jBJGfiltfUN

JS44DSDNY
REV. 4/2014
14 CV
CIVIL COVER SHEET
The JS-44civilcover sheet and the Information contained hereinneitherreplacenor supplementthe filing and aerviceof
pleadings orotherpaper* a»required bylaw,except a> provided by local rulesof court. This form, approved bythe
Judicial Conference of the United States InSeptember1874, Isrequired foruse of the Clerk of Court for the purpose of
initiating the civil docket sheet
plaintiffs
maya hayuk
DEFENDANTS
SONY MUSIC ENTERTAINMENT. EPIC RECORDS. INC., PARADIGM
TALENT AGENCY, LLC;42WEST. LLC: BILLYOUNG PRODUCTIONS, INC
and SARA BAREILLES
ATTORNEYS(FIRM NAME, ADDRESS, ANDTELEPHONE NUMBER ATTORNEYS (IF KNOWN)
Saunders &SilversteinLLP, 14Cedar Street. Ste. 224, Amesbury, MA01913
(978) 463-9130
CAUSE OFACTION(CITE THE US CIVIL STATUTE UNDER WHICH YOU ARE FBJNG AND WRITE ABRIEF STATEMENT OF CAUSE)
{DONOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
17 U.S.C § 101; Defendants reproduced and displayed infringing copies of Plaintiffs artwork
Has this action, case, or proceeding, or one essentially trie same been previously filed in SDNY at any time? NaSjVesQjudge Previously Assigned
If yes, was this case Vol. • Invol. • Dismissed. No • Yes • If yes, give date &Case No.
No H Yes •
NATURE OF SUIT
tl THISANINTERNATIONAL AR8ITAAT10NCASH
iPLAaANtxIINONlBOXONLY)
TOUTS
I l"0
I 1120
||130
I P«
I 1160
1 1151
I 1152
I 1153
I 1160
t 1100
I 1186
I use
PERSONAL INJURY
| ]310 AIRPLANE
| | SIS AIRPLANE PROOUCT
LIABILITY
| J320 ASSAULT. LIBEL 4
SLANDER
[ 1330 FEDERAL
EMPLOYERS
LIABILITY
| ]340 MARINE
| 1345 MARINE PRODUCT
LIABILITY
[ 1350 MOTOR VEHICLE
1 1355 MOTOR VEHICLE
PRODUCT LIABILITY
1 1360 OTHER PERSONAL
INJURY
| 1362 PERSONAL INJURY.
MEO MALPRACTICE
INSURANCE
MARINE
MILLER ACT
NEGOTIABLE
INSTRUMENT
RECOVERY Of
OVERPAYMENT 1
ENFORCEMENT
OF JUDGMENT
MEDICARE ACT
RECOVERY OF
DEFAULTED
STUDENT LOANS
IEXCL VETERANS)
RECOVERY OF
OVERPAYMENT
OF VETERAN'S
BENEFITS
STOCKHOLDERS
SUITS
OTHER
CONTRACT
CONTRACT
PRODUCT
LIABILITY
FRANCHISE
PERSONAL INJURY FORFEITURE/PENALTY
I 1387 HEALTHCARE/
PHARMACEUTICAL PERSONAL • , Ks [jruq REUTED
INJURY/PRODUCT LIABILITY ' '
t) 385 PERSONAL INJURY
PRODUCT LIABILITY . ,aaooTHF„
( 1368ASBESTOS PERSONAL I I•"»"»*«
INJURY PRODUCT
LIABILITY
PERSONAL PROPERTY
[I
370 OTHER FRAUD
371 TRUTH IN LENDING
| 1380 OTHER PERSONAL
PROPERTY DAMAGE
| 1385 PROPERTY DAMAGE
PROOUCT LIABILITY
PRISONER PETITIONS
[ 1483 AUEN DETAINEE
[ J510 MOTIONS TO
VACATE SENTENCE
28 USC 2255
I JS30 HABEAS CORPUS
I )S35 DEATH PENALTY
| 1540 MANDAMUS 4 OTHER
SEIZURE OF PROPERTY
21 use 881
