version (compare Exhibit "I" with "B").
86. The background ofPlaintiffsImage ofGUNPLAY in the GUNSHINE AD(S) has
been modified toinclude the image ofthe front of a car and the entrance toa theatre.
87. Upon information and belief, the GUNSHINE AD(S) were published by, or under the
direction or control of GUNPLAY.
88. Upon information and belief, one or more versions ofthe GUNPLAY AD(S) were
distributed by defendants, or one or more ofthem, to third parties to be displayed by same.
Gunplay Coast 2 Coast
89. Defendants, or one ormore ofthem, have utilized one ("1") ofplaintiffs Images of
GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled "Coast 2 Coast Volume
247"(copies ofasampling ofsuch various advertisements, as described hereinbelow, are annexed
hereto as Exhibit "J", hereinafter the "COAST 2 COAST AD(S)").
90. TheCOAST 2 COAST ADS have beenpublished in various media, including but not
limited to as internet posters, imagefiles, and as a mixtapecover.
91. Said COAST 2 COAST AD(S) includes plaintiffs photograph of GUNPLAY (see
Exhibit "C", specifically "Gunplay_108"), without plaintiffs license, authorization or consent.
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92. The COAST 2COAST AD(S) employ plaintiffs image ofGUNPLAY edited and
"photoshopped" in such amanner as to create an unauthorized derivative work of plaintiffsImage.
93. The foreground ofPlaintiffsImage ofGUNPLAY in the COAST 2COAST AD(S)
has been modified to include $100 dollar bills and the pouring ofwhat looks like awhite
substance.
94. Upon information and belief, the COAST 2COAST AD(S) were published by, or
under the direction or control of GUNPLAY.
95. Upon information and belief, one or more versions ofthe COAST 2COAST AD(S)
were distributed by defendants, or one or more ofthem, to third parties to be displayed by same.
Gunplay Photoshopped with MMG in Background
96. Upon information and belief, defendants, or one or more ofthem, have employed an
edited version ofone ("1") ofplaintiffs Images ofGUNPLAY (acopy ofsuch an edited version
with part ofthe MMG logo edited into the background is annexed hereto as Exhibit "K",
hereinafter the "LOGO AD").
97. The LOGO ADis an unauthorized derivative work of Plaintiffs Image of Gunplay
(Exhibit "C", specifically "GunPlay_108").
98. Upon information and belief, the LOGO AD was published by, orunder the direction
or control of GUNPLAY.
99. Upon information and belief, the LOGO AD has been distributed by defendants, orone
or more of them, to third parties to be displayed by same.
Plaintiffs Unedited Image of Gunplay
100. Upon information and belief, GUNPLAY, ROSS, and/or persons oneither
of their behalf, direction or control, have distributed and/or published Plaintiffs Image of Gunplay
(see Exhibit "B").
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101. Upon information and belief, DEF JAM published said image of
GUNPLAY (see Exhibit "B") on the DEF JAM website, www.defiam.com, as the primary image
for GUNPLAY (a copies ofsuch offending use(s) are annexed hereto as Exhibit "L").
Gunplay Unscripted Freestvles
102. Defendants, or one or more ofthem, have utilized one ("1") ofplaintiffs
Images of GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled "Unscripted
Freestyles"(copies of asampling of such various advertisements, as described hereinbelow, are
annexed hereto as Exhibit "M", hereinafter the"UNSCRIPTED AD(S)").
103. The UNSCRIPTED ADS have been published invarious media, including
but not limited to as internet posters, image files, andas a mixtape cover.
104. Said UNSCRIPTED AD includes plaintiffs photograph of GUNPLAY
(see Exhibit "B"), without plaintiffs license, authorization or consent.
105. The UNSCRIPTED AD employs plaintiffs image of GUNPLAY edited
and "photoshopped" in such amanner as to create an unauthorized derivative work of plaintiffs
Image.
106. The color of Plaintiffs Image of GUNPLAY intheUNSCRIPTED AD has
been modified toappear grainy and the color has been modified toinclude red.
107. Upon information and belief, the UNSCRIPTED AD was published by, or
under the direction or control of GUNPLAY, ROSS, and/or MMG.
108. At the bottom of the UNSCRIPTED AD is the MMG logo.
109. Upon information and belief, one or more versions of the UNSCRIPTED
AD have been distributed by defendants, or one or more ofthem, tothird parties tobe displayed by
same.
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Gunplay Living Legends
HO. Defendants, orone or more ofthem, have utilized one ("1") ofplaintiff s
Images of GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled "Living
Legends"(copies of asampling of such various advertisements, as described hereinbelow, are
annexed hereto asExhibit "N", hereinafter the "LIVING LEGENDS AD(S)").
111. The LIVING LEGENDS ADS have been published invarious media,
including but not limited to as internet posters and image files.
112. Said LIVING LEGENDS AD(S) includes plaintiffs photograph of
GUNPLAY (see Exhibit "B"), without plaintiffs license, authorization orconsent.
113. Each of theversions of the LIVING LEGENDS ADS employ plaintiffs
image ofGUNPLAY edited and "photoshopped" in such amanner as to create an unauthorized
derivative work of plaintiff s Image.
114. One of the versionsof the LIVING LEGENDS ADhas been alteredwith a city
skyline included in the background and ared and black banner displayed in the lower foreground
with the words "2014 GUNPLAY".
115. Anotherversionof the LIVING LEGENDS ADhas been alteredwith a city skyline
included inthe background and a red and black banner displayed inthe lower foreground with the
words "2014 GUNPLAY 'Living Legends' Coming Soon".
116. Athird version of the LIVINGLEGENDS AD has been altered with the Gunplay
logo appearing across GUNPLAY'S chest, and words inthe lower foreground stating "Living
Legend *** Coming Soon ***"
117. Upon information and belief, the LIVING LEGENDS AD(s) have been published
by, or under thedirection or control of GUNPLAY, ROSS, and/or MMG.
118. Upon information and belief, one or more versions of the LIVING LEGENDS
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AD(s) havebeendistributed by defendants, or one or more of them, to third parties to be displayed
by same.
119. The LIVING LEGENDS AD(S) has been published by or at the direction or control
of defendants, or one or more of them, on MMG's Twitter page.
120. The LIVING LEGENDS AD(S) has been published by or at the direction or control
of defendants, or one or more of them, on GUNPLAY'S Twitter page as his primary image.
