Djerrahian v. Rick Ross - Photographer Copyright Suit

JS 44C/SDNY

REV. 4/2014CIVIL COVER SHEET "t /f I \[ Q

The JS-44 civil cover sheet and the information contained herein neither replaceJLuppledkt the filinjfana service oKJrpleadings or other papers as required by law, except as provided by local rules of court. This form, approved by theJudicial Conference of the United States in September 1974, is required for use of the Clerkof Court for the purpose ofinitiating the civil docket sheet.

091

PLAINTIFFS

ARMEN DJERRAHIAN

jot-YVCENOC

DEFENDANTSWILLIAM LEONARD ROBERTS, II. p*/a RICK ROSS an! RICKY ROZAY; MAYBACH MUSIC GROUP: DEFIAM RECORDINGS,aUNIVERSAL MUSIC GROUP INC. company; ISLAND RECORDS, aUNIVERSAL MUSIC GROUP. INC coijpany; ATLANTICRECORDING CORPORATION, aWARNER MUSIC GROUP company, RICHARD MORALES, JR. p/k/a GUNPLAY; ROBERTWILLIAMS p/k/a MEEK MILL; TORSTEN STENZEL p/k/a DJ SCREAM; CARLOS SUAREZ p/k/a SPIFF TV

ATTORNEYS (IF KNOWN)

0^

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBEREdward C. Greenberg, LLC, 570 Lexington Avenue, 19th Floor, New York,New York 10022, 212-697-8777

./ v.ItAY 062014

CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OFCAUSE)(DO NOTCITEJURISDICTIONAL STATUTES UNLESSDIVERSITY)

17 U.S.C. 501-505, Copyright Infringement

Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY atany time? NtEJVesQjudge Previously Assigned

Ifyes, was this case Vol. • Invol. • Dismissed. No • Yes • If yes, give date &Case No.

No \x\ Yes •Is THISAN INTERNATIONAL ARBITRATION CASE?

(PLACE AN[x] INONEBOXONLY)

TORTS

NATURE OF SUIT

CONTRACT PERSONAL INJURY

[ ] 310 AIRPLANE[ ] 315 AIRPLANE PRODUCT

LIABILITY

[ J 320 ASSAULT, LIBEL &SLANDER

[ ] 330 FEDERALEMPLOYERS'LIABILITY

[ ] 340 MARINE[ ] 345 MARINE PRODUCT

LIABILITY[ ] 350 MOTOR VEHICLE[ ] 355 MOTOR VEHICLE

PRODUCT LIABILITY

( ] 360 OTHER PERSONALINJURY

[ ] 362 PERSONAL INJURY -MED MALPRACTICE

] 110J120]130] 140

INSURANCE

MARINE

MILLER ACT

NEGOTIABLE

INSTRUMENTRECOVERY OF

OVERPAYMENT &ENFORCEMENTOF JUDGMENT

MEDICARE ACT

RECOVERY OFDEFAULTED

STUDENT LOANS

(EXCL VETERANS)RECOVERY OF

OVERPAYMENT

OF VETERAN'S

BENEFITS

STOCKHOLDERS

SUITSOTHER

CONTRACT

CONTRACT

PRODUCT

LIABILITY

FRANCHISE

PERSONAL INJURY FORFEITURE/PENALTY[ ] 367 HEALTHCARE/PHARMACEUTICAL PERSONAL , , 625DRUG RELATEDINJURY/PRODUCT LIABILITY l '

[1150

: 1151:ns2

[ 1163

]160

]190

1195

(]196

REAL PROPERTY

]210

]2201230

240

245

[ ]290

LAND

CONDEMNATIONFORECLOSURE

RENT LEASE 4EJECTMENT

TORTS TO LANDTORT PRODUCTLIABILITY

ALL OTHER

REAL PROPERTY

ACTIONS UNDER STATUTES

CIVIL RIGHTS

[]440 OTHER CIVIL RIGHTS(Non-Prisoner)

[ ]441 VOTING[ ]442 EMPLOYMENT[ ]443 HOUSING/

ACCOMMODATIONS[ ]445 AMERICANS WITH

DISABILITIES -EMPLOYMENT

[ ] 446 AMERICANS WITHDISABILITIES -OTHER

[ ] 448 EDUCATION

Check ifdemandedin complaint:

CHECK IF THIS IS A CLASS ACTIONUNDER F.R.C.P. 23

I ] 365 PERSONAL INJURYPRODUCT LIABILITY

[ ) 368 ASBESTOS PERSONALINJURY PRODUCT

LIABILITY

PERSONAL PROPERTY

[ ] 370 OTHER FRAUD[ ] 371 TRUTH IN LENDING

SEIZURE OF PROPERTY

21 USC 881

[ J690 OTHER

[ ] 380 OTHER PERSONALPROPERTY DAMAGE

[ ] 385 PROPERTY DAMAGEPRODUCT LIABILITY

PRISONER PETITIONS

[ ]463 ALIEN DETAINEE[ ]510 MOTIONS TO

VACATE SENTENCE

28 USC 2255

[ ] 530 HABEAS CORPUS[ J535 DEATH PENALTY[ ] 540 MANDAMUS & OTHER

LABOR

[ ] 710 FAIR LABORSTANDARDS ACT

[ ] 720 LABOR/MGMTRELATIONS

[ ]740 RAILWAY LABOR ACT

[ 1 751 FAMILY MEDICALLEAVE ACT (FMLA)

[ ] 790 OTHER LABORLITIGATION

[ ] 791 EMPL RET INCSECURITY ACT

IMMIGRATION

[ ]462 NATURALIZATIONAPPLICATION

[ ] 465 OTHER IMMIGRATIONACTIONS

PRISONER CML RIGHTS

[ I 550 CIVIL RIGHTS[ ] 555 PRISON CONDITION[ ] 560 CML DETAINEE

CONDITIONS OF CONFINEMENT

ACTIONS UNDER STATUTES

BANKRUPTCY OTHER STATUTES

I 1375 FALSE CLAIMS(1400 STATE( ]422 APPEAL

28 USC 158 REAPPORTIONMENT[ ]423 WITHDRAWAL [ ]410 ANTITRUST

28 USC 157 [ ]430 BANKS & BANKING[ ]450 COMMERCE[ ]460 DEPORTATION

PROPERTY RIGHTS [ ]470 RACKETEER INFLUENCED & CORRUPT

M 820 COPYRIGHTS ORGANIZATION ACT[ ] 830 PATENT (RICO)[ ] 840 TRADEMARK [ ) 480 CONSUMER CREDIT

[ ]490 CABLE/SATELLITE TV

SOCIAL SECURITY I ] 850 SECURITIES/COMMODITIES/

[ ]861HIA(1395ff) EXCHANGE[ ] 862 BLACK LUNG (923)[ ] 863 DIWC/DIWW (405(g))[ ] 864 SSID TITLE XVI[ ]865 RSI (405(g)) [ ] 890 OTHER STATUTORY

ACTIONS[ ] 891 AGRICULTURAL ACTS

FEDERAL TAX SUITS

[ ]870 TAXES (U.S. Plaintiff orDefendant)

[ ) 871 IRS-THIRD PARTY26 USC 7609

[ ] 893 ENVIRONMENTALMATTERS

[ ] 895 FREEDOM OFINFORMATION ACT

[ ] 896 ARBITRATION

[ ] 899 ADMINISTRATIVEPROCEDURE ACT/REVIEW OR

APPEAL OF AGENCY DECISION

[ ]950 CONSTITUTIONALITY OFSTATE STATUTES

•DEMAND $_ OTHER

iJPgQ0^LCL^M THIS CASE IS RELATED TO ACIVIL CASE NOW PENDING IN S.D.N.Y.?

JUDGE DOCKET NUMBER

Check YES only ifdemanded incomplaintJURY DEMAND: S YES CjNO NOTE: You mustalso submitat the time offiling the Statement of Relatedness form (Form IH-32).

(PLACEAN x INONEBOXONLY) ORIGIN

H1 Original • 2 Removed from • 3 Remanded • 4 Reinstated or Q 5 Transferred from Q 6 Multidistrict Q 7 Appeal to DistrictProceeding stateCourt from Opened (Specify District) Litigaton iJ^Ejudge

Q a. all parties represented Appellate Judgment

I | b. Atleast oneparty is pro se.

(PLACEAN x INONEBOXONLY) BASIS OF JURISDICTION

• 1 U.S. PLAINTIFF • 2 U.S. DEFENDANT • 3 FEDERAL QUESTION Q4 DIVERSITY(U.S. NOT A PARTY)

IFDIVERSITY, INDICATECITIZENSHIP BELOW.

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

(Place an [X] inone box for Plaintiff and one box for Defendant)

PTF DEF

CITIZEN OFTHIS STATE [ ] 1 [ ] 1 CITIZEN OR SUBJECT OF AFOREIGN COUNTRY

PTF DEF PTF DEF[ ]3 [ ]3 INCORPORATED and PRINCIPAL PLACE [ ]5 [ ]5

OF BUSINESS IN ANOTHER STATE

CITIZEN OFANOTHER STATE []2 []2 INCORPORATED or PRINCIPAL PLACE []4[]4 FOREIGN NATIONOF BUSINESS IN THIS STATE

PLAINTIFF(S)ADDRESS(ES) AND COUNTY(IES)

ARMEN DJERRAHIAN, 164 Russell Street, Brooklyn, NY 11222

_DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)

[]6 []6

WILLIAMLEONARD ROBERTS, II, p/k/a RICK ROSS and RICKY ROZAY, 10398 Laurel Rd, Davie, FL 33328, Broward County;MAYBACH MUSIC GROUP, 10398 Laurel Rd, Davie, FL 33328, Broward County;DEF JAM RECORDINGS, a UNIVERSAL MUSIC GROUP INC. Company, 150 Fifth Avenue, New York, New York 10011, New York County;ISLAND RECORDS,a UNIVERSAL MUSIC GROUP, INC. Company, 150 Fifth Avenue, New York, New York 10011,New York County;ATLANTIC RECORDING CORPORATION, a WARNER MUSIC GROUP CORP. Company, 75 Rockefeller Plaza, 31st Floor, NewYork, NY10019, New York County

DEFENDANT(S) ADDRESS UNKNOWNREPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN

RE9IBENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

RICHARD MORALES, JR. p/k/a GUNPLAYROBERT WILLIAMS, p/k/a MEEK MILLTORSTEN STENZEL p/k/a DJ SCREAMCARLOS SUAREZ p/k/a SPIFF TV

Check one: THIS ACTION SHOULD BE ASSIGNED TO: Q WHITE PLAINS [x] MANHATTAN(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTSCOMPLAINT.)

