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Case 2:18-cv-01251 Document 1 Filed 02/15/18 Page 1 of 22 Page ID #:1

1 Edward K. Lee (SBN 294954)
elee@loeb.com
2 LOEB & LOEB LLP
10100 Santa Monica Blvd., Suite 2200
3 Los Angeles, CA 90067
Telephone: 310.282.2000
4 Facsimile: 310.282.2200
5 Tal E. Dickstein pro hac vice pending
tdickstein@loeb.com
6 C. Linna Chen pro hac vice pending
lchen@loeb.com
7 LOEB & LOEB LLP
345 Park Avenue
8 New York, New York 10154
9 Attorneys for Plaintiff
WORLD OF WONDER
10 PRODUCTIONS, INC.
11 UNITED STATES DISTRICT COURT
12 CENTRAL DISTRICT OF CALIFORNIA
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14 WORLD OF WONDER Case No.: 2:18-cv-01251
PRODUCTIONS, INC.,
15
Plaintiff, COMPLAINT FOR
16 (1) COPYRIGHT
v. INFRINGEMENT
17 (2) VIOLATIONS OF 17 U.S.C.
JOHN DOES 1-10, § 1202
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Defendants. DEMAND FOR JURY TRIAL
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Case 2:18-cv-01251 Document 1 Filed 02/15/18 Page 2 of 22 Page ID #:2

1 Plaintiff World of Wonder Productions, Inc. (“WOW”), by and through its
2 attorneys, hereby brings this complaint against Does 1-10 (“Defendants”), and
3 allege as follows:
4 NATURE OF THE ACTION
5 1. This is an action for copyright infringement under 17 U.S.C. § 501, et
6 seq. and for violations of the Digital Millennium Copyright Act, 17 U.S.C. § 1202,
7 arising out of Defendants’ unlawful theft and public dissemination of episodes of the
8 popular and critically-acclaimed reality television show “RuPaul’s Drag Race: All
9 Stars” (“All Stars”) series. All Stars, like the original series “RuPaul’s Drag Race”
10 (“Drag Race”), is hosted by the world’s most famous drag performer, RuPaul, and
11 features weekly competitions in which contestants design and construct custom
12 “drag” outfits, and compete in a series of unscripted and scripted performances for a
13 group of celebrity judges. In each weekly episode, one contestant is eliminated
14 from the competition.
15 2. Season 3 of All Stars began airing on VH1 on January 25, 2018 with
16 new episodes appearing every Thursday evening. As The New York Times recently
17 noted, “‘Drag Race’ has become a staple of modern television.” Drag Race was
18 nominated for eight Emmy awards in 2017 and won three, including a repeat win for
19 RuPaul as Outstanding Reality-Competition Host.
20 3. Plaintiff World of Wonder Productions, Inc. (“WOW”) produces and
21 owns the copyrights in and to every episode of All Stars, and continues to produce
22 original content involving RuPaul and/or the Drag Race and All Stars contestants.
23 4. Without WOW’s authorization, Defendants have obtained copies of
24 episodes of All Stars (the “All Stars Episodes” or “Episodes”), and have uploaded
25 them to social media platforms including Instagram, Twitter, and Reddit using the
26 username “RealityTVLeaks,” prior to the airing of each Episode.
27 5. As the username “RealityTVLeaks” implies, Defendants upload
28 content from other reality television series as well. Upon information and belief,

