`
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`TAMPA DIVISION
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`
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`Case No.:
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`Seugne Botha,
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`Plaintiff,
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`
`
`v.
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`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.
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`
`
`
`
`
`
`
`
`
`
` Defendants.
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`_____________________________ /
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`ORIGINAL COMPLAINT
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`Comes now Plaintiff Seugne Botha (“Botha” or “Plaintiff”) with her Complaint against
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`Sony Music Entertainment (“Sony”), Orchard Music Company (“Orchard”), Apple, Inc.
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`(“Apple”), Amazon, Inc. (“Amazon”), Spotify, Inc. (“Spotify”), Google, Inc. (“Google”),
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`Microsoft, Inc. (“Microsoft”), Deezer, Inc. (“Deezer”), Shazam Media Services, Inc.
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`(“Shazam”), MediaNet, Inc. (“MediaNet”), CD Universe, Inc. (“Universe”), and Saavn, LLC.
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`(“Saavn”) (collectively “Defendants”) and states as follows:
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 2 of 13 PageID 2
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`INTRODUCTION
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`1.
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`This is an action for Copyright Infringement under the United States Copyright Act of 1976, 17
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`U.S.C. § 101 et seq. (“Copyright Act”), and Unfair Competition under Florida common law.
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`PARTIES, JURISDICTION, AND VENUE
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`2.
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`Plaintiff is an individual located in Pretoria, Gauteng, South-Africa and is a performer,
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`composer, lyricist, pianist, and producer of her own original musical compositions.
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`3.
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`Upon information and belief Defendant Sony Music Entertainment is a corporation registered in
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`the State of Delaware, having its principal place of business and global headquarters located at 25
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`Madison Ave, New York, NY, 10010 USA and is an American music company owned by Sony that is
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`incorporated as a general partnership of Sony Music Holdings Inc., through Sony Entertainment Inc., a
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`subsidiary of Sony Corporation of America (“Sony”).
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`4.
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`Upon information and belief Defendant The Orchard Music Company, is a music and
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`entertainment Company located at 23 E 4th St, New York, NY 10003 USA and is wholly owned by
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`Sony Music Entertainment (“Orchard”).
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`5.
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`Upon information and belief Defendant Apple, Inc. is, inter alia, a corporation engaged in online
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`music distribution and device manufacturing with its principal place of business located at One Apple
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`Park Way, Cupertino, CA 95014, USA (“Apple”).
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`6.
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`Upon information and belief Defendant Amazon, Inc. is, inter alia, a corporation engaged in
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`online music distribution, book distribution, and device manufacturing with its principal place of
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`business located at 410 Terry Ave. North, Seattle, WA 98108-1226 USA (“Amazon”).
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`7.
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`Upon information and belief Defendant Spotify, Inc. is, inter alia, a corporation engaged in
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`online music distribution with its principal place of business located at 45 W. 18th Street, 7th Floor,
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`New York, NY 10011 USA (“Spotify”).
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`2
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 3 of 13 PageID 3
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`8.
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`Upon information and belief Defendant Google, Inc. is, inter alia, a corporation engaged in
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`online music distribution, search, and software with its principal place of business located at 1600
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`Amphitheatre Pkwy. Mountain View, CA 94043 USA (“Google”).
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`9.
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`Upon information and belief Defendant Microsoft, Inc. is, inter alia, a corporation engaged in
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`online music distribution and software with its principal place of business located at 1 Microsoft Way,
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`Redmond, WA 98052 USA (“Microsoft”).
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`10.
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`Upon information and belief Defendant Deezer, Inc. is, inter alia, a corporation engaged in
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`online music distribution with its principal place of business located at C/O KVB Partners, 60 Broad
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`Street, Ste. 3502, New York, NY 10004 USA (“Deezer”).
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`11.
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`Upon information and belief Defendant Shazam Media Services, Inc., is, inter alia, a corporation
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`engaged in online music distribution with its principal place of business located at 52 Vanderbilt Ave,
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`19th Floor, New York, NY 10017 USA (“Shazam”).
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`12.
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`Upon information and belief Defendant MediaNet, Inc. is, inter alia, a corporation engaged in
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`online music distribution with its principal place of business located at 2401 Elliott Ave., Suite 300,
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`Seattle, WA 98121 USA (“MediaNet”).
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`13.
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`Upon information and belief Defendant CD Universe, Inc. is, inter alia, a corporation engaged in
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`online music distribution with its principal place of business located at 101 N. Plains Industrial Road,
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`Wallingford, CT 06492-5857 USA (“Universe”).