DATE 5/6/14 ^NATURE OFATTORNEYJ3£*ECORD ADMITTED TO PRACTICE IN THISDISTRICT[] NOM YES (DATE ADMITTED Mo. 10 Yr. 1982 )

RECEIPT #y^^7 // / ^sy _ Attorney Bar Code # EG 5553

Maj

Magistrate Judge

Ruby J. Krajick, Clerk of Court by. . Deputy Clerk, DATED.

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

Clear Form Save

is so Designated.

Print

H^jp

EdwardC. Greenberg, Esq. (ECG 5553)Tamara L. Lannin, Esq. (TL 3784)EDWARD C. GREENBERG, LLC570 Lexington Ave., 19th FloorNew York, NY 10022Tel: (212) 697-8777Fax:(212)697-2528Attorneysfor Plaintiff

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK

ARMEN DJERRAHIAN,

JUDGE OETKBMntiff,- against -

WILLIAM LEONARD ROBERTS, II, p/k/a RICKROSS and RICKY ROZAY; MAYBACH MUSICGROUP; DEF JAM RECORDINGS a UNIVERSALMUSIC GROUP INC. Company; ISLANDRECORDS, a UNIVERSAL MUSIC GROUP, INC.Company; ATLANTIC RECORDINGCORPORATION, a WARNER MUSIC GROUPCompany; RICHARD MORALES, JR. p/k/aGUNPLAY; ROBERT WILLIAMS p/k/a MEEKMILL; TORSTEN STENZEL p/k/a DJ SCREAM;CARLOS SUAREZ p/k/a SPIFF TV,

Defendants.

14 CV

COMPLAINT

ECF CASE

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Plaintiff, ARMEN DJERRAHIAN, by his attorneys, EDWARD C. GREENBERG, LLC,

alleges as follows:

PARTIES

1. At all times hereinafter mentioned, ARMEN DJERRAHIAN was, and still is, a noted

and respected professional photographer, who with respect to matters relevant herein, has done

business in the form of a sole proprietorship.

2. Plaintiff ARMEN DJERRAHIAN (hereinafter "Plaintiff or "DJERRAHIAN") is an

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individual citizen ofFrance, who is actively engaged in the photography business in the State of

NewYork andelsewhere, andwho resides in Brooklyn, New York 11222.

3. Defendant WILLIAM LEONARD ROBERTS, II (hereinafter "ROSS") is an

individual, who upon information and belief resides in Davie, Florida, and who is aworld

renowned musical performer who does business under the names of"Ricky Rozay", "Rick Ross",

and "Rick Ro$$". That upon information and belief, ROSS works under contract for defendant

DEF JAM RECORDINGS. That ROSS is thefounder, CEO, and creator of therecord label

MAYBACH MUSIC GROUP.

4. Defendant MAYBACH MUSIC GROUP (hereinafter "MMG") is a recordlabel

imprint, founded by ROSS, which was has been distributed by DEF JAM RECORDINGS, Warner

Brothers Records, and ATLANTIC RECORDING CORPORATION. Upon information and

belief, MMG isbased inthe Miami suburb ofDavie, Florida. Upon information and belief, MMG

is an unincorporated business entity.

5. Defendant DEF JAM RECORDINGS (hereinafter "DEFJAM"), is uponinformation

and belief a Delaware Corporation, that regularly conducts business and has anoffice intheState,

City and County ofNew York, with an office at 150 Fifth Ave., New York, NY 10011, and which

is a subsidiary ofUniversal Music Group Inc. That upon information and belief DEF JAM

RECORDINGS was formerly part of theUniversal Music Group Inc. subsidiary Island DefJam

Music Group.

6. Defendant ISLAND RECORDS (hereinafter"ISLAND"), is upon information and

beliefa Delaware Corporation, that regularly conducts business and has anoffice in the State, City

and County ofNew York, with anoffice at 150 Fifth Ave., New York, NY 10011, and which isa

subsidiary ofUniversal Music Group Inc. That upon information and belief ISLAND RECORDS

was formerly partof the Universal Music Group Inc. subsidiary Island DefJamMusic Group.

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7. That upon information and belief, Universal Music Group Inc. previously had an

affiliate and/or subsidiary group entitled "Island Def Jam Music Group", which was comprised of

both ISLAND RECORDS and DEF JAM RECORDINGS. That upon information and belief, in

April 2014, Universal Music Group, Inc. announced that it would be breaking up the "Island Def

Jam Music Group Inc." such that ISLAND RECORDS and DEF JAM RECORDINGS could be

two separate entities. Defendants DEF JAM. and ISLAND (hereinafter "ISLAND DEF JAM")

appear to be inextricably intertwined to make it difficult to determine when one is acting as DEF

JAM or ISLAND such that for the purposes of this Complaint, they will both bereferred to as

"ISLAND DEF JAM.

8. Defendant ATLANTIC RECORDING CORPORATION, is upon information and

belief a Delaware Corporation, that regularly does business and has an office in the State, City and

County ofNew York, with an office at 75 Rockefeller Plaza, 31st FL, New York, NY 10019, and

which is a subsidiary of Warner Music Group.

9. Defendant RICHARD MORALES, JR. (hereinafter "GUNPLAY") is an individual,

who upon information and belief resides in Miami, Florida, and who isaperformer who does

business under thename of"Gunplay". That upon information and beliefGUNPLAY works under

contract for defendant DEF JAM, which serves as his agent.

10. Defendant ROBERT WILLIAMS (hereinafter "MEEKMILL") is an individual, who

upon information and belief resides Philadelphia, Pennsylvania, and who isaperformer who does

business under the name of "Meek Mill". That, upon information and belief, Meek Mill works

under contract for ATLANTIC, which serves as his agent.

11. Defendant TORSTEN STENZEL (hereinafter "DJ SCREAM") is an individual, who

upon information and belief resides Atlanta, Georgia and who isa performer who does business

under the name of DJ SCREAM.

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12. CARLOS SUAREZ (hereinafter "SPIFF") is an individual, who upon information and

belief resides in the City and State ofNew York, and who is an artist who does business under the

name ofSPIFF TV. Upon information and belief, SPIFF is amember ofand/or works for MMG

and/or ROSS.

13. All individual defendants regularly employ pseudonyms inconnection with their

music, branding of their personae andrelated business endeavors.

JURISDICTION AND VENUE

14. This is a civil action for copyright infringement.

15. Jurisdiction is conferred uponthis Courtby 28 U.S.C. Section 1338.

16. Venue in the Southern District of New Yorkis properpursuant to 28 U.S.C. 1400.

FACTS COMMON TO ALL CLAIMS

17. That PlaintiffDJERRAHIAN is a successful professional photographer with many

years of experience and a considerable reputation.

18. DJERRAHIAN is well known in the hip hop music business, as he has worked with

major artists including Jay-Z, Usher, 50 Cent, Eminem, Kanye West, Rick Ross and director Spike

Lee. DJERRAHIAN's work has been featured on the covers of several issues of Vibe Magazine,

and onThe Wild Magazine, XXL Magazine, and numerous international publications.

19. DJERRAHIAN has also shot and directed music videos and commercials, including a

music video featuring R&B recording artist Melanie Fiona, which received a nomination for [Best]

"Video of the Year" at the 2010 BET Awards.

20. DJERRAHIAN is also a successful fashionphotographer who has shot photos for

Shinola, Cazal Eyewear, Nike, Fila, Reebok, Marc Ecko, and commercials for Elle Magazine,

Revlon, Van Cleef & Arpels, and Piaget.

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THE IMAGES

21. On May 17, 2010, DJERRAHIAN shot images of ROSS for XXL Magazine, which

were published in the July/August 2010 issue ofXXL Magazine (a copy of such images are

annexed hereto as Exhibit "A". DJERRAHIAN submitted an application for the registration of

such images with the United States Copyright Office on April 4, 2014 (registration pending, case #

1-1338622681).

22. On June 27, 2012, DJERRAHIAN shot images ofROSS and other members of

MAYBACH MUSIC GROUP, GUNPLAY, MEEK MILL, Omarion, Stalley, and Wale. Aportion

ofsuch images were published in the August/September 2012 issue ofVibe Magazine (said images

published in Vibe Magazine are annexed hereto as Exhibit "B").

23. DJERRAHIAN granted a limited license to VIBE Magazine to use his images on the

cover and inthe contents ofthe August/September 2012 issue ofVibe Magazine, only. No other

rights were granted by plaintiff. Vibe is not a defendant herein.

24. DJERRAHIAN duly registered such images with the United States Copyright Office

on December 25, 2013, Registration No. VA 1-899-797 (acopy ofsaid registration is included

within Exhibit "B" hereto).

25. DJERRAHIAN further registered the other images shot of MMG members, ROSS,

GUNPLAY, MEEK MILL, Omarion, Stalley, and Wale, which were not published inVibe

Magazine, with the United States Copyright Office, Registration No. VAu 1-160-975 (a copy of

said images and the corresponding registration are annexed hereto as Exhibit"C".