121. The LIVING LEGENDS AD(S) has been published by or at the direction or control
of defendants, or one or more of them, on MMG's Facebook page on its "timeline".
122. The LIVING LEGENDS AD(S) has been published by or at the direction or control
of defendants, or one or more of them, on GUNPLAY'S Facebook page on its "timeline".
123. The LIVING LEGENDS AD(S) has been published by or at the direction or control
of defendants, or one or more of them, on GUNPLAY'S Facebook page as his "Cover Photo".
124. At least one version of the LIVING LEGENDS AD has been published to
GUNPLAY'S website, www.gunpalvalldav.com, which includes both the ISLAND DEF JAM and
MMG logos below the LIVING LEGENDS AD.
125. Upon information and belief, the LIVING LEGENDS AD(S) were published by, or
under the direction or control of GUNPLAY, ROSS, and/or MMG.
126. Upon information and belief, the LIVING LEGENDS AD(S) have been distributed
by defendants, or one or more of them, to third parties to be displayed by same.
Miscellaneous Gunplay promotions
127. At least two of plaintiff s Images of GUNPLAY (Exhibit "B", and Exhibit "C",
specifically "GunPlay_108") have been used in various promotional publications for various
events featuring GUNPLAY (hereinafter the "VARIOUS PROMOTIONS", copies of a sampling
of such VARIOUS PROMOTIONS as described hereinbelow are annexed hereto as Exhibit "O").
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128. Each ofsaid VARIOUS PROMOTIONS constitutes a separate act ofinfringement
and is aseparate unauthorized derivative work of PlaintiffsImages of Gunplay.
129. Upon information and belief, the VARIOUS PROMOTIONS were published by, or
under the direction or control of GUNPLAY.
130. That many ofthe VARIOUS PROMOTIONS have been published on the twitter
page for @gunplaymmg by the @gunplaymmg account.
131. That, upon information and belief, publications to the @gunplaymmg account are
made by GUNPLAY and/or ROSS and/or persons under the direction or control of GUNPLAY
and/or ROSS.
132. That upon information and belief, defendants or one or more ofthem, employed
Plaintiffs Image ofGUNPLAY to promote the GUNPLAY "Acquitted World Tour".
133. Upon information and belief, the VARIOUS PROMOTIONS have been distributed
by defendants, or one or more of them, or by persons under the direction or control of one or more
of them, to third partiesto be displayed by same.
Meek Mill Superbowl
134. At least one ofplaintiffs Images ofMEEK MILL (Exhibit "B") has been used in at
least one promotional publication for an event featuring MEEK MILL (hereinafter the
"SUPERBOWL EVENT AD", a copy of which is annexed hereto as Exhibit "P").
135. Plaintiffs Image ofMEEK MILL as employed inthe SUPERBOWL EVENT AD
is an unauthorized derivative work of Plaintiff s Image.
136. Upon information and belief, theSUPERBOWL EVENT AD was
published by, or under the direction or control ofMEEK MILL, ROSS, and/or MMG.
137. At the bottom of the SUPERBOEL EVENT AD is the MMG logo.
138. Upon information and belief, the SUPERBOEL EVENT AD has been distributed
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by defendants, or one or more ofthem, or by persons under the direction or control ofone or more
ofthem, to third parties to be displayed by same.
Meek Mill Promotional Event
139. Atleast one of plaintiffs Images of MEEK MILL (Exhibit "B") has been used inat
least one promotional publication for an event featuring MEEK MILL (hereinafter the
"FIRESTONE EVENTAD", a copyof whichis annexed heretoas Exhibit "Q").
140. The FIRESTONE EVENT AD is an unauthorized derivative work of Plaintiffs
Image of MEEK MILL.
141. Upon information and belief, the FIRESTONE EVENT AD was published
by, orunder the direction or control of MEEK MILL, ROSS, and/or MMG.
142. That, upon information and belief, MEEK MILL or someone onhis behalf or under
his direction or control published the FIRESTONE EVENT AD tohis Twitter account, which is
@MeekMill.
143. At the bottom of the FIRESTONE EVENT AD is the MMG logo.
144. Upon information and belief, the FIRESTONE EVENT AD has been distributed by
MEEK MILL, MMG, and persons onbehalf of and under the direction or control of one or more of
them, to third parties to be displayed by same.
Meek Mill 2014
145. Defendants, or one or moreof them, have utilized one ("1") of plaintiff s Images of
MEEK MILL in at least one version of an advertisement for MEEK MILL'S mixtape entitled
"DreamsWorthMore Than Money"(copies of a sampling of such various advertisements, as
described hereinbelow, are annexed hereto as Exhibit "R", hereinafter the "DREAMS AD").
146. The DREAMSAD has been published at least on the World Wide Web.
147. SaidDREAMS ADincludes plaintiff s photograph of MEEKMILL(see Exhibit
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"B"), without plaintiffs license, authorization or consent.
148. The DREAMS AD employs plaintiffs Image of MEEK MILL edited and
"photoshopped" in such a manner as to create an unauthorized derivative work of plaintiff s Image.
149. Plaintiff s Image of MEEK MILL as displayed in the DREAMS AD has been
altered with a city skyline included in the background and a red and black banner displayed in the
lower foreground with the words "2014 MEEK MILL 'DREAMS WORTH MORE
THANMONEY' COMING SOON' ".
150. Upon information and belief, the DREAMS AD has been published by, or under the
direction or control of MEEK MILL, ROSS, and/or MMG.
151. Upon information and belief, the DREAMS AD has been distributed by defendants,
or one or more of them, to third parties to be displayed by same.
152. Upon information and belief, the DREAMS AD has been published by or at the
direction or control of defendants, or one or more of them, on ROSS' Twitter page.
Rick Ross Gun Pic 911
153. Defendants, or one or more of them, have, upon information and belief, utilized
plaintiffs Image of ROSS, which depicts ROSS holding his fingers to his head in the style of a
gun (Exhibit "A" hereto) in various advertisements for ROSS and his music (copies of a sampling
of such various advertisements, as described hereinbelow, are annexed hereto as Exhibit "S",
hereinafter the "GUN PHOTO USE(S)").
154. The GUN PHOTO USE(S) have been published in various media, including but not
limited to as internet posters and image files, and in internet videos.
