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JONATHAN M. DEER, Esq., State Bar No. 164837
jdeer@taflaw.net
STEVEN A. MORRIS, Esq., State Bar No. 126193
morris@taflaw.net
TURNER AUBERT & FRIEDMAN, LLP
8383 Wilshire Blvd, Suite 510
Beverly Hills, CA 90211
(323) 653-3900 (Telephone)
(323) 653-3021 (Telefax)
Attorneys for Plaintiff
MICHAEL J. BEZJIAN
RUED
CLERK. U.3. DtSTBICT COURT
2 0 2014
RAL DISTRICT OF CALIFORNIA
DEPUTY
gf
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CV14-6553li/^
CASE NO.:
COMPLAINT FOR:
1. Copyright Infringement
MICHAEL J. BEZJIAN, an individual
Plaintiffs,
VS.
KIDSLINE, LLC, a Delaware limited
liability company; and KIDS
BRANDS, INC., a Delaware
corporation,
Defendants.
2. Contributory Copyright
Infringement
3. Vicarious Copyright
Infringement
4. Removal Of Copyright
Management Information
5. Breach of Contract
7£>f f
JURY TRIAL DEMANDED
Plaintiff MICHAELJ. BEZJIAN("Bezjian") hereby brings this complaint
dgainst defendants KIDSLINE, LLCand KIDS BRANDS, INC., and states as
follows:
1. This is an action arising under the Copyright Act, 17 U.S.C. §§ 501
and 1202.
2. This Court has subject matter jurisdiction over these claims pursuant
1
COMPLAINT
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to 15U.S.C. § 1121,and28U.S.C. §§ 1331, 1338(a).
3. The Defendants are subject to personal jurisdiction in California.
4. Venue is proper in this district under 28 U.S.C. § 1391(b) and (c) and
1400(a) because the events giving rise to the claims occurred in this district, the
Defendant engaged in infringement in this district, and the Defendant is subject to
personal jurisdiction in this district.
PARTIES
5. MICHAEL J. BEZJIAN ("Bezjian") is a professional photographer
whose photographs appear in Rolling Stone Magazine, New York Post, Los
Angeles Times, CNN, US Magazine andmany otherplaces andare regularly sold
through Wire Image for use in print media, online and otherwise.
6. KIDS LINE, LLC, ("Kidsline") is a Delaware limited liability
company registered as a foreign corporation in California and withits principal
place of business in California.
7. Upon information and belief, KIDS BRANDS, INC., ("Kids
Brands") is a publically traded Delaware corporation and is the parent corporation
of KIDS LINE, LLC, which is its subsidiary.
8. Kids Brands sells children's clothing, furniture, and accessories
throughout the nation, including in California, and through major retailers
identified by a number of different brands, including "Kidsline", "Disney" and
others, much of which is distributed through its subsidiary, Kidsline.
COPYRIGHT WORK AT ISSUE
9. In 2009, Mr. Bezjian was recruited by Kidsline as an independent
contractor to photograph Kidsline products. Kidsline represented that it wished to
substantially expandits use of an independent photographer, integrating high-end
photography into its marketing in a manner similar to the major retail chain
"Pottery Barn". Kidsline indicated it had a limited budget to start, but would have
more money available in very short order. Kidsline and Mr. Bezjian agreed that he
COMPLAINT
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would start on a trial basis at a reduced rate and that Kidsline would only have a
limited license to use Mr. Bezjian's photography until a more permanent
arrangement was agreed upon or until Mr. Bezjian stopped providing services to
Kidsline. Kidsline represented that it would negotiate a more permanent
arrangement very shortly, but this would get the parties started.
10. Mr. Bezjian began shooting photographs of defendants' products,
including individual product shots and room layouts featuring defendants'
products. Over the course of providing these services, Mr. Bezjian sought
multiple times to negotiatethe more permanent arrangement whichwould include
a buyout of the copyrights in the photos. Each time, Kidsline represented that it
intended to enter into those negotiations in the near future.
11. Based upon Kidsline's assurances that it would negotiate these rights,
Mr. Bezjian continued to photograph Kidsline products and invested around
$150,000 in photography equipment required specifically to provide these
services.
