Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 1 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 1 of 30
`
`,
`
`' L
`IN UNITED STATES DISTRICT COURT
`A ’
`FOR THE
`DISTRICT OF NEW YORK
`
`'x., ,
`
`'
`
`.’
`
`
`
`
`
`MICHAEL A. MEDINA, an individual,
`
`at,p,,
`
`'
`
`‘
`
`Plaintiff,
`
`v.
`
`DASH FILMS, INC., DAMON DASH
`and KANYE WEST
`
`Defendants.
`
`)
`
`’
`)
`)
`)
`)
`)
`)
`)
`)
`
`1
`
`»
`
`~
`
`CV
`‘
`
`Civil Action No.
`
`JURY TRIAL DEMANDED
`-
`
`F.”
`»
`.,:g
`T.
`A
`COMPLAINT FOR TRADEMARK INFRINGEMENT,
` if V‘;
`
`Plaintiff, Michael A. Medina, alleges his complaint against Defendants’, Dash Films,
`
`Inc., Damon Dash and Kanye West, as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This action arises from Defendants’ infringement of Plaintiffs “ownership” and
`
`“use” rights in the federally registered mark LOISAIDAS®, in connection with musical and film
`
`entertainment. Despite Plaintiff being the registered owner of the trademark LOISAIDAS® and
`
`offering various entertainment related services under such brand name including musical
`
`recordings and musical videos amongst other related goods and services, the Defendants’ have
`
`infringed Plaintiff’ s “exclusive” rights in the LOISAIDAS® mark by filming and releasing for
`
`sale a movie promoted and offered for sale under the LOISAIDAS® brand, which is an
`
`infringement of Plaintiffs registered trademark. Defendant's continued use of the LOISAIDAS®
`
`mark is likely to cause confusion in the marketplace as to the affiliation or connection between
`
`the Defendants’ and Plaintiff resulting in the unjust enrichment of Defendants’ by using
`
`Plaintiffs registered trademark.
`
`1
`
`A
`‘Pi
`
`—_;_>_
`‘-.r'=
`7 I3
`' ;’
`:»,.:=
`:2?!
`
`5;_;:
`9/’
`
`:5}
`
`“iii?
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 2 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 2 of 30
`
`JURISDICTION AND VENUE
`
`2.
`
`This Court has jurisdiction over this action pursuant to 15 U.S.C. §1051 et seq.,
`
`15 U.S.C. Sections 1114-1116; under Section 43(a) of the Trademark Act, 15 U.S.C. §1l25(a)
`
`and Section 43(c) of the Trademark Act, 15 U.S.C. §1125(c).
`
`3.
`
`This Court has personal jurisdiction over the Defendants because the Defendants
`
`engage in continuous business activities in, and directed to the State of New York within this
`
`judicial district and because upon information and belief Defendants Damon Dash and Kanye
`
`West reside in New York City, and because Defendants has committed tortuous acts aimed at
`
`and causing harm within the State of New York and this judicial district.
`
`4.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 139l(b) and (c)
`
`because it is where Plaintiff resides and the Defendant transacts business in this district, and
`
`because a substantial portion of the events giving rise to the asserted claims have occurred, and
`
`continue to occur, within this district. Furthermore, the damage to Plaintiff and its intellectual
`
`property described herein continues to occur in this judicial district.
`
`5.
`
`Plaintiff, Michael A. Medina is an individual residing at 65 Columbia Street,
`
`THE PARTIES
`
`Suite 15K, New York, NY 10002.
`
`6.
`
`Upon information and belief, Defendant Dash Films,
`
`Inc.
`
`is a Delaware
`
`corporation with its principal place of business at 60 Orchard Street, New York, New York
`
`10002.
`
`7.
`
`Upon information and belief, Defendant Damon Dash is an individual residing at
`
`25 N Moore Street #3A, New York, NY 10013.
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 3 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 3 of 30
`
`8.
`
`Upon information and belief, Defendant Kanye West is
`
`individual with a place
`
`of residence in New York, NY 10013.
`
`FACTS
`
`9.
`
`Since at
`
`least as early as 2008, Michael A. Medina has been using the
`
`LOISAIDAS® brand in interstate commerce in connection with the offering of musical
`
`entertainment including but not limited to musical sounds recordings, musical Videos and film
`
`pilots in the entertainment industry.
`
`10.
`
`The mark LOISAIDAS® is used by Plaintiff as the brand name of a musical
`
`group in the Latin genre of music that is comprised of two musical artists hailing from.
`
`Manhattan’s Lower East Side in New York City.
`
`11.