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1 Defendants intend to upload other WOW-created and produced content involving
2 RuPaul and/or the Drag Race and All Stars contestants.
3 6. Defendants brazenly tout their posts as “leaks” and “spoilers.”
4 Defendants have also removed copyright management information identifying
5 WOW as the copyright owner and author of the Episodes, and added misleading
6 copyright management information to the Episode clips they leak online, falsely
7 identifying Defendants as the copyright owners and authors of the Episodes.
8 7. A key driver of All Stars’ viewership, and therefore revenue to WOW,
9 is the reveal in each episode of the elimination of a contestant after a competition
10 before the judges. Defendants’ unauthorized and unlawful reproductions and public
11 disseminations are thus especially damaging to WOW because they occur prior to
12 the airing of the episode. Defendants have made clear that they intend to continue to
13 upload and disseminate infringing content prior to the airing of each new episode of
14 All Stars.
15 8. It is also clear that Defendants’ infringement is willful, as they have not
16 objected to any of WOW’s takedown requests directed to the social media
17 platforms, and, indeed, Defendants recently made their Instagram posts private and
18 viewable by “only” their more than 25,000 followers in an effort to evade WOW’s
19 detection.
20 9. Defendants’ unauthorized reproduction, distribution and public
21 performance of WOW’s Episodes contravenes the copyright laws of the United
22 States.
23 JURISDICTION AND VENUE
24 10. This is a civil action seeking damages and injunctive relief for
25 copyright infringement, arising under 17 U.S.C. §§ 101, et seq. This Court has
26 original subject matter jurisdiction over the action pursuant to 28 U.S.C. §§ 1331
27 and 1338(a), as this action asserts copyright claims arising under the laws of the
28 United States.

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1 11. Defendants, whose true identities are currently unknown to WOW,
2 acted in a collective and interdependent manner in the unlawful reproduction and
3 distribution of the All Stars Episodes. This Court has personal jurisdiction over
4 Defendants because Defendants either reside in, solicit, transact, or are doing
5 business within the State of California; they have committed unlawful and tortious
6 acts both within and outside California with the full knowledge that their acts would
7 cause injury here.
8 12. Each of the All Stars Episodes clearly states that it is produced, owned,
9 and copyrighted by WOW, whose business operations and offices are in California.
10 Therefore, all Defendants knew full well that their infringements of WOW’s
11 copyrights in the All Stars Episodes would cause harm and damage in California.
12 13. Defendants have had accounts with Instagram, Reddit and Twitter,
13 which are located in California. Moreover, Defendants’ user agreements with
14 Instagram, Reddit and Twitter each provide for application of California law. Thus,
15 Defendants should reasonably anticipate being subjected to jurisdiction in
16 California.
17 14. WOW’s claims arise out of Defendants’ conduct, which gives rise to
18 personal jurisdiction over Defendants.
19 15. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391(b)(2) and
20 1400(a). Although the true identities of each and every member of the collective
21 formed by the Defendants are unknown to WOW at this time, upon information and
22 belief, each Defendant may be found in this District and/or a substantial part of the
23 infringing acts complained of herein occurred in this District, and Defendants can
24 reasonably anticipate being required to appear in this District.
25 THE PARTIES
26 16. WOW is a corporation organized under the laws of the State of
27 California with its principal place of business in Los Angeles, California.
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1 17. The true names and capacities, whether individual, corporate, associate,
2 or otherwise, of defendants John Doe 1-10 are unknown to WOW, who therefore
3 sues said Defendants by such fictitious names. Defendants use the username
4 “RealityTVLeaks” on Instagram, Twitter, and on Reddit.com (“Reddit”) to commit
5 their infringing activity.
6 18. The Defendants include, among others, those persons who uploaded
7 and distributed the infringing content on Instagram, Twitter, and Reddit, as well as
8 any persons who obtained the infringing content for such reproduction and
9 distribution without the consent or authorization of WOW.
10 19. WOW is informed and believes, and based thereon alleges, that each of
11 the Defendants was and is the agent of the other Defendants, acting within the
12 purpose and scope of said agency. WOW is further informed and believes and
13 based thereon alleges, that each of the Defendants authorized and ratified the
14 conduct herein alleged of each of the other Defendants, and that each of the
15 fictitiously named Defendants herein is responsible in some manner for the
16 wrongful acts alleged herein, and WOW’s injuries as alleged herein were
17 proximately caused by such Defendants’ acts or omissions
18 20. WOW believes that information it will obtain in discovery will lead to
19 the identification of each Defendants’ true names and capacities, and will permit
20 WOW to amend its Complaint to allege the same.
21 ALLEGATIONS COMMON TO ALL CLAIMS
22 I. WOW’s Copyrighted Drag Race Episodes
23 21. Drag Race is a reality competition TV series produced by WOW, and
24 hosted by RuPaul, the world’s most famous and influential “drag” performer. In
25 Drag Race, RuPaul searches for America’s next drag superstar through a series of
26 challenges that test the contestants’ creativity, charisma, and talent. Each week, the
27 contestants participate in a mini challenge, a main challenge, a runway walk, and an
28 elimination challenge known as “Lip-Sync For Your Life,” where the bottom two