MAI PROPERTY
ACTIONSUNDER STATUTES
CIVK RIGHTS
1 )440 OTHER CIVIL RIGHTS
(Non-Pnionarl
[ J441 VOTING
[ ) 442 EMPLOYMENT
[ 1443 HOUSING'
ACCOMMODATIONS
1 1445 AMERICANS WITH
DISABILITIES-
EMPLOYMENT
I 1448 AMERICANS WITH
DISABILITIES OTHER
I 1448 EDUCATION
LABOR
I 1710 FAIR LABOR
STANDARDS ACT
I )720LABOR/MGMT
RELATIONS
[ 1740 RAILWAY-LABOR ACT
| ] 751 FAMILY MEDICAL
LEAVE ACT (FMLA)
| ]760 OTHER LABOR
LITIGATION
[ | 791 EMPL RET INC
SECURITY ACT
IMMIGRATION
I 1462 NATURALIZATION
APPLICATION
I 1485 OTHER IMMIGRATION
ACTIONS
I 12'0
I 1220
I 1230
I 1240
I 1245
1 )2»0
LAND
CONDEMNATION
FORECLOSURE
RENT LEASE 4
EJECTMENT
TORTS TO LAND
TORT PRODUCT
LIABILITY
ALL OTHER
REAL PROPERTY
Checkifdemanded incomplaint:
CHECK IFTHIS IS A CLASS ACTION
UNDER FRCP 23
PRISONER CIVIL RIGHTS
| I 550 CIVIL RIGHTS
| I 555 PRISON CONDITION
]S60 CIVILOETAINEE
CONDITIONS OF CONFINEMENT
ACTIONS UNDER STATUTES
BANKRUPTCY
| 1422 APPEAL
28 USC 158
[ 1423 WITHDRAWAL
28 USC 157
PROPERTY RIGHTS
M 820 COPYRIGHTS
[ 1830 PATENT
I 1840 TRADEMARK
SOCIAL SECURITY
[ 1861 HIA (139511)
I 1882 BLACK LUNG (623)
( |B83 0IWC/OIVWV(405(9))
( ) 884 8SID TITLE XVI
{ | BBS RSI (405(g))
FEDERAL TAX SUITS
[ ]870 TAXES (U S PlamMI a
Oaltnaani)
1 )871 IRS-THIRD PARTY
26 USC 7609
OTHER STATUTES
376 FALSE CLAIMS
400 STATE
REAPPORTIONMENT
| 1410 ANTITRUST
[ 1430 BANKS 4 BANKING
I 1450 COMMERCE
( 1480 DEPORTATION
| 1470 RACKETEER INFLU
ENCED 4 CORRUPT
ORGANIZATION ACT
(RICO)
( ]480 CONSUMER CREDIT
11490 CABLE/SATELLITE TV
( 1850 SECURITIES/
COMMODITIES/
EXCHANGE
I!
1 1890 OTHER STATUTORY
ACTIONS
1 J891 AGRICULTURAL ACTS
| )893 ENVIRONMENTAL
MATTERS
( 1895 FREEDOM OF
INFORMATION ACT
( 1 898 ARBITRATION
[ | 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR
APPEAL OF AGENCY DECISION
[ 1950CONSTITUTIONALITYOF
STATE STATUTES

DEMAND $ OTHER
(fCS0OS,TAT^M ™IS CASE IS RELATED TO AC,VIL CASE NOW PENDING IN SONY?
JUDGE DOCKETNUMBER_
Check Y£Sonly il demanded in complaint
JURY DEMAND 11YES LNO
NOTE: You must alsosubmitat the time of filing the Statement of Relatedness form (Form IH-32)
(PLAClAN-x INONEBOXONLY) ORIGIN
H 1 Original D 2 Removed from LJ3 Remanded D * Reinstated or Q 5 Tranaferred from • 6 MutlWUlna Q 7 Appeal to District
Proeeedino stateCourt from Reopened (Specify District) Litigation Judge from
• a. .a,-*-™—.- Aepattt. Magrttraie Judge
«a pwtlMnpMMrttad
Judgment
Court
| | b. AtlMSKMM
party Is pro se.
tHACEAN x INONEBOXONLY) BASIS OF JURISOiaiON
D 1 U.S. PLAINTIFF Q 2 U.S. DEFENDANT [5] 3 FEDERAL QUESTION Q4 DIVERSITY
(U.S. NOT A PARTY)
IFDIVERSITY, INDICATE
CITIZENSHIP BELOW.