`
`The word “Loisaida” is a term derived from the Spanish pronunciation of “Lower
`
`East Side”. (See Exhibit A)
`
`12.
`
`Plaintiff coined the word LOISAIDAS® as a brand for his musical group by
`
`adding the letter “S” to the word “Loisaida” in View of the 2 man Latin artist duo being from
`
`Manhattan’s Lower East Side.
`
`13.
`
`The LOISAIDAS® mark has been in continuous use by Plaintiff for musical
`
`related goods and services of which musical singles have reached a twenty (20) plus week run on
`
`Billboard Latin Tropical Airplay reaching number 8, and also reaching #2 on New York’s
`
`number one Tropical Latin station LaMega 97.9. (See Exhibit B.)
`
`14.
`
`Musical
`
`singles
`
`under
`
`the LOISADIAS® brand
`
`can
`
`be
`
`found
`
`on
`
`www.amazon.com, www.itunes.com and through Various other platforms that sell and/or
`
`promote musical goods and services.
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 4 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 4 of 30
`
`15.
`
`The LOISAIDAS® self-titled Debut Album was the number one (1) Top Pop
`
`Latin Albums on Itunes and was the number one (1) bestseller in Latin music on Amazon.
`
`(See
`
`Exhibit C)
`
`16.
`
`Plaintiff has used the LOISAIDAS® brand on musical videos and short film
`
`pilots that are available on YOUTUBE®, VEVO® and various other online platforms.
`
`(See
`
`Exhibit D).
`
`17.
`
`The LOISAIDAS® mark as used by Plaintiff has created a nationwide fan base
`
`and following for musical related goods and services under such brand name.
`
`18.
`
`Plaintiff has also been using the LOISADIAS® mark since 2008 on a wide array
`
`of other goods and services including merchandise, clothing, and promotional materials
`
`including stickers, posters, barmers and souvenirs.
`
`19.
`
`Plaintiff is the registered owner of United States Trademark Registration No.s
`
`3,917,555 and 4,086,336 for the mark LOISAIDAS®. (See Exhibit E).
`
`20.
`
`Defendant Dash Films, Inc. is an independent film company founded and run by
`
`music industry mogul and entrepreneur Damon Dash.
`
`21.
`
`Defendant Damon Dash has a long history in the music industry and musical
`
`entertainment field and is one of the founding members of legendary urban music label Roc-A-
`
`Fella Records that was also co-owned by musical superstar and entrepreneur Sean “JAY-Z®”
`
`Carter.
`
`22.
`
`Defendant Damon Dash is the founder and owner of the art gallery Poppington
`
`which is located in Manhattan’s Lower East Side.
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 5 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 5 of 30
`
`23.
`
`Defendant Damon Dash over the past few years has been conducting extensive
`
`business operations and activities from his Poppington art gallery located in Manhattan’s Lower
`
`East Side.
`
`24.
`
`Throughout the course of Defendant Damon Dash’s time spent in or around the
`
`Lower East Side as well as through his affiliations and resources in the music industry,
`
`Defendant became aware of Plaintiffs LOISAIDAS® brand and musical group.
`
`25.
`
`Throughout Defendant Damon Dash’s tenure as an executive at Roc-a-Fella
`
`Records, he released several independent films themed around the urban and ghetto streets of
`
`New York City which films have always included established and/or known musical artist who
`
`have played the role as actors in the released films.
`
`26.
`
`Defendant Damon Dash based on his knowledge and resources in the film
`
`entertainment industry decided to blatantly and willfully steal and utilize Plaintiff’ s registered
`
`trademark to brand and promote his independent film.
`
`27.
`
`Defendant Kanye West who is the executive producer of the LOISAIDAS film
`
`has a long history with Defendant Dash in the musical entertainment field and teamed up with
`
`Defendant Dash to produce the film. (See Exhibit F).
`
`28.
`
`Defendant Dash Films, Inc. has released the LOISAIDAS film themed with
`
`stories of characters from the ghetto streets of New York City that glorify and or promote
`
`murder, violence, and drug sales. (See Exhibit G).
`
`29.
`
`The majority of actors and or actresses that play a role in the LOISAIDAS movie
`
`by Defendants’ are either musical artists or individuals that have worked in the musical
`
`entertainment industry. (See Exhibit H).
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 6 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 6 of 30
`
`30.
`
`Plaintiff alleges and states that Defendants’ are promoting and offering for sale
`
`via social media and through the website www.loisaidasthemovie.com a film related to music
`
`and the streets of New York City under the Plaintiffs registered trademark LOISAIDAS®.
`
`3 1.
