.m
PIaintiff The Aurhaxs GUM, onbehatf of its XXI
Derrick Be11 and Lm Brewer (collectively `TiIamed P
al1 other persons similarly sifnated, by their attorneys,
1. PlaintB. bring tbis action pln-$-nt
amended, 17 U.S.C. 5 101, m-, for &ages and injunctive
copy&k.
,~$lyCTmN 44ND VENUE
2. This Cowt has jurisdidon over this matter p-t to 28 U.S.C. $133 1,
and 28 USC 8 133x(a) a
3- Venue is proper in this judidal disaict purnrant to 28 U.S.C. $13 9 1 (b)
ad (0). SHIES DefendaM is subject to personal jtisdiction in this judicial district, and pursuant
d&tie
u!lxIxE
The Associational Pl&ntiE
4. &,sociational PlaThe Authors G&Id is a noT-for-p&t corpoMion
organ&d under New YoC law and having its place of business at 330 West 4Zti Street, New
York, New York. The Authors Guild has three categoti of merpbdp: "Regular Member9
are book authors p~bli&.ed by an, established Amcrica~. publiz& who have had a book in print
within the last seven years, and freelance WI&S who have published three works of fiction M
non-fiction in a periodical of general c&&ion within &e l&t eigJ&m month.% "Associate
Membas" are authors who have a contmet with an established American publisher for a work
sot yet published, and T3ernM-s~at-Large" are litenxy agents, MIS, bxtm or exeeuto~~ of the
estates of dd members, &orneys and =IIII&U~S representi nIhors and book author
SNIPPETS:
PIaintiff The Aurhaxs GUM, onbehatf of its XXI
organ&d under New YoC law and having its place of business at 330 West 4Zti Street,
York, New York.
Membas" are authors who have a contmet with an established American publisher for a work
providing advice to members of developments in the law md in publishing that tiect tJx-3
The rights of book aurhors aad &eela~ce writers tit The
Named PlaW&Dmi& Bell, who resides in New York, New
Mr. Bell also is a pmfezxioti author who has written numerous books and freelmce
The articles of Mr. BeU pubLished in.
The New York Times imlude "A Commissivn
distribution or any other use of his works in Defmdant's or my other electronic deaabase.
Defendant has rqmduced md disfributed asd cmti~~~ to reproduce ad
New York, is a prof&oml au&or whu has w&ten freelmce articles, including &e following
other electrorde d&t&se.
payment to them for such u5x5
Defendant also operates aq &ckotic database t&at includes w&ten works
The Class consists of all anthots who, at tie lime of the 5Ikg of this
an effective registion da& that is earlier than the
coram~cement of aD act of infringement of&e regisnzed
The exact number of mti of rhe Class and each subclass is not tiown
the proper mm of shch damages.
interesrs ofthe class.
Refedam has infin@ the copyrights of the Named Plaintiffs andthe
Mbuting, displaying, excerpting publishing, upIoaiI&, downloading, andor trzumittjng
copy6&td worlds ofthe Named Plaintiffs and the Class, without they author&ion or consent
the Chs have suffered damages and Defend& haz- made profits.
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