Case 2:21-cv-07691-GW-JEM Document 1 Filed 09/27/21 Page 1 of 14 Page ID #:1

1 Neville L. Johnson (SBN 66329)

Daniel B. Lifschitz (SBN 285068)
2 Nima Kamali (SBN 294401)
3 JOHNSON & JOHNSON LLP
439 North Canon Drive, Suite 200
4 Beverly Hills, California 90210
Telephone: (310) 975-1080
5 Facsimile: (310) 975-1095
6 Email: [email protected]
[email protected]
7 [email protected]
8 Attorneys for Plaintiff
AOM MUSIC, INC
9
10 UNITED STATES DISTRICT COURT

11 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

12 AOM MUSIC, INC., a Florida CASE NO. 2:21-cv-7691

corporation,
13 COMPLAINT FOR:
14 Plaintiff,
1. DIRECT COPYRIGHT
15 vs. INFRINGEMENT
2. CONTRIBUTORY COPYRIGHT
16 BENITO ANTONIO MARTÍNEZ INFRINGEMENT
17 OCASIO p/k/a BAD BUNNY, an
individual; MARCOS EFRAIN MASIS DEMAND FOR JURY TRIAL
18 p/k/a TAINY, an individual; RANDY
ARIEL ORTIZ ACEVEDO p/k/a
19 RANDY, an individual; JOEL MUÑOZ
p/k/a JOWELL, an individual; EDWIN
20 ROSA p/k/a ÑENGO FLOW, an
21 individual; ORMANI PEREZ
GONZALES p/k/a DJ ORMA, an
22 individual; RIMAS
ENTERTAINMENT LLC, a Puerto
23 Rican limited liability company; CDA
24 MUSIC GROUP INC. d/b/a DJ
NEGRO PUBLISHING, a Florida
25 corporation; EMI BLACKWOOD
MUSIC INC, a Connecticut corporation;
26 SONGS OF UNIVERSAL, INC. d/b/a
RISAMAR PUBLISHING, a California
27 corporation; THE ROYALTY
28 NETWORK, INC. d/b/a TEYNOR
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1 MUSIC, a New York corporation;

UNIVERSAL SONGS OF
2 POLYGRAM INTERNATIONAL
3 INC., a Delaware corporation; and
DOES 1-10, inclusive;
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Defendants.
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1 Plaintiff AOM Music, Inc. d/b/a BM Records (“BM Records” or “Plaintiff”),

2 by and through his undersigned attorneys, brings this Complaint against Benito
3 Antonio Martínez Ocasio p/k/a Bad Bunny (“Ocasio”), Marcos Efrain Masis p/k/a
4 Tainy (“Masis”), Randy Ariel Ortiz Acevedo p/k/a Randy (“Acevedo”), Joel
5 Muñoz p/k/a Jowell (“Muñoz”), Edwin Rosa p/k/a Ñengo Flow (“Rosa”), Ormani
6 Perez Gonzales p/k/a DJ Orma (“Gonzales”), Rimas Entertainment LLC (“Rimas”);
7 CDA Music Group Inc. dba DJ Negro Publishing (“DNP”), EMI Blackwood
8 Music, Inc. (“EMI”), Songs of Universal, Inc. dba Risamar Publishing
9 (“Universal”) The Royalty Network, Inc. dba Teynor Music (“TRNI”), Universal
10 Songs of Polygram International Inc. (“Polygram”), and Does 1-10 (collectively
11 “Defendants”) upon knowledge and belief as to himself and as to all other matters
12 upon information and belief of his undersigned attorneys. With respect to facts
13 alleged herein on information and belief, Plaintiff and his undersigned attorneys are
14 informed and believe that those facts are likely to have evidentiary support after a
15 reasonable opportunity for further investigation or discovery, because, among other
16 reasons, evidence to support those facts is exclusively in Defendants’ possession.
17 NATURE OF THE ACTION
18 1. This is an action for copyright infringement arising out of Plaintiffs’
19 ownership of three copyrighted musical works – “Besa Tu Cuerpo,” “Chocha Con
20 Bicho,” and “Sigan Bailando” (collectively the “Playero Works”) – and
21 Defendants’ unauthorized incorporation of the Playero Works into the hit song
22 “Safaera,” for which no license or authorization was obtained.
23 PLAINTIFF
24 2. Plaintiff BM Records is a corporation organized under the laws of
25 Florida with its principal place of business in Pasco County, Florida.
26 DEFENDANTS
27 3. Defendant Benito Antonio Martínez Ocasio p/k/a Bad Bunny is an
28 individual domiciled, on information and belief, in San Juan, Puerto Rico.
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1 4. Defendant Marcos Efrain Masis p/k/a Tainy is an individual

