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11. The following is the Work showing Watsons CMI in the lower right
corner:
12. After Watson created the Work and added his CMI to it, he posted it
publicly on his Flickr photostream on the Internet at www.flickr.com.
13. When he posted the Work on his Flickr photostream Watson
indicated that it was protected by copyright and that he reserved all rights to the
Work.
Case 1:14-cv-00100-WBH Document 1 Filed 01/13/14 Page 3 of 7
16. Watson never gave Kappa permission or authority to copy the Work,
display the Work, or remove his CMI.
17. Watson contacted Kappa and requested it cease and desist from
infringing the Work and compensate him for the use of his Work.
18. Kappa refused to cease and desist and offered Watson total
compensation of ten dollars ($10.00) for the Work.
19. Watson has engaged the undersigned attorneys and has agreed to pay
them a reasonable fee.
COUNT I
COPYRIGHT INFRINGEMENT
20. Plaintiff Watson incorporates the allegations of paragraphs 1 through
19 of this complaint as if fully set forth herein.
21. Watson owns a valid copyright in the Work.
22. Watson has registered the Work with the Register of Copyrights
pursuant to 17 U.S.C. 411(a).
23. Kappa copied, displayed and distributed the Work and made
derivatives of the Work without Watsons authorization in violation of 17 U.S.C.
501.
24. Watson has been damaged.
Case 1:14-cv-00100-WBH Document 1 Filed 01/13/14 Page 5 of 7