26. Each of the images included within Exhibits "A", "B" and "C"hereto shall hereinafter

be referred to individually and collectively as applicable as the 'Tmage(s)".

27. MMG is a record label imprint, which was founded by the rapper and mogul ROSS.

28. MMG is home to artists such as ROSS, Omarion, Wale, Stalley, MEEK MILL, and

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GUNPLAY.

29. MMG has released at least six solo and two compilation albums, including three

certified Gold albums. MMG is, upon information and belief, based in the State ofFlorida, but

regularly does business inthe State ofNew York.

30. ROSS has sold millions ofalbums and has had atleast five (5) albums reach #1 on the

Billboard music charts.

31. Defendants orone ormore of them, have employed one ormore of the Image(s) onat

least tour posters, tour promotional advertisements, internet banners, advertisements, mixtape

covers, promotional materials, album/cd covers, as well as on various Internet websites including

MMG's website, Twitter page, Facebook page, and other websites.

32. Defendants, or one or more ofthem, have utilized the Images in wide spread marketing

to promote MMG and its members, including but not limited to Gunplay, Ross, and Meek Mill.

33. That Plaintiffs images ofMMG and its members were/are valuable to the Defendants,

or one or more of them.

34. That plaintiffs Image(s) ofMMG and its members creatively capture the personalities

of members of MMG.

35. The images ofGUNPLAY in particular are upon information and belief, the definitive

images ofhim and have been used in numerous promotional materials for GUNPLAY and on the

cover of at least five mixtapes.

36. That MMG and the Images of same are important elements of hiphopmusic culture.

That various blogs referring to MMG feature at least one ofthe Image(s) created by

DJERRAHIAN.

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THE OFFENDING USES OF THE IMAGES

Tour Advertisements

37. Defendants, or one or more of them, have utilized at least two ("2") of plaintiffs

Images invarious advertisements for an MMG tour (copies ofa sampling of such various

advertisements, as described hereinbelow, are annexed hereto as Exhibit "D", hereinafter the

"TOURAD(S)").

38. The TOUR ADS have been published in various media, including but not limited to as

internet posters and image files, internet website banners, physical print posters, and in internet

promotional videos.

39. Said TOUR AD(S) includes plaintiffs photographs of MEEK MILL, and Wale (see

Exhibit "B"), without plaintiffs license, authorization or consent.

40. TheTOUR AD(S) employs two ("2") separate images of plaintiffs (see Exhibit "B"

hereto), and is anunauthorized derivative work of such two ("2") ofplaintiffs images.

41. The TOUR AD(S) includes text at the top of the page which states "TheUntouchable

Maybach Music Empire Presents" and then below plaintiffs images ofMEEK MILL, ROSS, and

Wale, states "THEMMGTOURFEATURING MEEKMILL, RICKRO$$ Wale".

42. Different versions of the TOUR AD(S) were posted by or at the direction or control of

defendants, or one or more of them, on MMG's Facebook page on its "timeline".

43. The TOUR AD(S) was posted by or at the direction or control of defendants, or one or

more of them, on MMG's Facebook page as one of its "Profile Pictures".

44. The TOURAD(S) were posted by or at the directionor control of defendants, or one or

more of them, on DJ Scream's Facebook and Twitter pages, including in his Facebook Timeline.

45. That, upon information and belief, DJ Scream is the "official DJ" of MMG.

46. One version of the TOUR ADS includes the website and twitter handle for ROSS, to

wit, www.rozavraw.com, and @rickyrozay. Said version of the TOUR ADS further includes logos

for the following: MMG, Def Jam Recordings, Warner Brothers, DatPiff, Ciroc, and others.

47. Upon information and belief, one or more versions ofthe TOUR AD(S) were

distributed by defendants, or one or more ofthem, to third parties to be displayed by same.

48. The TOUR AD(S) were published, displayed, and disseminated, by or atthe direction

orcontrol ofdefendants, orone ormore ofthem, on MMG's YouTube page in several different

videos promoting the MMG tour and the purchase oftickets through LiveNation.com.

49. That the YouTube videos promoting the MMG tour also include another ofPlaintiffs

Images ofWale, ROSS, and MEEK MILL (a copy ofsaid image is annexed hereto as Exhibit

"E", hereinafterthe "SECOND TOUR AD").

50. The SECOND TOUR AD hasbeen published, displayed, and disseminated, by or at

thedirection or control of defendants, or one or more of them, on MMG'sYouTube page in

several different videos promoting the MMG tour and the purchase oftickets through

LiveNation.com.

51. Upon information and belief, both the TOUR AD(S) and the SECOND TOUR AD

were distributed by or atthe direction or control ofdefendants, or one ormore ofthem, to third

parties to display, distribute, and/or disseminate, so as to maximize the publicity for the tour.

2013 Takeover

52. Defendants, orone ormore of them, have utilized at least twelve ("12") ofplaintiffs

Images in various advertisements for MMG's mixtape entitled "Takeover" (copies ofa sampling

of suchvarious advertisements, as described hereinbelow, are annexed heretoas Exhibit "F",

hereinafter the "TAKOVER AD(S)").

53. The TAKEOVER ADS have been published in various media, including but not

limited toas internet posters and image files, physical print posters, mixtape cover(s) and in

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internet videos.

54. Said TAKEOVER AD(S) includes plaintiffs photographs ofOmarion, MEEK MILL,

ROSS, Staley, Wale and Gunplay (see Exhibit "C", specifically "Staley_021", "Omarion_001",

"Meek Mil_038", "Rick_033", "Wale_016", "Gunplay_018", "Omarion_212", "Meek Mil_278",

"Rick_081", "Stalley__086", "Wale_026", and "Gunplay_108"), without plaintiffs license,

authorization or consent.

55. The TAKEOVER AD(S) employ twelve ("12") separate images ofplaintiffs, and is an

unauthorized derivative work of suchtwelve ("12") of plaintiff s images.

56. At the bottom ofat least one ofthe versions ofthe TAKEOVER AD(S) states a credit

in print to each of the following: MAYBACH MUSIC GROUP, RICK ROSS, MEEK MILL,

WALE, OMARION, STALLEY, GUNPLAY, DEF JAM RECORDINGS, and ATLANTIC

RECORDS, among others.

57. That at the bottom of at least one of theversions of theTAKEOVER AD(S) includes

the logos for ATLANTIC, MMG and DEF JAM RECORDINGS.

58. Different versions of the TAKEOVER AD(S) were postedby or at the direction or

control of defendants, or oneor more of them, on MMG's Instagram andFacebook pages.

59. Different versions of the TAKEOVER AD(S) werepostedby or at the direction or

control of defendants, or one or more of them, on MMG's Twitter account.

60. The TAKEOVER AD(S), aspublished in a video asdisplayed onMMG's Facebook

Page, by, or at the direction or control ofdefendants, or one or more ofthem, with a link to

MMG's page at soundcloud.com.

61. The TAKEOVER AD(S), were published by,or at the direction or control of

defendants, or one or more of them on ROSS' website www.rozayraw.com.

62. Upon information and belief, one ormore versions ofthe TAKEOVER AD(S) were

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distributed by defendants, or one or more of them, to third parties to be displayed by same.

63. The TAKEOVER AD(S) have been used by defendants, orone ormore ofthem, as

cover for several mixtape songs, including but not limited to "Ball Freestyle (ft. Gunplay)", "Ball

Freestyle", "Ball", "Ball (Remix) Ft. Gunplay", "Ball (Remix").

Gunplay Acquitted

64. Defendants, or one or more ofthem, have utilized one ("1") ofplaintiffs Images of

GUNPLAY invarious advertisements for GUNPLAY'S mixtape entitled "Acquitted"(copies ofa

sampling of such various advertisements, as described hereinbelow, are annexed hereto as Exhibit

"G", hereinafter the "ACQUITTED AD(S)").

65. The ACQUITTED ADS have been published invarious media, including but not

limited to as internet posters and image files, internet background image, mixtape cover and

mixtape backside.

66. Said ACQUITTED AD(S) includes plaintiffs photograph ofGUNPLAY (see Exhibit

"C", specifically "Gunplay_108"), without plaintiffs license, authorization orconsent.

67. The ACQUITTED AD(S) employ plaintiffs image ofGUNPLAY edited and

"photoshopped" in such amanner as to create an unauthorized derivative work ofplaintiffs Image.

68. In the foreground ofthe ACQUITTED ADS are several microphones, on which are the

logos for MMG, and ISLAND DEF JAM, among others.

69. The backside to the Mixtape (an ACQUITTED AD) includes plaintiffs Image, and

logos forMMG, andISLAND DEF JAM, among others.

70. The backside to theMixtape (an ACQUITTED AD) further includes a credit for the

"artwork" to "Kideight.com".

71. The ACQUITTED AD was published by, or under the direction orcontrol of

GUNPLAY on his Facebook page as the "Cover Photo".

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72. Different versions ofthe ACQUITTED AD(S) were published by, or under the

direction orcontrol ofGUNPLAY onhis Facebook page inhis timeline.

73. Upon information and belief, the ACQUITTED ADS were published by, or under the

direction or control ofGUNPLAY and/or ROSS on the Twitter page for "gunplaymmg".

74. The Twitter page for "gunplaymmg" lists ROSS' website www.rozavraw.com instead

ofGunplay's website ofwww.gunplayallday.com.

75. Upon information and belief, one or more versions of the ACQUITTED AD(S) were


76. That Gunplay's mixtape "Acquitted" has been reported by an authoritative music

magazine, Spin Magazine, as one ofthe "40 Best Hip-Hop Albums of2013".

Group Photo AdolfSniffler

77. Defendants, orone or more ofthem, have utilized one ("1") ofplaintiffs Images ofa

group photo of MMG members Wale, MEEK MILL, ROSS, Stalley, Omarion and GUNPLAY at

least at the top ofthe twitter page for @gunplaymmg (a copy ofsuch offending use is annexed

hereto as Exhibit "H", hereinafter the "GROUP PHOTO").