`
`Plaintiff alleges that he has already experienced several
`
`instances of actual
`
`confusion where various third parties have made inquiries looking to purchase the film from
`
`Plaintiff and are under the belief that the LOISAIDAS film was a project come from one and the
`
`same source as the musical related goods and services under the LOISAIDAS® brand.
`
`32.
`
`Plaintiff further alleges that Defendants are aware of Plaintiffs use and ownership
`
`of the LOISADIAS® mark for entertainment related goods and services including music, music
`
`videos and film services and Defendants’ continued use of the mark will continue to cause
`
`confusion in commerce as to the source of the goods under the mark.
`
`FIRST CAUSE OF ACTION
`
`TRADEMARK INFRINGEMENT (15 U.S.C. §§ 1114-1116)
`
`33.
`
`Plaintiff repeats and realleges each and every allegation contained in Paragraphs 1
`
`through 32 of this Complaint.
`
`34.
`
`The use in commerce by Defendant of an identical and slightly identical version
`
`of Plaintiffs registered trademark is likely to cause confusion, mistake and deception among
`
`members of the public and in trade as to the source, origin, or sponsorship of defendants’ goods
`
`and services. Such use by Defendant constitutes a clear and direct infringement of Plaintiffs
`
`rights in and to Plaintiffs registered trademark, and has resulted in injury and damage to Plaintiff
`
`that will continue if Defendants are not ordered to cease all use of the LOISAIDAS® mark or
`
`any similar variation of the same.
`
`UNFAIR COMPETITION & FALSE DESIGNATION OF ORIGIN (15 U.S.C. § 1125(a)
`
`SECOND CAUSE OF ACTION
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 7 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 7 of 30
`
`35.
`
`Plaintiff repeats and realleges each and every allegation contained in Paragraphs 1
`
`through 34 of this Complaint.
`
`36.
`
`Plaintiff has the exclusive right to market, brand and use entertainment related
`
`services using the LOISAIDAS® mark.
`
`37.
`
`Defendant by reason of the aforementioned acts, have falsely described,
`
`represented and designated the origin of its goods and services. Defendant's continued activities
`
`are likely to create confusion and deceive the public concerning the source of the goods/services.
`
`38.
`
`Defendants have unfairly profited from the actions alleged herein and will
`
`continue to unfairly profit and become unjustly enriched unless and until such conduct is
`
`enjoined by this Court.
`
`39.
`
`By reason of Defendant’s willful acts conducted in conscious disregard for
`
`Plaintiffs rights, Plaintiff is entitled to treble damages under 15 U.S.C. § 1ll7(a).
`
`COMMON LAW TRADEMARK INFRINGEMENT & UNFAIR COMPETITION
`
`THIRD CAUSE OF ACTION
`
`40.
`
`Plaintiff repeats and realleges each and every allegation contained in Paragraphs 1
`
`through 39 of this Complaint.
`
`41.
`
`Defendants’ conduct constitutes deception by which Defendant’s services will be
`
`palmed off as those of Plaintiff. Such conduct constitutes trademark infringement and unfair
`
`competition in violation of the laws of the State of New York.
`
`42.
`
`Defendants’ unauthorized use of Plaintiff’s LOISAIDAS® mark is likely to
`
`continue to cause further confusion to the public as to the clothing goods and accessories of the
`
`respective parties.
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 8 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 8 of 30
`
`43.
`
`By reason of the foregoing, Defendants’ has infringed and continues to infringe
`
`on Plaintiffs ownership rights in the LOISAIDAS® mark and Defendants’ has become unjustly
`
`enriched by such acts of infringement.
`
`44.
`
`Defendants’ unlawful conduct has been and will continue to be willful or willfully
`
`blind to Plaintiffs rights, as Defendants have reason to know of Plaintiffs rights and ownership
`
`of the LOISAIDAS® trademark.
`
`FOURTH CAUSE OF ACTION
`
`UNJUST ENRICHMENT
`
`45.
`
`Plaintiff repeats and realleges each and every allegation contained in Paragraphs 1
`
`through 44 of this Complaint.
`
`46.
`
`Defendant has unjustly retained profits from the offering and sale of computer and
`
`social networking services bearing Plaintiffs trademark.
`
`47.
`
`Defendant’s actions constitute unjust enrichment.
`
`WHEREFORE, Plaintiff respectfully prays for relief as follows:
`
`PRAYER FOR RELIEF
`
`1.
