Case 3:11-cv-01530-GAG Document 1

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

Dennis Mario Rivera Plaintiffs v. Méndez & Compañía, Heineken, Luis Álvarez, Jane Doe, and the Legal Conjugal Partnership they Both Comprise, Insurance Company ABC, Store XYZ, Company 123, John Doe, Susan Roe Defendants Copyright Infringement and Permanent and Preliminary Injunction Plaintiff Demands Trial By Jury CASE No.:

COMPLAINT FOR COPYRIGHT INFRINGEMENT AND INJUNCTIVE RELIEF I. JURISDICTION AND VENUE 1. This action arises under the Copyright Laws of the United States, Title 17 U.S.C. § 101 the jurisdiction of this Court is founded on Title 28 U.S.C. § 1338 (a)(b) and Title 28 U.S.C. § 1331 of the Judicial Code with Supplementary Jurisdiction founded on Title 28 U.S.C. § 1367 of the Judicial Code for violations of Puerto Rico Moral Rights statutes. 2. Accordingly, venue is properly laid in this court under Title 28 U.S.C. § 1400(a) and § 1391(b), defendant or his agent resides or may be found in the district. II. PARTIES 3. Plaintiff, DENNIS MARIO RIVERA, is a known painter, visual artist, musician and actor with a career of over 30 years in the industry.

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4. Defendant MÉNDEZ & COMPAÑÍA is company or corporate entity registered under the laws of Puerto Rico or any state in the United States of America, with its principal office and operations located in Road 20, Km 2.4, Guaynabo, Puerto Rico, 00969, where defendants produce, display, and distribute for profit of artworks and unauthorized derivative works of the Plaintiff for the annual Puerto Rico HEINEKEN Jazz Fest (hereafter HJF) for the years 2010 and 2011. MÉNDEZ & COMPAÑÍA is jointly liable for all copyright violations alleged in the complaint. 5. Defendant HEINEKEN is one of the world’s leading consumer and corporate brands that owns and manages one of the world's leading portfolios of beer brands whose brand HEINEKEN beer is distributed and sold in Puerto Rico by defendant MÉNDEZ & COMPAÑÍA. HEINEKEN is the sponsor of the HJF 2010 and 2011 and is jointly liable for the production, display, and distribution for profit of artworks and unauthorized derivative works of the Plaintiff for the HJF. HEINEKEN’s world headquarters are located at Tweede Weteringplantsoen 2, 1017 ZD Amsterdam, The Netherlands. 6. Defendant LUIS ÁLVAREZ is Vice President of the liquor division of defendant MÉNDEZ & COMPAÑÍA and Executive Director of the HJF, who at all times alleged in the complaint, authorized the production, display, and distribution for profit of artworks and unauthorized derivative works of the Plaintiff for the HJF 2010 and 2011, including but not limited to, the creation of the HJF 2010 and 2011 label and corporate identity, marketing pieces such as posters, bus shelters and related paraphernalia, and HJF 2010 and 2011 event backdrops and merchandising such as t-shirts and program guides. 7. Defendant JANE DOE is the fictitious name of defendant Luis Álvarez’s wife, with who, upon Plaintiff’s belief, he had comprised a Legal Conjugal Partnership, all being jointly liable for damages resulting from the production, display, distribution, and distribution for profit of artworks and unauthorized derivative works of the Plaintiff for the HJF 2010 and 2011. 8. Defendant Insurance Company, ABC is the fictitious name of an insurance company that upon Plaintiff’s belief, during all the times herein mentioned, had in