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1 contestants compete against each other by lip-syncing and dancing to a popular
2 song. For each challenge, the contestants design and construct a unique custom
3 outfit and makeup. Thus, the viewers tune in to each episode of Drag Race and All
4 Stars for the reveals of the contestants’ outfits, to watch their performances, and to
5 find out which contestant gets eliminated.
6 22. Drag Race’s viewership and recognition has grown considerably since
7 its premiere in 2009. RuPaul won two Emmys for hosting Drag Race, and the show
8 itself earned eight Emmy nominations in 2017. Since 2013, certain seasons of Drag
9 Race have been available on Netflix, making it available globally to 30 countries
10 worldwide. Drag Race’s popularity has led to two successful spinoff series: All
11 Stars and “RuPaul’s Drag U.”
12 23. All Stars is currently in its third season, and airs weekly on VH1. All
13 Stars maintains the same format as Drag Race, with the exception that the top two
14 performing contestants of the main challenge participate in the lip-sync competition,
15 with the winner of the lip-sync earning a $10,000 prize and choosing which one of
16 the bottom contestants gets eliminated.
17 24. Season 3 of All Stars is currently airing on VH1 under the following
18 schedule:
Number Title Broadcast Date
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301 All-Star Variety Show 1/25/2018
20 302 Divas Live 2/1/2018
303 The Bitchelor 2/8/2018
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304 All Stars Snatch Game 2/15/2018
22 305 Warhol Ball 2/22/2018
306 Handmaids to Kitty Girls 3/1/2018
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307 My Best Squirrelfriend's Dragsmaids Wedding Trip 3/8/2018
24 308 A Jury of their Queers 3/15/2018