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
(Place an [X]in one box for Plaintiff and one box for Defendant)
PTF DEF
CITIZENOFTHIS STATE ( 11 [ ) 1 CITIZENOR SUBJECT OF A
FOREIGN COUNTRY
PTF DEF PTF DEF
I I 31 13 INCORPORATEDand PRINCIPALPLACE | )5 [ ]5
OF BUSINESS IN ANOTHER STATE
CITIZENOF ANOTHERSTATE |)2 1)2 INCORPORATEDor PRINCIPALPLACE ||4|J4 FOREIGNNATION
OF BUSINESS IN THIS STATE
PLAINTIFF(S) ADDRESSES) AND COUNTY(IES)
MAYA HAYUK
720 Lorimer Street #3R
Brooklyn, New York 11211
Kings County
1 16 [|6
DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
SONY MUSIC ENTERTAINMENT, 550 Madison Avenue, New York, NY 10022, New York County
EPIC RECORDS, INC., 550 Madison Avenue, 27th Floor, New York, NY10022, New York County
PARADIGM TALENTAGENCY, LLC, 360 N. Crescent Dr., Beverly Hills, CA 90210, Los Angeles County
42WEST, LLC, 220 West 42nd Street, 12th Floor, New York, NY 10036, New York County
BILLYOUNG PRODUCTIONS, INC., 750 Park Two Drive, Sugar Land, TX77478, Fort Bend County
SARA BAREILLES, 84 Grove St., Apt 9, New York, NY10014-3566, New York County, and 1343 14th St., Santa Monica, CA
90404, Los Angeles County
DEFENDANTS) ADDRESS UNKNOWN
REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME. I HAVE BEEN UNABLE. WITH REASONABLE DILIGENCE. TO ASCERTAIN
RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
Check one: THIS ACTION SHOULD BEASSIGNED TO: Q WHITE PLAINS |x] MANHATTAN
(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTS
COMPLAINT.)
DATE 08/18/2014 SIGN/^ytj^E^garTTORNEYJIFlaffJafflL. „ ADMITTED TOPRACTICE IN THIS DISTRICT
{] NO
M YES (DATE ADMITTED Mo.1J Yr 2012 I
RECEIPT # "^ Attorney Bar Code# AS2323
Magistrate Judge is to be designated by the Clerk of the Court.
Magistrate Judge MAG. JUDGE GQREHM js
Ruby J. Krajick. Clerk of Court by . Deputy Clerk, DATED.
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
so Designated.
00^
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
MAYA HAYUK,
Plaintiff,
v.
SONY MUSIC ENTERTAINMENT; EPIC
RECORDS, INC.; PARADIGM TALENT
AGENCY, LLC; 42WEST, LLC; BILL
YOUNG PRODUCTIONS, INC.; and SARA
BAREILLES,
Defendants.
Civil Action No.
COMPLAINT
Juty Trial Demanded
ECF Case
^«fi*
O"
Plaintiff Maya Hayuk, by her undersigned attorneys, brings this action against the
defendants Sony Music Entertainment; Epic Records, Inc.; Paradigm Talent Agency, LLC;
42West, LLC; Bill Young Productions, Inc.; and Sara Bareilles (individually, and collectively,
"Defendants") and asserts and alleges as follows:
Parties
1. Plaintiff Maya Hayuk ("Hayuk"), is a New York-based professional visual
artist who regularly creates, sells, and licenses original works of art.
2. Upon information and belief Sony Music Entertainment ("Sony") is a
Delaware general partnership transacting business within the State of New York, with its
principal place of business at 550 Madison Avenue, New York, New York 10022.
3. Upon information and belief, Epic Records, Inc. ("Epic Records") is a New
York corporation, transacting business within theState of New York, with its principal place
of business at 550 Madison Avenue, 27th Floor, New York, New York 10022.
4. Upon information andbelief, Paradigm Talent Agency, LLC ("Paradigm") is
a Delaware limited liability company, transacting business within the State of New York,
with its principal place of business at 360 North Crescent Drive, North Building, Beverly
Hills, California 90210.
5. Upon information and belief, 42West, LLC ("42West") is a Delaware limited
liability company with its principal place of business at 220 West 42nd Street, 12th Floor,
New York, New York 10036.
6. Upon information and belief, Bill Young Productions, Inc. ("Bill Young
Productions") is a Delaware corporation, transacting business within the State of New York,
with its principal place of business at 750Park Two Drive, SugarLand, Texas 77478.
7. Upon information and belief, Sara Bareilles ("Bareilles") is an individual,
transacting business in the State of New York, with addresses in Santa Monica, California,
and New York, New York.
Nature of the Complaint
8. This is an action for copyright infringement. The Defendants violated the
copyright laws, 17 U.S.C. § 101 et seq., by reproducing, distributing, and otherwise using,
Hayuk's original copyrighted work of art without her consent. Hayuk seeks damages,
appropriate injunctive relief, and recovery of her costs and attorneys' fees.
