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Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 1 of 13 PageID 1
`
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`TAMPA DIVISION
`
`
`
`Case No.:
`
`Seugne Botha,
`
`Plaintiff,
`
`
`
`v.
`
`Sony Music Entertainment, JURY DEMANDED
`The Orchard Music Company,
`Apple, Inc.,
`Amazon, Inc.,
`Spotify, Inc.,
`Google, Inc.,
`Microsoft, Inc.,
`Deezer, Inc.,
`Shazam Media Services, Inc.,
`MediaNet, Inc.,
`CD Universe, Inc.,
`Saavn, LLC.
`
`
`
`
`
`
`
`
`
`
`
` Defendants.
`
`_____________________________ /
`
`
`
`
`
`
`ORIGINAL COMPLAINT
`
`Comes now Plaintiff Seugne Botha (“Botha” or “Plaintiff”) with her Complaint against
`
`Sony Music Entertainment (“Sony”), Orchard Music Company (“Orchard”), Apple, Inc.
`
`(“Apple”), Amazon, Inc. (“Amazon”), Spotify, Inc. (“Spotify”), Google, Inc. (“Google”),
`
`Microsoft, Inc. (“Microsoft”), Deezer, Inc. (“Deezer”), Shazam Media Services, Inc.
`
`(“Shazam”), MediaNet, Inc. (“MediaNet”), CD Universe, Inc. (“Universe”), and Saavn, LLC.
`
`(“Saavn”) (collectively “Defendants”) and states as follows:
`
`
`
`
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 2 of 13 PageID 2
`
`INTRODUCTION
`
`1.
`
`This is an action for Copyright Infringement under the United States Copyright Act of 1976, 17
`
`U.S.C. § 101 et seq. (“Copyright Act”), and Unfair Competition under Florida common law.
`
`PARTIES, JURISDICTION, AND VENUE
`
`2.
`
`Plaintiff is an individual located in Pretoria, Gauteng, South-Africa and is a performer,
`
`composer, lyricist, pianist, and producer of her own original musical compositions.
`
`3.
`
`Upon information and belief Defendant Sony Music Entertainment is a corporation registered in
`
`the State of Delaware, having its principal place of business and global headquarters located at 25
`
`Madison Ave, New York, NY, 10010 USA and is an American music company owned by Sony that is
`
`incorporated as a general partnership of Sony Music Holdings Inc., through Sony Entertainment Inc., a
`
`subsidiary of Sony Corporation of America (“Sony”).
`
`4.
`
`Upon information and belief Defendant The Orchard Music Company, is a music and
`
`entertainment Company located at 23 E 4th St, New York, NY 10003 USA and is wholly owned by
`
`Sony Music Entertainment (“Orchard”).
`
`5.
`
`Upon information and belief Defendant Apple, Inc. is, inter alia, a corporation engaged in online
`
`music distribution and device manufacturing with its principal place of business located at One Apple
`
`Park Way, Cupertino, CA 95014, USA (“Apple”).
`
`6.
`
`Upon information and belief Defendant Amazon, Inc. is, inter alia, a corporation engaged in
`
`online music distribution, book distribution, and device manufacturing with its principal place of
`
`business located at 410 Terry Ave. North, Seattle, WA 98108-1226 USA (“Amazon”).
`
`7.
`
`Upon information and belief Defendant Spotify, Inc. is, inter alia, a corporation engaged in
`
`online music distribution with its principal place of business located at 45 W. 18th Street, 7th Floor,
`
`New York, NY 10011 USA (“Spotify”).
`
`
`
`2
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 3 of 13 PageID 3
`
`8.
`
`Upon information and belief Defendant Google, Inc. is, inter alia, a corporation engaged in
`
`online music distribution, search, and software with its principal place of business located at 1600
`
`Amphitheatre Pkwy. Mountain View, CA 94043 USA (“Google”).
`
`9.
`
`Upon information and belief Defendant Microsoft, Inc. is, inter alia, a corporation engaged in
`
`online music distribution and software with its principal place of business located at 1 Microsoft Way,
`
`Redmond, WA 98052 USA (“Microsoft”).