2 domiciled, on information and belief, in San Juan, Puerto Rico.
3 5. Defendant Randy Ariel Ortiz Acevedo p/k/a Randy is an individual
4 domiciled, on information and belief, in San Juan, Puerto Rico.
5 6. Defendant Joel Muñoz p/k/a Jowell is an individual domiciled, on
6 information and belief, in San Juan, Puerto Rico.
7 7. Defendant Edwin Rosa p/k/a Ñengo Flow is an individual domiciled,
8 on information and belief, in San Juan, Puerto Rico.
9 8. Defendant Ormani Perez Gonzales p/k/a DJ Orma is an individual
10 domiciled, on information and belief, in San Juan, Puerto Rico.
11 9. Defendant Rimas Entertainment LLC, on information and belief, is,
12 and at all relevant times was, a limited liability partnership organized under the
13 laws of Puerto Rico with its principal place of business in San Juan, Puerto Rico.
14 10. Defendant CDA Music Group Inc. dba DJ Negro Publishing, on
15 information and belief, is, and at all relevant times was, a corporation organized
16 under the laws of Florida with its principal place of business in Miami, Florida.
17 11. Defendant EMI Blackwood Music, Inc., on information and belief, is,
18 and at all relevant times was, a corporation organized under the laws of Connecticut
19 with its principal place of business in New York, New York.
20 12. Defendant Songs of Universal, Inc. dba Risamar Publishing, on
21 information and belief, is, and at all relevant times was, a corporation organized
22 under the laws of California with its principal place of business in Santa Monica,
23 California.
24 13. Defendant The Royalty Network, Inc. dba Teynor Music, on
25 information and belief, is, and at all relevant times was, a corporation organized
26 under the laws of New York with its principal place of business in New York, New
27 York.
28 14. Defendant Universal Songs of Polygram International Inc., on
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1 information and belief, is, and at all relevant times was, a corporation organized
2 under the laws of Delaware with its principal place of business in Santa Monica,
3 California.
4 15. Defendants Does 1 through 10 are sued herein by fictitious names for
5 the reason that their true names are unknown to Plaintiffs. Plaintiffs will seek leave
6 to amend this complaint to allege the true names and capacities of these Defendants
7 when the same have been ascertained. Plaintiffs are informed and believes and
8 based thereon alleges that these fictitiously named Defendants are responsible in
9 some manner for the actions and damages alleged herein.
10 16. Plaintiffs are further informed and believe and based thereon allege
11 that Defendants at all times herein alleged were the agents, employees, servants,
12 joint venturers and/or co-conspirators of each of the other remaining Defendants,
13 and that in doing the things herein alleged were acting in the course and scope of
14 such agency, employment, joint venture and/or conspiracy.
15 JURISDICTION AND VENUE
16 17. Subject matter jurisdiction is appropriate to this Court under 28 U.S.C.
17 §§ 1331 and 1338 because this action arises under the Copyright Laws of the
18 United States (17 U.S.C. §§ 101 et seq.), and this Court has supplemental
19 jurisdiction over any related state law claims under 28 U.S.C. § 1367.
20 18. Venue is appropriate under 28 U.S.C. §§ 1391 and 1400 because a
21 substantial part of the events giving rise to the claims for relief occurred in Los
22 Angeles County, and Defendants’ actions caused injury in Los Angeles County.
23 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
24 BM Records and DJ Playero
25 19. BM Records was founded in 1978 by Pedro Merced and eventually
26 became one of the largest and most influential record labels in Puerto Rican history,
27 selling more than 65 million records across multiple territories.
28 20. BM Records was an early popularizer of the nascent “underground”
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1 genre of music, which eventually became more widely known as “reggaeton.” The
2 genre combined Spanish-language singing and rapping with musical influences
3 including American hip hop, Latin American, and Caribbean music.
4 21. Prior to BM Records’ investment in the genre, reggaeton music was
5 largely spread by independent disc jockeys (“DJs”), who would curate and produce
6 music for young Puerto Rican artists, then distribute said music via cassette tapes
7 sold in the streets, public schools, “caserios,” “barrios,” and public residences.
8 22. One of the more influential reggaeton DJs was Pedro Gerardo
9 Torruellas Brito p/k/a DJ Playero (“DJ Playero”). His “Playero” mixtapes in
10 particular served to jumpstart the careers of numerous highly influential Latin
11 artists, including Ramón Luis Ayala Rodríguez p/k/a Daddy Yankee.
12 23. In 1991, Pedro Merced approached DJ Playero on behalf of BM
13 Records, and the parties entered into a distribution deal. In 1992, BM Records
14 released “Playero 37 Underground,” featuring “Besa Tu Cuerpo” and “Chocha Con
15 Bicho.” The release was wildly successful, quickly selling tens of thousands of
16 copies in Puerto Rico and achieving platinum status within eight months.
17 24. Over the following years, Pedro Merced would help shape the
18 burgeoning musical genre by working with the artists on BM Records’ roster to
19 give their output greater commercial appeal. “Playero Street Mix Vol. 1,” released
20 by BM Records in 1995, became the first underground record to gain significant
21 promotion by top Puerto Rican radio stations, ultimately selling more copies during
22 the holiday period of 1995 in Puerto Rico than any other record. This was followed
23 by “Playero Street Mix Vol. 2” in 1996, featuring “Sigan Bailando.”
24 25. “Playero 37: Underground” (Registration No. SR0000253493) and
25 “Playero Greatest Hits: Street Mix 2” (Registration No. SR0000251271) were
26 registered with the United States Copyright Office on June 3, 1998, each listing DJ
27 Playero as sole author and BM Records d/b/a. Latin Music Dist., Inc, Inc.as
28 copyright claimant. On July 1, 2020, the Playero Works were transferred from Latin
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1 Music Dist., Inc. to Plaintiff by written copyright assignment.