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full effect an insurance policy with an advertising injury provision or errors and omission or any other provision with coverage over this claim. This insurance company is a corporation and/or legal entity organized under the Laws of the Commonwealth of Puerto Rico or any state of the United States, doing business in Puerto Rico and with its principal offices in the Commonwealth of Puerto Rico or any state of the United States. Insurance Company ABC is jointly liable for all copyright violations alleged in the complaint. The real name is unknown at this time and will be substituted pursuant to the Federal Rules of Civil Procedure once the real name is made known. 9. Defendant STORE XYZ is the fictitious name any store located in Puerto Rico where defendants produced, displayed, distributed, and sold for profit works and unauthorized derivative works of the Plaintiff. STORE ABC is jointly liable for all copyright violations alleged in the complaint. The real name is unknown at this time and will be substituted pursuant to the Federal Rules of Civil Procedure once the real name is made known. 10. Company 123 is the fictitious name of any company or corporate entity jointly liable for the produce, display, distribute, and sells unauthorized derivative works of The Artist. Company 123 is jointly liable for all copyright violations alleged in the complaint. The real name of Company 123 is unknown at this time and will be substituted pursuant to the Federal Rules of Civil Procedure once the real name is made known. 11. John Doe and Susan Roe are the fictional names of any person jointly liable for all copyright violations alleged in the complaint, whose names and identities are unknown at this moment. The real name of John Doe and Susan Roe are unknown at this time and will be substituted pursuant to the Federal Rules of Civil Procedure once the real name is made known. III. Facts 12. The HEINEKEN JAZZ FEST (HJF) is an annual event organized, marketed, produced and sponsored by defendants since the year 1991.

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13. The Plaintiff, Dennis Mario Rivera, a known painter and visual artist with a career of more than 30 years in the industry. 14. The Plaintiff produces, displays, distributes, and sells works of art in different styles and media of the visual arts. 15. Defendants approached the Plaintiff in 1998 with the purpose of acquiring the artwork and corporate image for purposes of branding each annual HJF. 16. Each year thereafter, up until 2009, Plaintiff and defendants enjoyed a solid contractual relationship whereby the former would license a specific work of art to the later which was to be used specifically for branding each annual HJF. 17. Under the terms of the license, defendants paid a specific sum of money to Plaintiff who in turn would allow defendants to reproduce, display and distribute copies of each licensed work for use in relation to each HJF’s label and corporate identity, marketing pieces such as posters, bus shelters and related paraphernalia, and HJF event backdrops and merchandising such as t-shirts and program guides. 18. Defendants could not create unauthorized derivative works under the terms of the license. 19. Defendants could not create compilations utilizing previously licensed works under the terms of the license, defendant. 20. Plaintiff did not license further use of the artworks once each annual HJF event ended. 21. Defendants had to license a new piece of artwork for each year of the HJF, with each licensed work becoming the HJF’s identity for the specific year of the event for which the license was acquired. 22. Plaintiff did not license further use of the artwork once each HJF event ended. 23. From 1999 through 2009, defendants acquired licenses from Plaintiff to use the following artworks exclusively for each respective annual HJF: a. Generic Piece #1, 38” by 50” mixed media on paper licensed exclusively for HJF 1999.

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b. Generic Piece #2, 38” by 50” mixed media on paper licensed exclusively for HJF 2000. c. Chucho Valdes, 38” by 50” mixed media on paper licensed exclusively for HJF 2001. d. Patato Veldés, 38” by 50” mixed media on paper licensed exclusively for HJF 2002. e. Chick Corea, 38” by 50” mixed media on paper licensed exclusively for HJF 2003. f. Gato Barbieri, 38” by 50” mixed media on paper licensed exclusively for HJF 2004. g. Gal Costa, 38” by 50” mixed media on paper licensed exclusively for HJF 2005. h. Poncho Sánchez, 38” by 50” mixed media on paper licensed exclusively for HJF 2006. i. Arturo Sandoval, 38” by 50” mixed media on paper licensed exclusively for HJF 2007. j. Jerry & Andy González, 38” by 50” wood cut on paper licensed exclusively for HJF 2008. k. Giovanni Hidalgo, 38” by 50” mixed media on paper licensed exclusively for HJF 2009. 24. Each year of the HJF from 1998 through 2011, plaintiff’s licensed artworks were used to create label and corporate identity, marketing pieces such as posters, bus shelters and related paraphernalia, and HJF event backdrops and merchandising such as t-shirts and program guides. 25. After a twelve year relationship and just prior to the 2010 edition of the HJF, which was to mark the 20th anniversary of the event, defendant Luis Álvarez held a meeting with Plaintiff at the El Galeón restaurant in San Juan, where Plaintiff was informed that defendants would not be using or licensing any more Dennis Mario works of art to brand the HJF.

