Case 2:22-cv-02552-JTF-cgc Document 1 Filed 08/23/22 Page 1 of 5 PageID 1
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
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`TERESA LA DART,
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`Plaintiff,
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`v.
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`TAYLOR SWIFT, TAYLOR SWIFT
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`PRODUCTIONS, INC.
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`Defendants.
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`Case No.
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`COMPLAINT
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`INTRODUCTION
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`1. This is an action for copyright infringement by Teresa La Dart, (“TLD”),
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`the owner of the rights to the creative elements of her published book “Lover.” The “Lover”
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`book was written and designed by TLD and published by AuthorHouse on January 12, 2010.
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`“Lover” was registered with the United States Copyright Office that same year. Defendant
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`Taylor Swift (“Swift”), along with the other Defendant Taylor Swift Productions, Inc. (“TSP”)
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`released the album “Lover” with an accompanying book (“the Swift and TSP ‘Lover’ book”) of
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`the same name on August 23, 2019. The Swift and TSP “Lover” book included a number of
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`creative elements that copied the expressive designs and arrangements of the TLD “Lover” book
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`without authorization or credit, to the detriment of TLD.
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`FACTS
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`2. The TLD book, “Lover”, (the “TLD Work”) was written by TLD over a number of
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`years with the final compilation of writings and cover and internal designs and arrangements
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`1
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
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`TERESA LA DART,
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`:
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`:
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`Plaintiff,
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`:
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`v.
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`:
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`TAYLOR SWIFT, TAYLOR SWIFT
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`PRODUCTIONS, INC.
`:
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`:
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`Defendants.
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`:
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`Case No.
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`COMPLAINT
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`
`
`INTRODUCTION
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`1. This is an action for copyright infringement by Teresa La Dart, (“TLD”),
`
`the owner of the rights to the creative elements of her published book “Lover.” The “Lover”
`
`book was written and designed by TLD and published by AuthorHouse on January 12, 2010.
`
`“Lover” was registered with the United States Copyright Office that same year. Defendant
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`Taylor Swift (“Swift”), along with the other Defendant Taylor Swift Productions, Inc. (“TSP”)
`
`released the album “Lover” with an accompanying book (“the Swift and TSP ‘Lover’ book”) of
`
`the same name on August 23, 2019. The Swift and TSP “Lover” book included a number of
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`creative elements that copied the expressive designs and arrangements of the TLD “Lover” book
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`without authorization or credit, to the detriment of TLD.
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`
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`FACTS
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`2. The TLD book, “Lover”, (the “TLD Work”) was written by TLD over a number of
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`years with the final compilation of writings and cover and internal designs and arrangements
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`1
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`Case 2:22-cv-02552-JTF-cgc Document 1 Filed 08/23/22 Page 2 of 5 PageID 2
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`completed and published all together in 2010. The full book was registered for copyright on
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`February 5, 2010, under TX 7-143-843 (Exhibit A)(“TLD’s Registered Copyright”). The 2010
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`copyright registration used a full copy of the TLD Work as the deposit copy filed with the United
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`States Copyright Office.
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`3. It is Plaintiff TLD’s view that the scope of the 2010 copyright registration for the full
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`TLD Work includes the entirety of the book, including all design and textual elements thereof.
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`4. The design and textual elements embodied within the TLD Work are original and
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`unique.
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`5. The Swift and TSP “Lover” book was released as part of Swift’s “Lover” album on
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`August 23, 2019, with all credits for design and textual elements claimed as works by Swift
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`(and/or TSP).
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`6. Upon information and belief, the Swift and TSP “Lover” book has achieved
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`considerable sales in association with the Swift “Lover” album through numerous different
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`sources (retail stores and on-line services, at least) and has reached at least 2.9 million copies
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`sold within the United States since its release date (over 4 million copies sold internationally).
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`7. Plaintiff TLD was not accorded any credits nor received any payments related to the
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`Swift and TSP “Lover” book since August 23, 2019.
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`8. The Swift and TSP “Lover” book as released and published by Swift and TSP and
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`claiming all creative credits for Swift, as well, includes, at least, i) substantially the same format
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`of a recollection of past years memorialized in a combination of written and pictorial
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`components within a book, ii) with a substantially similar cover format, with the author
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`photographed in a downward pose, and color scheme (pastel pinks and blues) with the same title
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`(again, “Lover”), iii) with substantially the same introduction page formats with a similarly
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`2
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`Case 2:22-cv-02552-JTF-cgc Document 1 Filed 08/23/22 Page 3 of 5 PageID 3
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`styled “Lover” title, as well as an earlier photograph of the author in a nature setting and turned
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`to the right and an accompanying forward with substantially similar greetings and wishes for the
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`reader, iv) with a substantially similar inner book design with interspersed photographs and
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`writings throughout the body thereof, v) and with a substantially similar back cover format, with
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`the author photographed in an upward pose (juxtaposed with the front cover pose), and, again, a
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`substantially similar color scheme (pastel pinks and blues), all in comparison with the creative
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`elements of the TLD Work designs owned by TLD in total, as well as protected by TLD’s
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`Registered Copyright (comparisons provided in Exhibit B).