12. In 2012, defendants sought to have Mr. Bezjian's assistants sign
agreements which Mr. Bezjian felt sought to grant the defendants the copyrights to
future photographs taken by Mr. Bezjian. He informed Kidsline that his assistants
did not ownrights to the photography and demanded that theynot be required to
sign the agreements. Kidsline assured Mr. Bezjian that "the intention of these
contracts are not the rights of the photography" but merely for the assistants'
work. The assistants did not sign the agreements.
13. Mr. Bezjian made further attempts to negotiate a deal for buyout of
the photographs including a transfer of the copyrights to defendants. Around
August and September of 2013, Kidsline once again indicated it would negotiate
in the near future. In Januaryof 2014, Mr. Bezjianfollowed up again. Once
again, Kidsline indicated it would address the issue in the near future. In March of
2014, Kidsline informed Mr. Bezjian that it would no longer use his services.
COMPLAINT
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14. At that time, Mr. Bezjian again reminded Kidsline that it did not own
the copyrights to his photographs, inviteddefendants to negotiate for purchase of
the rights, and asked themto stop using the images until they negotiated a
purchase. Kidsline failed to respond in any way.
INFRINGING ACTIVITY
15. After March, 2014, despite having no right, defendants continued and
continue today to use Mr. Bezjian's photographs, including:
(a) launching a brand new Kidsline website around June, 2014, on
which almost every image is one for which the copyright belongs to Mr. Bezjian.
The following is the home page for this website and the photographic image of the
monkey and its setting is an image for which Mr. Bezjian owns the copyright:
C A '•.! icidslirv.com
DOWer bootor
CMauic OHffJbdwuads fnah
brarjds* products* afcaut* resources.» vhfie to buy coatac
grow together with kidsline j
i^w pnxincts.
;\\\l\
(b) using Mr. Bezjian's images on the separate Kids Brands website. The
following is a copy of the home page for Kids Brand's website and the images
above "LaJobi", "CoCaLo" and "Kidsline" are images for which Mr. Bezjian owns
COMPLAINT
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the copyright:
rw, tnc - Gcot; * 8us<ne& Sea>cn - B< * u> Kid Brands. kK.**
gj SignOn- WetB„ C3legal IB Tofloat Cj News B Google D Stuff O Internet* O LF on YouTuoe 13 LF on F8 13 Faceoook t LF onTwitter Q Lnkedki t* Goool
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SEC Filings
Latest Press
releases
Kid Brands, inc
Announces Suspension
o' LaJooi Wood
Furniture Operations
Kid Brands. Inc Reports
First Quarter 2014
Results
Kid Brands, Inc Reports
Fourth Quarter And Full
Year 20'.3 Results
K.d Brands, Inc
Announces Amended
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(c) based upon information and belief, Kidsline continues to place
Mr. Bezjian's photographs on new product packaging;
(d) based upon information and belief, defendants continue to
distribute Mr. Bezjian's photographs to national distributors to continue
publishing them on websites, place them in catalogues, and place them on new
products distributed under the third parties' brands.
16. Based upon information and belief, Kidsline is using hundreds and
possibly thousands of Mr. Bezjian's images without authorization.
17. On June 3, 2014, counsel for Mr. Bezjian sent Kidsline a formal
written demand to cease and desist infringing on Plaintiffs' copyrights. Kidsline
failed to respond in any way. This lawsuit follows.
///
///
///
COMPLAINT
1 COUNT ONE
2 COPYRIGHT INFRINGEMENT
3 (Copyright Infringement - 17 U.S.C. § 501)
4 18. Plaintiff is, and at all relevant times has been, the copyright owner
5 under United States copyright code with respect to copyrights in and to
6 photographs taken by Plaintiff of defendants' products between 2009 and March,
7 2014 (the "Work").
8 19. On August 19, 2014, the United States Copyright Office received
9 applications for copyright registrations, deposits and proper fees for the images
10 which are sued upon in this cause of action, which includes thousands of images
11 created between 2011 and 2014. The only copies of additional images, including
12 those taken before 2011, are in the possession of Defendants. As soon as Plaintiff
13 obtains copies of those images, Plaintiff intends to register those copyrights and
14 amend this action to include infringement of those images, as well.
15 20. Plaintiff is informed and believes that, since at least June of 2014,
16 without authorization, Defendants duplicated and distributed Plaintiffs Work by
17 placing the same on defendants' websites, catalogues and product packaging and
18 by distributing the Work to third parties to use on their websites, catalogues and
19 packaging, and that Defendants continue such conduct today.