25 25. WOW is the work-for-hire author of each All Stars Episode, and
26 thereby owns the United States copyrights in and to each of the All Stars Episodes.
27 WOW has submitted applications with the United States Copyright Office for the
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1 registration and, where appropriate, pre-registration, of each All Stars Episode, and
2 has complied with all applicable statutory registration requirements.
3 26. The All Stars Episodes are original works of authorship and constitute
4 copyrightable subject matter under the Copyright Act, 17 U.S.C. §§ 101, et seq.
5 27. WOW owns the exclusive right to distribute, reproduce, and publicly
6 perform the All Stars Episodes throughout the world, and has licensed such rights in
7 the United States to VH1. WOW also owns all clips and images from the All Stars
8 Episodes, and WOW is entitled to all of the protections and remedies for the All
9 Stars Episodes accorded to a copyright owner.
10 II. Defendants’ Infringing Activity
11 A. Julie Andrews Video
12 28. On February 2, 2018, Defendants, using the username
13 “RealityTVLeaks,” posted a video to Reddit’s subreddit,1 “RuPaulsDragRace,”
14 titled “*Spoiler* Bens performance as Julie Andrews!” (the “Julie Andrews
15 Video”). The Julie Andrews Video was available at URL
16 https://www.reddit.com/r/rupaulsdragrace/comments/7un02t/spoiler_bens_performa
17 nce_as_julie_andrews/. A screenshot of the Julie Andrews Video is shown below:
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12 29. Defendants were publicly performing the Julie Andrews Video via
13 Reddit, and by other means not yet known to WOW.
14 30. The Julie Andrews Video is a part of All Stars Episode 302, which
15 aired on February 1, 2018. Episode 302’s main challenge required the contestants to
16 dress, look like, and perform as a diva in a lip-sync dance routine inspired by the
17 classic TV special VH1 Divas Live. The Julie Andrews Video revealed, prior to the
18 airing of Episode 302, contestant BenDeLaCreme’s outfit, make up, and lip-sync
19 routine as the English actress and singer Julie Andrews.
20 31. Episode 302 contains copyright management information, identifying
21 WOW as its copyright owner. Without authorization from WOW, the copyright
22 owner, Defendants altered Episode 302’s copyright management information, and
23 added false and misleading copyright management information of their own,
24 showing the Reddit user RealityTVLeaks as the purported owner of the Julie
25 Andrews Video.
26 32. Defendants’ reproduction, distribution and public performance of the
27 Julie Andrews Video was not licensed or authorized by WOW.
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1 B. Thorgy Video
2 33. On February 1, 2018, Defendants using the username
3 “RealityTVLeaks” posted a video to their Instagram page featuring one of the All
4 Stars contestants named Thorgy (the “Thorgy Video”). The Thorgy Video was
5 available at the URL https://www.instagram.com/p/BerORjzh_Vu/?taken-
6 by=realitytvleaks and a screenshot of the video is shown below:
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17 34. The Thorgy Video was a part of then-unaired All Stars Episode 302,
18 and revealed the planning process behind the contestants’ performances for the main
19 divas lip-syncing challenge.
20 35. Episode 302 contains copyright management information, identifying
21 WOW as its copyright owner, which Defendants have subsequently removed
22 without authorization from WOW.
23 36. Defendants reproduced, distributed and publicly performed the Thorgy
24 Video via Instagram, and by other means not yet known to WOW, prior to the airing
25 of Episode 302, which took place later in the day on February 1, 2018.
26 37. Defendants’ reproduction, distribution and public performance of the
27 Thorgy Video was not licensed or authorized by WOW.
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1 C. Runway Reveals
2 38. On February 1, 2018, Defendants, using the username
3 “RealityTVLeaks,” posted a collage of images to Reddit’s subreddit
4 “RuPaulsDragRace,” titled “*Spoiler* All Stars 302 Runway Looks!,” at URL
5 https://www.reddit.com/r/rupaulsdragrace/comments/7umc8i/spoilerall_stars_302_r
6 unway_looks/ (the “Runway Reveal”). The Runway Reveal is shown below:
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22 39. The Runway Reveal is a collage of images from All Stars Episode 302.
23 The Runway Reveal revealed the contestants’ runway challenge costumes before the
24 airing of Episode 302, which took place later in the day on February 1, 2018. The
25 Runway Reveal is an unauthorized infringement of All Stars Episode 302.
26 40. All Stars Episode 302 contains copyright management information,
27 identifying WOW as its copyright owner. Defendants removed that copyright
28 management information without authorization from WOW, and added false and

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1 misleading copyright management information of their own, to show Instagram user
2 RealityTVLeaks as the purported owner of the Runway Reveal and of each of the
3 images contained therein.
4 41. Defendants’ reproduction, distribution and public performance of the
5 Runway Reveal was not licensed or authorized by WOW.
6 D. RuPaul Image
7 42. On January 26, 2018, Defendants, using the username
8 “RealityTVLeaks,” posted an image to Reddit’s subreddit “RuPaulsDragRace,”
9 titled “When the premiere airs in 25 mins” at URL
10 https://www.reddit.com/r/rupaulsdragrace/comments/7t0t7f/when_the_premiere_air
11 s_in_25_mins/ (the “RuPaul Image”). The RuPaul Image is shown below:
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23 43. The RuPaul Image was taken from All Stars Episode 302, and reveals
24 the outfit RuPaul wore on camera while judging that episode, before the episode
25 aired on February 1, 2018.
26 44. All Stars Episode 302 contains copyright management information,
27 identifying WOW as its copyright owner. Defendants removed that copyright
28 management information without authorization from WOW, and added false and

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1 misleading copyright management information of their own, showing Instagram
2 user RealityTVLeaks as the purported owner of the Rupaul Image.
3 45. Defendants’ reproduction, distribution and public performance of the
4 RuPaul Image was not licensed or authorized by WOW.
5 E. 10th Runway Look
6 46. On January 26, 2018, Defendants, using the username
7 “RealityTVLeaks,” posted an image to Reddit’s subreddit “RuPaulsDragRace,”
8 titled “SPOILER! Leaked 10th Queen RUNWAY Look!” at URL
9 https://www.reddit.com/r/rupaulsdragrace/comments/7t0crg/spoiler_leaked_10th_qu
10 een_runway_look/ (“10th Runway Look”). The 10th Runway Look is shown
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23 47. The 10th Runway Look revealed one contestant’s runway challenge
24 outfit for All Stars Episode 301, before that Episode aired later in the day on January
25 26, 2018.
26 48. All Stars Episode 301 contains copyright management information,
27 identifying WOW as its copyright owner. Defendants removed that copyright
28 management information, without authorization from WOW, and added false and