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26. In the same meeting, defendant Luis Álvarez informed Plaintiff that for the 2010 edition, artist Jose Luis Díaz de Villegas would be commissioned to create the 20th anniversary artwork to be used in the HJF. 27. Plaintiff then specifically told defendant Luis Álvarez that none of the previously licensed works from 1998 through 2009 were to be used in the 20th anniversary HJF of 2010 or any future HJF events. 28. Defendant Luis Álvarez later gave newspaper El Nuevo Día an interview where, apart from displaying artist José Luis Díaz de Villegas’s artwork for HJF 2010, Mr. Álvarez announced publicly for the first time that HJF 2011 and future artworks were to be selected by a panel of judges who would evaluate submitted proposals from local artists. 29. For the 20th anniversary HJF 2010, defendants, without obtaining a license, willfully reproduced, displayed and distributed for profit copies of the plaintiff’s works for the HJF 2010 label and corporate identity, marketing pieces such as posters, bus shelters and related paraphernalia, and HJF 2010 event backdrops and merchandising such as t-shirts and program guide individually, as derivative works and in the form of a compilation. 30. Plaintiff has been able to identify the following specific violations of his copyright as follows (defendants do not own copyright or have a license for the following): a . For all artworks named in paragraph #23, supra, Defendant Méndez & Compañía has displayed each individual artwork in their website http://www.mendezcopr.com . Defendants fail to identify Plaintiff as the author of the works. b . For artwork titled Chucho Valdes licensed exclusively for HJF 2001, defendants have utilized copies of the work and unauthorized derivative works for (1) the 20th Anniversary letterhead / corporate identity; (2) for the back-drop of the HJF 2010 musical event. c . For artwork titled Gato Barbieri licensed exclusively for HJF 2004, defendants have utilized copies of the work and unauthorized derivative

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works for (1) the 20th Anniversary letterhead / corporate identity; (2) in the HJF program guide; (3) for the back-drop of the HJF 2010 musical event; (4) for Bus Shelter advertising; (5) for newspaper and magazine articles and promotions; (6) for t-shirts; and (7) printed on the six-pack packaging of HEINEKEN Beer sold throughout the island. d. For artwork titled Gal Costa licensed exclusively for HJF 2005, defendants have utilized copies of the work and unauthorized derivative works for (1) the 20th Anniversary letterhead / corporate identity. e. For artwork titled Poncho Sánchez licensed exclusively for HJF 2006, defendants have utilized copies of the work and unauthorized derivative works for (1) in the HJF program guide; (2) for the back-drop of the HJF 2010 musical event; (3) for Bus Shelter advertising; (4) for newspaper and magazine articles and promotions; (5) for t-shirts; and (6) printed on the six-pack packaging of HEINEKEN Beer sold throughout the island. f. For artwork titled Arturo Sandoval licensed exclusively for HJF 2007, defendants have utilized copies of the work and unauthorized derivative works for (1) the 20th Anniversary letterhead / corporate identity; (2) in the HJF program guide; (3) for the back-drop of the HJF 2010 musical event; (4) for Bus Shelter advertising; (5) for newspaper and magazine articles and promotions; (6) for t-shirts; and (7) printed on the six-pack packaging of HEINEKEN Beer sold throughout the island. g. For artwork titled Jerry & Andy González licensed for HJF 2008, defendants have utilized copies of the work and unauthorized derivative works for (1) in the HJF program guide; (2) for the back-drop of the HJF 2010 musical event; (3) for Bus Shelter advertising; (4) for newspaper and magazine articles and promotions; (5) for t-shirts; and (6) printed on the six-pack packaging of HEINEKEN Beer sold throughout the island. h. For artwork titled Giovanni Hidalgo licensed exclusively for HJF 2009, defendants have utilized copies of the work and unauthorized derivative works for (1) the 20th Anniversary letterhead / corporate identity; (2) in