2 26. Owing to the success of these and other releases, BM Records struck a
3 partnership with a Latin music distributor in New York City, which helped to boost
4 the popularity of reggaeton beyond Puerto Rico and the United States generally. DJ
5 Playero’s music was played on the biggest Latin radio station in New York, gained
6 shelf space in numerous American retailers (such as Tower Records, Musicland,
7 Sam Goody’s, and Specs), and was licensed and distributed in various countries
8 including the Dominican Republic, Venezuela, Colombia, Panama, and Mexico.
9 27. The influence of the music released by BM Records, and DJ Playero’s
10 mixtapes in particular, can be readily identified in the work of later multi-platinum
11 Latin recording artists such as J. Balvin, Ozuna, Shakira, Maluma, and Becky G.
12 Many of these artists would go on to collaborate with pop artists in America such as
13 Katy Perry, Beyonce, Justin Bieber, Nicki Minaj, DJ Snake, Diplo, and Enrique
14 Iglesias, further spreading the fame and influence of reggaeton music.
15 Bad Bunny and “Safaera”
16 28. Ocasio is a Puerto Rican reggaeton artist who achieved chart-topping
17 success with his second studio album, “YHLQMDLG,” becoming the best-selling
18 Latin album in the United States of 2020, Spotify's most streamed album globally
19 of 2020, and winner of Best Latin Pop or Urban Album at the 63rd Annual
20 Grammy Awards, which was held on March 14, 2021. The album’s breakout single,
21 “Safaera,” has been described as “a five-minute tribute to DJ Playero’s genre-
22 defining mixtapes of the 1990s”1 and “a journey through DJ Playero style
23 underground—complete with cut-and-paste sampling[.]”2
24
25 1
Matthew Ismael Ruiz, “Bad Bunny: LAS QUE NO IBAN A SALIR Album
Review,” Pitchfork (May 16, 2020), https://pitchfork.com/reviews/albums/bad-
26 bunny-las-que-no-iban-a-salir/ (last accessed December 7, 2020).
27
2
Eduardo Cepeda, “On ‘YHLQMDLG,’ Bad Bunny Breaks the Urbano Mold From
Within,” Remezcla (March 3, 2020), https://remezcla.com/releases/music/bad-
28 bunny-yhlqmdlg-album-review/ (last accessed December 7, 2020).
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1 29. “Safaera” includes samples of various third-party compositions and