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1 misleading copyright management information of their own, showing Instagram
2 user RealityTVLeaks as the owner of the 10th Runway Reveal.
3 49. Defendants also posted the 10th Runway Look on Twitter on January
4 25, 2018, using the Twitter handle @RealityTVLeaks. The status update can be
5 accessed at URL https://twitter.com/RealityTVLeaks/status/956669516938862592
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18 50. Upon information and belief, Defendants are responsible for both the
19 RealityTVLeaks Instagram and RealityTVLeaks Twitter accounts. Both accounts
20 use the same “rabbit ear” television photo, and the RealityTVLeaks Instagram page
21 linked and directed followers to the RealityTVLeaks Twitter account as shown
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14 51. Defendants’ reproduction, distribution and public performance of the
15 10th Runway Look was not licensed or authorized by WOW.
16 F. Episode 3 Spoilers
17 52. On February 8, 2018, Defendants, using the username
18 “RealityTVLeaks,” posted five images to Instagram, revealing, among other things,
19 the contestant who was eliminated on the yet-to-be-aired Episode 3 (“Episode 3
20 Spoilers”). The Episode 3 Spoilers are shown below:
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19 53. The Episode 3 Spoilers revealed several of the contestants’ outfits, and
20 the last image shown above revealed which contestant would be eliminated at the
21 end of the episode, all before Episode 303 aired later in the day on February 8, 2018.
22 54. All Stars Episode 303 contains copyright management information,
23 identifying WOW as its copyright owner. Defendants removed that copyright
24 management information without authorization from WOW, and added false and
25 misleading copyright management information of their own, showing Instagram
26 user RealityTVLeaks as the purported owner of the Episode 3 Spoilers.
27 55. The Episode 3 Spoilers were not licensed by WOW.
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1 III. Defendants Intend to Continue to Infringe WOW’s Copyrights
2 56. Upon information and belief, Defendants will not cease infringing
3 WOW’s copyrights in the All Stars Episodes unless enjoined by the Court.
4 57. On or about February 1, 2018, an individual using the Reddit username
5 “sentaize” asked Defendants on the subreddit RuPaulsDragRace why Defendants
6 were leaking images and videos from All Stars prior to their airing.
7 58. Defendants, using the username “RealityTVLeaks,” responded that
8 they had or have access to the All Stars Episodes prior to their airing, and that they
9 intended to share portions of each All Stars Episode prior to its airing, stating “I’ll
10 be here every Thursday with bomb Leaks to keep ya quenched until the episode lol.”
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17 59. Moreover, Defendants have taken steps to evade WOW’s detection of
18 their infringements. Each time WOW discovers new infringements by Defendants,
19 WOW has sent takedown notices under the Digital Millennium Copyright Act
20 (“DMCA”) to the applicable social media platform. Upon information and belief, to
21 date, Defendants have not contested any of WOW’s takedown notices, or filed any
22 counter-notices. Instagram has taken down the post containing the Thorgy Video,
23 and Twitter has taken down the post containing the 10th Runway Look.
24 60. In response to Instagram taking down Defendants’ infringing content,
25 Defendants have made their Instagram posts “private,” so that they can be viewed
26 “only” by Defendants’ more than 25,000 followers, in an attempt to evade WOW’s
27 detection of Defendants’ continued infringements.
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1 61. Defendants confirmed this on February 6, 2018, with the following post
2 on their RealityTVLeaks Instagram page, stating “…World of Wonder staff that left
3 me no choice but to go private because they keep reporting my posts because I
4 Leaks their shit … mind ya business”:
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19 Reddit, encouraged other Reddit users to follow their posts on Instagram, stating
20 “[y]ou guys are going to be GAGGED at who goes home! [i.e., is eliminated from
21 the competition] . . . come to my IG [Instagram] to see her look”:
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1 63. As of February 9, 2018, Instagram appears to have suspended and/or
2 deactivated the RealityTVLeaks Instagram account. However, upon information
3 and belief, (a) if the account is suspended, Defendants will continue to infringe
4 WOW’s rights once the suspension period is over; and (b) if the account is de-
5 activated or banned, Defendants will create a new Instagram account in order to
6 continue to infringe WOW’s rights. Indeed, Defendants noted on RealityTVLeaks’
7 Instagram page that the account had previously been deactivated by Instagram.
8 64. Defendants have not licensed, nor sought to license, or otherwise seek
9 authorization or permission from WOW to reproduce, distribute or publicly perform
10 any portion of any of the All Stars Episodes.
11 FIRST CLAIM FOR RELIEF
12 Copyright Infringement
13 65. WOW incorporates by reference the allegations contained in
14 paragraphs 1 through 64 as though fully set forth herein.
15 66. The All Stars Episodes constitute copyrightable subject matter under
16 the Copyright Act, 17 U.S.C. §§ 101, et seq. WOW has submitted applications to
17 register and, where appropriate, preregister, its copyrights in and to the All Stars
18 Episodes with the United States Copyright Office and has complied with all
19 applicable statutory registration requirements.
20 67. WOW owns the United States copyrights in each of the All Stars
21 Episodes, including all images from the All Stars Episodes, along with the exclusive
22 right to distribute, reproduce, publicly perform, and create derivative works based
23 on the All Stars Episodes. WOW has licensed such rights in the United States to
24 VH1. WOW is entitled to all of the protections and remedies for the All Stars
25 Episodes accorded to a copyright owner.
26 68. In direct violation of WOW’s exclusive rights, Defendants have
27 willfully and directly infringed, and unless enjoined by this Court, will continue to
28 willfully infringe the copyrights in the All Stars Episodes by, among other things,