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`9. Stylistically, the Swift and TSP “Lover” book includes creative elements that are not
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`typical of or present within other published books and as compared with the TLD Work leaves
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`an overall impression that the Swift and TSP “Lover” book is, again, substantially similar in
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`terms of the above-noted design elements as those within the TLD Work.
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`10. The TLD Work was published in 2010 and made available through various channels
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`by publisher AuthorHouse, thus allowing for repeated and long-term access to Swift and TSP
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`(either directly or indirectly) until the Swift and TSP “Lover” book was released.
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`11. The Defendants to this day have neither sought, nor obtained, a license from TLD of
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`her creative design element rights, nor have they given any credit to TLD in relation to the TLD
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`Work and the infringing Swift and TSP “Lover” book release, let alone provided any monetary
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`payments for the TLD Work and the infringing Swift and TSP “Lover” release to the Plaintiff.
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`Case 2:22-cv-02552-JTF-cgc Document 1 Filed 08/23/22 Page 4 of 5 PageID 4
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`CAUSE OF ACTION
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`(Copyright Infringement – 17 U.S.C. § 101, et seq.)
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`12. Plaintiff repeats and realleges each of the foregoing Paragraphs as though fully set
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`forth herein. The Defendants’ reproduction, distribution, and sales of the infringing work, the
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`Swift and TSP “Lover” book in the United States and internationally, continue to this day, and
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`Defendants have not deigned to compensate the copyright owner of the Work (TLD) for the use
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`of the copyrighted work in the TLD Work. The Defendants’ reproduction, distribution, licensing,
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`merchandizing, and economic exploitation of the Swift and TSP “Lover” book, and authorizing
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`others to do the same, infringes Plaintiff’s exclusive rights under the Copyright Act.
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`13. As a direct and/or proximate result of the Defendants’ wrongful conduct, the Plaintiff
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`has been irreparably harmed, suffered damage, and Defendants have profited in an amount in the
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`amount to be determined at trial.
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`14. One or more of the Defendants infringed on Plaintiff’s exclusive copyright in the
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`TLD Work when it distributed and sold the Swift and TSP “Lover” book and generated all other
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`economic exploitation thereof associated with the same. Such reproduction and release were
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`wholly unauthorized as it was without any license or consent of authority from the Plaintiff
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`(TLD). By virtue of this unauthorized commercial exploitation, Defendants have realized illegal
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`revenues.
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`15. As a direct and/or proximate result of the Defendants’ infringement on Plaintiff’s
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`exclusive copyright in the TLD Work (again, the TLD “Lover” book), Plaintiff has suffered
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`damages. Said injuries are continuing and will not abate in the future.
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`28. Pursuant to 17 U.S.C. § 504(c), the Plaintiff is entitled to statutory damages since the
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`infringement occurred after the copyright was registered.
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`Case 2:22-cv-02552-JTF-cgc Document 1 Filed 08/23/22 Page 5 of 5 PageID 5
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`WHEREFORE, the Plaintiff TLD respectfully requests that judgment be entered against
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`the enumerated Defendants, as follows:
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`A. For judgment that all of the Defendants, by virtue of their involvement with the
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`creation, publication, reproduction, public dissemination, and distribution of the Swift and TSP
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`“Lover” book, have violated the Copyright Act;
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`B. For judgment assessing Defendants for the damages in excess of one million dollars
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`($1,000,000.00) suffered by Plaintiff, including an award of actual damages and Defendants’
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`profits attributable to the infringement, or statutory damages (at Plaintiff’s election), under the
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`Copyright Act, as well as costs and attorney’s fees to the full extent provided for by Sections
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`501, 504 and 505 of the Copyright Act, 17 U.S.C. §§ 501, 504 and 505; damages and profits
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`shall include all profits and damages resulting from exploitation of the work domestically and
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`internationally.
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`REQUEST FOR TRIAL BY JURY
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`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff demands a trial
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`by jury as to all issues triable by jury, as enumerated and set forth in more detail in this
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`Complaint.
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`Dated: August 23, 2022
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`5
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`Memphis, Tennessee
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`s/ William S. Parks
`William S. Parks, BPR# 27681
`William S. Parks, PLLC
`172 W. Viking Drive
`Cordova, Tennessee 38018
`(901) 412-2755
`billparks@billparkslaw.com
`Attorney for Plaintiff Teresa La Dart
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