2 sound recordings, as described by Isabella Herrera of Pitchfork:
3 The five-minute track ventures through at least eight beat changes, five
4 different rap flows, and 10+ years of references. A selected catalog of some
of its citations: the one-stringed tumbi sample from Missy Elliott’s “Get Ur
5 Freak On”; the bassline from Bob Marley’s “Could You Be Loved”; the
6 siren-like synths from DJ Nelson and DJ Goldy’s Xtassy Reggae tape; the
opening hook from Cosculluela’s “Pa’ La Pared” featuring Jowell & Randy;
7 the Jaws sample from Alexis y Fido’s “El Tiburón”–the list goes on.
8 Producers Tainy and DJ Orma select riddims and references that, for many of
us, will evoke memories of denim stains on basement walls, transferred
9 via contra-la-pared perreo, or maybe humid summers spent dancing
10 at marquesina parties when visiting our families back home.3

11 30. On information and belief, Defendants were well aware of the need to
12 “clear” the various third-party works sampled on “Safaera” by obtaining licenses to
13 each, as demonstrated by the fact that, for example, Melissa Elliott p/k/a Missy
14 Elliot is credited as a writer on “Safaera” due to its sampling of her hit song “Get
15 Ur Freak On.” Indeed, “Safaera” was briefly removed from the music streaming
16 service Spotify on May 14, 2020 due to Defendants’ failure to clear a sample on the
17 track and was later restored upon obtaining such clearance.4 However, at no point
18 did Defendants ever “clear” the Playero Works for use on “Safaera.”
19 31. “Safaera” was an instant success for Defendants, having been streamed
20 over one billion times between YouTube5 and Spotify alone.6 On November 12,
21
22
3
Isabella Herrera, “‘Safeara’ by Bad Bunny Review,” Pitchfork (Mar. 4, 2020),
https://pitchfork.com/reviews/tracks/bad-bunny-safaera-ft-jowell-and-randy-and-
23 nengo-flow/ (last accessed December 7, 2020).
4
See Spotify Mexico, Twitter (May 15, 2020),
24 https://twitter.com/SpotifyMexico/status/1261478552157007879.
25
5
Bad Bunny, “Safaera - Bad Bunny x Jowell & Randy x Ñengo Flow |
YHLQMDLG,” YouTube (Feb. 28, 2020), https://youtu.be/jCQ_6XbATPc
26 (313,503,826 views as of September 24, 2021); Bad Bunny, “Safaera,” YouTube
(Feb. 29. 2020), https://youtu.be/PZ6CgcC2uEs (151,394,814 views as of
27 September 24, 2021); Keller Lokomotion, “Safaera (LETRA) - Bad Bunny x Jowell
& Randy x Ñengo Flow,” YouTube (Mar. 10, 2020), https://youtu.be/tuQVkIvYJr0
28 (32,130,359 views as of September 24, 2021).
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1 2020, it was certified Gold, Platinum, and 21x Multi-Platinum for sales of 1.26
2 million units by the Recording Industry Association of America.7
3 32. Defendants Ocasio, Masis, Acevedo, Muñoz, Rosa, and Gonzales are
4 each credited as writers of “Safaera,” which is commercially distributed by Rimas
5 and for which DNP, EMI, Universal, TRNI, and Polygram serve as publishers.
6 Infringement of Plaintiff’s Works on “Safaera”
7 33. Of importance to the instant action, “Safaera” includes at least four
8 distinct uncleared samples of the Playero Works. The following chart illustrates the
9 lyrics taken from the Playero Works as they appear in “Safaera”:
10 Playero Works Safaera
11 A Chocha Con Bicho 0:00-0:10 Safaera 1:43-1:50
Chocha con bicho, bicho con nalgas Chocha con bicho, bicho con nalga
12 Cho-Chocha con bicho, bicho con nalgas Cho-Chocha con bicho, bicho con nalga, sí
Cho-Chocha con bicho, chocha con bicho
13 Chocha con bicho, bicho con nalgas Chocha con bicho, bicho con nalga
14 B Besa Tu Cuerpo 1:11 - 1:13 Safaera 1:50-1:53
Te-ta rozando mis tetilla’ Te-ta rozando mi tetilla
15
C Sigan Bailando 1:06 - 1:08 Safaera 1:53-1:56
16 Este año no quiero putilla Este año no quiero putilla