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`14.
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` Upon information and belief Defendant Saavn, LLC. is, inter alia, a corporation engaged in
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`online music distribution with its principal place of business located at 460 Park Avenue South, 4th
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`Floor, New York, NY 10016 USA (“Saavn”).1
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`1 Apple, Amazon, Spotify, Microsoft, Universe, Google, Deezer, Shazam, MediaNet, Saavn, are
`collectively referred to as the “Online Distributors”.
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`3
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 4 of 13 PageID 4
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`15.
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`Upon information and belief, at all times material hereto, Defendants operated through the acts
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`of their employees, agents, representatives, servants, and the like, acting within their course of
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`employment and scope of duties.
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`16.
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`This Complaint alleges Copyright Infringement under the Copyright Act and this Court has
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`subject matter jurisdiction over this federal question claim pursuant to 28 U.S.C. § 1338(a)
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`(“Copyright”).
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`17.
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`This Complaint alleges Unfair Competition under Florida law, arising from the same transaction
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`or occurrence as Plaintiff’s Copyright Infringement claim, and this Court has subject matter jurisdiction
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`over this claim pursuant to 28 U.S.C. § 1367 (“Supplemental Jurisdiction”).
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`18.
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`This Court has personal jurisdiction over Defendants because Defendants’ tortious, intentional,
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`willful and malicious acts of copyright infringement and unfair competition, occurred within this
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`jurisdiction and throughout the world, were expressly aimed at this jurisdiction, and caused harm
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`Defendants knew or should have known was likely to be suffered in this jurisdiction. Upon information
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`and belief, this Court also has personal jurisdiction over Defendants because they have offices in this
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`forum, and/or have transacted business in this judicial district.
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`19.
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`Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b) and (c) because
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`Defendants reside and may be found in this judicial district such that they are subject to personal
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`jurisdiction in this judicial district.
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`ALLEGATIONS COMMON TO ALL COUNTS
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`20.
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`Botha composed the music and lyrics to “U is Daar” (“U Are There”) between December 2011
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`and February 2012; and recorded it in South Africa between April 30, 2013 and May 15, 2013.
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`4
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 5 of 13 PageID 5
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`21.
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`Botha composed the music and lyrics to “Ek Slaan My Oe Na Die Berge” (“I Lift My Eyes to the
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`Mountains”) on or about April 2012; and recorded it in South Africa between April 30, 2013 and May
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`15, 2013.
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`22.
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`On or about October 24, 2013 Botha assigned five songs to the Maranatha Record Company
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`(“Maranatha”), this agreement (“Assignment”) did not include either “U is Daar” or “Ek Slaan my Oë
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`Na Die Berge” (“Songs”). See Exhibit A, assignment between Botha and Maranatha, attached hereto and
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`included herein by reference.2
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`23.
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`On or about March 4, 2014, Maranatha’s General Manager, Hester Moolman (“Moolman”)
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`requested permission from Botha to include “Ek Slaan my Oe Na Die Berge” on a compilation album
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`for Easter entitled “Kruishou Liefde.” See Exhibit B, request from Moolman.
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`24.
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`Botha allowed Maranatha to use “Ek Slaan My Oe Na Die Berge” only for “Kruishou Liefde.”
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`25. Maranatha also negotiated a distribution agreement with Botha, (“Contract”). However, the
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`Contract was never perfected because Botha never signed it. See Exhibit C, copy of unsigned Contract.
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`The alleged Contract was for manufacturing and physical distribution in South Africa only.
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`26. Maranatha terminated the Contract with Botha on or about October 14, 2014. See Exhibit D,
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`Moolman Notice of Termination of relationship. Such termination was given immediate effect.
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`27. Ms. Botha never licensed any rights to the Songs to Maranatha. Botha performed her own
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`marketing and paid for her own master3 pursuant to the Songs.
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`28.
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`Additionally, Botha took her own photographs which she used in promotional materials
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`(“Photos”).
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`29.
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`Botha never licensed any rights in the Songs to any entity.
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`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.
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`5
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 6 of 13 PageID 6
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`30.
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`Botha also recorded and arranged an album entitled “U Alleen is God” (“Album”). The Album
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`included the Songs as well as other titles selected, recorded, and arranged by Botha. She did not grant
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`any express rights in this album to any entity. Botha granted Maranatha a limited oral license to
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`distribute the Album via iTunes in South Africa only. This agreement was terminated on or about
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`October 10, 2014 when Maranatha terminated the Contract.