20 21. The conduct of Defendants is causing and, unless enjoined and
21 restrained by this Court, will continue to cause Plaintiffs great and irreparable
22 injury that cannot fully be compensated or measured in money. Plaintiffs have no
23 adequate remedy at law. Pursuant to 17 U.S.C. §§ 502 and 503, Plaintiffs are
24 entitled to injunctive relief prohibiting Defendant from further infringing
25 Plaintiffs' copyrights, and ordering Defendant to destroy all product packaging,
26 catalogues, website images and any other items which incorporate Mr. Bezjian's
27 images in violation of Plaintiffs' exclusive rights.
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6
COMPLAINT
1 22. Defendants' conduct was willful within the meaning of the Copyright
2 Act.
3 23. As a result of their wrongful conduct, Defendants are liable to
4 Plaintiff for copyright infringement pursuant to 17 U.S.C. § 501. Plaintiff has and
5 will continue to suffer substantial losses, includingbut not limitedto damage to
6 his business reputation and goodwill.
7 24. Plaintiff is entitled to recover damages, which include his losses and
8 any and all profits Defendants have made as a result of their wrongful conduct. 17
9 U.S.C. § 504. Alternatively, Plaintiff is entitled to statutory damages under 17
10 U.S.C. § 504(c).
11 25. In addition, because Defendants' infringement was willful, the award
12 of statutory damages should be enhanced in accordance with 17 U.S.C. §
13 504(c)(2).
14 26. Plaintiff is entitled to recover its attorneys' fees and costs of suit
15 pursuant to 17 U.S.C. § 505.
16 SECOND CAUSE OF ACTION
17 (Contributory Copyright Infringement)
18 27. Plaintiff repeats and incorporates by this reference each and every
19 allegation set forth in paragraphs 1 through 26, inclusive.
20 28. Numerous individuals and entities directly infringed Plaintiffs
21 copyrighted works.
22 29. Defendants induced, caused and materially contributed to the
23 infringing acts of others by encouraging, inducing, allowing and assisting others to
24 reproduce and distribute Plaintiffs works.
25 30. Defendants had knowledge of the infringing acts relating to
26 Plaintiffs copyrighted works.
27 31. The acts and conduct of Defendants, as alleged above in this
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7
COMPLAINT
1 Complaint constitute contributory copyright infringement.
2 THIRD CAUSE OF ACTION
3 (Vicarious Copyright Infringement)
4 32. Plaintiff repeats and incorporates by this reference each and every
5 allegation set forth in paragraphs 1 through 26, inclusive.
6 33. Numerous individuals and entities directly infringed Plaintiffs
7 copyrighted works.
8 34. Defendants had the right and ability to control the infringing acts of
9 the individuals or entities who directly infringed Plaintiffs works.
10 35. Defendants obtained a direct financial benefit from the infringing
11 activities of the individuals or entities who directly infringed Plaintiffs works.
12 36. The acts and conduct of Defendants, as alleged above in this
13 Complaint constitute vicarious copyright infringement.
14 FOURTH CAUSE OF ACTION
15 (Removal of Copyright Management Information)
16 37. Plaintiff repeats and incorporates by this reference each and every
17 allegation set forth in paragraphs 1 through 26, inclusive.
18 38. Many, if not all, of the digital photographic images which constitute
19 the Work contained copyright management information ("CMI") including digital
20 metadata identifying the date of the image, the camera with which it was
21 photographed, and the fact that Mr. Bezjian is the copyright owner. That
22 information is common for digital photographs taken by professional
23 photographers and is specifically included to notify the world of the identity of the
24 copyright holder and protect against copyright infringement.
25 39. Based upon information and belief, prior to copying and distributing
26 the Work, defendants removed that CMI from each image it distributed with the
27 intent to enable or facilitate copyright infringement, in violation of 17 U.S.C.
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8
COMPLAINT
1 §1202(b).
2 40. Defendants removed Mr. Bezjian's CMI knowing or having
3 reasonable grounds to know that this will enable, facilitate or conceal infringement
4 of Mr. Bezjian's rights in the Work protected under the Copyright Act.
5 41. Mr. Bezjian has been damaged.
6 42. The harm caused to Mr. Bezjian has and continues to be irreparable.