155. Said GUN PHOTO USE(S) includes plaintiffs photographs of ROSS (Exhibit "A")
without plaintiffs license, authorization or consent.
156. Each version of the GUN PHOTO USE(S) is an unauthorized derivative work of
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plaintiffs Image.
157. Various versions of the GUN PHOTO USE(S) have been cropped, without
plaintiffs license, authorization or consent.
158. At least one version of the GUN PHOTO USE(S) has been edited to include the text
of "911" in bold black numbers across plaintiffs Image of ROSS.
159. At least one version of the GUN PHOTO USE(S) has been edited to appear
alongside a photographof MEEKMILL, and with text in red, white and black letters stating,
"RICK ROSS +MEEK MILL TheMansionElan Saturday Sept. 28th #BreakingNews".
160. That the aforementioned modifications of the GUN PHOTO USE(S) were without
plaintiffs license, authorization or consent.
161. Upon information and belief, at least one version of the GUN PHOTO USE(S) was
published to ROSS' Instagram page, by, on behalf of, or under the directionof control of ROSS.
162. Upon information and belief, at least one version of the GUN PHOTO USE(S) was
publishedto ROSS' SoundCloudpage, by, on behalf of, or under the direction of control of ROSS.
163. Upon information and belief, ROSS, and/or persons on his behalf or under his
direction or control have employed the GUN PHOTO USE(S) to publicize ROSS' song, entitled
"911".
164. Upon information and belief, ROSS, and/or persons on his behalf or under his
direction or control have employed the GUN PHOTO USE(S) to publicize ROSS' song, entitled
"Birthday Cake (Remix)".
165. Upon information and belief, ROSS, and/or persons on his behalf or under his
direction or control have employed the GUN PHOTO USE(S) to publicize ROSS' song, entitled
"How Many Drinks (Remix)".
166. Upon information and belief, ROSS, and/or persons on his behalf or under his
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direction or control have employed the GUN PHOTO USE(S) to publicize ROSS' song, entitled
"Cut Her Off (Remix)".
167. At least one version of the GUN PHOTO USE(S) was published to the Twitter
account of MEEK MILL, which is @meekmill, by, on behalf of, or under the direction of control
of ROSS, MEEK MILL, or one or more of them.
168. At least one version of the GUN PHOTO USE(S) was published to DJ SCREAM'S
website, which is www.di screamtv.com, by, on behalf of, or under the direction of control of
ROSS, DJ SCREAM, or one or more of them.
169. Upon information and belief, one or more versions of the GUN PHOTO USE(S)
were distributed by defendants, or one or more of them, to third parties to be displayed by same.
Miscellaneous
170. That none of the aforementioned uses of plaintiff s Image(s), inclusive of any
unauthorized derivative works thereof, as set forth and referenced with respect to Exhibits "D"
through "S" were with plaintiffs license, authorization or consent. This is notwithstanding the
fact that defendants, or one or more of them, knew that plaintiff was the photographer, had
plaintiffs contact information, and indeed were in contact with plaintiff.
171. That, upon information and belief, each of defendants, or one or more of them, do
business in the State of New York.
172. Upon information and belief, the events giving rise to this action, including the
photo shoot with Vibe Magazine, occurred in the State of New York and/or out of the transaction
of business within the State of New York.
173. That the full nature and extent of the use(s) of plaintiff s image by the defendants,
or one or more of them, is unknown to plaintiff pre-discovery as such is within the sole knowledge
of the defendants, or one or more of them.
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174. Defendant(s) have refused to provide such information although duly demanded.
175. Upon information and belief, defendants or one or more of them, have employed
Plaintiffs Image(s) in amyriad of ways and mediums, and have made uses of PlaintiffsImage(s)
in addition to what is set forth herein.
176. That the aforementioned uses of plaintiffs Image(s) bythe defendants, or one or
more of them, are for branding and/or other purposes.
177. That defendant(s)' uses ofPlaintiff s Images have been for their sole economic
benefit and to the economic detriment of Plaintiff.
178. Inor around October of 2012, DJERRAHIAN provided SPIFF TV with low res and
non-retouched versions of hisImages for MMG to review and possibly license from
DJERRAHIAN.
179. When delivering the Images to SPIFF TV by email, DJERRAHIAN specified that if
MMG is interested in any ofthe images to let DJERRAHIAN know and to specify the requested
use so that DJERRAHIAN couldthen considerthe licenseand provide an estimatefor the
proposedterms of use, if any.
180. Rather than informing DJERRAHIAN of theImages inwhich they were interested
and for what manner they sought touse the Images, defendants orone or more ofthem, boldly and
brazenly used Plaintiffs Images as aforesaid without requesting orobtaining Plaintiffs license,
authorization or consent.
181. Upon seeing the"TAKEOVER AD(S)", onJanuary 9, 2013, DJERRAHIAN
confronted SPIFF with regard tothe offenses to his intellectual property. SPIFF responded by
saying "I got your brother".
182. DJERRAHIAN also discussed the unauthorized uses of his image with MMG's vice
president, Kendall "Young Sav" Freeman from in or around June of2013 to September of2013.
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183. On October 29, 2013, a mutual acquaintance ofboth DJERRAHIAN and ROSS'
and MMG's lawyer, Ms. Adeline Ferretti, Esq., introduced DJERRAHIAN to Ferretti by email (a
copy ofsaid email isannexed hereto within Exhibit "T").
184. On October 31, 2013, DJERRAHIAN wrote to attorney Ferretti and informed her of
the various unauthorized uses ofhis Images (acopy of said email is annexed hereto within Exhibit
185. OnNovember 13, 2013, having received no response from Ferretti, DJERRAHIAN
re-sent hisemail to her from October 31, 2013 (a copy of said email is annexed hereto within
Exhibit "T").
186. That Ms. Ferretti responded to DJERRAHIAN onNovember 13, 2013 and
scheduled atelephone call to discuss the issues (acopy ofsaid email isannexed hereto within
Exhibit "T").
187. That Ms. Ferretti told DJERRAHIAN on the phone that she would discuss the
matter withMMG (a copy of saidemail is annexed hereto within Exhibit "T").
188. On December 4, 2013, DJERRAHIAN wroteto Ferretti to ascertainwhether
Ferretti had spoken with MMG, and Ferretti never responded toDJERRAHIAN's email (acopy of
said email is annexed hereto within Exhibit "T").