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the HJF program guide; (3) for the back-drop of the HJF 2010 musical event; (4) for Bus Shelter advertising; (5) for newspaper and magazine articles and promotions; (6) for t-shirts; and (7) printed on the six-pack packaging of HEINEKEN Beer sold throughout the island. 31. Defendants destroyed the integrity of Plaintiff’s works when creating unauthorized derivative works in the form collages and compilations that fuse together the artworks listed in paragraph #30, supra. 32. Defendants attacked the paternity of the works by (1) making a false designation of origin in the 2010 HJF program guide, wherein they included copies of Plaintiff’s works and unauthorized derivative works while only naming artist Jose Luis Díaz de Villegas as the creator of all Artwork contained in the Program Guide; (2) publishing copies of plaintiff’s works listed in paragraph #23, supra, in their website without naming plaintiff as the author; and (3) Defendants publicly hailed artist Jose Luis Díaz de Villegas and other contributors of the HJF during the HJF 20th anniversary activities of 2010 but never once mentioned Plaintiff, all the while the latter’s works and unauthorized derivative works had been reproduced, displayed, distributed and sold for profit in connection with the event. 33. Plaintiff, through information or belief claims that other infringements have occurred that may only be discovered when disclosed by defendants when defending this case. 34. Plaintiff, through information or belief claims that without obtaining a license, Defendants will reproduce, display and distribute for profit unauthorized derivative pieces of the plaintiff’s works for the HJF 2011 label and corporate identity, marketing pieces such as posters, bus shelters and related paraphernalia, and HJF 2011 event backdrops and merchandising such as t-shirts and program guide in the form of collages and compilations containing unlicensed works of the Plaintiff. 35. Plaintiff, through information or belief claims that Defendants will continue to destroy the integrity and attack the paternity oh his works.

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36. Plaintiff will identify infringements for the HJF 2011 edition as they occur or when disclosed by defendants when defending this case. IV. CAUSES OF ACTION A. COPYRIGHT INFRIGMENT 37. Plaintiff realleges paragraphs one (1) through thirty six (36) of this complaint. 38. Plaintiff has registered the copyright for all infringed works listed in paragraph 23, supra. 39. The Defendants had access to Plaintiff’s artworks due to previous expired license agreements. 40. Defendants willfully reproduced, displayed, and distributed for profit Plaintiff’s artworks and / or created unauthorized derivative works for HJF 2010 and 2011 of the following1: a. Generic Piece #1 licensed for HJF 1999 b. Generic Piece #2 licensed for HJF 2000 c. Chucho Valdes licensed for HJF 2001 d. Patato Veldes licensed for HJF 2002 e. Chick Corea licensed for HJF 2003 f. Gato Barbieri licensed for HJF 2004 g. Gal Costa licensed for HJF 2005 h. Poncho Sánchez licensed for HJF 2006 i. Arturo Sandoval licensed for HJF 2007 j. Jerry & Andy González licensed for HJF 2008 k. Giovanni Hidalgo licensed for HJF 2009
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Section 106 of the 1976 Copyright Act lists exclusive rights of authors and owners of copyrighted works. “Subject to sections 107 through 122, the owner of copyright under this title has the exclusive rights to do and to authorize any of the following: (1) to reproduce the copyrighted work in copies or phonorecords; (2) to prepare derivative works based upon the copyrighted work; (3) to distribute copies or phonorecords of the copyrighted work to the public by sale or other transfer of ownership, or by rental, lease, or lending… …(5) in the case of literary, musical, dramatic, and choreographic works, pantomimes, and pictorial, graphic, or sculptural works, including the individual images of a motion picture or other audiovisual work, to display the copyrighted work publicly…” 17 U.S.C. §106

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41. Defendants are not owners of the copyright for the above listed works and do not have a license to reproduce, display, create derivative works and distribute these works for HJF 2010 and 2011. 42. Defendants therefore are jointly liable for copyright infringement as pleaded in this complaint. B. MORAL RIGHTS UNDER V.A.R.A. 43. Plaintiff realleges paragraphs one (1) through forty two (42) of this complaint. 44. Defendants have violated plaintiff’s rights under the Visual Artists Rights Act2. 45. Defendants have taken plaintiff’s works of art and without a license, have (1) Named Jose Luis Díaz de Villegas as creator of the artwork in the HJF 2010 program guide, violating plaintiff’s right of attribution of origin; (2) Distorted, mutilated or modified plaintiff’s artworks listed in paragraph #30, supra by creating a collage (unauthorized derivative work) or otherwise fusing these works for the 20th Anniversary letterhead / corporate identity, the HJF program guide, the back-drop of the HJF 2010 musical event, Bus Shelter advertising, newspaper and magazine articles and promotions, t-shirts, and six-pack packaging of HEINEKEN Beer sold throughout the island; (3) publishing copies of plaintiff’s works listed in paragraph #23, supra, in their website without naming plaintiff as
2