7 FIFTH CAUSE OF ACTION
8 (Breach of Contract)
9 43. Plaintiff repeats and incorporates by this reference each and every
10 allegation set forth in paragraphs 1 through 26, inclusive.
11 44. Mr. Bezjian and defendants had an oral agreement, confirmed in
12 emails, that defendants would not use the Work after Mr. Bezjian was no longer
13 being paid to shoot photographs for defendants, unless and until the parties
14 entered into a new agreement providing therefore, if ever, and that defendants
15 would negotiate in good faith to acquire those rights.
16 45. Defendants breached that agreement both by using the Work after Mr.
17 Bezjian was no longer shooting photographs for defendants and by refusing to
18 negotiate in good faith for use of the Work after Mr. Bezjian was no longer
19 shooting photographs for defendants.
20 46. Mr. Bezjian has been damaged thereby.
21 JURY DEMAND
22 47. Plaintiff hereby demands a jury trial in this case.
23 PRAYER FOR RELIEF
24 WHEREFORE, Plaintiff Michael Bezjian respectfully requests judgment as
25 follows:
26 (1) That the Court enter a judgment against Defendants that they have
27 willfully infringed Plaintiffs rights in federally registered copyrights under 17
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COMPLAINT
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U.S.C. §501,
(2) That the Court issue injunctive relief against Defendants, and that
Defendants, their agents, representatives, servants, employees, attorneys,
successors and assigns, and all others in active concert or participation with them,
be enjoined and restrained from copying, posting or making any other infringing
use or infringing distribution of photographs or other materials owned by or
registered to Plaintiff;
(3) That the Court enter an order of impoundment pursuant to 17 U.S.C.
§§ 503 and 509(a) impounding all infringing copies of Plaintiff photographs or
other materials, which are in Defendants' possession or under its control;
(4) That the Court order Defendants to pay Plaintiffs general, special,
actual and statutory damages including Plaintiffs damages and Defendants'
profits pursuant to 17 U.S.C. § 504(b), or in the alternative, enhanced statutory
damages pursuant to 17 U.S.C. §504(c)(2), for Defendants' willful infringement of
Plaintiffs copyrights, in an amount that is yet to be ascertained;
(5) That the Court award general damages for breach of contract, in
amount that is yet to be ascertained;
(6) That the Court order defendants to pay Plaintiff the costs of this
action and attorneys fees pursuant to 17 U.S.C. §§ 504-505.
(7) Such other and further relief as is just and proper.
Dated: August 19, 2014 TURNER AUBERT & FRIEDMAN, LLP
10
HONATHAN M. DEER
ittorneys for Plaintiffs
COMPLAINT
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
I. (a) PLAINTIFFS ( Check box if you are representing yourself Q )
MICHAELJ. BEZJIAN,an individual
DEFENDANTS (Check box if you are representing yourself Q )
KIDSLINE, LLC, a Delawarelimited liability company; and KIDS BRANDS, INC., a
Delaware corporation
(b) County of Residence of First Listed Plaintiff LOSANGELES
(EXCEPTINU.S. PLAINTIFF CASES)
County of Residence of First Listed Defendant
(INU.S.PLAINTIFF CASES ONLY)
(c) Attorneys {Firm Name, Address andTelephone Number) Ifyouare
representing yourself, provide the same information.
Jonathan M. Deer, Esq.,Turner Aubert &Friedman, LLP, 8383 Wilshire Blvd., Ste. 510,
Beverly Hills,CA90211 (323) 653-3900
Attorneys {Firm Name, Address andTelephone Number) Ifyouare
representing yourself, provide the same information.
II. BASIS OFJURISDICTION (Place an Xinone boxonly.) III. CITIZENSHIP OFPRINCIPAL PARTIES-For Diversity Cases Only
(Place an Xin one box for plaintiff and one for defendant)
PTF DEF
D 1
I 11. U.S. Government
Plaintiff
I I 2. U.S. Government
Defendant
I 3. Federal Question (U.S.