`
`10.
`
`Upon information and belief Defendant Deezer, Inc. is, inter alia, a corporation engaged in
`
`online music distribution with its principal place of business located at C/O KVB Partners, 60 Broad
`
`Street, Ste. 3502, New York, NY 10004 USA (“Deezer”).
`
`11.
`
`Upon information and belief Defendant Shazam Media Services, Inc., is, inter alia, a corporation
`
`engaged in online music distribution with its principal place of business located at 52 Vanderbilt Ave,
`
`19th Floor, New York, NY 10017 USA (“Shazam”).
`
`12.
`
`Upon information and belief Defendant MediaNet, Inc. is, inter alia, a corporation engaged in
`
`online music distribution with its principal place of business located at 2401 Elliott Ave., Suite 300,
`
`Seattle, WA 98121 USA (“MediaNet”).
`
`13.
`
`Upon information and belief Defendant CD Universe, Inc. is, inter alia, a corporation engaged in
`
`online music distribution with its principal place of business located at 101 N. Plains Industrial Road,
`
`Wallingford, CT 06492-5857 USA (“Universe”).
`
`14.
`
` Upon information and belief Defendant Saavn, LLC. is, inter alia, a corporation engaged in
`
`online music distribution with its principal place of business located at 460 Park Avenue South, 4th
`
`Floor, New York, NY 10016 USA (“Saavn”).1
`
`
`1 Apple, Amazon, Spotify, Microsoft, Universe, Google, Deezer, Shazam, MediaNet, Saavn, are
`collectively referred to as the “Online Distributors”.
`
`
`
`3
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 4 of 13 PageID 4
`
`15.
`
`Upon information and belief, at all times material hereto, Defendants operated through the acts
`
`of their employees, agents, representatives, servants, and the like, acting within their course of
`
`employment and scope of duties.
`
`16.
`
`This Complaint alleges Copyright Infringement under the Copyright Act and this Court has
`
`subject matter jurisdiction over this federal question claim pursuant to 28 U.S.C. § 1338(a)
`
`(“Copyright”).
`
`17.
`
`This Complaint alleges Unfair Competition under Florida law, arising from the same transaction
`
`or occurrence as Plaintiff’s Copyright Infringement claim, and this Court has subject matter jurisdiction
`
`over this claim pursuant to 28 U.S.C. § 1367 (“Supplemental Jurisdiction”).
`
`18.
`
`This Court has personal jurisdiction over Defendants because Defendants’ tortious, intentional,
`
`willful and malicious acts of copyright infringement and unfair competition, occurred within this
`
`jurisdiction and throughout the world, were expressly aimed at this jurisdiction, and caused harm
`
`Defendants knew or should have known was likely to be suffered in this jurisdiction. Upon information
`
`and belief, this Court also has personal jurisdiction over Defendants because they have offices in this
`
`forum, and/or have transacted business in this judicial district.
`
`19.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b) and (c) because
`
`Defendants reside and may be found in this judicial district such that they are subject to personal
`
`jurisdiction in this judicial district.
`
`ALLEGATIONS COMMON TO ALL COUNTS
`
`20.
`
`Botha composed the music and lyrics to “U is Daar” (“U Are There”) between December 2011
`
`and February 2012; and recorded it in South Africa between April 30, 2013 and May 15, 2013.
`
`
`
`4
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 5 of 13 PageID 5
`
`21.
`
`Botha composed the music and lyrics to “Ek Slaan My Oe Na Die Berge” (“I Lift My Eyes to the
`
`Mountains”) on or about April 2012; and recorded it in South Africa between April 30, 2013 and May
`
`15, 2013.
`
`22.
`
`On or about October 24, 2013 Botha assigned five songs to the Maranatha Record Company
`
`(“Maranatha”), this agreement (“Assignment”) did not include either “U is Daar” or “Ek Slaan my Oë
`
`Na Die Berge” (“Songs”). See Exhibit A, assignment between Botha and Maranatha, attached hereto and
`
`included herein by reference.2
`
`23.