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`31.
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`On information and belief, in or about July through August 2014, Tygerberg 104FM, a South
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`African radio station hosted its annual gospel concert, Gospel Skouspel, featuring local gospel artists, in
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`two different cities: (a) Pretoria on July 23, 2014; and (b) Cape Town on August 30, 2014. Unbeknownst
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`to Botha, and on information and belief, Andriette Norman (“Norman”) performed “Ek Slaan My Oe Na
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`Die Berge” during the concert, which was attended by approximately 22,000 people. On information
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`and belief, the concert was also televised in December 2014.
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`32.
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`33.
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`On information and belief, Andriette Norman is signed to Sony BMG.
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`Neither Sony nor Ms. Norman had the right to perform “Ek Slaan My Oe Na Die Berge.” No one
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`ever sought Botha’s permission for a live performance.
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`34.
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`A CD and DVD of this performance were released on or about May 25, 2015. Again, no
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`one sought or received permission from Botha for the recording or distribution of “Ek Slaan My
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`Oe Na Die Berge.” A CD was recorded and released for sale sometime in 2015. The title of
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`Norman’s performance of Botha’s song was altered and appeared as “Ek slaan my Oe op.” See
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`Exhibit E, Gospel Skouspel CD and DVD offered for sale at Raru. On information and belief, the
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`CD was also offered for sale at Echosrecordbar, Loot, and Cum Books in South Africa.
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`35.
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`In approximately December 2017 Botha discovered the Songs offered for sale individually on
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`the Online Distributors’ websites. See Exhibit F, Online Distributors offering the Songs for sale.
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`6
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 7 of 13 PageID 7
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`36.
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`In approximately December 2017 Botha discovered “Ek Slaan My Oe Na Die Berge” included as
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`a track on Loof Hom Vol. 3, sold by the Online Distributors. See Exhibit G, Online Distributors listing
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`“Ek Slaan My Oe Na Die Berge” on Loof Hom Vol. 3.
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`37.
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`In approximately December 2017 Botha discovered the Gospel Skouspal CD and DVD including
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`the performance of “Ek Slaan My Oe Na Die Berge” for sale online.
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`38.
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`Upon information and belief, Maranatha unlawfully passed the Songs and Album to Next Music,
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`a South African Indie Music Company (“Next Music”) in partnership with The Orchard, even though
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`Maranatha did not have a license to reproduce and distribute the Songs. Upon information and belief
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`Next Music unlawfully passed the Songs to Orchard, who henceforth passed the Songs on to the Online
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`Distributors for distribution in the USA.
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`39.
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`Upon information and belief, Defendants are in the business of, inter alia, publishing and
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`distributing music worldwide.
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`40.
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`Defendants used Botha’s name, Photos, and Album packaging, in promoting the Songs and
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`Album. See Exhibit H, U Alleen is God album offered for sale by Online Distributors.
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`41.
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`Defendants altered design elements of the Album packaging and offered the altered product for
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`sale. See Exhibit I, altered album artwork.
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`42.
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`Next Music wrongfully altered Botha’s Copyright Management Information. (“CMI”) by
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`identifying themselves as the Copyright holder to the Songs. See Exhibit J, Next Music’s CMI placed on
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`“Ek Slaan my Oe Na Die Berge.”
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`43.
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`Defendants knowingly, or with reckless indifference, distributed the Songs and Album sans any
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`license agreement whatsoever with Botha.
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`44.
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`Defendants jointly and severally caused injury to Botha by publishing and distributing the Songs
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`and Album without any compensation to her.
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`7
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 8 of 13 PageID 8
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`COPYRIGHT INFRINGEMENT
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`45.
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`The Songs are original works authored by Botha, which represent copyrightable subject matter
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`under Copyright Act as amended. 17 U.S.C. § 101 et. seq.
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`46.
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`The Songs contain “protectable elements” afforded copyright protection; said elements include,
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`but are not limited to, the compositions (i.e. music and lyrics) and other unique expressions set forth in
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`the Songs. 17 U.S.C. § 101 et. seq.
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`47.
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`The Album is an original compilation authored by Botha (i.e. selection and arrangement), which
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`represents copyrightable subject matter under Copyright Act as amended. 17 U.S.C. § 101 et. seq.
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`48.
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`The Album’s recordings (“Recordings”) contain “protectable elements” afforded copyright
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`protection; and other unique expressions set forth in the Album. 17 U.S.C. § 101 et. seq.
