Warner Bros. Entertainment Inc. et al v WTV Systems, Inc.

Filing 1

COMPLAINT against Defendants Venkatesh Srinivasan, WTV Systems, Inc., WTV Systems, LLC.Case assigned to Judge John F. Walter for all further proceedings. Discovery referred to Magistrate Judge Charles F. Eick.(Filing fee $ 350 PAID) Jury Demanded, filed by plaintiffs Paramount Pictures Corporation, Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Columbia Pictures Industries, Inc., Warner Bros. Entertainment Inc., Disney Enterprises, Inc.(car) (Additional attachment(s) added on 4/7/2011: # 1 Civil Cover Sheet) (ds). (Additional attachment(s) added on 4/7/2011: # 2 Notice of Assignment, # 3 Summons) (ds).

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GLENN D. POMERANTZ (SBN 112503)
Glenn.Pomerantz({i)mto.com
KELLY M. KLAtT'S (SBN 161091)
KeJfy~Klaus({i)mto. com
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue, Thirty-Fifth Floor
Los Angeles, CA 90071-1560
Tel: [phone]; Fax: [phone]

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.:::-

DANIEL E. ROBBINS (SBN 156934)
Dan Robbins({i)mpaa.org
BENJAMIN S":'SHEFFNER (SBN 212629)
Ben [e-mail]
153U1 Ventura Boulevard, Building E
Sherman Oaks, California 91403-3102
Tel: [phone]; Fax: [phone]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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WARNER BROS. ENTERTAINMENT
INC., COLUMBIA PICTURES
INDUSTRIES, INC., DISNEY
ENTERPRISES, INC., PARAMOUNT
PICTURES CORPORATION,
TWENTIETH CENTURY FOX FILM
CORPORATION, and UNIVERSAL
CITY STUDIOS PRODUCTIONS
LLLP,

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Plaintiffs,

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COMPLAINT FOR COPYRIGHT
INFRINGEMENT
DEMAND FOR JURY TRIAL

vs.
WTV SYSTEMS, INC. and WTV
SYSTEMS, LLC d/b/a ZED IVA, and
VENKA TESH SRINIVASAN,
Defendants.

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COMPLAINT

1

The Court has original subject matter jurisdiction over all claims pursuant to

2

17 U.S.C. §§ 101, et seq. and 28 U.S.C. §§ 1331 and 1338(a). Plaintiffs Warner

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Bros. Entertainment Inc., Columbia Pictures Industries, Inc., Disney Enterprises,

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Inc., Paramount Pictures Corporation, Twentieth Century Fox Film Corporation,

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and Universal City Studios Productions LLLP (collectively, "Plaintiffs" or

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"Studios"), by their attorneys, for their complaint against WTV Systems, Inc. and

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WTV Systems, LLC d/b/a Zediva ("Zediva"), and Venkatesh Srinivasan

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(collectively, "Defendants") allege, on personal knowledge as to themselves and

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information and belief as to others, as follows:

NATURE OF THE ACTION

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1.

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Defendants operate a commercial video-on-demand ("VOD") service-

12 found at http://www.zediva.com-thatstreamsPlaintiffs·movies on demand to
13 paying customers over the Internet. Defendants promote their service as bringing
14 "new release and popular movies to the Internet"] and focus their marketing pitch on
15 the fact that Zediva users can "instantly watch new movies much earlier (often
16 several weeks or months)" than they can on authorized services such as Netflix.2
2.

17

Unlike Netflix and other licensed online services, Defendants' business

18 is based on infringing Plaintiffs' rights. Defendants transmit performances of
19 Plaintiffs' copyrighted works to members of the public without Plaintiffs'
20 authorization. Defendants thereby infringe Plaintiffs' exclusive rights to perform
21 their works publicly, 17 U.S.C. §§ 101, 106(4). Plaintiffs and their affiliates invest
22 billions of dollars in creating copyrighted motion pictures. Defendants exploit that
23 investment without any authorization from Plaintiffs, while pocketing all of the
24 money Defendants charge Zediva users for unauthorized performances of Plaintiffs ,
25 works.
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] http://www.zediva.comlabout (last visited Apr. 1, 2011).
2 htip:llwww.zediva.comlfaq (last visited Apr. 1, 2011).