`
`On or about March 4, 2014, Maranatha’s General Manager, Hester Moolman (“Moolman”)
`
`requested permission from Botha to include “Ek Slaan my Oe Na Die Berge” on a compilation album
`
`for Easter entitled “Kruishou Liefde.” See Exhibit B, request from Moolman.
`
`24.
`
`Botha allowed Maranatha to use “Ek Slaan My Oe Na Die Berge” only for “Kruishou Liefde.”
`
`25. Maranatha also negotiated a distribution agreement with Botha, (“Contract”). However, the
`
`Contract was never perfected because Botha never signed it. See Exhibit C, copy of unsigned Contract.
`
`The alleged Contract was for manufacturing and physical distribution in South Africa only.
`
`26. Maranatha terminated the Contract with Botha on or about October 14, 2014. See Exhibit D,
`
`Moolman Notice of Termination of relationship. Such termination was given immediate effect.
`
`27. Ms. Botha never licensed any rights to the Songs to Maranatha. Botha performed her own
`
`marketing and paid for her own master3 pursuant to the Songs.
`
`28.
`
`Additionally, Botha took her own photographs which she used in promotional materials
`
`(“Photos”).
`
`29.
`
`Botha never licensed any rights in the Songs to any entity.
`
`
`2 All exhibits are attached hereto and included herein by reference unless otherwise noted.
`3 A master is “an original recording, film, or document from which copies can be made.” See
`https://en.oxforddictionaries.com/definition/master. Last visited April 10, 2018.
`
`
`
`5
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 6 of 13 PageID 6
`
`30.
`
`Botha also recorded and arranged an album entitled “U Alleen is God” (“Album”). The Album
`
`included the Songs as well as other titles selected, recorded, and arranged by Botha. She did not grant
`
`any express rights in this album to any entity. Botha granted Maranatha a limited oral license to
`
`distribute the Album via iTunes in South Africa only. This agreement was terminated on or about
`
`October 10, 2014 when Maranatha terminated the Contract.
`
`31.
`
`On information and belief, in or about July through August 2014, Tygerberg 104FM, a South
`
`African radio station hosted its annual gospel concert, Gospel Skouspel, featuring local gospel artists, in
`
`two different cities: (a) Pretoria on July 23, 2014; and (b) Cape Town on August 30, 2014. Unbeknownst
`
`to Botha, and on information and belief, Andriette Norman (“Norman”) performed “Ek Slaan My Oe Na
`
`Die Berge” during the concert, which was attended by approximately 22,000 people. On information
`
`and belief, the concert was also televised in December 2014.
`
`32.
`
`33.
`
`On information and belief, Andriette Norman is signed to Sony BMG.
`
`Neither Sony nor Ms. Norman had the right to perform “Ek Slaan My Oe Na Die Berge.” No one
`
`ever sought Botha’s permission for a live performance.
`
`34.
`
`A CD and DVD of this performance were released on or about May 25, 2015. Again, no
`
`one sought or received permission from Botha for the recording or distribution of “Ek Slaan My
`
`Oe Na Die Berge.” A CD was recorded and released for sale sometime in 2015. The title of
`
`Norman’s performance of Botha’s song was altered and appeared as “Ek slaan my Oe op.” See
`
`Exhibit E, Gospel Skouspel CD and DVD offered for sale at Raru. On information and belief, the
`
`CD was also offered for sale at Echosrecordbar, Loot, and Cum Books in South Africa.
`
`35.
`
`In approximately December 2017 Botha discovered the Songs offered for sale individually on
`
`the Online Distributors’ websites. See Exhibit F, Online Distributors offering the Songs for sale.
`
`
`
`6
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 7 of 13 PageID 7
`
`36.
`
`In approximately December 2017 Botha discovered “Ek Slaan My Oe Na Die Berge” included as
`
`a track on Loof Hom Vol. 3, sold by the Online Distributors. See Exhibit G, Online Distributors listing
`
`“Ek Slaan My Oe Na Die Berge” on Loof Hom Vol. 3.
`
`37.
`
`In approximately December 2017 Botha discovered the Gospel Skouspal CD and DVD including
`
`the performance of “Ek Slaan My Oe Na Die Berge” for sale online.