189. OnJanuary 15, 2014, plaintiff, bycounsel, issued anddelivered correspondence to
ROSS and MMG by and through their counsel Ms. Ferretti, advising her, inter alia, that ROSS and
MMG were in violation of plaintiffs copyright through the use of the Image(s), that theyshould
immediately cease and desist all uses of theImages, and that they should provide any information
that might rebut the plaintiffs presumption that the Image(s) had been unlawfully used inviolation
of Plaintiffs copyrights, and thatthey should disclose usage information without prejudice (a copy
of said letter, sans its exhibits is annexed hereto as Exhibit "U").
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190. That no response was received to said January 15,2014 letter until the end of
March of 2014.
191. As ofthe date ofthis Complaint, ROSS, MMG and their counsel, Ms. Ferretti, have
failed to adequately respond to plaintiffs counsel's letter, and have not provided any information
regarding the nature and extent ofthe use(s) ofplaintiffs Image(s).
192. On February 12,2014, Plaintiff, by counsel, issued and delivered correspondence to
ROSS and MMG to two separate addresses for MMG inthe State ofFlorida, advising them, inter
alia, that they were in violation ofplaintiffs copyright through the use ofthe Image(s), that they
should immediately cease and desist all uses ofthe Images, and that they should provide any
information that might rebut the plaintiffs presumption that the Image(s) had been unlawfully used
in violation of Plaintiffs copyrights.
193. That noresponse was received toeither of said February 12, 2014 letters to ROSS
and MMG.
194. OnFebruary 12, 2014, Plaintiff, bycounsel, issued and delivered correspondence to
the general counsel at ATLANTIC, advising it, inter alia, that it is inviolation ofplaintiffs
copyright through the use ofthe Image(s), that they should immediately cease and desist all uses of
the Images, and that they should provide any information that might rebut theplaintiffs
presumption that the Image(s) had been unlawfully used inviolation of Plaintiffs copyrights.
195. OnFebruary 12, 2014, Plaintiff, by counsel, issued anddelivered correspondence to
the general counsel at DEF JAM, advising it, inter alia, that it is inviolation of plaintiffs copyright
through the use of the Image(s), that they should immediately cease and desist all uses of the
Images, and that they should provide any information that might rebut the plaintiffs presumption
that the Image(s) hadbeen unlawfully usedin violation of Plaintiffs copyrights.
196. That despite plaintiffs requests, defendants have failed to provide plaintiff with the
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full nature andextent of defendant(s)' use(s) of Plaintiff s Images.
197. That despite plaintiffsrequests, many ofthe unauthorized use(s)' ofplaintiffs
images remain published on the World Wide Web and have not been removed, though duly
requested byplaintiffs counsel.
198. That upon information and belief, defendants, or one or more ofthem, continue to
employ plaintiffs Image.
199. That such post notice use is particularly egregious and willful.
200. Upon information and belief, each ofdefendants, orone ormore ofthem, are
sophisticated licensees and licensors ofintellectual property and employ persons expert in all
aspects of licensing, rights management and related matters.
201. Upon information and belief, each ofdefendants, orone ormore ofthem, have
extensive resources including but not limited to legal counsel, available to themto assure
compliance with all appropriate business protocols and federal or state statutes including but not
limited to USC Title 17.
202. That defendants, or one or more of them, knewor shouldhave knownof the
procedures and protocols for the licensing ofintellectual property created by third parties.
203. That despite such resources, and despite the actual notice that Plaintiff created the
images, defendants, orone ormore ofthem, employed Plaintiffs Image(s) without plaintiffs
license, authorization or consent.
204. Upon information and belief, as of result of theaforementioned uses of Plaintiffs
Image(s) by the defendants, or one or more of them, plaintiffs Image(s) have been widely
distributed and madeavailablefor others to appropriate and republishwith ease. Consequently,
Plaintiffs Image(s) are now published oncountless web pages bythird parties inviolation of
plaintiffs copyright.
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205. That, upon information and belief, the defendants, or one or more ofthem, were
fully aware at all times relevant herein that it lacked awritten license or permission necessary to
employ the use ofat least seventeen (17) ofPlaintiffsImage(s) in any form.
206. That, notwithstanding such knowledge, defendants, or one or more ofthem, wholly
failed to obtaina license or permission from the Plaintiff.
207. That pursuant to Federal Rule 11, Plaintiff sought to obviate litigation and resolve
the matters complained ofherein and made extensive efforts toward that end.
208. That subsequent to DJERRAHIAN'S notices to MMG, ROSS, SPIFF, and
subsequent to plaintiffs counsel's notices, defendants, or one or more ofthem, have continued to
use Plaintiffs Image(s), without hisauthorization, consent, or license.
209. That as of the date of thiscomplaint, theparties have been unable resolve their
disputes without the need for litigation, despite plaintiffs good faith attempts at same.
210. That the defendants have no defenses at law to the claims set forth herein.
211. Upon information and belief, each and all ofthe defendant(s) rely onUSC Title 17
and hold copyrights for their own intellectual property.
212. Paragraphs "1" through "210" are incorporated by reference with respect toeach of
the below counts or claims for relief.
FIRST CLAIM FOR RELIEF
Willful Copyright Infringement
Under Section 501 of the Copyright Act
213. The use(s) of Plaintiff s Image(s) by the defendants, or one or moreof them, as
described hereinabove, were and are without the plaintiffs authorization, license or consent.
214. That, upon information andbelief, the defendants, or oneor more of them have
infringed the copyright for Plaintiffs Image(s).
215. That, upon information andbelief, the aforementioned acts of thedefendants, or one
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or more ofthem, constitute federal statutory copyright infringement under Section 501 ofthe
Copyright Act in violation of the rights granted to DJERRAHIAN as copyright holder.
216. That the use ofeach image by each defendant constitutes a separate and distinct act
ofinfringement ofPlaintiffscopyright. That, upon information and belief, defendants, or one or
more ofthem, individually and/or collectively, have infringed no less than seventeen (17) of
plaintiffs copyright(s).
217. That, upon information and belief, defendant(s)' use(s) ofthe subject Image were
willful, intentional and in bad faith.