- 1-

COMPLAINT

1

3.

Defendants claim they do not have to obtain a license from and

2 compensate Plaintiffs for exploiting their rights because Zediva purportedly is a
3 "movie rental service," which involves a user "renting both a DVD and DVD player
4 in [Defendants'] data center,,,3 and Zediva transmitting the movie to the user "over
5 the Internet using streaming technologies.,,4
6

4.

Defendants' comparison of the Zediva service to a rental store is

7 disingenuous, and Defendants are attempting to rely on technical gimmicks in an
8 effort to avoid complying with U.S. Copyright Law. Defendants operate an online
9 VOD service, not a neighborhood rental store. Unlike Zediva, rental stores do not
10 transmit performances of movies to the public "over the Internet using streaming
11 technologies.,,5 A rental store or any other establishment would also need a license
12 to do so.
13

5.

Under the plain language of the Copyright Act, Defendants are

14 exercising Plaintiffs' exclusive rights to publicly perform their copyrighted works.
15 Defendants' transmissions of the performances of Plaintiffs' works are to the public
16 regardless of whether Defendants' users receive those performances "in the same
17 place or in separate places and at the same time or at different times." 17 U.S.C.
18 § 101 (definition of"[t]o perform ... a work 'publicly,'" clause (2)). Exercising
19 Plaintiffs' exclusive rights without their permission-something Defendants do not
20 have and claim they do not need-is copyright infringement.
21

6.

Defendants' flagrant violation of Plaintiffs' exclusive rights directly

22 undermines Plaintiffs' present and continuing development of a legitimate market for
23 the exploitation of Plaintiffs' rights.
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3 http://www.zediva.comlfaq (last visited Apr. 1,2011).
4 Letter from Venkatesh Srinivasan to Julius Genachowski, FCC Chairman at 1
(Dec. 10, 2010) ("FCC Letter"), ht!R://www.zediva.comlZedivaFCCLetter12102010.pdf (last visited Apr. 1,2011).
5 FCC Letter at 1.
-2-

COMPLAINT

THE PARTIES

1

2

7.

Plaintiff Warner Bros. Entertainment Inc. is a corporation duly

3 incorporated under the laws of the State of Delaware with its principal place of
4 business located in Burbank, California.
5

8.

Plaintiff Columbia Pictures Industries, Inc. is a corporation duly

6 incorporated under the laws of the State of Delaware with its principal place of
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usiness located in Culver City, California.
9.

Plaintiff Disney Enterprises, Inc. is a corporation duly incorporated

9 under the laws of the State of Delaware with its principal place of business located in
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urbank, California.
10.

Plaintiff Paramount Pictures Corporation is a corporation duly

12 incorporated under the laws of the State of Delaware with its principal place of
13 business located in Los Angeles, California.
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11.

Plaintiff Twentieth Century Fox Film Corporation is a corporation duly

15 incorporated under the laws of the State of Delaware with its principal place of
16 business located in Los Angeles, California.
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12.

Plaintiff Universal City Studios Productions LLLP is a limited liability

18 limited partnership duly organized under the laws of the State of Delaware with its
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rincipal place of business located in Universal City, California.
13.

Plaintiffs and/or their affiliates own or control the copyrights and/or the

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elevant exclusive rights in the works at issue in this case under the United States

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opyright laws. Plaintiffs or their licensors have obtained Certificates of Copyright

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egistration from the Register of Copyrights for their works. Attached hereto as

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xhibit A is a list of certain of Plaintiffs' copyrighted works that Defendants have

25 infringed by the acts complained of herein. Exhibit A identifies by number the
26 Certificates of Copyright Registration issued to Plaintiffs or their licensors.
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-3-

COMPLAINT

1

14.

On infonnation and belief, Defendant WTV Systems, Inc. is

2 incorporated under the laws of the State of Delaware with its principal place of
3 business at 1549 Bedford Avenue, Sunnyvale, California 94807.
4

15.

On infonnation and belief, Defendant WTV Systems, LLC is

5 incorporated under the laws of the State of Delaware with its principal place of
6 business at 1549 Bedford Avenue, Sunnyvale, California 94807.
7

16.

On infonnation and belief, Defendant Venkatesh Srinivasan's principal

8 place of residency is 1549 Bedford Avenue, Sunnyvale, California 94807.
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JURISDICTION AND VENUE

17.