`
`Entry of an order and judgment requiring that all Defendant’s, their subsidiaries,
`
`officers, agents, servants, employees, owners, and representatives, and all other persons or
`
`entities in active concert or participation with them, be preliminarily and, thereafter, permanently
`
`enjoined and restrained from (a) using in any manner the trade name, trademark, domain name or
`other indicia or origin, including in whole or part the term LOISAIDAS®, or any colorable
`
`imitation thereof; (b) advertising, operating a website, using business stationary or offering any
`goods or services using the trade name, trademark, domain name, URL, or any other indicia of
`origin including in whole or part the term LOISAIDAS®, or any colorable imitation thereof; (0)
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 9 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 9 of 30
`
`otherwise engaging in any acts of unfair competition and infringement which tend to injure
`
`Plaintiff’s rights in the LOISAIDAS® mark.
`
`2.
`
`That Defendant be required to account to Plaintiff for any and all profits derived
`
`by it, and to compensate Plaintiff for all the damages sustained by reason of the acts complained
`
`of herein, and that the damages herein be trebled pursuant to the Trademark Act.
`
`3.
`
`That Defendant be ordered to deliver up for destruction any and all infringing
`
`materials bearing the LOISAIDAS® mark, and any colorable imitation thereof, in whole or part.
`
`4.
`
`5.
`
`That Plaintiff be awarded punitive damages.
`
`That Defendant be required to place advertisements or send notifications to past
`
`and present customers that it improperly has been using the LOISAIDAS® mark.
`
`6.
`
`That Plaintiff be awarded the cost and disbursements of this action.
`
`7.
`
`That Plaintiff have such other and further relief as the Court deems just and
`
`proper.
`
`JURY DEMAND
`
`Pursuant to Federal Rule of Civil Procedure 38(b), Plaintiff hereby demands a trial by
`
`jury as to all issues.
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 10 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 10 of 30
`
`Dated: April '2. , 2015
`New York, NY
`
`Respectfully submitted,
`Michael A. Medina — Pro Se
`
`11%‘4%,
`
`Michael A. Medina.
`
`Pro Se Plaintiff
`
`65 Columbia Street — Suite 15K
`
`New York, New York 10002
`(718) 809-4031
`
`

`
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 11 of 30
`Case 1:15—cv—O2551—KBF Document 1 Filed 04/02/15 Page 11 of 30
`
`EXHIBIT A
`
`

`
`. Alphabet C"2§al‘é1&’i¥¥§*'-‘Ev-li’21§§’f5li‘BI9‘e§8EL?l%°é’fil°P°‘l3fied 04/02/15 Page 12 of so Page 4 °f7
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 12 of 30
`
`In 2008, nearly the entire Alphabet City area was “downzoned” as part of an effort lead by local community groups including GVSHP, the local
`community board, and local elected officials. In most parts of Alphabet City, the rezoning requires that new development occurs in harmony with
`the low-rise character of the area.“9]
`
`Loisaida
`
`rv
`
`
`
`Loisaid /___l_<_)’i_r_._i’:‘sa1d:>_/ is a term derived from the Spanish (and es eciall N
`
`ronunciation o
`- Et Side". Originally coine by poet/activist Bittrnan "Bimbo" Rivas in
`
`largely been Hispanic manly Nuyorican) since the 1960s. V’
`Since the 1940s the demographic has changed markedly several times: the addition of the large
`labor-backed Stuyvesant Town~—Peter Cooper Village after World War II at the northern end added
`a lower-middle to middle-class element to the area, which contributed to the eventual gentrification
`of the area in the 21st century; the construction of large government housing projects south and east
`of those and the growing Latino population transformed a large swath of the neighborhood into a
`Latin one until the late 1990s, when low rents outweighed high crime rates and large numbers of
`artists and students moved to the area. Manhattan's growing Chinatown then expanded into the
`southern portions of the Lower East Side, but Hispanics are still concentrated in Alphabet City.
`With crime rates down, the area surrounding Alphabet City, the East Village, and the Lower East
`Side, is quickly becoming gentrified; the borders of the Lower East Side differ from its historical
`ones in that Houston Street is now considered the northern edge, and the area north of that between
`Houston Street and 14th Street is considered Alphabet City. But, because the Alphabet City term is largely a relic of a high-crime era, English-
`speaking residents refer to Alphabet City as part of the East Village, while Spanish-speaking residents continue to refer to Alphabet City only as
`Loisaida.
`
`'
`
`homeless man walks pasta trendy sidewalk
`bar on Avenue C, showing the area's penurious ’
`past and gentrified present.