Government Not a Party)
| 14. Diversity (Indicate Citizenship
of Parties in Item III)
Citizen ofThis State • 1
Citizenof Another State n 2 | | 2
Citizen or Subject of a
Foreign Country l_l 3 LI 3
Incorporated or Principal Place
of Business in this State
PTF
• 4
Incorporated and Principal Place • 5
of Business in Another State
Foreign Nation fj 6
DEF
• *
• 5
• 6
IV. ORIGIN(Place an Xin one box only.)
r^i 1.Original i—i 2. Removedfrom i—i 3. Remanded from
I—I State Court I—I
• 4. Reinstated or i—i
Reopened I—I
5. Transferred from Another i—i
District (Specify) I I
6. Multi-
District
Litigation
Proceeding Appellate Court
V. REQUESTED IN COMPLAINT: JURY DEMAND: fx] Yes • No (Check "Yes" onlyifdemanded incomplaint.)
CLASS ACTION under F.R.Cv.P. 23: [J Yes [x] No fx] MONEY DEMANDED IN COMPLAINT: $ to bedetermined
VI. CAUSE OF ACTION (Cite theU.S. Civil Statute under which you are filing and write abrief statement ofcause. Do not cite jurisdictional statutes unless diversity.)
17 U.S.C. § 501. Defendants duplicated and distributed Plaintiffs copyrighted works without Plaintiffs permission.
VII. NATUREOFSUIT (Place an Xin one box only).
OTHER STATUTES
• 375 False Claims Act
• 400 State
Reapportionment
• 410 Antitrust
| | 430 Banksand Banking
• 450 Commerce/ICC
Rates/Etc.
• 460 Deportation
• 470 Racketeer Influ
enced &Corrupt Org.
[~| 480 Consumer Credit
• 490 Cable/Sat TV
• 850 Securities/Com
modities/Exchange
• 890 Other Statutory
Actions
• 891 Agricultural Acts
• 893 Environmental
Matters
• 895 Freedom of Info.
Act
• 896 Arbitration
899 Admin. Procedures
| | Act/Review of Appeal of
Agency Decision
• 950 Constitutionality of
State Statutes
FOR OFFICE USE ONLY:
CONTRACT
| | 110 Insurance
• 120Marine
fj 130Miller Act
• 140 Negotiable
Instrument
150 Recovery of
| | Overpayments
Enforcement of
Judgment
• 151 Medicare Act
152 Recovery of
• Defaulted Student
Loan (Excl. Vet.)
153 Recovery of
| | Overpayment of
Vet. Benefits
• 160 Stockholders'
Suits
r—| 190 Other
Contract
• 195 Contract
Product Liability
fj 196Franchise
REAL PROPERTY
• 210Land
Condemnation
| | 220 Foreclosure
|—I 230 Rent Lease &
'—' Ejectment
REAL PROPERTY CONT.
• 240Torts to Land
rj 245 Tort Product
Liability
[J 290All OtherReal
Property
• 310Airplane










315 Airplane
Product Liability
320 Assault, Libel &
Slander
330 Fed. Employers'
Liability
• 340Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury-
Med Malpratice
365 Personal Injury-
Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
._. 368 Asbestos
I I Personal Injury
Product Liability
Case Number:
IMMIGRATION
462 Naturalization
Application
465 Other
Immigration Actions
. ; »sTORTS : •,.,
PERSONAL PROPERTY
• 370Other Fraud
• 371 Truth inLending
380 Other Personal

Property Damage
• 385 Property Damage
Product Liability

BANKRUPTCY
422 Appeal 28
USC 158
• 423 Withdrawal 28
USC 157
CIVIL RIGHTS
• 440OtherCivil Rights
• 441 Voting
I | 442 Employment
• 443 Housing/
Accommodations
445 American with
• Disabilities-
Employment
446 American with
Disabilities-Other

• 448 Education
CV-71 (06/14) CIVIL COVER SHEET
PRISONER PETITIONS
Habeas Corpus:
I | 463 Alien Detainee
I—I 510Motions to Vacate
'—' Sentence
• 530General
• 535Death Penalty
Other
• 540Mandamus/Other
• 550Civil Rights
r—1 555 Prison Condition
560 Civil Detainee
LI Conditions of
Confinement
FORFEITURE/PENALTY
!_. 625 Drug Related
I I Seizure ofProperty 21
USC 881
• 690Other
LABOR
• 710 Fair Labor Standards
Act
|—I 720Labor/Mgmt.
*—' Relations
• 740Railway Labor Act
I—I 751 Family and Medical
• .
r—I 791 Employee Ret. Inc.