The Court has subject matter jurisdiction over the federal law cause of

11 action pleaded herein pursuant to 28 U.S.C. §§ 1331 (federal question), and 1338(a)
12 (any act of Congress relating to copyright), and pursuant to the Copyright Act, 17
13 U.S.C. §§ 101, et seq.
14

18.

This Court has personal jurisdiction over Defendants, and venue is

15 proper in this Judicial District pursuant to 28 U.S.C. § 1391(b) because, inter alia,
16 (a) Defendants and/or their agents are doing business in this District; and (b) a
17 substantial part of the events or omissions giving rise to this lawsuit, as well as
18 substantial injury to Plaintiffs, have occurred or will occur in interstate commerce, in
19 the State of California, and in the Central District of California. Venue also is proper
20 in this District pursuant to 28 U.S.C. § 1400(a) because Defendants may be found in
21 this District in light of their extensive commercial activities here.
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BACKGROUND FACTS
Plaintiffs and their Copyrighted Works

19.

Plaintiffs, directly or through their affiliates, are engaged in the business

25 of developing, producing, and distributing, and licensing to others the right to'
26 distribute and exhibit, copyrighted motion pictures in the United States and
27 throughout the world.
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COMPLAINT

1

20.

Plaintiffs own or have the exclusive rights in the United States to,

2 among other things, publicly perform the copyrighted works at issue in this action,
3 including by means of streaming those works over the Internet to the public.
4 Defendants have not received any authorization, permission or consent to publicly
5 perform the Plaintiffs' copyrighted works at issue in this lawsuit.
6

21.

Plaintiffs, either directly or through their affiliates and/or licensees,

7 distribute and publicly perform their copyrighted works in various forms, including,
8 without limitation, for exhibition in theaters; through television broadcasts; through
9 cable and direct-to-home satellite services (including basic, premium, "pay-per10 view" and "video on demand" services); and through authorized, licensed Internet11 based services such as Netflix, Apple iTunes, Amazon VOD services, Microsoft
12 Xbox LIVE Marketplace, Blockbuster On Demand, CinemaNow, and the Sony
13 Playstation Network. Plaintiffs also distribute their works to the home viewing
14 market, including by selling copies of the motion pictures on tangible products, such
15 as DVDs and Blu-ray discs, and by licensing digital downloads through various
16 servIces.
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22.

Plaintiffs have invested (and continue to invest) substantial sums of

18 money and effort each year to develop, produce, distribute and publicly perform their
19 motion pictures which are protected under copyright and other laws. Defendants'
20 illegal actions, as described herein, infringe upon Plaintiffs' exclusive rights and
21 deprive Plaintiffs of the economic value of those rights.
22

The Zediva Service

Defendants Transmit Plaintiffs' Copyrighted Content to the Public

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23.

Defendants operate Zediva, a web site located on the Internet at http://

25 www.zediva.com. Defendants officially launched their service on March 16, 2011. 6
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http://zedivamovies.blogspot.coml20 11103/weve-Iaunched.html (last visited Apr.
1,2011).

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-5-

COMPLAINT

1

24.

Defendants describe their service as a way to "watch new movies

2 online. Just pick the movie you want to watch and enjoy.,,7 As Defendant
3 Srinivasan states, "[o]ur goal is to have the top 100 movies of the last 12 months at
4 any time," providing "immediate access to the most current and popular
5 blockbusters.,,8 Defendants' "Terms & Conditions of Use" refer to Plaintiffs as
6 purported "third party content providers,,9 whose content is critical to Defendants'

7 business.
8

25.

Defendants' advertising clearly shows they offer to transmit

9 performances of popular motion picture releases:
10
11

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Pricing

How It Works

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7http://www.facebook.com!apps/application.p.hp?id 163946686950855#!/apps/appl
icatlOn.php?id=163946686950855&sk=info (last visited Apr. 1,2011).
8 http://alltopstartups.com!20 11103/23/zediva-is-the-new-n~tflix-with-a­
controversial-twist? (last visited Apr. 1,2011); http://www.xconomy.com!sanfrancisco/20 11103116/zediva-Iaunches-online-dvd-viewing/ (same).
9 http://www.zediva.com!tou (last visited Apr. 1,2011).
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COMPLAINT

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Pricing

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I] u ...~

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Movies

!])