`
`There also exists a mixed drink called a Loisaida that gained popularity in 2008. It consists of lime, Olde English malt liquor, and apple cider. The
`name comes from combining sounds from each ofthe ingredients, as in L(ime), OE (common abbreviation for Olde English) and "Cida" (cider).[2°]
`
`Notable residents
`
`I Louis Abolafia, artist, social activist, folk figure, and hippie candidate for President of the United States
`I Rosario Dawson, actress
`
`I Bobby Driscoll, actor
`
`I Allen Ginsberg poet, 206 E. 7th Streetm]
`I Madonna, singer
`
`I Charlie Parker, jazz musician lived at 151 Avenue B between East 9th and East 10th Streets
`
`I Geraldo Rivera, TV personality, resident during the late 60s - early 70s
`
`In popular culture
`
`Novels and poetry
`
`I The protagonist of the novel The Russian
`Debutante 's Handbook by Gary Shteyngart
`lives in Alphabet City in the mid-1990s.
`I A fictional version of NYC's Alphabet City is
`explored in the Fallen Angels supplement to
`Kult.
`
`I Allen Ginsberg wrote many poems relating to
`
`the streets of his neighborhood in Alphabet
`city,
`I Henry Roth's novel Call It Sleep took place in
`Alphabet City, with the novel's main
`character, David and his family, living there.
`Jerome Charyn's novel War Cries Over
`Avenue C takes place in Alphabet City.
`
`I
`
`I
`
`In his book Kitchen Confidential, Anthony
`Bourdain says "Hardly a decision was made
`without drugs. Cannabis, methaqualone,
`cocaine, LSD, psilocybin mushrooms soaked
`in honey and used to sweeten tea,
`secobarbital, tuinal, amphetamine, codeine
`and, increasingly, heroin, which we'd send a
`Spanish-speaking busboy over to Alphabet
`City to get."
`
`Comics
`
`I
`
`In Marvel Comics, Alphabet City is home to
`District X, also known as Mutant Town, a
`
`ghetto primarily populated by mutants. The
`ghetto was identified as being inside
`Alphabet City in New X-Men #127. It was
`described in District X as having the ‘highest
`unemployment rate in the USA, the highest
`rate of illiteracy and the highest severe
`overcrowding outside of Los Angeles‘. (These
`figures would suggest a large population.) It
`
`was destroyed in X-Factor #34.
`Photo books
`
`I The photo and text book "Alphabet City" by
`
`Geofirey Biddleml chronicles life in
`Alphabet City over the years 1977 to 1989.
`
`file:///C:/Users/WORKST~1/AppData/Local/Temp/700CZHH4.htm
`
`3/3 0/2015
`
`

`
`- Alphabet Citl§ei\§I3J1i'.2§Lt§1b\7-l§]2i%i@f5l.{3Bltihe 388%’ r‘ii°i°e‘i—il’Ied 04/02/15 Page 13 of 30
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 13 of 30
`
`Page 5 of 7
`
`The photo book "Street Play" by Martha
`
`Cooperm‘
`
`Places
`
`The punk house and independent gig venue
`C-Squat is called so because it sits on Avenue
`C, between 9th and 10th St. Bands and artists
`to emerge from the former squat include
`Lefiover Crack, Choking Victim, and Stza.
`Leftover Crack makes several references to
`
`"9th and C", the approximate location of
`C-Squat in the song "Homeo Apathy" from
`the album Mediocre Generica.
`
`Television
`
`The fictional 15th Precinct in the police
`
`drama NYPD Blue appeals to cover Alphabet
`City, at least in part.
`
`In an appearance on The Tonight Show, writer
`P. J. O'Rourke said that when he lived in the
`
`neighborhood in the late 1960s, it was
`dangerous enough that he and his friends
`referred to Avenue A, Avenue B, and Avenue
`C as "Firebase Alpha", "Firebase Bravo", and
`"Firebase Charlie", respectively.
`
`In the episode "My First Kill" in Season 4 of
`Scrubs, J.D. (Zach Braff) wears a T—shirt with
`"Alphabet City, NYC" on it.
`The 1996 TV movie Mrs. Santa Claus is
`
`primarily set on Avenue A in Alphabet City
`in 19103“
`
`In episode 6 of the 2009 police drama The
`Unusuals, "The Circle Line", an identity thief
`buys his ID from a dealer in Alphabet City.
`The episode "The Pugilist Break" of Forever
`is about a murder that takes place in Alphabet
`City; the episode highlights the history of the
`neighborhood and its current development
`and gentrification.
`
`In the episode "The Safety Dance" in "Season
`2" of "The Carrie Diaries", Walt helps his
`boyfriend move into an apartment in
`Alphabet City.