Leave Act
790 Other Labor
Litigation
791 Emplc
Security Act
'PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
SOCIAL SECURITY
• 861 HI A(1395ft)
• 862Black Lung (923)
• 863DIWC/DIWW (405 (g))
• 864SSIDTitle XVI
• 865RSI (405 (g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff or
Defendant)
871 IRS-ThirdParty 26 USC
7609
Page 1 of 3
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
VIII. VENUE: Your answers to the questions below will determine the division of the Court to which this case will be initially assigned. This initial assignment is subject
tochange, inaccordance with the Court's General Orders, uponreview bythe Court ofyour Complaint or Notice ofRemoval.
QUESTION A: Was this case removed
from state court?
• Yes \x\ No
If"no," skip to Question B. If"yes,"check the
box to the right that applies, enter the
corresponding division in response to
Question E, below, and continue from there.
STATE CASEWAS PENDING INTHE COUNTY OF::
INITIAL DIVISIONINCACD IS:
I I Los Angeles, Ventura, Santa Barbara, or SanLuis Obispo
Western
|~| Orange
• Riverside or SanBernardino
Q»«l*s--4-#%J
QUESTION B: Is the United States, or
one of its agencies or employees, a
PLAINTIFF in this action?
• Yes No
If"no," skip to Question C. If"yes,"answer
Question B.I, at right.
B.I. Do 50% or more of the defendants who reside in
the district reside in Orange Co.?
check one ofthe boxes to the right "m^
B.2. Do 50% or more of the defendants who reside in
the district reside in Riverside and/or San Bernardino
Counties? (Consider the two counties together.)
checkone of the boxes to the right
•<a£t&irr&t>l& •f*t^il>&&&t!v*S*--2>&.&ii. .-^feiv •'•• •
QUESTION C: Is the United States, or
one of its agencies or employees, a
DEFENDANT in this action?
• Yes fx] No
C.I. Do 50% or more of the plaintiffs who reside in the
district reside in Orange Co.?
check one ofthe boxes to the right ^^P*
If"no," skip to Question D. If"yes," answer
Question C.I, at right.
C.2. Do 50% or more of the plaintiffs who reside in the
district reside in Riverside and/or San Bernardino
Counties? (Consider the two counties together.)
check oneoftheboxes totheright mmT
Southern
Eastern
' *** 3frXS"-».fii «•>'/-.^rC^"'"^^.^
YES. Your case will initiallybe assigned to the Southern Division.
I-! Enter "Southern" inresponseto Question E, below, and continue
from there.
fj NO. Continueto Question B.2.
YES. Your case will initiallybe assigned to the Eastern Division.
fj Enter "Eastern" inresponseto Question E, below, and continue
from there.
NO. Your case will initiallybe assigned to the Western Division,
fj Enter "Western" inresponseto Question E, below, and continue
from there.
*?l * .flJS'iJ^irft - ^
r't& "-U*1:
YES. Your case will initially be assigned to the Southern Division.
fj Enter "Southern" inresponseto Question E, below, and continue
from there.
fj NO. Continueto Question C.2.
YES. Your case will initiallybe assigned to the Eastern Division.
• Enter"Eastern" inresponseto QuestionE, below,and continue
from there.
NO. Your case will initiallybe assigned to the Western Division.
I~l Enter"Western" in response to Question E, below, and continue
from there.
QUESTIOND: Location of plaintiffs and defendants?
A.
Orange County
B.
Riverside or San ••
Bernardino County
LosAngeles^Ventura,
Santa Barbara, or San
Luis Obispo County
Indicate the location(s) in which 50% or more of plaintiffswho residein thisdistrict
reside. (Checkup to two boxes, or leave blank ifnone of these choices apply.)
Indicate the location(s) in which 50% or more of defendants who reside in this
district reside. (Check up to two boxes, or leave blank if none of these choices
apply.)
D.I. Is there at least one answer in Column A?
• Yes [x] No
If"yes,"your case will initially be assigned to the
SOUTHERN DIVISION.
Enter "Southern" in response to Question E, below, and continue from there.
If"no," goto questionD2 to the right. ""^-
QUESTION E: Initial Division?
Enter the initial division determined by Question A, B,C, or Dabove:
QUESTION F: Northern Counties?
• • s
• • •
D.2. Is there at least one answer in Column B?
• Yes [X] No
If"yes,"your case will initiallybe assigned to the
EASTERN DIVISION.
