WHITE O'CONNOR CURRY GATTI & AVANZADO LLP
Andrew M. White (State Bar No. 060181)
Jonathan H. Anschell (State Bar No. 162554)
Lee S. Brenner (State Bar No. 180235)
10100 Santa Monica Boulevard
Los Angeles, California 90067
Telephone (310) 712-6100
Facsimile (310) 712-6199
WILMER, CUTLER & PICKERING
Thomas P. Olson
Randolph D. Moss
Peter B. Rutledge
2445 M Street, NW
Washington, DC 20037
Telephone (202) 663-6000
Facsimile (202) 663-6363
Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
PARAMOUNT PICTURES Civ. No. ________________
CORPORATION; DISNEY
ENTERPRISES, INC.; NATIONAL
BROADCASTING COMPANY, COMPLAINT FOR:
INC.; NBC STUDIOS, INC.;
SHOWTIME NETWORKS INC.; 1. Contributory copyright infringement
THE UNITED PARAMOUNT
NETWORK; ABC, INC.; VIACOM 2. Vicarious copyright infringement
INTERNATIONAL INC.; CBS
WORLDWIDE INC.; and CBS 3. Violation of Section 553 of the
BROADCASTING INC., Communications Act
Plaintiffs, 4. Violation of Section 605 of the
Communications Act
v.
5. Unfair business practices
REPLAYTV, INC. and
SONICBLUE, INC.,
Defendants.
1
Plaintiffs Paramount Pictures Corporation, Disney Enterprises, Inc.,
2 National Broadcasting Company, Inc., NBC Studios, Inc., Showtime Networks
3 Inc., The United Paramount Network, ABC, Inc., Viacom International Inc.,
4 CBS Worldwide Inc., and CBS Broadcasting Inc. (hereinafter referred to as
SNIPPETS:
DC 20037 Telephone 663-6000 Facsimile 663-6363 Attorneys for Plaintiffs
CENTRAL DISTRICT OF CALIFORNIA
CORPORATION; DISNEY
NETWORK; ABC, INC.; VIACOM 2.
INTERNATIONAL INC.; CBS
National Broadcasting Company, Inc., NBC Studios, Inc., Showtime Networks
CBS Worldwide Inc., and CBS Broadcasting Inc. (hereinafter referred to as
"plaintiffs"), by their counsel, allege the following against defendants Replay,
Inc. and SONICblue Inc..
21 copyright infringement, violations of the Communications Act, and unfair
television distribution services, including their own program services.
"ReplayTV 4000," seeks to profit from two novel methods of violating
television programming for the purpose of -- at the touch of a button -- viewing
features that are calculated to disrupt the ability of copyright owners to market
17 or both of two methods: advertiser support and subscription fees.
26 plaintiffs) that broadcast the programming of those networks.
22 set "AutoSkip" so that it will automatically delete all commercials in all future
25 Section 106 of the Copyright Act.
17 distribution to third parties, digital copies of "Will & Grace," "The Tonight
20 Showtime offers (through cable systems, satellite carriers, and other
transmitted to television viewers in the United States.
19 without authorization is a violation of plaintiffs' exclusive rights under 17
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