`
`Character actor Josh Pais, who grew up in
`
`Alphabet City, conceived and directed a very
`personal documentary film, 7th Street
`(http://7thstreet:movie.com/index.html),
`released in 2003. Shot over a period often
`years, it is both a "love letter" to the
`characters he saw everyday and a chronicle of
`the changes that took place in the
`neighborhood.
`
`Films
`
`Alphabet City was mentioned in the
`monologue by Montgomery Brogan in the
`movie 25th Hour.
`
`A 1984 movie called Alphabet City, about a
`drug dealer's attempts to flee his life of crime,
`took place in the district. It starred Vincent
`Spano, Zohra Lampert and Jami Gertz.
`A 1985 movie by Paul Morrissey, Mixed
`Blood was set and filmed in the pre-
`
`gentriflcation Alphabet City of the early
`1980s.
`
`The 1999 film Flawless, starring Philip
`
`Seymour Hoffman, Robert De Niro, and
`Wilson Jennaine Heredia, takes place in
`
`Alphabet City with all filming taking place
`there.
`
`Alphabet City was featured in the film 200
`Cigarettes, also from 1999.
`Much of the independent film Supersize Me,
`released in 2004, takes place in Alphabet
`City, near the residence of director Morgan
`Spurlock.
`
`The 2005 motion picture Rent, starring
`Rosario Dawson, Wilson Jennaine Heredia,
`Jesse L. Martin, Anthony Rapp, Adam
`Pascal, Idina Menzel, Taye Diggs, and Tracie
`Thorns, is an adaptation of the 1996
`Broadway rock opera of the same name by
`Jonathan Larson (which itself is heavily
`based on Puccini's opera La Boheme) and set
`in Alphabet City on llth Street and Avenue
`B, although many scenes were filmed in San
`Francisco. Unlike the stage musical, which
`was not set in a specific period of time, the
`film is clear that the story takes place
`between 1989 and 1990. Although this leads
`to occasional anachronisms in the story, the
`
`time period is explicitly mentioned to
`establish that the story takes place before the
`gentrification of Alphabet City.
`
`Theatre
`
`I The Broadway musical Rent takes place in
`Alphabet City. The characters live on East
`llth Street and Avenue B. They hang out at
`such East Village locales as Life Cafe.
`In Tony Kushner's play, Angels in America
`(and the film adaptation of same), the
`character Louis makes a comment about
`
`"Alphabet Land," saying it's where the Jews
`lived when they first came to America, and
`"now, a hundred years later, the place to
`which their more seriously fucked—up
`grandchildren repair."
`
`The Broadway musical Avenue Q takes place
`on the fictitious Avenue Q, which is, for the
`
`sake of the plot, located in Alphabet City.
`One of the main characters mentions he is
`
`looking for cheap accommodation in
`Alphabet City.
`
`Music: Specific avenues
`
`"The Belle of Avenue A" is a song by Ed
`Sanders.
`
`"Avenue A" is a song by The Dictators, from
`their 2001 CD, DFFD.
`
`"Avenue A" is a song by Red Rider off their
`1980 album, Don't Fight It.
`"Avenue B" is a song by Gogol Bordello
`"Avenue B" is a song by Mike Stern
`Avenue B is an album by Iggy Pop, who
`wrote the album while living at the
`Christodora House on Avenue B.
`
`"Avenue C" is a Count Basie Band song,
`
`recorded by Barry Manilow in 1974 for his
`album Barry Manilow 1].
`"Venus of Avenue D" is a song by Mink
`DeVille.
`‘
`Avenue D is referred to in the Steely Dan
`
`song, "Daddy Don't Live In That New York
`City No More" off the 1975 album Katy Lied.
`Singer-songwriter Ryan Adams refers to
`Avenue A and Avenue B in his track "New
`
`York, New York".
`
`In Bongwater's "Folk Song" there is the
`repeated chorus "Hello death, goodbye
`Avenue A". Ann Magnuson, lead singer of
`Bongwater, lives on Avenue A.
`The Pink Martini song "Hey Eugene" takes
`place "at a party on Avenue A."
`The 1978 classical salsa hit "Pedro Navaja",
`
`by Panamanian singer Ruben Blades, says at
`the end that the "lifeless bodies" of Pedro
`
`Barrios (Pedro Navaja) and Josefina Wilson
`were found on "lower Manhattan" "between
`Avenues A and B"...
`
`In Lou Reed's "Halloween Parade", from his
`
`highly acclaimed concept album New York
`(album), he mentions "the boys from Avenue
`B and the girls from Avenue D."
`It is mentioned in Sunrise on Avenue C,
`
`James Maddock from the album Fragile?"