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`49.
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`Botha delivered a completed application, deposit and fee for copyright registration of the
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`Songs and the Album on February 23, 2018, registration number PA0002093773. See Exhibit K,
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`Botha’s U.S. Copyright registration.
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`50.
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`Botha is the sole copyright owner of the infringed upon elements of the Songs, Album and
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`Recordings (“Works”).
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`51.
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`Defendants have used, copied, made derivative works of, sold and/or otherwise distributed
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`unauthorized copies of the Works in violation of 17 U.S.C. § 501 et seq.
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`52.
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`Botha is entitled to damages and profits through 17 U.S.C. § 505 including, without limitation,
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`statutory damages, Defendants’ profits, her lost profits and/or a reasonable royalty.
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`UNFAIR COMPETITION
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`53.
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`Defendants’ theft of Botha’s Works, as well as their use of her name and Photos, and subsequent
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`use of same on their own websites, was intended to gain increased sales, and revenue for themselves at
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`the expense of Botha, competing in the same market.
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`8
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 9 of 13 PageID 9
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`54.
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`Defendants’ theft of the Works and use of her name and Photos is likely to confuse consumers in
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`the marketplace regarding the source or sponsorship of the Songs.
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`55.
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`The confusion caused by Defendants is likely to result in consumers assuming that Botha is
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`associated with Defendants.
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`Count I- Copyright Infringement
`[Copyright Infringement 17 U.S.C. § 501(a)]
`As to All Defendants
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`Botha incorporates by reference all the allegations set forth in 1-52 as if fully set forth herein.
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`Botha is the rightful owner of intellectual property rights related to the Works, pursuant to 17
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`56.
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`57.
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`U.S.C. § 102(a), owns the copyrightable matter in same for which she filed and received registration.
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`58.
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`Defendants reproduced, publicly displayed, created derivative versions of copyrighted elements
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`of the Works, and offered same for sale.
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`59.
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`Defendants’ acts of infringement are willful, intentional and purposeful, in disregard of and with
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`indifference to Botha’s rights.
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`60.
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`Defendants’ infringement has caused Botha actual damages, as well as lost opportunities, and
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`exposure.
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`61.
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`As a direct and proximate result of said infringement by Defendants, Botha is entitled to
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`damages in an amount to be proven at trial.
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`62.
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`As a direct and proximate result of the foregoing acts and conduct, Botha has sustained and will
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`continue to sustain substantial, immediate, and irreparable injury, for which there is no adequate remedy
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`at law. Botha is informed and believes and, on that basis, avers that unless enjoined and restrained by
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`this Court, Defendants will continue to infringe her rights in the Works. Botha is entitled to preliminary
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`and permanent injunctive relief to restrain and enjoin Defendants’ continuing infringing conduct.
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`63.
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`Plaintiff is entitled to costs and attorneys’ fees pursuant to 17 U.S.C. § 505.
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`9
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 10 of 13 PageID 10
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`Count II- Copyright Infringement
`[Copyright Infringement 17 U.S.C. § 501(a)]
`As to Sony Only
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`Botha incorporates by reference all the allegations set forth in 1-52 as if fully set forth herein.
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`Botha is the rightful owner of intellectual property rights related to “Ek Slaan My Oe Na Die
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`64.
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`65.
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`Berge” and, pursuant to 17 U.S.C. § 102(a), owns the copyrightable matter in same for which she filed
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`and received registration.
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`66.
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`Defendant, Sony, by and through their artist Norman publicly performed, recorded, created
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`derivative versions of copyrighted elements of the “Ek Slaan My Oe Na Die Berge,” and offered same
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`for sale. Further, as described herein, Norman performed Botha’s song on South African national
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`television in December 2014.
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`67.
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`Defendant Sony’s acts of infringement are willful, intentional and purposeful, in disregard of and
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`with indifference to Botha’s rights.
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`68.
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`Defendant Sony’s infringement has caused Botha actual damages, as well as lost opportunities,
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`and exposure.
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`69.
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`As a direct and proximate result of said infringement by Defendant Sony, Botha is entitled to
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`damages in an amount to be proven at trial.
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`70.
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`As a direct and proximate result of the foregoing acts and conduct, Botha has sustained and will
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`continue to sustain substantial, immediate, and irreparable injury, for which there is no adequate remedy
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`at law. Botha is informed and believes and, on that basis, avers that unless enjoined and restrained by
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`this Court, Defendant Sony will continue to infringe her rights in “Ek Slaan My Oe Na Die Berge.”