78. Plaintiffcreated the GROUP PHOTO (see Exhibit "C", specifically "MMG09").

79. Upon information and belief, the GROUP PHOTO was published by, or under the

direction or control of GUNPLAY and/orROSS on the Twitter page for "gunplaymmg".

80. Upon information and belief, the GROUP PHOTO has been distributed by defendants,

or one or more of them, to third parties to be displayed by same.

Gunplay Sunshine State ofMind

81. Defendants, or one ormore of them, have utilized one ("1") of plaintiffs Images of

GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled"Gunshine State of

Mind"(copies ofasampling ofsuch various advertisements, as described hereinbelow, are annexed

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hereto asExhibit "I", hereinafter the "GUNSHINE AD(S)").

82. The GUNSHINE ADS have been published in various media, including but not limited

to as internet posters, image files, and as a mixtape cover.

83. Said GUNSHINE AD(S) includes plaintiffs photograph ofGUNPLAY (see Exhibit

"B"), without plaintiffs license, authorization orconsent.

84. The GUNSHINE AD(S) employ plaintiffs image ofGUNPLAY edited and

"photoshopped" in such amanner as to create an unauthorized derivative work of plaintiffsImage.

85. The color ofthe jacket worn by GUNPLAY in the GUNSHINE AD(S) has been color

edited from the original version (compare Exhibit "I" with "B").

86. The background ofPlaintiffs Image ofGUNPLAY in the GUNSHINE AD(S) has

been modified to include the image ofthe front ofa car and the entrance to a theatre.

87. Upon information and belief, the GUNSHINE AD(S) were published by, or under the

direction or control of GUNPLAY.

88. Upon information and belief, one or more versions ofthe GUNPLAY AD(S) were


Gunplay Coast 2 Coast

89. Defendants, orone ormore ofthem, have utilized one ("1") ofplaintiffs Images of

GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled "Coast 2 Coast Volume

247"(copies ofasampling ofsuch various advertisements, as described hereinbelow, are annexed

hereto as Exhibit "J", hereinafter the "COAST 2 COAST AD(S)").

90. TheCOAST 2 COAST ADS have beenpublished in various media, including but not

limited to as internetposters, image files, and as a mixtape cover.

91. Said COAST 2 COAST AD(S) includes plaintiffs photograph of GUNPLAY (see

Exhibit "C", specifically "Gunplay_108"), without plaintiffs license, authorization orconsent.

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92. The COAST 2 COAST AD(S) employ plaintiffs image ofGUNPLAY edited and

"photoshopped" in such amanner as to create an unauthorized derivative work of plaintiffsImage.

93. The foreground ofPlaintiffs Image ofGUNPLAY in the COAST 2COAST AD(S)

has been modified to include $100 dollar bills and the pouring ofwhat looks like a white

substance.

94. Upon information and belief, the COAST 2COAST AD(S) were published by, or

under the direction or control of GUNPLAY.

95. Upon information and belief, one or more versions ofthe COAST 2COAST AD(S)

were distributed by defendants, or one or more ofthem, to third parties to be displayed by same.

Gunplay Photoshopped with MMG in Background

96. Upon information and belief, defendants, or one or more ofthem, have employed an

edited version ofone ("1") ofplaintiffs Images ofGUNPLAY (acopy ofsuch an edited version

with part ofthe MMG logo edited into the background is annexed hereto as Exhibit "K",

hereinafter the "LOGO AD").

97. The LOGO AD is an unauthorized derivative work of Plaintiffs Image of Gunplay

(Exhibit "C", specifically "GunPlay_108").

98. Upon information and belief, the LOGO AD was published by, orunder the direction

or control of GUNPLAY.

99. Upon information and belief, the LOGO AD has been distributed by defendants, orone

or more of them, to third parties to be displayed by same.

Plaintiffs Unedited Image of Gunplay

100. Upon information and belief, GUNPLAY, ROSS, and/or persons oneither

of their behalf, direction or control, have distributed and/or published Plaintiffs Image of Gunplay

(see Exhibit "B").

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101. Upon information and belief, DEF JAM published said image of

GUNPLAY (see Exhibit "B") on the DEF JAM website, www.defiam.com, as the primary image

for GUNPLAY (a copies ofsuch offending use(s) are annexed hereto as Exhibit "L").

Gunplay Unscripted Freestvles

102. Defendants, or one or more ofthem, have utilized one ("1") ofplaintiffs

Images of GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled "Unscripted

Freestyles"(copies ofasampling of such various advertisements, as described hereinbelow, are

annexed hereto as Exhibit "M", hereinafter the"UNSCRIPTED AD(S)").

103. The UNSCRIPTED ADS have been published invarious media, including

but not limited to as internet posters, image files, and as a mixtape cover.

104. Said UNSCRIPTED AD includes plaintiffs photograph of GUNPLAY

(see Exhibit "B"), without plaintiffs license, authorization orconsent.

105. The UNSCRIPTED AD employs plaintiffs image ofGUNPLAY edited

and "photoshopped" in such amanner as to create an unauthorized derivative work of plaintiffs

Image.

106. The color ofPlaintiffs Image of GUNPLAY in theUNSCRIPTED AD has

been modified to appear grainy and the color has been modified to include red.

107. Upon information and belief, the UNSCRIPTED AD was published by, or

under the direction or control of GUNPLAY, ROSS, and/or MMG.

108. At the bottom of the UNSCRIPTED AD is the MMG logo.

109. Upon information and belief, one ormore versions of the UNSCRIPTED

AD have been distributed by defendants, orone ormore ofthem, to third parties to be displayed by

same.

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Gunplay Living Legends

HO. Defendants, orone or more ofthem, have utilized one ("1") ofplaintiffs

Images of GUNPLAY in various advertisements for GUNPLAY'S mixtape entitled "Living

Legends"(copies ofasampling of such various advertisements, as described hereinbelow, are

annexed hereto asExhibit "N", hereinafter the "LIVING LEGENDS AD(S)").

111. The LIVING LEGENDS ADS have been published invarious media,

including but not limited to as internet posters and image files.

112. Said LIVING LEGENDS AD(S) includes plaintiffs photograph of

GUNPLAY (see Exhibit "B"), without plaintiffs license, authorization orconsent.

113. Each of the versions of the LIVING LEGENDS ADS employ plaintiffs

image ofGUNPLAY edited and "photoshopped" in such amanner as to create an unauthorized

derivative work of plaintiff s Image.

114. One of the versionsof the LIVING LEGENDS AD has been altered with a city

skyline included in the background and ared and black banner displayed in the lower foreground

with the words "2014 GUNPLAY".

115. Anotherversionof the LIVING LEGENDS AD has been altered with a city skyline

included inthe background and a red and black banner displayed inthe lower foreground with the

words "2014 GUNPLAY 'Living Legends' Coming Soon".

116. A third version of the LIVING LEGENDS AD has been altered with the Gunplay

logo appearing across GUNPLAY'S chest, and words inthe lower foreground stating "Living

Legend *** Coming Soon ***"

117. Upon information and belief, the LIVING LEGENDS AD(s) have been published

by, orunder thedirection or control of GUNPLAY, ROSS, and/or MMG.

118. Upon information and belief, one ormore versions of the LIVING LEGENDS

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AD(s) havebeendistributed by defendants, or one or more of them, to third parties to be displayed

by same.

119. The LIVING LEGENDS AD(S) has been published by or at the direction or control

of defendants, or one or more of them, on MMG's Twitter page.


of defendants, or one or more of them, on GUNPLAY'S Twitter page as his primary image.


of defendants, or one or more of them, on MMG's Facebook page on its "timeline".


of defendants, or one or more of them, on GUNPLAY'S Facebook page on its "timeline".


of defendants, or one or more of them, on GUNPLAY'S Facebook page as his "Cover Photo".

124. At least one version of the LIVING LEGENDS AD has been published to

GUNPLAY'S website, www.gunpalvalldav.com, which includes both the ISLAND DEF JAM and

MMG logos below the LIVING LEGENDS AD.

125. Upon information and belief, the LIVING LEGENDS AD(S) were published by, or

under the direction or control of GUNPLAY, ROSS, and/or MMG.

126. Upon information and belief, the LIVING LEGENDS AD(S) have been distributed

by defendants, or one or more of them, to third parties to be displayed by same.

Miscellaneous Gunplay promotions

127. At least two of plaintiff s Images of GUNPLAY (Exhibit "B", and Exhibit "C",

specifically "GunPlay_108") have been used in various promotional publications for various

events featuring GUNPLAY (hereinafter the "VARIOUS PROMOTIONS", copies of a sampling

of such VARIOUS PROMOTIONS as described hereinbelow are annexed hereto as Exhibit "O").

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128. Each ofsaid VARIOUS PROMOTIONS constitutes a separate act ofinfringement

and is aseparate unauthorized derivative work ofPlaintiffs Images of Gunplay.

129. Upon information and belief, the VARIOUS PROMOTIONS were published by, or

under the direction or control of GUNPLAY.

130. That many ofthe VARIOUS PROMOTIONS have been published on the twitter

page for @gunplaymmg by the @gunplaymmg account.

131. That, upon information and belief, publications to the @gunplaymmg account are

made by GUNPLAY and/or ROSS and/or persons under the direction or control of GUNPLAY

and/or ROSS.

132. That upon information and belief, defendants or one or more ofthem, employed

Plaintiffs Image ofGUNPLAY to promote the GUNPLAY "Acquitted World Tour".

133. Upon information and belief, the VARIOUS PROMOTIONS have been distributed

by defendants, or one or more of them, or by persons under the direction or control of one or more

of them, to third partiesto be displayed by same.