`
`Music: General
`
`Elliott Smith refers to "Alphabet City" in his
`song, "Alphabet Town," from his self-titled
`album.
`
`Alphabet City is an album by ABC.
`
`file:///C:/Users/WORKST~1/AppData/Local/Temp/700CZHH4.htm
`
`3/30/2015
`
`

`
`- A1P_hab°‘C"7z§el¥;‘é’Ei¥‘1tE>‘%‘EE\7-lY2§§’f5li"E3i‘=1‘eEl88L‘ilin°é/i‘it?°‘i3fied 04/02/15 Page 14 of so Page 6 °f7
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 14 of 30
`
`"Take A Walk With The Fleshtones" is a
`
`song by The Fleshtones on their album
`Beautiful Light (1994). The song devotes a
`verse to each Avenue.
`
`Alphabet City is mentioned in the song
`"Poster Girl" by the Backstreet Boys.
`
`In the song "New York City," written by Cub
`and popularized by They Might be Giants,
`Alphabet City is mentioned in the chorus.
`The Clash mentions the neighborhood in the
`song "Straight to Hell": "From Alphabet City
`all the way a to z, dead, head"
`
`I U2 refer to the neighborhood as "Alphaville"
`in their song "New York".
`
`In their song "Click Click Click Click" on the
`2007 album The Broken String, Bishop Allen
`
`sing, "Sure I've got pictures of my own, of all
`the people and the places that I've known.
`Here's when I'm carryin' your suitcase,
`outside of Alphabet City".
`On Dan the Automator's "A Better
`
`Tomorrow", rapper Kool Keith quips that he
`is the "King of New York, running Alphabet
`City".
`
`I
`
`"Alphabet City" is the name of the fifih track
`on the 2004 release, The Wall Against Our
`Back from the Columbus, Ohio band Two
`Cow Garage.
`
`Steve Earle's expressionistic "Down Here
`Below" (track 2 of Washington Square
`Serenade) cites: "And hey, whatever
`happened to Alphabet City? Ain’t no place
`
`left in this town that a poor boy can go"
`The dance hit "Sugar is Sweeter (Danny
`Saber Mix)" by CJ Bolland refers to the
`neighborhood with the lyrics, "Down in
`Alphabet City..."
`
`See also
`
`Community gardening
`Dos Blockos
`
`Museum of Reclaimed Urban Space
`
`Nuyorican Poets Cafe
`Riis Houses
`
`St. Brigid's Church
`
`References
`
`Notes
`
`1.
`
`"Selling the Lower East Side - Geography
`Page" (http://www.upress.umn.edu/sles/sles-maps.html).
`Upress.umn.edu. Retrieved 2010-10-15.
`"Exhibitions" (http://www.thevillager.com/villager_l 79/exhibitions.html).
`The Villager. October 4, 2006. Retrieved 2009-08-22.
`Foderaro, Lisa W. (May 17, 1987). "Will it be Loisaida of Alphabet
`city?; Two Visions Vie In the East
`Village" (http://www.nytimes.com/1987/05/17/realestate/will-it-be-
`loisaida-or-alphabet-city-two-visions-vie-in-the-east-village.html). The
`New York Times. Retrieved 2009-08-22.
`
`Rowe, Peter G. (1999). "Civic Realism" (http://books.google.com/books?
`id==NnUjjjjyjOgC&printsec=frontcover&dq=peter+g+rowe+civic+realismé
`MIT Press. Retrieved 2010-03-22.
`
`Koch, Ed (April 27, 1984). "Needed: Federal Anti-Drug
`Aid" (http://wvvw. nytimes.com/1 984/04/27/opinion/needed-federa1-anti-
`drug-aid.html). The New York Times. Retrieved 2010-03-22.
`Freedman, Samuel (November 4, 1984). "Metropolis of the
`Mind" (http://wvvw.nytimes.com/1984/1 1/04/magazine/metropolis-of-
`the-mind.html). The New York Times. section 6, page 32, column 1.
`Retrieved 2010-03-22.
`
`Shaw, Dan (November 1 1, 2007). "Rediscovering New York as It Used
`to Be" (http://www.nytimes.com/2007/1 1/1 1/realestate/1 1habi.html?
`_r—=l&relErealestate&oref=slogin). The New York Times. ISSN 0362-
`4331 (https://www.worldcatorg/issn/0362-4331). Archived
`(http://web.archive.org/web/20071 1 12161508/http://www.nytimes.com/20(
`__r=l&ref=realestate&oref=slogin) from the original on 12 November
`2007. Retrieved 2007-11-12.