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1 reproducing, distributing, and publicly performing copyrighted elements of the All
2 Stars Episodes.
3 SECOND CLAIM FOR RELIEF
4 Violation of 17 U.S.C. § 1202
5 69. WOW incorporates by reference the allegations contained in
6 paragraphs 1 through 68 as though fully set forth herein.
7 70. Upon information and belief, at the time Defendants obtained the All
8 Stars Episodes without WOW’s authorization, each of the episodes included
9 copyright management information for that Episode, identifying WOW as the
10 copyright owner and author of the Episode.
11 71. Defendants removed or altered the copyright management information
12 from the All Stars Episodes before reproducing portions of the All Stars Episodes in
13 the form of the Julie Andrews Video, the Thorgy Video, the Runway Reveals, the
14 RuPaul Image, the 10th Runway Look, and the Episode 3 Spoilers.
15 72. Defendants also added false and misleading copyright management
16 information to the Julie Andrews Video, the Runway Reveals, the RuPaul Image,
17 the 10th Runway Look, and the Episode 3 Spoilers, by identifying themselves,
18 under the Instagram username “RealityTVLeaks,” as the purported owners and/or
19 authors of those works.
20 73. Defendants, knowingly and with the intent to induce, enable, facilitate
21 or conceal their copyright infringement, removed and altered the copyright
22 management information associated with the All Stars Episodes, including but not
23 limited to the name of the author of the All Stars Episodes, the name of the owner of
24 the All Stars Episodes, the terms and conditions for the use of the All Stars
25 Episodes, and identifying numbers or symbols referring to such information, before
26 distributing, reproducing, and publicly performing the works.
27 74. Defendants, without the authority of the copyright owner (WOW),
28 intentionally removed or altered copyright management information.