Meek Mill Superbowl

134. At least one ofplaintiffs Images ofMEEK MILL (Exhibit "B") has been used in at

least one promotional publication for an event featuring MEEK MILL (hereinafter the

"SUPERBOWL EVENT AD", a copy of which is annexed hereto as Exhibit "P").

135. Plaintiffs Image ofMEEK MILL as employed inthe SUPERBOWL EVENT AD

is an unauthorized derivative work of Plaintiff s Image.

136. Upon information and belief, theSUPERBOWL EVENT AD was

published by, or under the direction or control ofMEEK MILL, ROSS, and/or MMG.

137. At the bottom of the SUPERBOEL EVENT AD is the MMG logo.

138. Upon information and belief, the SUPERBOEL EVENT AD has been distributed

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by defendants, or one or more ofthem, or by persons under the direction or control ofone or more

of them, to third parties to be displayed by same.

Meek Mill Promotional Event

139. Atleast one ofplaintiffs Images ofMEEK MILL (Exhibit "B") has been used inat

least one promotional publication for an event featuring MEEK MILL (hereinafter the

"FIRESTONE EVENTAD", a copy of which is annexed hereto as Exhibit "Q").

140. The FIRESTONE EVENT AD is an unauthorized derivative work of Plaintiffs

Image of MEEK MILL.

141. Upon information and belief, the FIRESTONE EVENT AD was published

by, orunder the direction orcontrol ofMEEK MILL, ROSS, and/or MMG.

142. That, upon information and belief, MEEK MILL or someone onhis behalf orunder

his direction orcontrol published the FIRESTONE EVENT AD to his Twitter account, which is

@MeekMill.

143. At the bottom of the FIRESTONE EVENT AD is the MMG logo.

144. Upon information and belief, the FIRESTONE EVENT AD has been distributed by

MEEK MILL, MMG, and persons onbehalf of and under the direction or control ofone ormore of

them, to third parties to be displayed by same.

Meek Mill 2014

145. Defendants, or one or more of them, have utilized one ("1") of plaintiff s Images of

MEEK MILL in at least one version of an advertisement for MEEK MILL'S mixtape entitled

"DreamsWorthMore Than Money"(copies of a sampling of such various advertisements, as

described hereinbelow, are annexed hereto as Exhibit "R", hereinafter the "DREAMS AD").

146. The DREAMS AD has been published at least on the World Wide Web.

147. Said DREAMS AD includes plaintiffs photograph of MEEKMILL(see Exhibit

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"B"), without plaintiffs license, authorization or consent.

148. The DREAMS AD employs plaintiffs Image of MEEK MILL edited and

"photoshopped" in such a manner as to create an unauthorized derivative work of plaintiff s Image.

149. Plaintiff s Image of MEEK MILL as displayed in the DREAMS AD has been

altered with a city skyline included in the background and a red and black banner displayed in the

lower foreground with the words "2014 MEEK MILL 'DREAMS WORTH MORE

THANMONEY' COMING SOON' ".

150. Upon information and belief, the DREAMS AD has been published by, or under the

direction or control of MEEK MILL, ROSS, and/or MMG.

151. Upon information and belief, the DREAMS AD has been distributed by defendants,

or one or more of them, to third parties to be displayed by same.

152. Upon information and belief, the DREAMS AD has been published by or at the

direction or control of defendants, or one or more of them, on ROSS' Twitter page.

Rick Ross Gun Pic 911

153. Defendants, or one or more of them, have, upon information and belief, utilized

plaintiffs Image of ROSS, which depicts ROSS holding his fingers to his head in the style of a

gun (Exhibit "A" hereto) in various advertisements for ROSS and his music (copies of a sampling

of such various advertisements, as described hereinbelow, are annexed hereto as Exhibit "S",

hereinafter the "GUN PHOTO USE(S)").

154. The GUN PHOTO USE(S) have been published in various media, including but not

limited to as internet posters and image files, and in internet videos.

155. Said GUN PHOTO USE(S) includes plaintiffs photographs of ROSS (Exhibit "A")

without plaintiffs license, authorization or consent.

156. Each version of the GUN PHOTO USE(S) is an unauthorized derivative work of

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plaintiffs Image.

157. Various versions of the GUN PHOTO USE(S) have been cropped, without

plaintiffs license, authorization or consent.

158. At least one version of the GUN PHOTO USE(S) has been edited to include the text

of "911" in bold black numbers across plaintiffs Image of ROSS.

159. At least one version of the GUN PHOTO USE(S) has been edited to appear

alongside a photograph of MEEK MILL, and with text in red, white and black letters stating,

"RICK ROSS + MEEK MILL TheMansionElan Saturday Sept. 28th #BreakingNews".

160. That the aforementioned modifications of the GUN PHOTO USE(S) were without

plaintiffs license, authorization or consent.

161. Upon information and belief, at least one version of the GUN PHOTO USE(S) was

published to ROSS' Instagram page, by, on behalf of, or under the directionof controlof ROSS.

162. Upon information and belief, at least one version of the GUN PHOTO USE(S) was

publishedto ROSS' SoundCloudpage, by, on behalf of, or under the direction of control of ROSS.

163. Upon information and belief, ROSS, and/or persons on his behalf or under his

direction or control have employed the GUN PHOTO USE(S) to publicize ROSS' song, entitled

"911".



"Birthday Cake (Remix)".



"How Many Drinks (Remix)".


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"Cut Her Off (Remix)".

167. At least one version of the GUN PHOTO USE(S) was published to the Twitter

account of MEEK MILL, which is @meekmill, by, on behalf of, or under the direction of control

of ROSS, MEEK MILL, or one or more of them.

168. At least one version of the GUN PHOTO USE(S) was published to DJ SCREAM'S

website, which is www.di screamtv.com, by, on behalf of, or under the direction of control of

ROSS, DJ SCREAM, or one or more of them.

169. Upon information and belief, one or more versions of the GUN PHOTO USE(S)

were distributed by defendants, or one or more of them, to third parties to be displayed by same.

Miscellaneous

170. That none of the aforementioned uses of plaintiff s Image(s), inclusive of any

unauthorized derivative works thereof, as set forth and referenced with respect to Exhibits "D"

through "S" were with plaintiffs license, authorization or consent. This is notwithstanding the

fact that defendants, or one or more of them, knew that plaintiff was the photographer, had

plaintiffs contact information, and indeed were in contact with plaintiff.

171. That, upon information and belief, each of defendants, or one or more of them, do

business in the State of New York.

172. Upon information and belief, the events giving rise to this action, including the

photo shoot with Vibe Magazine, occurred in the State ofNew York and/or out of the transaction

of business within the State ofNew York.

173. That the full nature and extent of the use(s) of plaintiff s image by the defendants,

or one or more of them, is unknown to plaintiff pre-discovery as such is within the sole knowledge

of the defendants, or one or more of them.

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174. Defendant(s) have refused to provide such information although duly demanded.

175. Upon information and belief, defendants or one or more of them, have employed

Plaintiffs Image(s) in amyriad of ways and mediums, and have made uses of PlaintiffsImage(s)

in addition to what is set forth herein.

176. That the aforementioned uses of plaintiffs Image(s) by the defendants, or one or

more of them, are for branding and/or other purposes.

177. That defendant(s)' uses ofPlaintiffs Images have been for their sole economic

benefit and to the economic detriment of Plaintiff.

178. Inor around October of 2012, DJERRAHIAN provided SPIFF TV with low res and

non-retouched versions ofhis Images for MMG to review and possibly license from

DJERRAHIAN.

179. When delivering the Images to SPIFF TV by email, DJERRAHIAN specified that if

MMG is interested in any ofthe images to let DJERRAHIAN know and to specify the requested

use so that DJERRAHIAN could then considerthe licenseand provide an estimate for the

proposedterms of use, if any.

180. Rather than informing DJERRAHIAN of theImages in which they were interested

and for what manner they sought touse the Images, defendants orone ormore ofthem, boldly and

brazenly used Plaintiffs Images as aforesaid without requesting orobtaining Plaintiffs license,

authorization or consent.

181. Upon seeing the "TAKEOVER AD(S)", on January 9, 2013, DJERRAHIAN

confronted SPIFF with regard to the offenses to his intellectual property. SPIFF responded by

saying "I got your brother".

182. DJERRAHIAN also discussed the unauthorized uses of his image with MMG's vice

president, Kendall "Young Sav" Freeman from in or around June of2013 to September of2013.

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183. On October 29, 2013, a mutual acquaintance ofboth DJERRAHIAN and ROSS'

and MMG's lawyer, Ms. Adeline Ferretti, Esq., introduced DJERRAHIAN to Ferretti by email (a

copy ofsaid email isannexed hereto within Exhibit "T").

184. On October 31, 2013, DJERRAHIAN wrote to attorney Ferretti and informed her of

the various unauthorized uses ofhis Images (acopy of said email is annexed hereto within Exhibit

185. OnNovember 13, 2013, having received no response from Ferretti, DJERRAHIAN

re-sent hisemail to her from October 31,2013 (a copy of said email is annexed hereto within

Exhibit "T").

186. That Ms. Ferretti responded to DJERRAHIAN onNovember 13, 2013 and

scheduled a telephone call to discuss the issues (acopy ofsaid email isannexed hereto within

Exhibit "T").

187. That Ms. Ferretti told DJERRAHIAN on the phone that she would discuss the

matter withMMG (a copy of saidemail is annexed hereto within Exhibit "T").

188. On December 4, 2013, DJERRAHIAN wrote to Ferretti to ascertainwhether

Ferretti had spoken with MMG, and Ferretti never responded to DJERRAHIAN's email (acopy of

said email is annexed hereto within Exhibit "T").