`
`Leland, John (8 December 2012). "East Village Shrine to Riots and
`Radicals" (http://www.nytimes.com/2012/ 12/09/nyregion/the-museum-
`of-reclaimed-urban-space-enshrines-the-east-village-struggle.html?_r=0).
`New York Times.
`
`"East 10th Street Historic District Designation
`
`Report" (http://wvvw.nyc.gov/htm1/lpc/downloads/pdflreports/2492.pdf).
`NYC Landmarks Preservation Commission.
`
`11.
`
`“St. Nicholas of Myra Orthodox Church Designation
`Report" (http://www.nyc.gov/htrnl/lpc/downloads/pdf/reports/StNicholasl
`NYC Landmarks Preservation Commission.
`
`"Free Public Baths of the City of New York, East 11th Street
`Bath" (http://www.nyc.gov/html/lpc/downloads/pdf/reports/1 lst_baths.pd
`NYC Landmarks Preservation Commission.
`"Public National Bank ofNew York
`
`Building" (http://www.nyc.gov/html/lpc/downloads/pdflreports/publicnati
`NYC Landmarks Preservation Commission.
`
`. "Former Congregation Beth Hamedrash Hagadol Anshe Ungarn
`Building" (http://wvvw.nyc.gov/html/lpc/downloads/pdflreports/ansheungz
`NYC Landmarks Preservation Commission.
`"Former Public School
`
`64" (http://wvvw.nyc.gov/html/1pc/downloads/pdf/reports/ps64.pdi). NYC
`Landmarks Preservation Commission.
`
`"Congregation Mezritch Request for
`Evaluation" (http://gvshp.org_gvshp/preservation/mezritch/doc/Congrega
`Greenwich Village Society for Historic Preservation.
`
`file:///C:/UsersNVORKST~1/AppData/Local/Temp/700CZHH4.htm
`
`3/30/2015
`
`

`
`. AlphabetCi‘Z§al‘éItE’r“i¥“l‘E»*1‘E£\7-ll/2i1§§°f5li*t3I’i1‘er§’8ESh‘1°é/fiiTe‘l3fied 04/02/15 Page 15 of so Page 7 °f7
`Case 1:15-cv-02551-KBF Document 1 Filed 04/02/15 Page 15 of 30
`
`"Historic East Village House Rejected by
`Landmarks" (http://www.gvshp.org/_gvshp/preservation/east__village/ev-
`O9-14-11.htm). Greenwich Village Society for Historic Preservation.
`"The Robyn is now fully exposed on East 3rd
`Street" (http://evgrieve.com/2014/O7/the-robyn-is-now—fully-exposed-on-
`east.html). EV Grieve blog.
`"326 & 328 East 4th
`
`18.
`
`Street" (http2//www.gvshp.org/_gvshp/preservation/326-328—e4/326-328-
`e4-main.htm). Greenwich Village Society for Historic Preservation.
`"Keeping in Character: A Look at the Impacts of Recent Community-
`Initiated Rezonings in the East
`Village" (http://www.gvshp.org/_gvshp/preservation/east_village/doc/keep
`in-characterpdi). Greenwich Village Society for Historic Preservation.
`
`"Loisaida recipe" (http://www.drinksmixer.com/drinkrq17512.html). 30
`December 2008.
`4
`
`Ix) .—a
`
`. http://www.allenginsbergorg/index.php?page=allen-ginsberg-1 953-2
`"Geoffrey Biddle" (http://geoffreybiddlecom/). Retrieved 24 October
`2010.
`
`whatyouwrite (2006-09-13). "Street Play, Photographs By Martha
`Cooper
`« Whatyouwrite.Com" (http://whatyouwrite.wordpress.com/2006/09/13/st
`play-photographs-bymartha-cooper/). Whatyouwrite.wordpress.com.
`Retrieved 2010-10-15.
`'
`
`24.
`
`http://wvvw.imdb.com/title/ttOl 17 103/
`"James Maddock" (http://jamesmaddock.net/).
`
`Further reading
`
`I Alphabet City: The ABCs of Gentrification (http://www.businessweek.com/magazine/content/0l_24/b3736044.htrn), Karin Pekarchik,
`BusinessWeek, June 11, 2001
`
`Retrieved from "http://en.wikipedia.org/w/index.php?title=Alphabet_City,__Manhattan&oldid=654235924"
`
`Categories: Neighborhoods in Manhattan I East Village, Manhattan I Hispanic and Latino American culture in New York City
`
`I Puerto Rican culture in New York I Ethnic enclaves in New York
`
`
`This page was last modified on 30 March 2015, at