17 D Sigan Bailando 1:15 - 1:33 Safaera 1:56-2:13

18 Te ven con mucho macho y te quieren pegar Te ven con mucha' prenda' y se quieren pegar
Te ven empericao y te quieren pegar Te ven bien activa'o y se quieren pegar
19 Y los que fuman pasto se quieren pegar

20 Porque está bien buena, porque está bien buena Porque está bien buena, porque está bien buena
Nalgas bien grande como Iris Chacón Teta bien grande como Lourdes Chacón
21 Teta bien grande como Lourdes Chacón Las nalga' bien grande como Iris Chacón
La chocha no se porque no la he visto La chocha no sé porque no la he visto
22 Pero vamos pa’la cama a divertirse Pero vamo' pa' la cama a clavarte en panty

23 34. Similarly, a side-by-side transcription of these four segments, attached

24
6
Bad Bunny, Jowell & Randy, Nengo Flow, “Safaera,” Spotify,
25 https://open.spotify.com/track/2DEZmgHKAvm41k4J3R2E9Y (546,904,358
streams as of September 24, 2021).
26 7
“Gold & Platinum,” Recording Industry Association of America,
27 https://www.riaa.com/gold-platinum/?tab_active=default-
award&ar=Bad+Bunny%2C+Jowell+%26+Randy%2C+%C3%91engo+Flow&ti=S
28 afaera
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1 hereto as Exhibit 1, reveals a quantitatively and qualitatively substantial amount of

2 similarity between protectable aspects of the works, including shared pitches (i.e.,
3 selection of musical notes), rhythms (i.e., patterns of sound and silence), and
4 syllables shared between the works’ vocal melodies.
5 35. At no point in time did any of the Defendants obtain a valid license to
6 sample Plaintiff’s Works as part of “Safaera.” As such, the continuing exploitation
7 of “Safaera” infringes the copyrights to the Playero Works owned by Plaintiff.
8 FIRST CAUSE OF ACTION
9 DIRECT COPYRIGHT INFRINGEMENT
10 (Against All Defendants)
11 36. Plaintiff hereby incorporates the allegations set forth above in
12 paragraphs 1 through 35 above, as though fully set forth herein.
13 37. Without Plaintiff’s authorization, license, or consent, Defendants
14 prepared “Safaera” as a derivative work based upon the Playero Works, then
15 reproduced, prepared derivative works based upon, distributed, and publicly
16 performed “Safaera,” thereby infringing Plaintiff’s exclusive rights of copyright in
17 the Playero Works under the Copyright Act, 17 U.S.C. §§ 106(1)-(4), 501.
18 38. On information and belief, Defendants have authorized and continue to
19 authorize the reproduction, adaptation, distribution, and/or public performance of
20 “Safaera” in physical CDs, records, digital downloads, and digital streams.
21 39. Each unauthorized reproduction, preparation of a derivative work,
22 distribution, and/or public performance of the Playero Works constitutes a separate
23 and distinct act of copyright infringement.
24 40. Defendants’ conduct has been and continues to be intentional, willful
25 and with full knowledge of Plaintiff’s copyrights in the Playero Works and the
26 direct infringement thereof.
27 41. Pursuant to 17 U.S.C. § 504(b), as a direct and proximate result of
28 Defendants’ direct infringement of Plaintiff’s copyrights, Plaintiff is entitled to
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1 recover his actual damages, including Defendants’ profits from infringement, as