189. On January 15, 2014, plaintiff, by counsel, issued anddelivered correspondence to

ROSS and MMG by and through their counsel Ms. Ferretti, advising her, inter alia, that ROSS and

MMG were in violation of plaintiffs copyright through the use of the Image(s), that theyshould

immediately cease and desist all uses of the Images, and that they should provide any information

that might rebut the plaintiffs presumption that the Image(s) had been unlawfully used in violation

ofPlaintiffs copyrights, and thatthey should disclose usage information without prejudice (a copy

of said letter, sans its exhibits is annexed hereto as Exhibit "U").

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190. That no response was received to said January 15,2014 letter until the end of

March of 2014.

191. As ofthe date ofthis Complaint, ROSS, MMG and their counsel, Ms. Ferretti, have

failed to adequately respond to plaintiffs counsel's letter, and have not provided any information

regarding the nature and extent ofthe use(s) ofplaintiffs Image(s).

192. On February 12,2014, Plaintiff, by counsel, issued and delivered correspondence to

ROSS and MMG to two separate addresses for MMG inthe State ofFlorida, advising them, inter

alia, that they were in violation ofplaintiffs copyright through the use ofthe Image(s), that they

should immediately cease and desist all uses ofthe Images, and that they should provide any

information that might rebut the plaintiffs presumption that the Image(s) had been unlawfully used

in violation of Plaintiffs copyrights.

193. That no response was received to either of said February 12, 2014 letters to ROSS

and MMG.

194. OnFebruary 12, 2014, Plaintiff, bycounsel, issued and delivered correspondence to

the general counsel atATLANTIC, advising it, inter alia, that it is inviolation ofplaintiffs

copyright through the use ofthe Image(s), that they should immediately cease and desist all uses of

the Images, and that they should provide any information that might rebut theplaintiffs

presumption that the Image(s) had been unlawfully used inviolation ofPlaintiffs copyrights.

195. On February 12, 2014, Plaintiff, by counsel, issued anddelivered correspondence to

the general counsel at DEF JAM, advising it, inter alia, that it is inviolation ofplaintiffs copyright

through the use of the Image(s), that they should immediately cease and desist all uses of the

Images, and that they should provide any information that might rebut the plaintiffs presumption

that the Image(s) had been unlawfully used in violation of Plaintiffs copyrights.

196. Thatdespite plaintiffs requests, defendants have failed to provide plaintiff with the

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full nature and extentof defendant(s)' use(s)of Plaintiff s Images.

197. That despite plaintiffs requests, many ofthe unauthorized use(s)' ofplaintiffs

images remain published on the World Wide Web and have not been removed, though duly

requested byplaintiffs counsel.

198. That upon information and belief, defendants, or one or more ofthem, continue to

employ plaintiffs Image.

199. That such post notice use is particularly egregious and willful.

200. Upon information and belief, each ofdefendants, orone ormore ofthem, are

sophisticated licensees and licensors ofintellectual property and employ persons expert in all

aspects of licensing, rights management and related matters.

201. Upon information and belief, each ofdefendants, orone ormore ofthem, have

extensive resources including but not limited to legal counsel, available to themto assure

compliance with all appropriate business protocols and federal or state statutes including but not

limited to USC Title 17.

202. That defendants, or one or more of them, knew or should have known of the

procedures and protocols for the licensing ofintellectual property created by third parties.

203. That despite such resources, and despite the actual notice thatPlaintiff created the

images, defendants, orone ormore ofthem, employed Plaintiffs Image(s) without plaintiffs

license, authorization or consent.

204. Upon information and belief, as of result of theaforementioned uses of Plaintiffs

Image(s) by the defendants, orone ormore of them, plaintiffs Image(s) have been widely

distributed and made available for others to appropriate and republishwith ease. Consequently,

Plaintiffs Image(s) are now published oncountless web pages bythird parties inviolation of

plaintiffs copyright.

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205. That, upon information and belief, the defendants, or one or more ofthem, were

fully aware at all times relevant herein that it lacked awritten license or permission necessary to

employ the use ofat least seventeen (17) ofPlaintiffs Image(s) in any form.

206. That, notwithstanding such knowledge, defendants, or one or more ofthem, wholly

failed to obtaina license or permission from the Plaintiff.

207. That pursuant to Federal Rule 11, Plaintiff sought to obviate litigation and resolve

the matters complained ofherein and made extensive efforts toward that end.

208. That subsequent to DJERRAHIAN'S notices to MMG, ROSS, SPIFF, and

subsequent to plaintiffs counsel's notices, defendants, or one or more ofthem, have continued to

use Plaintiffs Image(s), without hisauthorization, consent, or license.

209. That as of the date of thiscomplaint, the parties have been unable resolve their

disputes without the need for litigation, despite plaintiffs good faith attempts at same.

210. That the defendants have no defenses at law to the claims set forth herein.

211. Upon information and belief, each and all ofthe defendant(s) rely onUSC Title 17

and hold copyrights for their own intellectual property.

212. Paragraphs "1" through "210" are incorporated by reference with respect to each of

the below counts or claims for relief.

FIRST CLAIM FOR RELIEF

Willful Copyright Infringement

Under Section 501 of the Copyright Act

213. The use(s) of Plaintiff s Image(s) by the defendants, or one or moreof them, as

described hereinabove, were and are without the plaintiffs authorization, license or consent.

214. That, upon information andbelief, the defendants, or one or more of them have

infringed the copyright for Plaintiffs Image(s).

215. That, upon information andbelief, the aforementioned acts of thedefendants, or one

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or more ofthem, constitute federal statutory copyright infringement under Section 501 ofthe

Copyright Act in violation of the rights granted to DJERRAHIAN as copyright holder.

216. That the use ofeach image by each defendant constitutes a separate and distinct act

ofinfringement ofPlaintiffscopyright. That, upon information and belief, defendants, or one or

more ofthem, individually and/or collectively, have infringed no less than seventeen (17) of

plaintiffs copyright(s).

217. That, upon information and belief, defendant(s)' use(s) ofthe subject Image were

willful, intentional and in bad faith.

218. That, upon information and belief, defendants, orone ormore ofthem, had actual

and/or constructive knowledge and/or through the exercise ofordinary business care and/or the

examination ofpublic records, knew or should have known that the plaintiff held the copyright in

the Image, that neither defendants, nor one ormore ofthem, ever had (at any ofthe relevant times

herein) a license, consent, orauthorization by plaintiff for the use ofPlaintiffs image as

complained ofherein by the defendants, or one or more ofthem, and that any such use(s) would be

in violation of Plaintiffs copyright.

219. That as a result of defendant(s)' acts, plaintiffhas been and will continueto be

damaged inan amount as yet to be determined. Indeed, notwithstanding, Plaintiffs counsel's

letters referenced hereinabove, the date(s) or term(s) of use(s) of plaintiffs image are as yet

unknown, suchinformation beingwithinthe sole custody, possession, and control of the

defendants, or one or more of them.

220. That Plaintiff is further entitled to damages, attorneys' fees and costs under Section

504 and 505 of the Copyright Act, 17U.S.C. Section 101 et., seq., given the willful, intentional,

maliciousand bad faith nature of defendant(s)' copyright infringement, and as an alternative to

statutory damages, Plaintiff, at herelection prior to judgment is entitled to recover heractual

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damages and any additional profits of the defendants, or one or more of them, attributable to the

infringement as under 17 U.S.C. Sections 504 (a)-(b).

SECOND CLAIM FOR RELIEF

Negligent Copyright InfringementUnder Section 501 of the Copyright Act

221. The use(s) ofPlaintiffs Image(s) by the defendants, or one or more ofthem, as

described hereinabove, were and are without the plaintiffs authorization, license orconsent.

222. That, upon information and belief, the defendants, or one or more ofthem have

infringed the copyright for Plaintiffs Image(s).

223. That, upon information and belief, the aforementioned acts ofthe defendants, or one

or more ofthem, constitute federal statutory copyright infringement under Section 501 ofthe

Copyright Act in violation ofthe rights granted to DJERRAHIAN as copyright holder.

224. That the use ofeach image byeach defendant constitutes a separate and distinct act

ofinfringement ofPlaintiffs copyright. That, upon information and belief, defendants, or one or

more ofthem, individually and/or collectively, have infringed no less than seventeen (17) of


225. That, upon information and belief, defendant(s)' use(s) ofthe Image(s) inviolation

ofplaintiffs copyright were negligent in that defendants, or one or more ofthem, knew or should

have known that it was without a license for the use(s) complained of herein.

226. That, upon information and belief, defendants, orone ormore ofthem, had actual

and/or constructive knowledge and/or through the exercise of ordinary business care and/or the

examination ofpublic records, knew orshould have known that the plaintiff held the copyright in

the Image, that neither defendants, nor one ormore ofthem, ever had (at any ofthe relevant times

herein) a license, consent, orauthorization by plaintiff for the use ofPlaintiffs image as

complained ofherein by the defendants, or one or more ofthem, and that any such use(s) would be

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in violation of Plaintiffs copyright.

227. That as a result of defendant(s)' acts, plaintiff has been and will continue to be

damaged in an amount as yet to be determined. Indeed, notwithstanding, Plaintiffs counsel's

letters referenced hereinabove, the date(s) or term(s) of use(s) of plaintiffs image are as yet

unknown, such information being within the sole custody, possession, and control ofthe

defendants, or one or more of them.

228. That Plaintiffis further entitled to damages, attorneys' fees andcosts under Section

504 and 505 ofthe Copyright Act, 17 U.S.C. Section 101 et., seq., given the willful, intentional,

malicious andbadfaith nature of defendant(s)' copyright infringement, and as an alternative to

statutory damages, Plaintiff, at her election prior to judgment isentitled to recover her actual

damages and any additional profits ofthe defendants, orone ormore ofthem, attributable to the

infringement as under 17 U.S.C. Sections 504 (a)-(b).