HlW MOVIU HOW

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New Releases

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J:lckOJ':' 1 In 20

Top 10

All DVDs

Coming Soon

The Next

Morning Glory

Thr~

OOlV-'

Burle,quc

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25

10

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http://w1.zediva.comlsplashlindex.php (last visited Apr. 1,2011);

http:Tlw l.zediva.comlsplashlworks.htmf (same).
-7-

COMPLAINT

1

26.

Defendants promote their unauthorized service as allowing users to

2 watch new movies much earlier-"often several weeks or months"-than they could
3 with authorized online services. Defendants currently charge as little as a dollar per
4 streamed work, when a user purchases a "bundle" of streams of 10 different
5 movies. 11 Defendants' prices may be half (or less than half) of the prices that
6 licensed services charge.
7

27.

As Time Magazine noted on its "Techland" blog, the reason that

8 Defendants can "shave[] down" their pricing is because they "cut[] movie studios out
9 of the equation" and do not "negotiat[e] streaming rights. ,,12
10

28.

Defendants digitally transmit content to members of the public through

11 Internet streaming, much the same as authorized services that have licensed these
12 rights from Plaintiffs.
13

29.

Defendants stream performances of Plaintiffs' copyrighted works from

14 the same DVD to numerous different members of the public.
15

30.

By way of example, Defendants' website describes a basic "rental"

16 period of 14 days. The user has access to the movie on the DVD for four hours at a
17 time, or until the user's playback is paused for an extended time period; in either
18 event, Defendants' service deems the particular DVD to be "returned" and available
19 for streaming to other users. 13
20
21 .

Defendants' Announced Plans to Expand Their Service

31.

Defendants plan to expand their user base by increasing the number of

22 devices to which they will stream Plaintiffs' works. Defendants state that the Zediva
23 service is "limited to PC, MAC and Google TV" and handheld, cellular "Android
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II http://www.zediva.comlfaq (last visited Apr. 1,2011);
http://wl.zediva.comlsplashlpncing.html ( same).
12 http://techland.time.coml20 11103116/zedivas-movie-rentals-are-50-cheaper-thanitunes/#ixzzlHqSGXAfx (last visited Apr. 1,2011).
I3 http://www.zediva.comlfag (last visited Apr. 1, 2011). Defendants say that this
"is out of consideration to otlier users who may be waiting to rent the DVD." Id.

-8-

COMPLAINT

1 devices," and is "working hard to add support for iPhone/iPad and game consoles
2 like Xbox, PS3," and "hope[s] to quickly expand the number of platforms and
3 devices we can serve in 2011.,,14

4

Zediva Founder and CEO Venkatesh Srinivasan's Active Participation in

5

and Control ofZediva's Infringing Activities

6

32.

Defendant Srinivasan is Zediva's Founder and CEO. Srinivasan directs,

7 controls, ratifies, and participates in Zediva's infringing activity.
8

33.

Srinivasan has been personally involved in and personally responsible

9 for (a) Zediva's decision to stream the Plaintiffs' copyrighted works over the Internet
10 without Plaintiffs' consent; (b) the development of Zed iva's business model and
11 technological systems employed by Zediva in the infringement of Plaintiffs'
12 copyrights; (c) the solicitation of financial support for the infringing Zediva service;
13 (d) the widespread promotion of Zediva' s infringing service through public
14 appearances and statements to the press and others; and (e) the decision to continue
15 and to expand Zediva's infringing activity despite widespread reports regarding the
16 service's illegal nature. Srinivasan spent several years leading a team that developed
17 the infringing Zediva service; he has personally supervised, and has a direct and
18 personal financial interest in, its infringing activities.
19

34.

As Srinivasan personally posted on Zediva's blog,

20 http://zedivamovies.blogspot.comi, he created and developed Zediva's infringing
21 business model, and the "rest as they say is history. We set out to build that service 22 and with a few tweaks here, and a modification there, Zediva was born.,,15
23 Srinivasan played a central role in the development of Zediva's technology which
24 facilitates its infringing conduct. He is listed as an "inventor" on the patent
25
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14 http://www.zediva.comiabout (last visited Apr. 1,2011);
http://www.zediva.comifaq (same).
15 http://zedivamovies .blogspot.comi20 11 1031genesis-of-zediva.html (last visited
Apr. 1,2011).
-9-

COMPLAINT

1 application for the technology underlying the Zediva service. 16 Indeed, in many
2 respects, Zediva and Srinivasan are one and the same. According to Zediva's own
3 SEC "Form D" filing, Defendant WTV Systems, LLC (along with WTV Systems,
4 Inc., "Zediva") and Defendant Srinivasan share the same address.
5

35.

