UNITED STATES DISTRICT COURT
F.ll !`I)
FOR THE DISTRICT OF MASSACHUSETTS , ,i I, ,. . ;
HARVARD BUSINESS SCHOOL
PUBLISHING CORPORATION and
PRESIDENT AND FELLOWS OF
HARVARD COLLEGE,
Plaintiffs,
V.
BUSINESS BOOK REVIEW, LLC,
JAGDISH SHETH, LYDIA MORRIS
BROWN, and JOHN FAYAD,
Defendants.
1DATa.~
COMPLAINT
Plaintiffs Harvard Business School Publishing Corporation ("HBSP") and
President and Fellows of Harvard College ("Harvard"), by and through their attorneys,
Lucash, Gesmer & Updegrove LLP, for their Complaint against Business Book Review,
LLC, Jagdish Sheth, Lydia Morris Brown and John Fayad (collectively BBR), allege,
upon knowledge as to themselves and otherwise upon information and belief, as follows:
NATURE OF THE ACTION
1. In this action plaintiffs seek preliminary and permanent injunctive relief
and damages arising out of BBR's ongoing infringements of plaintiffs' copyrights, as well
as damages on account of BBR's violations of the Lanham Act, the Massachusetts
Consumer Protection Act and common law unfair business practices.
2. This lawsuit is occasioned by BBR's willful infringement of plaintiffs'
SNIPPETS:
BUSINESS BOOK REVIEW, LLC, JAGDISH SHETH, LYDIA MORRIS
Plaintiffs Harvard Business School Publishing Corporation and
President and Fellows of Harvard College, by and through their attorneys,
LLC, Jagdish Sheth, Lydia Morris Brown and John Fayad (collectively BBR), allege,
In this action plaintiffs seek preliminary and permanent injunctive relief
as damages on account of BBR's violations of the Lanham Act, the Massachusetts
Consumer Protection Act and common law unfair business practices.
This lawsuit is occasioned by BBR's willful infringement of plaintiffs'
copyrights and exclusive publishing rights; through publication of so-called "book
reviews" that are in fact abridgments or condensations of twenty-six books published by
HBSP (hereinafter the "Infringed Books" or the "Works").
The BBR "book reviews" use verbatim copying or paraphrasing so close
In derogation of plaintiffs' legal rights BBR has converted the text of its
BBR advertises its infringing reviews on the Internet in a
which has itself authorized and licensed the creation of summaries of some of the
professional schools is Harvard Business School.
Lydia Morris Brown is an individual,
Georgia and is employed by BBR as its publisher.
authorized, endorsed, or created the Infringing Abridgements.
constitute acts of copyright infringement in violation of exclusive copyright rights in the
Defendants Sheth, Brown and Fayad are each responsible for the infringement of
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