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1 75. Defendants distributed copyright management information knowing
2 that the copyright management information had been removed or altered without the
3 authority of WOW, the copyright owner.
4 76. Defendants distributed and/or copied works, knowing that copyright
5 management information had been removed or altered without the authority of the
6 copyright owner (WOW).
7 77. Defendants engaged in the above described acts despite knowing or
8 having reasonable grounds to know that the above acts would induce, enable,
9 facilitate or conceal an infringement of WOW’s rights under Title 17 of the United
10 States Code.
11 PRAYER FOR RELIEF
12 WHEREFORE, WOW respectfully requests that this Court enter judgment
13 against Defendants as follows:
14 1. That the Court find that Defendants have willfully infringed WOW’s
15 copyrights in the All Stars Episodes;
16 2. That the Court find that Defendants have violated 17 U.S.C. § 1202;
17 3. That the Court find that as a direct and proximate result of Defendants’
18 foregoing acts, WOW is entitled to the following damages:
19 a. At WOW’s election, statutory damages of $150,000 for each
20 separate All Stars Episode infringed, pursuant to 17 U.S.C. § 504(c), or WOW’s
21 actual damages sustained as a result of Defendants’ acts of copyright infringement
22 and Defendants’ profits obtained as a result of their acts of copyright infringement;
23 b. At WOW’s election, statutory damages of $25,000 for each
24 violation of 17 U.S.C. § 1202, or WOW’s actual damages and Defendants’ profits,
25 pursuant to 17 U.S.C. § 1203(c); and
26 c. WOW’s reasonable attorneys’ fees and costs pursuant to 17
27 U.S.C. §§ 101, et seq., and 17 U.S.C. §§ 505, 1203;
28

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A Limited Liability Partnership 20 COMPLAINT
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Case 2:18-cv-01251 Document 1 Filed 02/15/18 Page 21 of 22 Page ID #:21

1 4. That the Court find that the threat of irreparable harm to WOW as a
2 result of Defendants’ conduct leaves WOW without adequate remedy at law, and
3 therefore that WOW is entitled to an injunction restraining Defendants, their agents,
4 servants, employees, attorneys, successors, assigns, subsidiaries, and all persons,
5 firms, and corporations acting in concert with them, from directly or indirectly
6 (a) infringing the copyrights in the All Stars Episodes, including but not limited to
7 continuing to distribute, reproduce or publicly perform any works derived or copied
8 from the All Stars Episodes, (b) violating 17 U.S.C. § 1202, and (c) from
9 participating or assisting in any of the foregoing activities;
10 5. That the Court enjoin Defendants, their agents, servants, employees,
11 attorneys, successors, assigns, subsidiaries, and all persons, firms, and corporations
12 acting in concert with them, from directly or indirectly (a) infringing WOW’s
13 copyrights in the All Stars Episodes, including by distributing, reproducing or
14 publicly performing any works derived or copied from the All Stars Episodes,
15 (b) violating 17 U.S.C. § 1202, and (c) from participating or assisting in any such
16 activity;
17 6. That, pursuant to 17 U.S.C. § 503, the Court order the impounding,
18 destruction or other reasonable disposition of all copies of the All Star Episodes
19 found to have been made or used by Defendants in violation of WOW’s rights and
20 7. That the Court grant such other, further relief as it deems just and
21 proper.
22
23 Dated: February 15, 2018 LOEB & LOEB LLP
24
By: /s/ Edward K. Lee
25 Edward K. Lee
Tal E. Dickstein pro hac vice pending
26 C. Linna Chen pro hac vice pending
Attorneys for Plaintiff
27 WORLD OF WONDER
PRODUCTIONS, INC.
28

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A Limited Liability Partnership 21 COMPLAINT
Including Professional
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Case 2:18-cv-01251 Document 1 Filed 02/15/18 Page 22 of 22 Page ID #:22

1 DEMAND FOR JURY TRIAL
2 Plaintiffs demand a trial by jury as provided by Rule 38 of the Federal Rules
3 of Civil Procedure.
4 Dated: February 15, 2018 LOEB & LOEB LLP
5
By: /s/ Edward K. Lee
6 Edward K. Lee
Tal E. Dickstein pro hac vice pending
7 C. Linna Chen pro hac vice pending
Attorneys for Plaintiff
8 WORLD OF WONDER
PRODUCTIONS, INC.
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A Limited Liability Partnership 22 COMPLAINT
Including Professional
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