Srinivasan plays a core, central role in Zediva's infringing activities.

6 Zediva's website lists five key employees, and Srinivasan is at the top of even that
7 short list. I7 Srinivasan is intimately involved in the company's day-to-day
8 operations. After Zediva's servers crashed when the company launched out of beta,
9 Srinivasan personally posted on Zediva's blog that the company's news blitz "drove
10 huge volumes of traffic our way, and our servers got overwhelmed," but that they
11 were "back in business just after midnight" and will "build the service you want, and
12 get you off that waiting list as soon as we can.,,18
13

36.

Srinivasan has been quoted in a flurry of press on Zediva's recent

14 launch. Srinivasan repeatedly (and erroneously) has compared Zediva to using a
15 long remote control over the Intemet. 19 Srinivasan also has promoted the Zediva
16 service as allowing users to avoid "pay[ing] premium prices" for online streaming, 20
17 and as allowing users to watch movies earlier than other streaming sites because "we
18 are not party" to those "contractual agreement[ s]" that the Studios have with
19 authorized streaming services?1
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21
22
23
24
25
26
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28

Remote Rental of Digital Content Peripheral Storage Entities, U.S. Patent
Application No. US 201010125529 AI, at 1 (filed May 20,2010) ..
17 http://www.zediva.com/about (last visited Apr. 1,2011).
18 http://zedivamovies.blogspot.com/2011103/Iaunch-day-recap.html (last visited
Apr. 1,2011).
19 http://www.washingtonpost.comlblogs/faster-forwardlpost/zediva-offers-newapproach-to-online-movies/20111031167AB3sX6e blog.litml (last visited AJ)r. 1,
2011) ("It's like watching with a long cable and a10ng remote control."); FCC
Letter at 1 (Zediva like "a really realTy' long video cable and really long remote
control cable connected to the DVD player.").
20 http://hollywooddaily.us/20 11103117Izediva-streams-new-releases-beforenetlfIix-and-redboxi (last visited Apr. 1,2011).
21 http://business.financialpost.com/20 11103/16/zediva-Iaunches-netflix-rivall (last
visited Apr. 1, 2011).
- 10 -

COMPLAINT

1

37.

Srinivasan has been and is the primary actor in the activities of Zediva

2 that give rise to Plaintiffs' claims; he has had knowledge of, consented to and
3 exercised control over Zediva's infringing activities.
4

Defendants' Conduct Causes Immediate and Irreparable Harm to

5

Plaintiffs

6

38.

The significant harm caused by Defendants' conduct is both immediate

7 and irreparable to Plaintiffs' exclusive rights protected under federal law. The
8 Zediva service directly supplants and undermines Plaintiffs' and their authorized
9 licensees' offering of digital Studio content to consumers, including authorized
10 online streaming services, video-on-demand channels, DVD rentals, and other
11 platforms. Indeed, in a recent letter to the FCC, Srinivasan conceded that Zediva
12 "may be perceived to directly compete with the Video-on-Demand service,
13 PayPerView or other PayTV services offered by cable providers and, in some cases,
14 the providers of fiber networks and wireless networks.,,22 Defendants' illegal service
15 threatens to undermine these present and potential legitimate channels, at significant
16 cost to Plaintiffs and their licensees.
17

39.· By characterizing Zediva as a legitimate and lawful competitor to

18 licensed online services and as "fully compliant with the law,,,23 Defendants threaten
19 to confuse customers and the public and drive up early and immediate adoption of
20 the Zediva service by numerous additional end users, causing even greater immediate
21 and irreparable injury to Plaintiffs.
22

FIRST CAUSE OF ACTION

23

(Copyright Infringement, 17 U.S.C. §§ 106(4) and 501)

24

40.