Enter "Eastern" in response to Question E, below.
If"no," your case will be assigned to the WESTERN DIVISION.
Enter "Western" in response to Question E, below.
INITIAL DIVISION IN CACD
WESTERN
Do 50%ormore ofplaintiffs ordefendants in this district reside in Ventura, Santa Barbara, orSan Luis Obispo counties? Q Yes
No
CV-71 (06/14) CIVIL COVER SHEET
Page 2 of 3
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
IX(a). IDENTICAL CASES: Has this action been previously filedin this court?
If yes, list case number(s):
NO • YES
IX(b). RELATED CASES: Is thiscaserelated (as defined below) to anycasespreviously filed inthis court?
If yes, list case number(s):
NO • YES
Civil cases are related when they:
I | A. Arise from the same or closely relatedtransactions, happening, or event;
Q B. Call for determinationof the same or substantially relatedor similar questions of lawand fact; or
• C. For other reasons would entail substantial duplication of labor ifheard bydifferent judges.
Checkall boxes that apply. That cases may involvethe same patent, trademark, or copyright is not, in itself, sufficientto deem cases
related.
X. SIGNATURE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT):
r
^<J(^7
DATE: 08/19/2014
Notice to Counsel/Parties: The submissionbf this Civil Cover Sheet is required by Local Rule 3-1. This Form CV-71 and the information contained herein
neitherreplaces nor supplementsthe filing ar\dservide of pleadingsor other papers as requiredbylaw, except as provided bylocal rules of court. For
more detailed instructions, seeseparate instruction s/eet (CV-071 A).
Keyto Statistical codes relating to Social Security Cases:
Nature of Suit Code Abbreviation Substantive Statement of Cause of Action
All claims for health insurance benefits (Medicare) under Title 18, Part A,of the Social SecurityAct,as amended. Also,
include claims by hospitals, skillednursing facilities,etc., for certification as providers of services under the program.
(42U.S.C. 1935FF(b))
All claims for "Black Lung"benefits under Title4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. (30 U.S.C.
923)
All claimsfiled by insured workersfor disabilityinsurance benefits under Title2 of the Social SecurityAct,as amended; plus
all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405 (g))
All claimsfiledfor widows or widowers insurance benefits based on disabilityunder Title2 of the Social SecurityAct,as
amended. (42 U.S.C. 405 (g))
All claimsfor supplemental securityincome payments based upon disabilityfiled under Title16of the Social SecurityAct,as
amended.
861 HIA
862 BL
863 DIWC
863 DIWW
864 SSID
865 RSI
CV-71 (06/14)
All claims for retirement (old age) and survivors benefits under Title 2 of the SocialSecurityAct,as amended.
(42 U.S.C.405 (g))
CIVIL COVER SHEET Page 3 of 3
AO 440 (Rev. 06/12) Susimons in a Civil Action
United States District Court
for the
Central District of California
MICHAEL J. BEZJIAN, an individual,
Plaintiff(s)
v.
KIDSLINE, LLC, a Delaware limited liability company;
and KIDS BRANDS, INC., a Delaware corporation
Defendants)
SUMMONS IN A CIVIL ACTION
To: (Defendant's name and address) KIDSLINE, LLC, a Delaware limited liability company
CV14-6553 Sv*j ^^
Civil Action No.
KIDS BRANDS, INC., a Delaware corporation
A lawsuit has been filed against you.
Within21 days after serviceof this summons on you (not countingthe day you receivedit) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motionmust be servedon the plaintiff or plaintiffs attorney,
whose name and address are: Jonathan M. Deer, Esq. (SBN164837)
Turner Aubert & Friedman, LLP
8383 Wilshire Blvd., Ste. 510
Beverly Hills, CA 90211
Tel. (323) 653-3900
If you fail to respond, judgment by default will be enteredagainst you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
Date:
%- IX -N
CLERKOF COUM^^o' <•• /^
Jr' "<•» 'A* %
Signahfyeffi'tlerk'Vr Depufa Clerk
AO 440 (Rev. 06/12) Sumisons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (I))
This summons for (name ofindividual and title, ifany)
was received by me on (date)
Date:
D I personally served the summons on the individual at (place)
on (date) ; or
D I left the summons at the individual's residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual's last known address; or
O I served the summons on (name ofindividual) , who is
designated by law to accept service of process on behalf of (name oforganization)
on (date) ; or
O I returned the summons unexecuted because ; or
O Other (specify):
My fees are $ for travel and $ for services, for a total of $ q.00
I declare under penalty of perjury that this information is true.