218. That, upon information and belief, defendants, orone ormore ofthem, had actual
and/or constructive knowledge and/or through the exercise of ordinary business care and/or the
examination ofpublic records, knew or should have known that the plaintiff held the copyright in
the Image, that neither defendants, nor one ormore ofthem, ever had (at any ofthe relevant times
herein) a license, consent, orauthorization by plaintiff for the use of Plaintiffs image as
complained ofherein by the defendants, or one or more ofthem, and that any such use(s) would be
in violation of Plaintiffs copyright.
219. That as a result of defendant(s)' acts, plaintiff has been and will continueto be
damaged inan amount as yet tobe determined. Indeed, notwithstanding, Plaintiffs counsel's
letters referenced hereinabove, the date(s) or term(s) of use(s) of plaintiffs image are as yet
unknown, suchinformation beingwithinthe sole custody, possession, and control of the
defendants, or one or more of them.
220. That Plaintiff is further entitled to damages, attorneys' fees and costs under Section
504 and 505 of the Copyright Act, 17U.S.C. Section 101 et., seq., given the willful, intentional,
malicious and bad faith nature of defendant(s)' copyright infringement, and as an alternativeto
statutory damages, Plaintiff, at herelection prior tojudgment is entitled to recover heractual
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damages and any additional profits of the defendants, or one or more of them, attributable to the
infringement as under 17 U.S.C. Sections 504 (a)-(b).
SECOND CLAIM FOR RELIEF
Negligent Copyright Infringement
Under Section 501 of the Copyright Act
221. The use(s) ofPlaintiffsImage(s) by the defendants, or one or more ofthem, as
described hereinabove, were and are without the plaintiffs authorization, license or consent.
222. That, upon information and belief, the defendants, or one or more ofthem have
infringed the copyright for PlaintiffsImage(s).
223. That, upon information and belief, the aforementioned acts ofthe defendants, or one
or more ofthem, constitute federal statutory copyright infringement under Section 501 ofthe
Copyright Act in violation ofthe rights granted to DJERRAHIAN as copyright holder.
224. That the use of each image byeach defendant constitutes a separate and distinct act
ofinfringement ofPlaintiffs copyright. That, upon information and belief, defendants, or one or
more ofthem, individually and/or collectively, have infringed no less than seventeen (17) of
plaintiffs copyright(s).
225. That, upon information and belief, defendant(s)' use(s) ofthe Image(s) inviolation
ofplaintiffscopyright were negligent in that defendants, or one or more ofthem, knew or should
have known that it was without a license for the use(s) complained of herein.
226. That, upon information and belief, defendants, orone ormore ofthem, had actual
and/or constructive knowledge and/or through the exercise of ordinary business care and/or the
examination ofpublic records, knew or should have known that the plaintiff held the copyright in
the Image, that neither defendants, nor one ormore ofthem, ever had (at any ofthe relevant times
herein) a license, consent, or authorization by plaintiff for the use of Plaintiffs image as
complained ofherein by the defendants, or one or more ofthem, and that any such use(s) would be
28
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in violation of Plaintiffs copyright.
227. That as a result of defendant(s)' acts, plaintiff has been and will continue to be
damaged in an amount as yet to be determined. Indeed, notwithstanding, Plaintiffs counsel's
letters referenced hereinabove, the date(s) or term(s) of use(s) of plaintiffs image are as yet
unknown, such information being within the sole custody, possession, and control ofthe
defendants, or one or more of them.
228. That Plaintiffis further entitled to damages, attorneys' fees andcosts under Section
504 and 505 ofthe Copyright Act, 17 U.S.C. Section 101 et., seq., given the willful, intentional,
malicious andbadfaith nature of defendant(s)' copyright infringement, andas an alternative to
statutory damages, Plaintiff, at her election prior to judgment isentitled to recover her actual
damages and any additional profits ofthe defendants, or one ormore ofthem, attributable to the
infringement as under 17U.S.C. Sections 504(a)-(b).
THIRD CLAIM FOR RELIEF
Induced Copyright Infringement
Under Section 501 of the Copyright Act
Against Defendants ROSS, MMG and SPIFF
229. Upon information and belief, defendants, or one or more of them, have directly
infringed Plaintiffs copyright(s) by, inter alia employing, printing, manufacturing, editing,
cropping, broadcasting, disseminating, distributing, sublicensing, and/or enabling the copying or
appropriation of Plaintiffs Image(s) (or unauthorized derivative works thereof) asdescribed more
fully hereinabove, inviolation of Plaintiffs exclusive rights under theCopyright Act, 17 U.S.C.
Sections 106 and 501.
230. Upon information and belief, defendants ROSS, MMG and SPIFF, or one or more of
them, areliable for inducing the copyright infringement(s) of various thirdparties who have used
plaintiffs images as described hereinabove.
231. Defendants, ROSS, MMG and SPIFF, or one or more of them, have selected,
29
0 0
employed, broadcast, printed, manufactured, modified, altered, edited, cropped, distributed,
sublicensed, provided, and/or enabled the copying or appropriation ofPlaintiffsImage(s) or
unauthorized derivative work(s) thereof for use in connection with, inter alia, materials and
publications to promote MMG, its members, tour(s), and the music of MMG and its members, as
specifiedhereinabove.
232. As explained herein, upon information and belief, defendants, ROSS, MMG and
SPIFF, or one or more ofthem, have actively facilitated, encouraged, and/or enticed at least
GUNPLAY, MEEK MILL, DJ SCREAM, DEF JAM, ISLAND DEF JAM, ATLANTIC,
Facebook, Instagram, Twitter, YouTube, KidEight, DatPiff, SoundCloud, and various blogs and
websites, or one or more of them, to commit copyright infringement.
233. As set forth hereinabove, defendants, ROSS, MMG and SPIFF, or one or moreof
them, upon information and belief, have induced and/or continue to induce infringement(s),
willfully and/or negligently by, inter alia: employing, broadcasting, printing, publishing,
distributing, manufacturing, orenabling the copying ofplaintiffs Image(s), orunauthorized
derivative work(s) thereof, thereby inducing third parties, including but not limited toGUNPLAY,
MEEK MILL, DJ SCREAM, DEFJAM, ISLAND DEFJAM, ATLANTIC, Facebook, Instagram,
Twitter, YouTube, KidEight, DatPiff, SoundCloud, andvarious blogs andwebsites, or oneor more
of them, to infringe on Plaintiffs copyright(s).
234. That saidinfringements havecontinued post notice, with defendants, or one or more
of them having received constructive and/or actual notice of Plaintiffs copyrights and the
corresponding infringement(s).