Plaintiffs incorporate herein by reference each and every averment

25 contained in paragraphs 1 through 39 inclusive.
26
27
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22 FCC Letter at 1.
23 http://www.sfgate.comicgibiniarticle.cgi?f:-/c/a/2011l03/22IBU6QIIE40J.DTL&type=tech (last visited Apr.
1,2011).
- 11 -

COMPLAINT

1

41.

Through their conduct averred herein, Defendants have infringed

2 Plaintiffs' copyrights in their works by publicly performing Plaintiffs' copyrighted
3 works, without authorization from Plaintiffs, in violation of 17 U.S.C. §§106(4) and
4 501.
5

42.

Each infringement by Defendants of Plaintiffs' copyrighted works

6 constitutes a separate and distinct act of infringement.
7

43.

Defendants' acts of infringement are willful, in disregard of and with

8 indifference to the rights of Plaintiffs.
9

44.

As a direct and proximate result of the infringements by Defendants,

10 Plaintiffs are entitled to damages and Defendants' profits in amounts to be proven at
11 trial which are not currently ascertainable.
12

45.

Alternatively, Plaintiffs are entitled to the maximum statutory damages

13 in the amount of$150,000 per statutory award, or for such other amounts as may be
14 proper under 17 U.S.C. § 504.
15

46.

Plaintiffs further are entitled to recover their attorneys' fees and full

16 costs pursuant to 17 U.S.C. § 505.
17

47.

As a direct and proximate result of the foregoing acts and conduct,

18 Plaintiffs have sustained and will continue to sustain substantial, immediate and
19 irreparable injury, for which there is no adequate remedy at law. Unless enjoined
20 and restrained by this Court, Defendants will continue to infringe Plaintiffs' rights in
21 their copyrighted works. Plaintiffs are entitled to preliminary and permanent
22 injunctive relief.
23
24
25
26
27

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendants and against

all of their affiliates, agents, servants, employees, partners and all persons in active
concert or participation with them, for the following relief:

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COMPLAINT

1

1.

For Plaintiffs' damages and Defendants profits in such amount as may

2

be found; alternatively, for maximum statutory damages in the amount of$150,000

3

per statutory award, or for such other amounts as may be proper pursuant to 17

4

U.S.C. § 504(c).

5

2.

For preliminary and permanent injunctions enjoining Defendants, and

6

all persons acting in concert or participation with them, from publicly performing or

7

otherwise infringing in any manner Plaintiffs' copyrighted works.

8

9

3.

An order directing that Defendants file with the Court and serve upon

counsel for Plaintiffs within thirty (30) days after the entry of such order or

10

judgment, a report in writing and under oath setting forth in detail the manner and

11

form in which Defendants have complied with the injunction

12

4.

F or prejudgment interest according to law.

13

5.

For Plaintiffs' attorneys' fees and full costs incurred in this action

14
15
16

pursuant to 17 U.S.C. § 505.
6.

For all such further and additional relief, in law or in equity, to which

Plaintiffs may be entitled or which the Court deems just and proper.

17

DEMAND FOR JURY TRIAL

18

19

Plaintiffs hereby request a trial by jury on all issues triable by jury.

20
21

DATED: April 4, 2011

MUNGER, TOLLES & OLSON LLP

22
23
24

By~:~D~(~V~~~_
GLENN D. POME

25
26

NTZ

Attorneys for Plaintiffs

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- 13 -

COMPLAINT

Exhibit A

Plaintiff

U.S. Copyright
Registration
Number

Title

Warner Bros. Entertainment Inc.

Book of Eli, The

PA 1-659-118

Warner Bros. Entertainment Inc.

CoP Out

PA 1-703-015

Warner Bros. Entertainment Inc.

Dark Knight, The

PA 1-606-857

Warner Bros. Entertainment Inc.

Hereafter

PREOOOO03929

Warner Bros. Entertainment Inc.

Invention of Lying, The

PA 1-647-143

Warner Bros. Entertainment Inc.

Invictus

PA 1-684-663

Warner Bros. Entertainment Inc.

Life As We Know It

PA 1-709-859

Warner Bros. Entertainment Inc.

Sherlock Holmes

PA 1-656-999

Warner Bros. Entertainment Inc.

Yogi Bear

PREOOOO04120

Columbia Pictures Industries, Inc.