`
`38.
`
`Upon information and belief, Maranatha unlawfully passed the Songs and Album to Next Music,
`
`a South African Indie Music Company (“Next Music”) in partnership with The Orchard, even though
`
`Maranatha did not have a license to reproduce and distribute the Songs. Upon information and belief
`
`Next Music unlawfully passed the Songs to Orchard, who henceforth passed the Songs on to the Online
`
`Distributors for distribution in the USA.
`
`39.
`
`Upon information and belief, Defendants are in the business of, inter alia, publishing and
`
`distributing music worldwide.
`
`40.
`
`Defendants used Botha’s name, Photos, and Album packaging, in promoting the Songs and
`
`Album. See Exhibit H, U Alleen is God album offered for sale by Online Distributors.
`
`41.
`
`Defendants altered design elements of the Album packaging and offered the altered product for
`
`sale. See Exhibit I, altered album artwork.
`
`42.
`
`Next Music wrongfully altered Botha’s Copyright Management Information. (“CMI”) by
`
`identifying themselves as the Copyright holder to the Songs. See Exhibit J, Next Music’s CMI placed on
`
`“Ek Slaan my Oe Na Die Berge.”
`
`43.
`
`Defendants knowingly, or with reckless indifference, distributed the Songs and Album sans any
`
`license agreement whatsoever with Botha.
`
`44.
`
`Defendants jointly and severally caused injury to Botha by publishing and distributing the Songs
`
`and Album without any compensation to her.
`
`
`
`7
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 8 of 13 PageID 8
`
`COPYRIGHT INFRINGEMENT
`
`45.
`
`The Songs are original works authored by Botha, which represent copyrightable subject matter
`
`under Copyright Act as amended. 17 U.S.C. § 101 et. seq.
`
`46.
`
`The Songs contain “protectable elements” afforded copyright protection; said elements include,
`
`but are not limited to, the compositions (i.e. music and lyrics) and other unique expressions set forth in
`
`the Songs. 17 U.S.C. § 101 et. seq.
`
`47.
`
`The Album is an original compilation authored by Botha (i.e. selection and arrangement), which
`
`represents copyrightable subject matter under Copyright Act as amended. 17 U.S.C. § 101 et. seq.
`
`48.
`
`The Album’s recordings (“Recordings”) contain “protectable elements” afforded copyright
`
`protection; and other unique expressions set forth in the Album. 17 U.S.C. § 101 et. seq.
`
`49.
`
`Botha delivered a completed application, deposit and fee for copyright registration of the
`
`Songs and the Album on February 23, 2018, registration number PA0002093773. See Exhibit K,
`
`Botha’s U.S. Copyright registration.
`
`50.
`
`Botha is the sole copyright owner of the infringed upon elements of the Songs, Album and
`
`Recordings (“Works”).
`
`51.
`
`Defendants have used, copied, made derivative works of, sold and/or otherwise distributed
`
`unauthorized copies of the Works in violation of 17 U.S.C. § 501 et seq.
`
`52.
`
`Botha is entitled to damages and profits through 17 U.S.C. § 505 including, without limitation,
`
`statutory damages, Defendants’ profits, her lost profits and/or a reasonable royalty.
`
`UNFAIR COMPETITION
`
`53.
`
`Defendants’ theft of Botha’s Works, as well as their use of her name and Photos, and subsequent
`
`use of same on their own websites, was intended to gain increased sales, and revenue for themselves at
`
`the expense of Botha, competing in the same market.
`
`
`
`8
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 9 of 13 PageID 9
`
`54.
`
`Defendants’ theft of the Works and use of her name and Photos is likely to confuse consumers in
`
`the marketplace regarding the source or sponsorship of the Songs.
`
`55.
`
`The confusion caused by Defendants is likely to result in consumers assuming that Botha is
`
`associated with Defendants.
`
`Count I- Copyright Infringement
`[Copyright Infringement 17 U.S.C. § 501(a)]
`As to All Defendants
`
`Botha incorporates by reference all the allegations set forth in 1-52 as if fully set forth herein.