2 will be proven at trial. Alternatively, at Plaintiff’s election, pursuant to 17 U.S.C. §
3 504(c), Plaintiff is entitled to recover up to $150,000 in statutory damages for each
4 infringed work.
5 42. Plaintiff is also entitled to recover its attorneys’ fees and costs pursuant
6 to 17 U.S.C. § 505, and prejudgment interest according to law.
7 43. Defendants are causing, and unless enjoined by the Court, will
8 continue to cause, Plaintiff irreparable harm for which Plaintiff has no adequate
9 remedy at law. Plaintiff is entitled to an injunction under 17 U.S.C. § 502,
10 prohibiting the continued infringement of the Playero Works and an order under 17
11 U.S.C. § 503 directing the impoundment, destruction or other reasonable
12 disposition of all infringing works.
13 SECOND CAUSE OF ACTION
14 CONTRIBUTORY COPYRIGHT INFRINGEMENT
15 (Against All Defendants)
16 44. Plaintiffs hereby incorporate the allegations set forth above in
17 paragraphs 1 through 43 above, as though fully set forth herein.
18 45. Through its conduct alleged herein, Defendants knowingly and
19 systematically induced, caused, materially contributed to and participated in
20 infringing distribution by third parties of the Playero Works and derivative works
21 thereof, including, without limitation, by way of reproduction and distribution of
22 digital and physical copies, and by public performance via web streaming.
23 Specifically, by licensing to third parties the right to distribute and/or publicly
24 perform “Safaera,” both physically and digitally, the Defendants induced and
25 encouraged these third parties to directly infringe Plaintiff’s copyright in the
26 Playero Works.
27 46. Defendants’ conduct has been and continues to be intentional, willful
28 and with full knowledge of Plaintiff’s copyright in the Playero Works, and the
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1 contributory infringement thereof.

2 47. Pursuant to 17 U.S.C. § 504(b), as a direct and proximate result of
3 Defendants’ contributory infringement of Plaintiff’s copyright, Plaintiff is entitled
4 to recover his actual damages, including Defendants’ profits from infringement, as
5 will be proven at trial. Alternatively, at Plaintiff’s election, pursuant to 17 U.S.C. §
6 504(c), Plaintiffs are entitled to recover up to $150,000 in statutory damages for
7 each infringed work.
8 48. Plaintiff is also entitled to recover his attorneys’ fees and costs
9 pursuant to 17 U.S.C. § 505, and prejudgment interest according to law.
10 49. Defendants are causing, and unless enjoined by the Court, will
11 continue to cause, Plaintiff irreparable harm for which Plaintiff has no adequate
12 remedy at law. Plaintiff is entitled to an injunction under 17 U.S.C. § 502
13 prohibiting the continued contributory infringement of the Playero Works, and an
14 order under 17 U.S.C. § 503 directing the impoundment, destruction or other
15 reasonable disposition of all infringing works.
16 PRAYER FOR RELIEF
17 WHEREFORE, Plaintiffs pray for Judgment as follows:
18 On the First Claim for Direct Copyright Infringement:
19 1. For an award of damages, including actual damages and the disgorgement of
20 any and all gains, profits and advantages obtained by Defendants, as a result
21 of their acts of infringement in an amount according to proof at trial, or,
22 alternatively, for an award of statutory damages in an amount of up to
23 $150,000 for each infringing work, according to proof at the time of trial;
24 2. For a temporary, preliminary and permanent injunction, prohibiting the
25 continued infringement of the Playero Works during the term of copyright;
26 and
27 3. For Plaintiff’s attorneys’ fees and costs.
28 \\
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1 On the Second Claim for Contributory Copyright Infringement:

2 1. For an award of damages, including actual damages and the disgorgement of
3 any and all gains, profits and advantages obtained by Defendants, as a result
4 of their acts of contributory infringement in an amount according to proof at
5 trial, or, alternatively, for an award of statutory damages in an amount of up
6 to $150,000 for each infringing work, according to proof at the time of trial;
7 2. For a temporary, preliminary and permanent injunction, prohibiting the
8 continued infringement of the Playero Works during the term of copyright;
9 and
10 3. For Plaintiff’s attorneys’ fees and costs.
11 On All Claims For Relief:
12 1. For costs of suit and attorneys’ fees incurred herein;
13 2. For prejudgment interest at the legal rate; and
14 3. For such other and further relief as the Court deems just and proper.
15
16 Dated: September 27, 2021 JOHNSON & JOHNSON LLP

17 By /s Neville Johnson
18 Neville L. Johnson
Attorneys for Plaintiffs
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1 DEMAND FOR JURY TRIAL

2 Plaintiff hereby demands a trial by jury.
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Dated: September 27, 2021 JOHNSON & JOHNSON LLP
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5 By /s Neville Johnson
Neville L. Johnson
6 Attorneys for Plaintiffs
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