The Visual Artists Rights Act has recognized plaintiffs’ rights of attribution and to prevent distortion or mutilation of his works. “(a) Rights of Attribution and Integrity.— Subject to section 107 and independent of the exclusive rights provided in section 106, the author of a work of visual art— (1) shall have the right— (A) to claim authorship of that work, and (B) to prevent the use of his or her name as the author of any work of visual art which he or she did not create; (2) shall have the right to prevent the use of his or her name as the author of the work of visual art in the event of a distortion, mutilation, or other modification of the work which would be prejudicial to his or her honor or reputation; and (3) subject to the limitations set forth in section 113 (d), shall have the right— (A) to prevent any intentional distortion, mutilation, or other modification of that work which would be prejudicial to his or her honor or reputation, and any intentional distortion, mutilation, or modification of that work is a violation of that right, and (B) to prevent any destruction of a work of recognized stature, and any intentional or grossly negligent destruction of that work is a violation of that right.” 17 U.S.C. § 106A.

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the author; and (4) Defendants publicly hailed artist Jose Luis Díaz de Villegas and other contributors of the HJF during the HJF 20th anniversary activities of 2010 but never once mentioned Plaintiff, all the while the latter’s works and unauthorized derivative works had been reproduced, displayed, distributed and sold for profit in connection with the event C. MORAL RIGHTS UNDER P.R. LAWS FOR DESTRUCTION OF THE INTEGRITY OF THE ARTWORK 46. Plaintiff realleges paragraphs one (1) through forty five (45) of this complaint. 47. Defendants have violated plaintiff’s rights under Puerto Rico Moral Rights statutes3. 48. Defendants have destroyed the integrity of Plaintiff’s works when creating unauthorized derivative works in the form collages and compilations that fuse together the artworks listed in paragraph #23, supra. D. MORAL RIGHTS UNDER P.R. LAWS FOR ATTACK ON THE PATERNITY OF THE WORKS 49. Plaintiff realleges paragraphs one (1) through forty eight (48) of this complaint. 50. Defendants have attacked the paternity of the works by (1) making a false designation of origin in the 2010 HJF program guide, wherein they included copies of Plaintiff’s works and unauthorized derivative works while only naming artist Jose Luis Díaz de Villegas as the creator of all Artwork contained in the Program Guide; (2) publishing copies of plaintiff’s works listed in paragraph #23, supra, in their website without naming plaintiff as the author; and (3) Defendants publicly

3

Puerto Rico Moral Rights Laws state that the author of a visual work of art has exclusive right of to benefit from his work and dispose of it, attribute paternity, authorize publication, and protect the work’s integrity pursuant to the laws of intellectual property. 31 PR Laws Anntd. Sec. 1401, Article 359a. Violation of Moral Rights grants the author / creator of a work the right the request temporary or permanent injunctive relief that may include restitution, confiscation, or destruction of the works. The author may also seek damages. Id, Article 295b

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hailed artist Jose Luis Díaz de Villegas and other contributors of the HJF during the HJF 20th anniversary activities of 2010 but never once mentioned Plaintiff, all the while the latter’s works and unauthorized derivative works had been reproduced, displayed, distributed and sold for profit in connection with the event. V. RELIEF A. INJUNCTIVE RELIEF 51. Plaintiff realleges paragraphs one (1) through fifty (50) of this complaint. 52. These works of art were created by Plaintiff and have been registered in the U.S. Copyright Office. 53. Defendants’ willful and ongoing infringements of copyright in the HJF 2011 require injunctive relief in order to avoid irreparable harm4. 54. By reason of defendant’s actions plaintiff has suffered and will continue to suffer extreme hardship, actual and impeding irreparable loss and/or damage in the reproduction, display, creation and distribution of copies of original works and unauthorized derivative works for HJF 2010 and 2011, events enjoyed and attended by the general public. 55. At this stage in the proceedings Plaintiff has no adequate or speedy remedy at law for the above-mentioned conduct of defendants, and this injunctive relief here sought is plaintiff’s only means for securing relief. 56. Being that Plaintiff is the author of the works and defendants had no license to use the works for HJF2010 and 2011, it is highly likely that Plaintiff will prevail on the merits of his claim. 57. The injury sustained by plaintiff will be drastically reduced through the issuance of an injunction even if the defendants seek an appeal of this Honorable Court’s order.