235. Upon information andbelief, at all times relevant herein, defendants, or oneor more
of them, were onconstructive and/or actual notice of Plaintiffs rights to the Image(s), andthat any
unauthorized use(s) thereof wouldbe in violationof Plaintiff s copyright(s).
30
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236. Upon information and belief, defendants, or one or more of them, relied on the use of
Plaintiffs Image(s) and/or derivative works thereof for the success of their business(s) and/or the
promotion or marketing thereof.
237. That the use ofeach image by each defendant constitutes a separate and distinct
infringement ofPlaintiffscopyright. That, upon information and belief, defendants, or one or
more ofthem, individually and/or collectively, have infringed no less than seventeen ("17") of
plaintiffs copyright(s).
238. Upon information and belief, through the acts described hereinabove, defendants, or
one or more of them, are liable for inducing theinfringement(s) described herein.
239. Upon information and belief, defendant(s)' infringement(s) are and have been willful,
intentional, purposeful, and with disregard ofthe rights ofPlaintiff, and have caused substantial
damage to Plaintiff.
240. As a direct and proximate result ofdefendant(s)' infringement(s), Plaintiff isentitled
tothe maximum statutory damages under 17 U.S.C. Section 504 (c), and asanalternative to
statutory damages, Plaintiff, at his election prior to judgment isentitled to recover his actual
damages and any additional profits ofthe defendants, or one ormore ofthem, attributable to the
infringement(s) as under 17U.S.C. Sections 504(a)-(b).
241. Pursuant to 17 U.S.C. Section 505, Plaintiff is entitled to his costs, including
reasonable attorneys' fees.
FOURTH CLAIM FOR RELIEF
Contributory Copyright Infringement
Under Section 501 of the Copyright Act
Against Defendants ROSS. MMG and SPIFF
242. Upon information and belief, defendants, or one or more of them, have directly
infringed Plaintiffs copyright(s) by, inter alia employing, printing, manufacturing, editing,
cropping, broadcasting, disseminating, distributing, sublicensing, and/or enabling the copying or
31
0 0
appropriation of PlaintiffsImage(s) (or unauthorized derivative works thereof) as described more
fully hereinabove, in violation of Plaintiffsexclusive rights under the Copyright Act, 17 U.S.C.
Sections 106 and 501.
243. Upon information and belief, defendants, ROSS, MMG and SPIFF, or one or more of
them, are liable as contributory infringer(s) for the copyright infringement(s) committed via:
selecting, employing, broadcasting, printing, manufacturing, editing, cropping, sublicensing,
distributing, and/or enabling the copying or appropriation of PlaintiffsImage(s); and that such
use(s) were inviolation of Plaintiffs copyrights.
244. Upon information and belief, defendants, ROSS, MMG and SPIFF, or one or more of
them, have directly and/or indirectly, willfully and/or negligently caused, enabled, encouraged,
facilitated, and/or materially contributed to the infringement(s) by at least GUNPLAY, MEEK
MILL, DJ SCREAM, DEF JAM, ISLAND DEF JAM, ATLANTIC, Facebook, Instagram, Twitter,
YouTube, KidEight, DatPiff, SoundCloud, and various blogs and websites, or one or more of
them, described hereinabove, by selecting, employing, broadcasting, printing, publishing,
manufacturing, editing, cropping, sublicensing, distributing, disseminating and/or enabling the
copying orappropriation ofPlaintiffs Image(s), inviolation ofPlaintiffs copyrights.
245. Upon information and belief, defendants, ROSS, MMG and SPIFF, or one or more of
them, have inaddition tothe actions above, provided the tools (i.e. a print or electronic copy(ies)
ofPlaintiffs Image(s), and/or electronically displayed the Image(s) ina manner whereby they
could be copied or appropriated), support, and/or instruction for the infringement(s), via the
infringements described herein, inviolation in Plaintiffs copyright(s).
246. Upon information and belief, defendants, ROSS, MMG and SPIFF, orone ormore of
them, by inter alia, selecting, distributing, modifying, altering, cropping, editing, sublicensing,
providing, and/or enabling the copying orappropriation ofthe Image(s) as specified hereinabove,
32
0 0
contributed to the infringement(s) by third parties and at least GUNPLAY, MEEK MILL, DJ
SCREAM, DEF JAM, ISLAND DEF JAM, ATLANTIC, Facebook, Instagram, Twitter, YouTube,
KidEight, DatPiff, SoundCloud, and various blogs and websites, or one or more of them.
247. Upon information and belief, defendants, or one or more of them, knew or should
have known that it/they was not authorized to use Plaintiffs Image(s).
248. Upon information and belief, defendants, or one or more of them, had actual and/or
constructive knowledge and/or through the exercise ofordinary business care and/or the
examination of public and/or business records, knew or should have known of Plaintiffsrights in
the Image(s), and that any use of such Image(s) or of derivative works thereof would be in
violation of Plaintiffs copyright(s).
249. That the use ofeach image by each defendant constitutes a separate and distinct
infringement ofPlaintiff scopyright(s). That, upon information and belief, defendants, or one or
more ofthem, individually and/or collectively, have infringed no less than seventeen ("17") of
plaintiffs copyright(s).
250. Upon information and belief, through the conduct described hereinabove, defendants,
ROSS, MMG and SPIFF, or one or more ofthem, are contributorily liable for the infringement(s)
described herein.
251. Upon information and belief, the aforementioned acts ofthe defendants, orone or
more ofthem, constitutes federal statutory contributory copyright infringement under Section 501
ofthe Copyright Act in violation ofthe exclusive rights granted DJERRAHIAN as copyright
holder.
252. Upon information and belief, defendant(s)' infringement(s) are and have been willful,
intentional, purposeful, and/or in disregard ofthe rights ofPlaintiff, and have caused substantial
damage to Plaintiff.
33
0 0
253. As adirect and proximate result ofdefendant(s)' infringement(s), Plaintiff has been
and will continue to be damaged in an amount as yet undetermined. Indeed, the full nature and
extent of defendant(s)' use(s) ofPlaintiffsImages is as yet unknown, such information being
within the sole custody, possession, and control ofthe defendants, or one or more ofthem.