Jurisdiction and Venue
9. This Court has jurisdiction over the subject matter of this Complaint under
28 U.S.C. §§ 1331 and 1338(a).
10. On information and belief, this Court has personal jurisdiction over
Defendants in that Defendants conduct business throughout the State of New York,
including this District.
11. Venue is appropriate in this Court under 28 U.S.C. §§ 1391(b) and 1400(a) in
that Defendants are transacting business within this District. Further, venue is appropriate
since a substantial portion of the acts complained of herein was committed by Defendants
within this District.
Maya Hayuk and Chem Trails NYC
12. Hayuk is an internationally renowned visual artist. Her iconic murals,
paintings, and other artworks are highly sought after by collectors, corporations, and
individuals throughout the world.
13. Hayuk has received critical praise throughout her fine art career, whichspans
over two decades.
14. Hayuk's career includes more than 150 group and solo gallery shows,
installations, and murals throughout the United States and over a dozen foreign countries on
six continents.
15. Hayuk's artwork has been published in numerous books and magazines, and
has been featured on countless websites.
16. Hayuk often licenses her artwork for use on, among other things, apparel,
consumer electronics, and sporting goods.
17. Hayuk commands premium fees and royalties for the use of her artwork in
commercial settings.
18. In or around February 2014, Hayuk created an original work of art entided
Chem Trails NYC.
19. Chem Trails NYCwas a large-scale mural, measuring approximately 60 feet by
20 feet.
20. Chem Trails NYCwas painted and displayed on the Bowery Mural wall, a
well-known outdoor exhibition space located on the corner of Houston Street and Bowery
in New York City.
21. An image of Chem Trails NYC appears below:
22. On February 7, 2014, Hayuk caused her copyright in Chem Trails NYC to be
registered in the United States Copyright Office, such registration being assigned
Registration No. VA 1-173-957. A copy of the Certificate of Registration is attached as
Exhibit A.
23. Chem Trails NYC is whollycopyrightableunder the laws of the United States,
and Hayuk, the creator and sole owner of Chem Trails NYC, holds all copyright interests
therein.
Bareilles, Epic Records, Sony. Paradigm, and 42West
24. Bareilles is a prominent pop musician. She has a significant fan base, with
over three million followers on Twitter, five thousand Facebook fans, and almost two
hundred thousand followers on Instagram. She has sold over one million records, appeared
on national television shows, served as a judge for the popular singing competition The Sing
Off, has sold out venues for her live music performances, and has been nominated for
multiple industry awards, including five Grammy Awards.
25. Epic Records is Bareilles' record label. Epic Records publicizes Bareilles'
music-related activities, including her sound recordings, television appearances, and tours.
Epic Records distributes its promotional materials through numerous channels, including its
website, www.epicrecords.com, and on information and belief, to third parties for further
distribution.
26. Sony is the parent company of Epic Records. Sony also owns Bareilles'
official website, www.sarabmusic.com, and controls the content thereof.
27. Paradigm is a leading talent agency in the entertainment industry, with offices
in California, Georgia, and NewYork. Paradigm represents Bareilles, arranges for Bareilles'
live performances, creates publicity materials for Bareilles, and generally supports and
promotes Bareilles' endeavors in the entertainment industry.
28. 42West manages Bareilles' publicity, including media relations and tour
support.
29. On or around April 2014, without Hayuk's authorization, Chem Trails NYC
was prominendy featured in promotional photographs of Bareilles (individually,
"Photograph" and collectively, the "Photographs").
30. Defendants have extensively reproduced, displayed, created derivatives, and
otherwise engaged in unauthorized use of Chem Trails NYC to promote Bareilles, her
recordings, and her live performances.
31. In or around May 2014, the Photographs were used as the primary vehicle
for announcing and subsequendy promoting and advertising Bareilles' then upcoming Litde
BlackDress Tour (the "Tour").
32. Defendants displayed the Photographs on their respective websites and
social media pages, including Facebook andTwitter ("Defendants' Social Media"). Below are
representative examples of Tour promotions using the Photographs:
^ www.cplcrKortJf.com/n
TOUR ANNOUNCEMENT
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tews • wtgts • Raasts • vdhb - stoic
'« epic
epic.
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Chicago TOcatrt - Chicsgo, il.