Bounty Hunter, The

PA 1-667-359

Columbia Pictures Industries, Inc.

Eat Pray Love

PA 1-689-770

Columbia Pictures Industries, Inc.

Grown Ups

PA 1-682-702

Columbia Pictures Industries, Inc.

How Do You Know

PA 1-712-186

Columbia Pictures Industries, Inc.

Karate Kid, The

PA 1-680-527

Columbia Pictures Industries, Inc.

Other Guys, The

PA 1-689-167

Columbia Pictures Industries, Inc.

Salt

PA 1-687-265

Columbia Pictures Industries, Inc.

Social Network, The

PA 1-698-016

Columbia Pictures Industries, Inc.

Tourist, The

PA 1-712-189

Disney Enterprises, Inc.

Alice in Wonderland

PA 1-675-924

Disney Enterprises, Inc.

Last Song, The

PA 1-679-726

Disney Enterprises, Inc.

Prince of Persia: The Sands of Time

PA 1-689-164

IQisney Enterprises, Inc.
IDisney Enterprises, Inc.

Secretariat

PA 1-706-963

Sorcerer's Apprentice, The

PA 1-691-405

Disney Enterprises, Inc.

Toy Story 3

PA 1-688-323

Disney Enterprises, Inc.

When in Rome

PA 1-667-869

Disney Enterprises, Inc.

You Again

PA 1-702-216

Paramount Pictures Corporation

Jackass 3D

PA 1-700-556

Paramount Pictures Corporation

Last Airbender, The

PA 1-683-283

Paramount Pictures Corporation

Morning Glory

PA 1-706-205

Paramount Pictures Corporation

Paranormal Activity 2

PA 1-701-514

Paramount Pictures Corporation

Shutter Island

PA 1-663-207

Twentieth Century Fox Film Corporation

127 Hours

PA 1-705-419

Warner Bros. Entertainment Inc. et al v.

wrv Systems, Inc. et al

Complaint; Exhibit A; page 1

Plaintiff

U.S. Copyright
Registration
Number

Title

Twentieth Century Fox Film Corporation

A-Team, The

PA 1-679-727

Twentieth Century Fox Film Corporation

Avatar

PA 1-395-488

Twentieth Century Fox Film Corporation

Crazy Heart

PA 1-655-279

Twentieth Century Fox Film Corporation

Date NiQht

PA 1-669-165

Twentieth Century Fox Film Corporation

Diary of a Wimpy Kid

PA 1-667-079

Twentieth Century Fox Film Corporation

KniQht and Day

PA 1-681-723

Twentieth Century Fox Film Corporation

Love and Other DruQs

PA 1-706-799

Twentieth Century Fox Film Corporation

Marmaduke

PA 1-678-666

Twentieth Century Fox Film Corporation

Predators

PA 1-683-294

Twentieth Century Fox Film Corporation

Ramona and Beezus

PA 1-687-191

Twentieth Century Fox Film Corporation

Unstoppable

PA 1-705-418

Twentieth Century Fox Film Corporation

Vampires Suck

PA 1-689-743

Twentieth Century Fox Film Corporation

Wall Street: Money Never Sleeps

PA 1-693-817

Universal Cit)' Studios Productions LLLP

American, The

PA 1-697-735

Universal City Studios Productions LLLP

Babies

PA 1-690-561

Universal City Studios Productions LLLP

Charlie St. Cloud

PA 1-690-720

Universal City Studios Productions LLLP

Despicable Me

PREOOOO03604

Universal City Studios Productions LLLP

Get Him to the Greek

PREOOOO03528

Universal City Studios Productions LLLP

It's Complicated

PA 1-656-395

Universal City Studios Productions LLLP

Kids Are All Right, The

PAu 3-457-290

Universal City Studios Productions LLLP

Love Happens

PA 1-644-272

Universal City Studios Productions LLLP

MacGruber

PA 1-685-732

Universal City Studios Productions LLLP

My Soul to Take

PA 1-703-035

Universal City Studios Productions LLLP

Robin Hood

PREOOOO03429

Universal City Studios Productions LLLP

Scott Pilgrim vs. the World

PA 1-692-200

Warner Bros. Entertainment Inc. et al v. WTV Systems, Inc. et al

Complaint; Exhibit A; page 2