254. Plaintiff is entitled tothe maximum statutory damages under 17 U.S.C. Section 504
(c), and as an alternative to statutory damages, Plaintiff, at his election prior to judgment is entitled
to recover his actual damages and any additional profits ofthe defendants, or one or more ofthem,
attributable tothe infringement(s) as under 17U.S.C. § 504 (a)-(b).
255. Plaintiff is further entitled to damages, attorneys' fees and costs under Section 504
and 505 ofthe Copyright Act, 17 U.S.C. Section 101 et., seq., given the repeated and systematic,
willful, intentional, malicious and bad faith nature ofdefendant(s)' copyright infringement(s).
JURY DEMAND
256. That Plaintiff requests a trial byjury of all issues.
WHEREFORE, Plaintiffdemands judgmentas against the defendant as follows:
ON THE FIRST CLAIM FOR RELIEF- (A) Awardto plaintiff his actual damages
incurred as a result of defendant(s)' infringement(s), and all profits realized as a result of each of
their infringement(s), in amounts to be determined at trial; or (B) inthe alternative, at plaintiffs
election, award toplaintiff maximum statutory damages pursuant to 17 U.S.C. §504 for each
separate and distinct act ofinfringement; and for an order ofinjunction permanently enjoining
and prohibiting the defendants, or one ormore ofthem, including but not limited towholly
ownedsubsidiaries and/or affiliates, fromemploying or utilizingin any manner or media
whatsoever, including all future uses, sales, transfers, assignments, or licensing of any and all of
plaintiffs copyrighted images, pursuant to 17 U.S.C. §502 and for an award ofcosts and
attorneys' fees pursuant to 17 U.S.C. § 505;
34
0 0
ON THE SECOND CLAIM FOR RELIEF- (A) Award to plaintiff his actual damages
incurred as aresult of defendant(s)' infringement(s), and all profits realized as aresult of each of
their infringement(s), in amounts to be determined at trial; or (B) in the alternative, at plaintiffs
election, award to plaintiff maximum statutory damages pursuant to 17 U.S.C. §504 for each
separate and distinct act of infringement, and for an order of injunction permanently enjoining
and prohibiting the defendants, or one or more of them, including but not limited to wholly
owned subsidiaries and/or affiliates, from employing or utilizing in any manner or media
whatsoever, including all future uses, sales, transfers, assignments, or licensing of any and all of
plaintiffs copyrighted images, pursuant to 17 U.S.C. §502 and for an award of costs and
attorneys' fees pursuant to 17U.S.C. § 505;
ONTHE THIRD CLAIM FOR RELIEF - (A) Award to plaintiff his actual damages
incurred as aresult ofdefendant(s)' infringement(s), and all profits realized as aresult ofeach of
their infringement(s), in amounts to be determined at trial; or (B) in the alternative, at plaintiffs
election, award to plaintiff maximum statutory damages pursuant to 17 U.S.C. §504 for each
separate and distinct act of infringement, and for an order ofinjunction permanently enjoining
and prohibiting the defendants, or one or more ofthem, including but not limited to wholly
owned subsidiaries and/or affiliates, from employing or utilizing inany manner or media
whatsoever, including all future uses, sales, transfers, assignments, or licensing ofany and all of
plaintiffs copyrighted images, pursuant to 17 U.S.C. §502 and for an award ofcosts and
attorneys' fees pursuant to 17U.S.C. § 505;
ON THE FORTH CLAIM FOR RELIEF - (A) Award to plaintiffhis actual damages
incurred as aresult ofdefendant(s)' infringement(s), and all profits realized as aresult ofeach of
their infringement(s), in amounts to be determined at trial; or (B) in the alternative, at plaintiffs
election, award to plaintiff maximum statutory damages pursuant to 17 U.S.C. §504 for each
35
0 0
separate and distinct act of infringement, and for an order of injunction permanently enjoining
and prohibiting the defendants, or one or more of them, including but not limited to wholly
owned subsidiaries and/or affiliates, from employing or utilizing in any manner or media
whatsoever, including all future uses, sales, transfers, assignments, or licensing of any and all of
plaintiffs copyrighted images, pursuant to 17 U.S.C. §502 and for an award of costs and
attorneys' fees pursuant tol7U.S.C.§505;
Prejudgment interest onall sums due;
And such other and further reliefas this Court may deemjust and proper inclusive of any
and all relief orremedies allowable by the statutes referenced above orapplicable hereinabove.
Dated: New York, New York
May 6, 2014
Yours, etc.
Tamara L. Lannin, Esq. (TL 3784)
EDWARD C. GREENBERG, LLC
570 Lexington Avenue, 19th Floor
New York, NY 10022
Tel: (212) 697-8777
Fax: (212) 697-2528
Attorneysfor Plaintiff
36
EXHIBIT A
0
EXHIBIT B
*•>•
•>#'
3
C
•?$t ^.,0>
0
Certificate of Registration
^•2±if*.
77,.* >
•J8-0
Title
This Certificate issued under the sealof the Copyright
Office in accordance with title 17, United States Code,
attests that registration has been madefor the work
identified below. The information on this certificate has
been made a part of the Copyright Officerecords.
Register ofCopyrights, United States of America
0
Registration Number
VA 1-899-797
Effective date of
registration:
December 25. 2013
Title ofWork: Vibe magazine Aug/'Sept 2012 feat Maybach Music Group's artists: Rick Ross, Meek
Mill, Wale, Omarion, Stalley, Gunplay
Completion/ Publication
Author
Year of Completion: 2012
Date of 1st Publication: September 1, 2012
Author: Armen Charles Djerrahian
Pseudonym: armenexpo
Author Created: photograph(s)
Citizen of: France
Year Born: 1969
Copyright claimant
Nation of 1st Publication: United States
Domiciled in: United States
Copyright Claimant: Armen Charles Djerrahian
164 Russell Street, Apt#2R, Brooklyn, NY, 11222
Rights and Permissions
Name: Armen Charles Djerrahian
Email: armen@armenexpo.com
Address: 164 Russell Street, Apt#2R
Brooklyn, NY 11222
Telephone: 646-642-1633
Certification
Name: Armen Djerrahian
Date: December 25,2013
Page 1 of 2
0
Q
Correspondence: Yes
Page 2 of 2
EXHIBIT C
0
GunPlay_0l8 GunPlay_108 GunPlay_118
^H^^
&<«« *
Meek Mil 058 Meek Mil 060 Meek Mil 278
£!>%
MMG07 MMG08 MMG09
Omarion 212 Omarion 231 Omarion 236
Rick 022 Rick 033 Rick 046
Rick 088 Rick 089 Rick 135
Staley_021 Staley_027 Staley_081
/^m
^| m-.