`
`Botha is the rightful owner of intellectual property rights related to the Works, pursuant to 17
`
`56.
`
`57.
`
`U.S.C. § 102(a), owns the copyrightable matter in same for which she filed and received registration.
`
`58.
`
`Defendants reproduced, publicly displayed, created derivative versions of copyrighted elements
`
`of the Works, and offered same for sale.
`
`59.
`
`Defendants’ acts of infringement are willful, intentional and purposeful, in disregard of and with
`
`indifference to Botha’s rights.
`
`60.
`
`Defendants’ infringement has caused Botha actual damages, as well as lost opportunities, and
`
`exposure.
`
`61.
`
`As a direct and proximate result of said infringement by Defendants, Botha is entitled to
`
`damages in an amount to be proven at trial.
`
`62.
`
`As a direct and proximate result of the foregoing acts and conduct, Botha has sustained and will
`
`continue to sustain substantial, immediate, and irreparable injury, for which there is no adequate remedy
`
`at law. Botha is informed and believes and, on that basis, avers that unless enjoined and restrained by
`
`this Court, Defendants will continue to infringe her rights in the Works. Botha is entitled to preliminary
`
`and permanent injunctive relief to restrain and enjoin Defendants’ continuing infringing conduct.
`
`63.
`
`Plaintiff is entitled to costs and attorneys’ fees pursuant to 17 U.S.C. § 505.
`
`
`
`9
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 10 of 13 PageID 10
`
`Count II- Copyright Infringement
`[Copyright Infringement 17 U.S.C. § 501(a)]
`As to Sony Only
`
`Botha incorporates by reference all the allegations set forth in 1-52 as if fully set forth herein.
`
`Botha is the rightful owner of intellectual property rights related to “Ek Slaan My Oe Na Die
`
`64.
`
`65.
`
`Berge” and, pursuant to 17 U.S.C. § 102(a), owns the copyrightable matter in same for which she filed
`
`and received registration.
`
`66.
`
`Defendant, Sony, by and through their artist Norman publicly performed, recorded, created
`
`derivative versions of copyrighted elements of the “Ek Slaan My Oe Na Die Berge,” and offered same
`
`for sale. Further, as described herein, Norman performed Botha’s song on South African national
`
`television in December 2014.
`
`67.
`
`Defendant Sony’s acts of infringement are willful, intentional and purposeful, in disregard of and
`
`with indifference to Botha’s rights.
`
`68.
`
`Defendant Sony’s infringement has caused Botha actual damages, as well as lost opportunities,
`
`and exposure.
`
`69.
`
`As a direct and proximate result of said infringement by Defendant Sony, Botha is entitled to
`
`damages in an amount to be proven at trial.
`
`70.
`
`As a direct and proximate result of the foregoing acts and conduct, Botha has sustained and will
`
`continue to sustain substantial, immediate, and irreparable injury, for which there is no adequate remedy
`
`at law. Botha is informed and believes and, on that basis, avers that unless enjoined and restrained by
`
`this Court, Defendant Sony will continue to infringe her rights in “Ek Slaan My Oe Na Die Berge.”
`
`Botha is entitled to preliminary and permanent injunctive relief to restrain and enjoin Defendant Sony
`
`from continuing infringing conduct.
`
`71.
`
`Plaintiff is entitled to costs and attorneys’ fees pursuant to 17 U.S.C. § 505.
`
`
`
`10
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 11 of 13 PageID 11
`
`Count III- Unfair Competition
`[Florida Common Law]
`As to All Defendants
`
`Botha incorporates by reference all the allegations set forth in 1-44, 53-55 as if fully set forth
`
`72.
`
`herein.
`
`73.
`
`As detailed above, Defendants have intentionally and improperly used Botha’s name and Photos
`
`in commerce which is likely to cause confusion, mistake or deceive as to the affiliation, connection, or
`
`association of Botha with Defendants, or as to Botha’s sponsorship or approval of Defendants’ goods,
`
`service, or commercial activities, in violation of Florida Unfair Competition Laws.
`
`74.