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Blue WHs Bank Pmnllon - SoKon, MA
Mann Center PAC- PtiiiadelpHie, PA
Theater at MauBoit Square Garter - New 1
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£) https://www.facebook.com/sarabareilles
L
Sara Bareilles
It's happening. #iittleblackdresstour. Dates announced
next week. Coming to you with no pants. Wait. That
sounds weird. http://instagram.eom/p/nXQACRDCMP/
Like Comment - Share l7 2.236
tS KarenBonifacio Rutaquto,AlexandraRooney, TopComments•
Zavn Mirtic and 18,109 others like this.
HAIcx Cosu Come xo Brazil, Sara*
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33. Defendants have also authorized third parties to use the Photographs to
promotethe Tour and to sell tickets to Bareilles' live performances. Below is a representative
example of such use:
J; www.ticketmaster.cofn/Sara-Bareilles-tickets/artist/978402
ticketmaster
AlTfckatt > Mutt TieKKi > Rocli « Pop * Sara B
Rock and Pop
Sara Bareilles Tickets
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Friter Artist Tns-r-. or Venue
and Concort Dates Video
Greater Boston Area (1J
View: =
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15
TUE
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Boston. MA
07:30 PM
Sara BarellteB -LitOe Black
Dress Tour
Ortt*. Sara Barman. Hanrum
Find Tickets •
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TMU
Tlia Chicago Theatre
Chicago. H
07:30 PM
Sara Baronies- Liae Black
Dress Tour
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Find Tickets »
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Jacob* Pavilion at ttautica ffemMrty
Mauttca Pavilion)
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07:30 PM
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07:30 PM
Sara Bareilles - u»e Black
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Find Tickets >
Are you going to see Sart BaraMas?
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Dress Tour
Find Tickets >
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Mew York, NY Detain' ssra BareiM. Em*y
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34. Additionally, Defendants have used the Photographs to promote and sell
Bareilles' album entitled The blessed Unrest and to otherwise publicize, promote, andadvertise
Bareilles' endeavors in the entertainment industry. Representative examples of these
promotional uses are inserted below:
SARA BAREILLES
C L wrww.para^igmagtncv.com/divistons/arlist/index/ 3-3 5#photo_gatlerv
~ in«a«ramxoiivp/n()HZ«4jG!MX'
35. Defendants Bareilles, Sony, Epic Records, Paradigm, and 42West violated
Hayuk's copyrights by displaying, reproducing, and creating unauthorized derivatives of
Chem Trails NYC.
Bill Young Productions
36. Bill Young Productions is an audio-video production company that creates
marketing materials, including posters and videos, for concerts and touring performing
artists.
37. In or around April and May 2014, Bill Young Productions produced
promotional posters prominently featuring the Photographs (the "Posters"). A
representative example of the Posters is below:
10
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38. In addition, Bill Young Productions produced a video that featured extensive
use of Chem Trails NYC (the "Video").
39. Specifically, the Videoopenedwith the image of Chem Trails NYC, which was
thenmanipulated and animated, becoming the featured design element of the Video:
11
_•] www.byp.com/tour-info/3835
40. Following this display and manipulation of Chem Trails NYC, the Video
prominently features still images of Chem Trails NYC behind various moving images of
Bareilles singingand dancing.
12
41. Chem Trails NYC pervades the Video and, indeed, serves as the constant focal
point of the Video.
42. The Video has been distributed to numerous third parties to promote the
Tour.
43. The Video has been used as a television spot for an extensive nationwide
advertising campaign.
44. The Posters have been used nationwide to advertise the Tour.
45. Defendants knew or should have known of Hayuk's copyright in Chem Trails
NYCby virtue of Hayuk's prominent signature on Chem Trails NYC, ample press and social
13
media coverage of Chem Trails NYC, and by Hayuk's reputation in the art world. Directly
below is a photograph of Hayuk's signature on Chem Trails NYC.
46. Indeed, Chem Trails NYC is an enormously popular artwork and has
generated a great deal of media attention since its completion. Defendants exploited the
popularity and notoriety that Chem Trails NYChad developed in order to promote Bareilles.
47. Hayuk has suffered and continues to suffer damages and irreparable injury as
a result of Defendants' infringement of the Chem Trails NYCcopyright.
Count I
Copyright Infringement - Against All Defendants
48. Hayuk incorporates by reference paragraphs 1-47 of this Complaint,
inclusive, as if the same were fully set forth herein.
49. Hayuk is the owner of all right, title, and interest in and to the copyright of
14
Chem Trails NYC.