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc:
^AO 121 (6/90)
TO:
Register of Copyrights
Copyright Office
Library of Congress
Washington, D.C. 20559
CLERK. U.S
DtSTTOCTCOURT
AUG
2 0 2014
FIIING
REPORT ON THE
OR DETERMINATION OF AN
ACTION OR APPEAL
REGARDING A COPYRIGHT
J
DISTfSCT OFCALFORMA
DEPUTY
IcENViALDIST
In compliance with the provisions of17 U.S.C. 508, you are hereby advised that acourt action or appeal has been filed
on the following copyright(s):
0 ACTION • APPEAL
DOCKET NO. DATE FILED
8/20/2014
COURT NAME AND LOCATION
United States District Court
Central District of California
Western Division
PLAINTIFF
Micheal J. Bezjian
DEFENDANT
Kidsline, LLC; Kids Brands, Inc.
(JV14-6553 SvuJ rm^
COPYRIGHT
REGISTRATION NO.
1Applied for
2 Applied for
3 Applied for
4 Applied for
5
TITLE OF WORK
Michael Bezjian Kidsline 2011 Vol. 1
Michael Bezjian Kidsline 2012 Vol. 1
Michael Bezjian Kidsline 2013 Vol. 1
Michael Bezjian Kidsline 2014 Vol. 1
In the above-entitledcase, the following copyright(s) have been included:
AUTHOR OR WORK
Michael Bezjian
Michael Bezjian
Michael Bezjian
Michael Bezjian
DATE INCLUDED INCLUDED BY
• Amendment • Answer • Cross Bill • Other Pleading
COPYRIGHT
REGISTRATION NO.
TITLE OF WORK
AUTHOR OF WORK
1
2
3
In the above-entitled case, afinal decision was rendered on the date entered below. Acopy ofthe order or judgment
together with the written opinion, if any, of the court is attached.
COPY ATTACHED
• Order • Judgment
CLERK
WRITTEN OPINION ATTACHED
• Yes • No
(BY) DEPUTY CLERK
DATE RENDERED
DATE
DISTRIBUTION:
1)Upon initiation ofaction, 2) Upon filing ofdocument adding copyright(s), 3) Upon termination ofaction,
mail copy toRegister ofCopyrights mail copy to Register ofCopyrights mail copy to Register ofCopyrights
4) In the event of an appeal, forward copy to Appellate Court
5) Case File Copy
NAME, ADDRESS, ANDTELEPHONE NUMBER OFATTORNEY(S)
OR OF PARTY APPEARING IN PRO PER
Jonathan M. Deer, Esq. (SBN 164837)
Turner Aubert & Friedman, LLP
8383 Wilshire Blvd., Ste. 510
BeverlyHills, CA 90211
(323) 653-3900; jdeer@taflaw.net
attorney(s) for; Plainitff, Michael J. Bezjian
FILED _,
CLERK. U.S. DISTRICTCOURT
AUG 2 0 2014
(CENTRAL DKSTRiCT OF CAUFOflNjAJ
UiAIUOKM
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Michael J. Bezjian
Plaintiff(s),
Kidsline, LLC; Kids Brands, Inc.
Defendant(s)
CASE NUMBER:
CV14-6553;v^ ity*^
CERTIFICATION AND NOTICE
OF INTERESTED PARTIES
(Local Rule 7.1-1)
TO: THE COURT AND ALL PARTIES OF RECORD:
The undersigned, counsel of record for Michael J. Bezjian, Plaintiff
orparty appearing inpro per, certifies that the following listed party (orparties) may have apecuniary interest in
the outcome ofthis case. These representations are made to enable the Court to evaluate possible disqualification
or recusal.
(List the names ofall such parties and identify their connection and interest. Use additional sheet ifnecessary.)
PARTY
Michael J. Bezjian
Kidsline, LLC
Kids Brands, Inc.
August 19, 2014
Date
CV-30 (05/13)
CONNECTION / INTEREST
Plaintiff
Defendant
Defendant
Attbcttey of recordfor (or name of partyappearing in proper):
Jonathan M. Deer, Esq.
NOTICE OF INTERESTED PARTIES