4

Section 502(a) of the 1976 Copyright Act, provides for injunctive relief for copyright infringement. “(a) Any court having jurisdiction of a civil action arising under this title may, subject to the provisions of section 1498 of title 28, grant temporary and final injunctions on such terms as it may deem reasonable to prevent or restrain infringement of a copyright.” 17 U.S.C. §502(a).

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58. Therefore, plaintiff move the court to issue an Injunction restraining the defendants, their agents, and servants, daring the probable appeal of this action, from infringing plaintiffs copyrights rights over artworks listed in paragraph #23, supra. 59. Accordingly, the injunctive relief should order Defendants to relinquish all unauthorized derivative works to the plaintiff that may be in defendants’ possession5. B. DAMAGES 60. Plaintiff realleges paragraphs one (1) through fifty nine complaint. 61. At the present Plaintiff has identified 43 infringements (See paragraph #30, supra). 62. Plaintiff seeks actual damages for these infringements6. The HJF is an extremely profitable event, which is a primary reason the defendants have celebrated the festival for over 20 years. Due to the fact that the infringements include sales of various merchandising including t-shirts and HEINEKEN beer sixpacks with plaintiffs artwork sold throughout the island, these damages are
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(59) of this

The Copyright Act provides for plaintiff to request defendants to turn over all infringing works. “(1) At any time while an action under this title is pending, the court may order the impounding, on such terms as it may deem reasonable— (A) of all copies or phonorecords claimed to have been made or used in violation of the exclusive right of the copyright owner; (B) of all plates, molds, matrices, masters, tapes, film negatives, or other articles by means of which such copies of phonorecords may be reproduced; and (C) of records documenting the manufacture, sale, or receipt of things involved in any such violation, provided that any records seized under this subparagraph shall be taken into the custody of the court.” 17 U.S.C. § 503(a) The Copyright Act allows plaintiff to seek either Actual Damages or Statutory Damages “(a) In General.— Except as otherwise provided by this title, an infringer of copyright is liable for either— (1) the copyright owner’s actual damages and any additional profits of the infringer, as provided by subsection (b); or (2) statutory damages, as provided by subsection (c). (b) Actual Damages and Profits.— The copyright owner is entitled to recover the actual damages suffered by him or her as a result of the infringement, and any profits of the infringer that are attributable to the infringement and are not taken into account in computing the actual damages. In establishing the infringer’s profits, the copyright owner is required to present proof only of the infringer’s gross revenue, and the infringer is required to prove his or her deductible expenses and the elements of profit attributable to factors other than the copyrighted work.” 17 U.S.C. §504

6

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estimated in a sum greater than one million dollars ($1,000,000). Due to the success of the HJF, they could be much more. 63. Plaintiff requests that Defendants pay damages for violations of his moral rights, including violation of paternity of the works, distortion, modification and mutilation of these works, in the sum of one million dollars ($1,000,000). 64. Plaintiffs request that Defendants pay to plaintiff the costs and disbursements of this action, together with reasonable attorneys’ fees. WHEREFORE, plaintiffs respectfully request that the Honorable Court provide for Injunctive Relief as requested, and furthermore declare defendants jointly liable for all copyright infringements alleged in the complaint and pay the amount of $1,000,000 with an additional $1,000,000 for violation for moral rights, plus attorney’s fees and grant any other relief as may be deemed necessary by the court. In San Juan, Puerto Rico this 7th day of June, 2011. s/ROBERTO SUEIRO DEL VALLE USDC No. 207801 Tulipán 170 Urb. San Francisco San Juan, PR 00927-6221 Tel.: 753-4712 Fax: 274-0191 E-MAIL: rsdv@me.com s/FREDDIE OSCAR TORRES USDC No. Tulipán 170 Urb. San Francisco San Juan, PR 00927-6221 Tel.: 753-4712 Fax: 274-0191 E-MAIL: ftorres151@gmail.com

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