50. Hayuk has never authorized, licensed, or otherwise permitted Defendants to
reproduce, display, or otherwise use Chem Trails NYCor any copies thereof.
51. Without Hayuk's authorization, Defendants reproduced, displayed, and
otherwise used Chem Trails NYC. Such unauthorized use constitutes an infringement of
Hayuk's copyright for which she is entitled to damages and injunctive relief.
52. Hayuk has been damaged and continues to be damaged by Defendants'
infringement of her copyright in Chem Trails NYC.
Count II
Contributory Copyright Infringement - Against All Defendants
53. Hayuk repeats and realleges paragraphs 1—52 of this Complaint, inclusive, as
if the same were fully set forth herein.
54. Defendants caused, enabled, encouraged, facilitated, and induced others to
violate Hayuk's copyright in Chem Trails NYC by enabling, encouraging, inducing, and
facilitating the copying, distribution, and display of unauthorized derivatives of Chem Trails
NYC.
55. Upon information and belief, Defendants benefittedcommercially from such
unauthorized use of Chem Trails NYC.
56. Defendants' conduct constitutes contributory infringement of Hayuk's
copyright in Chem Trails NYC.
57. Hayuk has been damaged and continues to be damaged by Defendants'
contributoryinfringement of her copyrightin Chem Trails NYC
15
Prayer for Relief
WHEREFORE, Hayuk prays for judgment against Defendants as follows:
1. For a declaration that Defendants have directiy and/or secondarilyinfringed
Hayuk's copyright in Chem Trails NYCunder the Copyright Act;
2. For a preliminary order enjoining Defendants from all further use of Chem
Trails NYCduring the pendency of this litigation;
3. For a permanent injunction requiring Defendants, their respective agents,
servants, employees, officers, successors, licensees, and assigns and all
persons acting in concert or participation with each or any of them, or for
them, to cease and desist from infringing Chem Trails NYC, in any manner;
4. For an award of damages arising from Defendants' infringement of Hayuk's
copyright;
5. For an award of profits earned by Defendants from the infringement of
Hayuk's copyright in accordance with § 504(b) of the Copyright Act;
6. For an award, if elected by Hayuk, of statutory damages within the
provisions of the Copyright Act in a sum not less than $750.00, nor more
than $30,000.00, or if the Court finds that the infringement was committed
willfully, such statutory damages within the provisions of the Copyright Act
in a sum up to and including $150,000.00;
7. For an award of attorneys' fees, costs of suit and interest; and
8. For such other and further relief as the Court deems just and proper.
PLAINTIFF DEMANDS A TRIAL BYJURY ON ALL COUNTS.
16
Dated: August 18, 2014
Respectfully submitted,
MAYA HAYUK
Aaron Y. Silverstein (AS-2323)
Saunders & Silverstein LLP
14 Cedar Street, Suite 224
Amesbury, MA 01913
P: 978-463-9130
F: 978-463-9109
E: asilverstein@massiplaw.com
Attorneys for Plaintiff
Maya Hayuk
17
DEMAND FOR TURY TRIAL
Pursuant to Fed. R. Civ. P. 38(b), PlaintiffMaya Hayukhereby demands a jurytrial
on all triable issues raised by this Complaint.
Dated: August 18, 2014
SAUNDERS & SILVERSTEIN LLP
Aaron Y. Silverstein (AS-2323)
Saunders & Silverstein LLP
14 Cedar Street, Suite 224
Amesbury, MA 01913
P: 978-463-9130
F: 978-463-9109
E: asilverstein@massiplaw.com
Attorneys for Plaintiff
Maya Hayuk
18
EXHIBIT A
Certificate of Registration
This Certificateissuedunder the seal of the Copyright
Office in accordance with title 17. United States Code,
atteststhat registration has been madefor the work
identified below. The information on this certificate lias
been made a part of the Copyright Officerecords.
^n :/9u OLM&*-
Registerof Copyrights, United Statesof America
Title —
Title ofWork: CHEM TRAILS NYC
Completion/Publication
Author
Year of Completion: 2014
Author: Maya Hayuk
Author Created: 2-D artwork
Citizen of: United States
Year Born: 1969
Copyright claimant
Registration Number
VAu 1-173-957
Effective date of
registration:
February 7,2014
Domiciled in: United States
Copyright Claimant: Maya Hayuk
720 Lorimer Street, #3R. Brooklyn, NY, 11211, United States
Certification
Name: Aaron Y. Silverstein
Date: February 7.2014
Applicant's Tracking Number: 4.137.11
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