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`Botha is entitled to preliminary and permanent injunctive relief to restrain and enjoin Defendant Sony
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`from continuing infringing conduct.
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`71.
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`Plaintiff is entitled to costs and attorneys’ fees pursuant to 17 U.S.C. § 505.
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`10
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 11 of 13 PageID 11
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`Count III- Unfair Competition
`[Florida Common Law]
`As to All Defendants
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`Botha incorporates by reference all the allegations set forth in 1-44, 53-55 as if fully set forth
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`72.
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`herein.
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`73.
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`As detailed above, Defendants have intentionally and improperly used Botha’s name and Photos
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`in commerce which is likely to cause confusion, mistake or deceive as to the affiliation, connection, or
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`association of Botha with Defendants, or as to Botha’s sponsorship or approval of Defendants’ goods,
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`service, or commercial activities, in violation of Florida Unfair Competition Laws.
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`74.
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`Defendants’ actions constitute unfair competition and as a direct and proximate result of
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`Defendants’ actions, Botha has been injured and suffered damages in an amount to be proved at trial.
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`75.
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`76.
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`Defendants’ misappropriation was willful and malicious.
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`As a direct and proximate result of Defendants’ misuse of Botha’s name and Photos, Botha was
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`damaged in an amount to be proven at trial.
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`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
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`Botha incorporates by reference all the allegations set forth in 1-52 as if fully set forth herein.
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`Defendants knowingly falsified and altered Botha’s copyright management information,
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`77.
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`78.
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`knowing, or having reasonable grounds to know, that it would induce, enable, facilitate, or conceal an
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`infringement of Botha’s rights under this title.
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`79.
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`Defendants knowing alteration of Botha’s copyright management information infringed Botha’s
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`copyright under the Digital Millennium Copyright Act, 17 U.S.C. § 1202(a) and (b).
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`Botha is entitled to damages or statutory damages pursuant to 17 U.S.C. § 1203.
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`Botha is entitled to attorney’s fees pursuant to 17 U.S.C. § 1203.
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`11
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`80.
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`81.
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 12 of 13 PageID 12
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`Plaintiff demands trial by jury.
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`JURY DEMAND
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff Botha respectfully requests that this Court:
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`Count I - Copyright Infringement
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`(A) Permanently enjoin Defendants and all other persons in active concert or participation with
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`Defendants from continuing to infringe Botha’s Works;
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`(B) Order Defendants to delete and permanently remove copies of Botha’s Works from each of
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`the computers under Defendants’ possession, custody or control;
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`(C) Award Botha actual, consequential, and incidental damages in the amount to be proved at
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`trial including costs and attorneys’ fees under 17 U.S.C. § 505;
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`(D) Grant Botha any other and further relief as this Court deems just and proper.
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`Count II – Copyright Infringement
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`(A) Permanently enjoin Defendant Sony and all other persons in active concert or participation
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`with Defendants from continuing to infringe “Ek Slaan My Oe Na Die Berge;”
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`(B) Order Defendant Sony to delete and permanently remove copies of “Ek Slaan My Oe Na Die
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`Berge” from each of the computers under Defendants’ possession, custody or control;
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`(C) Award Botha actual, consequential, and incidental damages in the amount to be proved at
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`trial including costs and attorneys’ fees under 17 U.S.C. § 505;
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`(D) Grant Botha any other and further relief as this Court deems just and proper.
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`Case 8:18-cv-01145-VMC-JSS Document 1 Filed 05/10/18 Page 13 of 13 PageID 13
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`Count III - Unfair Competition
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`(A) Award Botha the profits Defendants’ have accrued from their misappropriations,
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`misrepresentations and other unlawful acts that have caused both public confusion and inequitable
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`market advantage;
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`(B) Award Botha punitive damages for Defendants’ willful and malicious misappropriation to
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`deter others from acting in kind;
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` (C) Grant Botha any other and further relief as this Court deems just and proper.
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`Count IV - Digital Millennium Copyright Act
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`(A) Award Botha costs and attorneys’ fees under 17 U.S.C. § 1203;
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`(B) Grant Botha any other and further relief as this Court deems just and proper.
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`Designation of Place of Trial
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`Plaintiff hereby designates Tampa, Florida as the place of trial of the above styled matter.
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`Respectfully submitted,
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`/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
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`DATED: May 9, 2018
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`13
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