THIRD CLAIM FOR RELIEF

Induced Copyright InfringementUnder Section 501 of the Copyright Act

Against Defendants ROSS, MMG and SPIFF

229. Upon information and belief, defendants, or one or more of them, have directly

infringed Plaintiffs copyright(s) by, inter alia employing, printing, manufacturing, editing,

cropping, broadcasting, disseminating, distributing, sublicensing, and/or enabling the copying or

appropriation ofPlaintiffs Image(s) (or unauthorized derivative works thereof) asdescribed more

fully hereinabove, inviolation of Plaintiffs exclusive rights under the Copyright Act, 17 U.S.C.

Sections 106 and 501.

230. Upon information and belief, defendants ROSS, MMG and SPIFF, or one or more of

them, are liable for inducing the copyright infringement(s) of various thirdparties who have used

plaintiffs images as described hereinabove.

231. Defendants, ROSS, MMG and SPIFF, or one or more of them, have selected,

29

0 0

employed, broadcast, printed, manufactured, modified, altered, edited, cropped, distributed,

sublicensed, provided, and/or enabled the copying or appropriation ofPlaintiffs Image(s) or

unauthorized derivative work(s) thereof for use in connection with, inter alia, materials and

publications to promote MMG, its members, tour(s), and the music of MMG and its members, as

specifiedhereinabove.

232. As explained herein, upon information and belief, defendants, ROSS, MMG and

SPIFF, or one or more ofthem, have actively facilitated, encouraged, and/or enticed at least

GUNPLAY, MEEK MILL, DJ SCREAM, DEF JAM, ISLAND DEF JAM, ATLANTIC,

Facebook, Instagram, Twitter, YouTube, KidEight, DatPiff, SoundCloud, and various blogs and

websites, or one or more of them, to commitcopyright infringement.

233. As set forth hereinabove, defendants, ROSS, MMG and SPIFF, or one or moreof

them, upon information and belief, have induced and/or continue to induce infringement(s),

willfully and/or negligently by, inter alia: employing, broadcasting, printing, publishing,

distributing, manufacturing, orenabling the copying ofplaintiffs Image(s), orunauthorized

derivative work(s) thereof, thereby inducing third parties, including but not limited to GUNPLAY,

MEEK MILL, DJ SCREAM, DEFJAM, ISLAND DEF JAM, ATLANTIC, Facebook, Instagram,

Twitter, YouTube, KidEight, DatPiff, SoundCloud, andvarious blogs and websites, or one or more

of them, to infringe on Plaintiffs copyright(s).

234. That said infringements have continued post notice, with defendants, or one or more

of them having received constructive and/or actual notice of Plaintiffs copyrights and the

corresponding infringement(s).

235. Upon information andbelief, at all times relevant herein, defendants, or one or more

of them, were on constructive and/or actual notice of Plaintiffs rights to the Image(s), andthat any

unauthorized use(s) thereof would be in violationof Plaintiffs copyright(s).

30

0 0

236. Upon information and belief, defendants, or one or more of them, relied on the use of

Plaintiffs Image(s) and/or derivative works thereof for the success of their business(s) and/or the

promotion ormarketing thereof.

237. That the use ofeach image by each defendant constitutes a separate and distinct

infringement ofPlaintiffscopyright. That, upon information and belief, defendants, or one or

more ofthem, individually and/or collectively, have infringed no less than seventeen ("17") of


238. Upon information and belief, through the acts described hereinabove, defendants, or

one or more of them, are liable for inducing the infringement(s) described herein.

239. Upon information and belief, defendant(s)' infringement(s) are and have been willful,

intentional, purposeful, and with disregard ofthe rights ofPlaintiff, and have caused substantial

damage to Plaintiff.

240. As a direct and proximate result ofdefendant(s)' infringement(s), Plaintiff isentitled

to the maximum statutory damages under 17 U.S.C. Section 504 (c), and asanalternative to

statutory damages, Plaintiff, at his election prior to judgment isentitled to recover his actual

damages and any additional profits ofthe defendants, or one ormore ofthem, attributable to the

infringement(s) as under 17U.S.C. Sections 504 (a)-(b).

241. Pursuant to 17 U.S.C. Section 505, Plaintiff is entitled to his costs, including

reasonable attorneys' fees.

FOURTH CLAIM FOR RELIEF

Contributory Copyright InfringementUnder Section 501 of the Copyright Act

Against Defendants ROSS. MMG and SPIFF

242. Upon information and belief, defendants, or one or more of them, have directly

infringed Plaintiffs copyright(s) by, inter alia employing, printing, manufacturing, editing,

cropping, broadcasting, disseminating, distributing, sublicensing, and/or enabling the copying or

31

0 0

appropriation ofPlaintiffsImage(s) (or unauthorized derivative works thereof) as described more

fully hereinabove, in violation of Plaintiffsexclusive rights under the Copyright Act, 17 U.S.C.

Sections 106 and 501.

243. Upon information and belief, defendants, ROSS, MMG and SPIFF, or one or more of

them, are liable as contributory infringer(s) for the copyright infringement(s) committed via:

selecting, employing, broadcasting, printing, manufacturing, editing, cropping, sublicensing,

distributing, and/or enabling the copying or appropriation of PlaintiffsImage(s); and that such

use(s) were inviolation ofPlaintiffs copyrights.


them, have directly and/or indirectly, willfully and/or negligently caused, enabled, encouraged,

facilitated, and/or materially contributed to the infringement(s) by atleast GUNPLAY, MEEK

MILL, DJ SCREAM, DEF JAM, ISLAND DEF JAM, ATLANTIC, Facebook, Instagram, Twitter,

YouTube, KidEight, DatPiff, SoundCloud, and various blogs and websites, or one or more of

them, described hereinabove, by selecting, employing, broadcasting, printing, publishing,

manufacturing, editing, cropping, sublicensing, distributing, disseminating and/or enabling the

copying orappropriation ofPlaintiffs Image(s), inviolation ofPlaintiffs copyrights.


them, have inaddition to the actions above, provided the tools (i.e. a print orelectronic copy(ies)

ofPlaintiffs Image(s), and/or electronically displayed the Image(s) ina manner whereby they

could be copied orappropriated), support, and/or instruction for the infringement(s), via the

infringements described herein, in violation in Plaintiffs copyright(s).

246. Upon information and belief, defendants, ROSS, MMG and SPIFF, orone ormore of

them, by inter alia, selecting, distributing, modifying, altering, cropping, editing, sublicensing,

providing, and/or enabling the copying orappropriation ofthe Image(s) as specified hereinabove,

32

0 0

contributed to the infringement(s) by third parties and at least GUNPLAY, MEEK MILL, DJ

SCREAM, DEF JAM, ISLAND DEF JAM, ATLANTIC, Facebook, Instagram, Twitter, YouTube,

KidEight, DatPiff, SoundCloud, and various blogs and websites, or one or more of them.

247. Upon information and belief, defendants, or one or more of them, knew or should

have known that it/they was not authorized to use Plaintiffs Image(s).

248. Upon information and belief, defendants, or one or more of them, had actual and/or

constructive knowledge and/or through the exercise ofordinary business care and/or the

examination ofpublic and/or business records, knew or should have known ofPlaintiffsrights in

the Image(s), and that any use of such Image(s) or of derivative works thereof would be in

violation of Plaintiffs copyright(s).

249. That the use ofeach image by each defendant constitutes a separate and distinct

infringement ofPlaintiffscopyright(s). That, upon information and belief, defendants, or one or

more ofthem, individually and/or collectively, have infringed no less than seventeen ("17") of


250. Upon information and belief, through the conduct described hereinabove, defendants,

ROSS, MMG and SPIFF, or one or more ofthem, are contributorily liable for the infringement(s)

described herein.

251. Upon information and belief, the aforementioned acts ofthe defendants, orone or

more ofthem, constitutes federal statutory contributory copyright infringement under Section 501

ofthe Copyright Act in violation ofthe exclusive rights granted DJERRAHIAN as copyright

holder.

252. Upon information and belief, defendant(s)' infringement(s) are and have been willful,

intentional, purposeful, and/or in disregard ofthe rights ofPlaintiff, and have caused substantial

damage to Plaintiff.

33

0 0

253. As adirect and proximate result ofdefendant(s)' infringement(s), Plaintiff has been

and will continue to be damaged in an amount as yet undetermined. Indeed, the full nature and

extent of defendant(s)' use(s) ofPlaintiffs Images is as yet unknown, such information being

within the sole custody, possession, and control ofthe defendants, or one or more ofthem.

254. Plaintiff is entitled to the maximum statutory damages under 17 U.S.C. Section 504

(c), and as an alternative to statutory damages, Plaintiff, at his election prior to judgment is entitled

to recover his actual damages and any additional profits ofthe defendants, or one or more ofthem,

attributable to the infringement(s) as under 17U.S.C. § 504 (a)-(b).

255. Plaintiff is further entitled to damages, attorneys' fees and costs under Section 504

and 505 ofthe Copyright Act, 17 U.S.C. Section 101 et., seq., given the repeated and systematic,

willful, intentional, malicious and bad faith nature ofdefendant(s)' copyright infringement(s).