Meek Mil 029
Meek Mil 301
Omarion 001
#•
Rick 007
Rick 051
rickross06b
Staley_083
*4
Meek Mil 038
Meek Mil 309
I
Omarion 009
Rick 009
Rick 081
0
Staley__009
Staley„086
0
*
*
Wale 005
Wale 009
Wale 011
Wale 016
Wale 017
Wale 024
Wale 026
0
Certificate of Registration
s'v'u'*.y.
Title
I'his Certificateissued under the seal of the Copyright
Office in accordance with title 17, United States Code,
attests that registration has been made for the work
identified below. The information on this certificate has
been made a part of the Copyright Office records.
LA ' (XAiC«~-. ot^JsJL
Register of Copyrights,UnitedStates of America
Title of Work: GunPlayOl 8, et al.
Contents Titles: GunPlay018
GunPlay108
GunPlay118
MeekMil029
MeekMil038
MeekMil058
MeekMil060
MeekMil278
MeekMiOOl
MeekMil309
OmarionOOl
Omarion009
Omarion212
Omarion231
Omarion236
Rick007
Rick009
Rick022
Rick033
Rick046
Rick051
Rick081
Rick088
Rick089
Number
f%
Registration Number
VAu 1-160-975
Effective date of
registration:
December 25,2013
Page 1 of 3
Rickl35
Staley009
Staley021
Staley027
Staley081
Staley083
Staley086
Wale005
Wale009
WaleOll
Wale016
Wale017
Wale024
Wale026
MMG07
MMG09
MMG08
rickross06b
Completion/Publication
Year of Completion: 2012
Author —
0
Author: Armen Charles Djerrahian
Pseudonym: armenexpo
Author Created: photograph(s)
• Citizen of: France Domiciled in: UnitedStates
Copyright claimant
Copyright Claimant: Armen Charles Djerrahian
164Russell Street, Apt#2R, Brooklyn, NY, 11222
Rights and Permissions
Name: Armen Charles Djerrahian
Email: armen@armenexpo.com Telephone: 646-642-1633
Address: 164 Russell Street, Apt#2R
Brooklyn, NY 11222
Certification
Name: Armen Djerrahian
Date: December 25, 2013
Paae 2 of 3
EXHIBIT D
0.
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1/13/14
Maybach Music Group's Photos - Maybach Music Group | FaGebook
0
Maybach Music Group's Photos
Back to Album
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Maybach Music Group
The Black Bar Mitzvah Mixtapedrops at rridnight! Checkout the traddisting.
Dont forget to folowthe Untouchable Maybach Empire onTumbir: http://
mmgofricial.tumblr.conV
And Instagram: UntouchableMMG
(5 Manjeet Singh, Alexouw MaybachMusBc, Natukwasa Undon Da Boss and741
others Bke this.
Up 90 shares
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WmQ
Joel Vazquez 2, 3, 4, 7, andthat's about itthat I would care
about.
•'itfoberS, 2012 ai 4:51pm
Tyreke Bi Hobenu Mmg
Octobers, 2012at4;5ipn)-«ai
Manuel Acosta This Shit gonna sound Nice
October 8, 2012 at 4:51pm
Kayb Abitia PLEASE READ THIS YOU WILL BE KISSED ON THE
NEARESTFRIDAYBYTHE LOVE OF YOURLIFE. NOWYOUVE
STARTED READINGTHIS. DONT STOP. THIS IS FREAKY.... See More
Octobers, 2012 at 4:51pm
Kevin English DEC 1st SACTOWN
October 8, 2012 at. 4:$2pm
Xabiso Boas Mkalipi Mafavourite group intha fuckin game
Octobers, 2012 3t4:S3prfi
Lautaro De Rosa I likeit. RickRoss you're the boss
Octobers, 2012 at 4:53pm-til
hupsi/Aawwfecebookcar^^ &set=pb. 177110875670631.-2207520000.1389648694.&type=3&src=https%3A%2F%2Fscontent-a-ia.. 1/3
1/13/14
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:eboc^^ Timeline Photos - MaybachMusic Group | Fao
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Maybach Musk Group
Big announcement today for the Maybach Music Groupfatrily! Rick Ross, MeekMil, Waleand
DJ Screamare hitting the road this Fall.
Watchthe videoannouncement here: http://www.youtube.com/watch?
v=LEu6r_cmTzE&feature=youtu.be
l5 SaberMenrouk, SAabella Kamano, Yayo Orlando Lamo and1,317otherslike
this.
(U 176shares
(3 View previous comments 4? of 82
Badge Prod Musk #MMG Famiy
September 2-1, 20.12 at i i:2Qprn
Dylan A Howard MGK istrash I fucks with MMG but ifthe best u can
do is MGK I save mymoneywe aht al Rick foeva niggaa!i Haha
September 24, 2012 at ll:22pmvlB mobile
Dylan A Howard Rich*
September 24, 2012 at 11:22;jmvia rr*>b4-
ByWk MMG BITCH!
September 24, 2012 at 11:24pra
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HamiltonH-babys Babys, MuhammedIbrahim, Bryan Alex Parker and 120
others like this.
32 shares
H
Shaven Singh Hayer wish i could go
September 26, 2012 at 8:47am
Hj|^ AdamDe Man badofbotocks didnt even turn upIn melboume
BB September 29, 2012 at 10:56pm
Matheus Correa FEEL LIKE A BOSS!
October 2, 2012 at 9:24am
*X3 SaiekzOlmos Juarez GinobJiVamos we!
|jH October S, 2012 at 1:39pm
Kevin Ginobili Pero es en estados unidos no we?
October 5, 2012 at 3:13pm
Evandro Baptists Evandro Newton pik
October 11, 2012 at 1:40pm
John f Foryoh MMG is the new "torrmorrow"
October 13, 2012 at 11:41pm • 1
Ritshuri Martin MMG saved hiphop
October 19, 2012 at 7:50am • 3
MCcbunda Huis-money Ntiyiso DoubleMI'vegotta G-zoutta
rariifnnra HIHHIIihl
j Keepmeloggedin Forgotyour password?
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