`
`Defendants’ actions constitute unfair competition and as a direct and proximate result of
`
`Defendants’ actions, Botha has been injured and suffered damages in an amount to be proved at trial.
`
`75.
`
`76.
`
`Defendants’ misappropriation was willful and malicious.
`
`As a direct and proximate result of Defendants’ misuse of Botha’s name and Photos, Botha was
`
`damaged in an amount to be proven at trial.
`
`Count IV – Violation of Digital Millennium Copyright Act
`[Integrity of Copyright Management Information 17 U.S.C § 1202]
`As to Defendants Orchard and Sony Only
`
`Botha incorporates by reference all the allegations set forth in 1-52 as if fully set forth herein.
`
`Defendants knowingly falsified and altered Botha’s copyright management information,
`
`77.
`
`78.
`
`knowing, or having reasonable grounds to know, that it would induce, enable, facilitate, or conceal an
`
`infringement of Botha’s rights under this title.
`
`79.
`
`Defendants knowing alteration of Botha’s copyright management information infringed Botha’s
`
`copyright under the Digital Millennium Copyright Act, 17 U.S.C. § 1202(a) and (b).
`
`Botha is entitled to damages or statutory damages pursuant to 17 U.S.C. § 1203.
`
`Botha is entitled to attorney’s fees pursuant to 17 U.S.C. § 1203.
`
`11
`
`80.
`
`81.
`
`
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 12 of 13 PageID 12
`
`Plaintiff demands trial by jury.
`
`JURY DEMAND
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff Botha respectfully requests that this Court:
`
`Count I - Copyright Infringement
`
`(A) Permanently enjoin Defendants and all other persons in active concert or participation with
`
`Defendants from continuing to infringe Botha’s Works;
`
`(B) Order Defendants to delete and permanently remove copies of Botha’s Works from each of
`
`the computers under Defendants’ possession, custody or control;
`
`(C) Award Botha actual, consequential, and incidental damages in the amount to be proved at
`
`trial including costs and attorneys’ fees under 17 U.S.C. § 505;
`
`(D) Grant Botha any other and further relief as this Court deems just and proper.
`
`Count II – Copyright Infringement
`
`(A) Permanently enjoin Defendant Sony and all other persons in active concert or participation
`
`with Defendants from continuing to infringe “Ek Slaan My Oe Na Die Berge;”
`
`(B) Order Defendant Sony to delete and permanently remove copies of “Ek Slaan My Oe Na Die
`
`Berge” from each of the computers under Defendants’ possession, custody or control;
`
`(C) Award Botha actual, consequential, and incidental damages in the amount to be proved at
`
`trial including costs and attorneys’ fees under 17 U.S.C. § 505;
`
`(D) Grant Botha any other and further relief as this Court deems just and proper.
`
`
`
`
`
`
`
`
`
`12
`
`

`

`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 13 of 13 PageID 13
`
`Count III - Unfair Competition
`
`(A) Award Botha the profits Defendants’ have accrued from their misappropriations,
`
`misrepresentations and other unlawful acts that have caused both public confusion and inequitable
`
`market advantage;
`
`(B) Award Botha punitive damages for Defendants’ willful and malicious misappropriation to
`
`deter others from acting in kind;
`
` (C) Grant Botha any other and further relief as this Court deems just and proper.
`
`Count IV - Digital Millennium Copyright Act
`
`(A) Award Botha costs and attorneys’ fees under 17 U.S.C. § 1203;
`
`(B) Grant Botha any other and further relief as this Court deems just and proper.
`
`Designation of Place of Trial
`
`Plaintiff hereby designates Tampa, Florida as the place of trial of the above styled matter.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`/s/ Carlos A. Leyva
`Carlos A. Leyva (Florida Bar Number: 51017)
`cleyva@digitalbusinesslawgroup.com
`Digital Business Law Group, P.A.
`3958 Talah Dr.
`Palm Harbor, FL 34684
`Telephone: (800) 516-7903
`Facsimile: (800) 257-9128
`ATTORNEY FOR PLAINTIFF
`SEUGNE BOTHA
`
`DATED: May 9, 2018
`
`
`
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`
`13
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`

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