JURY DEMAND

256. That Plaintiff requests a trial by jury of all issues.

WHEREFORE, Plaintiffdemands judgmentas against the defendant as follows:

ON THE FIRST CLAIM FOR RELIEF- (A) Award to plaintiffhis actual damages

incurred as a result of defendant(s)' infringement(s), and allprofits realized as a result of each of

their infringement(s), in amounts to be determined at trial; or (B) inthe alternative, at plaintiffs

election, award toplaintiff maximum statutory damages pursuant to 17 U.S.C. § 504 for each

separate and distinct act ofinfringement; and for an order ofinjunction permanently enjoining

and prohibiting the defendants, or one ormore ofthem, including but not limited to wholly

ownedsubsidiaries and/or affiliates, from employing or utilizing in any manner or media

whatsoever, including all future uses, sales, transfers, assignments, or licensing of any and all of

plaintiffs copyrighted images, pursuant to 17 U.S.C. § 502 and for an award ofcosts and

attorneys' fees pursuant to 17 U.S.C. § 505;

34

0 0

ON THE SECOND CLAIM FOR RELIEF- (A) Award to plaintiff his actual damages

incurred as aresult of defendant(s)' infringement(s), and all profits realized as aresult of each of

their infringement(s), in amounts to be determined at trial; or (B) in the alternative, at plaintiffs

election, award to plaintiff maximum statutory damages pursuant to 17 U.S.C. §504 for each

separate and distinct act of infringement, and for an order of injunction permanently enjoining

and prohibiting the defendants, or one or more of them, including but not limited to wholly

owned subsidiaries and/or affiliates, from employing or utilizing in any manner or media

whatsoever, including all future uses, sales, transfers, assignments, or licensing ofany and all of

plaintiffs copyrighted images, pursuant to 17 U.S.C. §502 and for an award ofcosts and

attorneys' fees pursuant to 17U.S.C. § 505;

ON THE THIRD CLAIM FOR RELIEF - (A)Award to plaintiff his actual damages

incurred as a result ofdefendant(s)' infringement(s), and all profits realized as a result ofeach of



separate and distinct act of infringement, and for an order ofinjunction permanently enjoining

and prohibiting the defendants, or one or more ofthem, including but not limited to wholly


whatsoever, including all future uses, sales, transfers, assignments, or licensing ofany and all of


attorneys' fees pursuant to 17 U.S.C. § 505;

ON THE FORTH CLAIM FOR RELIEF - (A) Award to plaintiffhis actual damages

incurred as a result ofdefendant(s)' infringement(s), and all profits realized as a result ofeach of



35

0 0

separate and distinct act of infringement, and for an order of injunction permanently enjoining

and prohibiting the defendants, or one or more of them, including but not limited to wholly


whatsoever, including all future uses, sales, transfers, assignments, or licensing of any and all of


attorneys' fees pursuant tol7U.S.C.§505;

Prejudgment interest on all sums due;

And such other and further reliefas this Court may deem just and proper inclusive of any

and all relief orremedies allowable by the statutes referenced above orapplicable hereinabove.

Dated: New York, New YorkMay 6, 2014

Yours, etc.

Tamara L. Lannin, Esq. (TL 3784)EDWARD C. GREENBERG, LLC570 Lexington Avenue, 19th FloorNew York, NY 10022Tel: (212) 697-8777Fax: (212) 697-2528Attorneysfor Plaintiff

36

EXHIBIT A

0

EXHIBIT B

*•>••>#' 3

C•?$t ^.,0>

0

Certificate ofRegistration

^•2±if*.

77,.* >•J8-0

Title

This Certificate issued under the sealof the CopyrightOffice in accordance with title 17, United States Code,attests that registration hasbeen madefor the workidentified below. The information on this certificate has

been made a part of the Copyright Officerecords.

Register ofCopyrights, United States ofAmerica

0

Registration Number

VA 1-899-797

Effective date of

registration:

December 25. 2013

Title ofWork: Vibe magazine Aug/'Sept 2012 feat Maybach Music Group's artists: Rick Ross, MeekMill, Wale, Omarion, Stalley, Gunplay

Completion/ Publication

Author

Year ofCompletion: 2012

Date of 1st Publication: September 1, 2012

Author: Armen Charles Djerrahian

Pseudonym: armenexpo

Author Created: photograph(s)

Citizen of: France

Year Born: 1969

Copyright claimant

Nation of 1st Publication: United States

Domiciled in: United States

Copyright Claimant: Armen Charles Djerrahian

164 Russell Street, Apt#2R, Brooklyn, NY, 11222

Rights and PermissionsName: Armen Charles Djerrahian

Email: [email protected]

Address: 164 Russell Street, Apt#2R

Brooklyn, NY 11222

Telephone: 646-642-1633

Certification

Name: Armen Djerrahian

Date: December 25,2013

Page 1 of 2

0 Q

Correspondence: Yes

Page 2 of 2

EXHIBIT C

0

GunPlay_0l8 GunPlay_108 GunPlay_118

^H^^&<«« *

Meek Mil 058 Meek Mil 060 Meek Mil 278

£!>%MMG07 MMG08 MMG09

Omarion 212 Omarion 231 Omarion 236

Rick 022 Rick 033 Rick 046

Rick 088 Rick 089 Rick 135

Staley_021 Staley_027 Staley_081

/^m

^| m-.

Meek Mil 029

Meek Mil 301

Omarion 001

#•

Rick 007

Rick 051

rickross06b

Staley_083

*4Meek Mil 038

Meek Mil 309

I

Omarion 009

Rick 009

Rick 081

0

Staley__009

Staley„086

0

* *

Wale 005 Wale 009 Wale 011 Wale 016 Wale 017

Wale 024 Wale 026

0

Certificate of Registration

s'v'u'*.y.

Title

I'his Certificateissued under the sealof the CopyrightOffice in accordance with title 17, United States Code,attests that registration has been made for the workidentified below. The information on this certificate has

been made a part of the Copyright Office records.

LA '(XAiC«~-. ot^JsJL

Register of Copyrights,United States of America

Title ofWork: GunPlayOl 8, et al.

Contents Titles: GunPlay018

GunPlay 108

GunPlay118

MeekMil029

MeekMil038

MeekMil058

MeekMil060

MeekMil278

MeekMiOOl

MeekMil309

OmarionOOl

Omarion009

Omarion212

Omarion231

Omarion236

Rick007

Rick009

Rick022

Rick033

Rick046

Rick051

Rick081

Rick088

Rick089

Number

f%

Registration Number

VAu 1-160-975

Effective date of

registration:

December 25,2013

Page 1 of 3

Rickl35

Staley009

Staley021

Staley027

Staley081

Staley083

Staley086

Wale005

Wale009

WaleOll

Wale016

Wale017

Wale024

Wale026

MMG07

MMG09

MMG08

rickross06b

Completion/PublicationYear of Completion: 2012

Author —

0

Author: Armen Charles Djerrahian

Pseudonym: armenexpo

Author Created: photograph(s)

• Citizen of: France Domiciled in: UnitedStates

Copyright claimantCopyright Claimant: Armen Charles Djerrahian

164Russell Street, Apt#2R, Brooklyn, NY, 11222

Rights and PermissionsName: Armen Charles Djerrahian

Email: [email protected] Telephone: 646-642-1633

Address: 164 Russell Street, Apt#2R

Brooklyn, NY 11222

Certification

Name: Armen Djerrahian

Date: December 25, 2013

Paae 2 of 3

EXHIBIT D

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01/13/14 Maybach Music Group's Photos - Maybach Music Group | FaGebook

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mv mmm m smmmwiammm !ia«T3» >> trnmk

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Maybach Music GroupThe Black BarMitzvah Mixtapedrops at rridnight! Checkout the traddisting.

Dontforget to folowthe Untouchable Maybach Empire onTumbir: http://mmgofricial.tumblr.conV

And Instagram: UntouchableMMG

(5 Manjeet Singh, Alexouw MaybachMusBc, Natukwasa Undon Da Boss and741others Bke this.

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Joel Vazquez 2, 3, 4, 7, and that's about itthat I would careabout.

•'itfoberS, 2012 ai 4:51pm

Tyreke Bi Hobenu Mmg

Octobers, 2012at4;5ipn)-«ai

Manuel Acosta This Shit gonna sound Nice

October 8, 2012 at 4:51pm

Kayb Abitia PLEASE READ THIS YOU WILL BE KISSED ON THENEARESTFRIDAYBYTHE LOVE OF YOUR LIFE. NOW YOUVESTARTED READINGTHIS. DONT STOP. THIS IS FREAKY.... See More

Octobers, 2012 at 4:51pm

Kevin English DEC 1st SACTOWN

October 8, 2012 at. 4:$2pm

Xabiso Boas Mkalipi Mafavourite group in tha fuckin gameOctobers, 2012 3t4:S3prfi

Lautaro De Rosa I like it. RickRoss you're the boss

Octobers, 2012 at 4:53pm-til

hupsi/Aawwfecebookcar^^ &set= pb.177110875670631.-2207520000.1389648694.&type=3&src=https%3A%2F%2Fscontent-a-ia.. 1/3

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0:eboc^^Timeline Photos - Maybach Music Group | Fao

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Maybach Musk GroupBig announcementtoday for the Maybach Music Groupfatrily! Rick Ross, MeekMil, WaleandDJ Scream are hitting the road this Fall.

Watchthe videoannouncementhere: http://www.youtube.com/watch?v=LEu6r_cmTzE&feature=youtu.be

l5 SaberMenrouk, SAabella Kamano, Yayo Orlando Lamo and1,317otherslikethis.

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Badge Prod Musk #MMG Famiy

September 2-1, 20.12 at i i:2Qprn

Dylan A Howard MGK is trash I fucks with MMG but if the best u cando is MGK I save mymoneywe aht al Rick foeva niggaa!i HahaSeptember 24, 2012 at ll:22pmvlB mobile

Dylan A Howard Rich*

September 24, 2012 at 11:22;jm via rr*>b4-

ByWk MMG BITCH!

September 24, 2012 at 11:24pra

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HamiltonH-babys Babys, MuhammedIbrahim, Bryan Alex Parker and 120others like this.

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HShaven Singh Hayer wish icould go

September 26, 2012 at 8:47am

Hj|^ AdamDe Man badofbotocks didnt even turn upIn melboumeBB September 29, 2012 at 10:56pm

Matheus Correa FEEL LIKE A BOSS!

October 2, 2012 at 9:24am

*X3 SaiekzOlmos Juarez GinobJiVamos we!|jH October S, 2012 at 1:39pm

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October 13, 2012 at 11:41pm • 1

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MCcbunda Huis-money Ntiyiso DoubleMI'vegotta G-zouttarariifnnra HIHHIIihl

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