47970881-Righthaven-v-Pajamas-Media-Complaint

Document Sample
47970881-Righthaven-v-Pajamas-Media-Complaint Powered By Docstoc
					Case 1:11-cv-00240-CMA Document 1              Filed 01/28/11 USDC Colorado Page 1 of 7




                       IN THE UNITED STATES DISTRICT COURT
                             FOR THE DISTRICT OF COLORADO

Civil Action No.:_________________________

RIGHTHAVEN LLC, a Nevada limited-liability company,

               Plaintiff,
v.

PAJAMAS MEDIA, INC., a California corporation; and
BRYAN PRESTON, an individual,


               Defendants.


                     COMPLAINT AND DEMAND FOR JURY TRIAL



       Righthaven LLC (“Righthaven”) complains as follows against Pajamas Media, Inc.
(“Pajamas Media”), and Bryan Preston (“Mr. Preston”; collectively with Pajamas Media known
herein as the “Defendants”), on information and belief:


                                      NATURE OF ACTION
       1.      This is an action for copyright infringement pursuant to 17 U.S.C. § 501.


                                            PARTIES
       2.      Righthaven is, and has been at all times relevant to this lawsuit, a Nevada limited-
liability company with its principal place of business in Nevada.
       3.      Righthaven is, and has been at all times relevant to this lawsuit, in good standing
with the Nevada Secretary of State.
Case 1:11-cv-00240-CMA Document 1               Filed 01/28/11 USDC Colorado Page 2 of 7




       4.      Pajamas Media is, and has been at all times relevant to this lawsuit, a California
corporation.
       5.      Pajamas Media is, and has been at all times relevant to this lawsuit, identified by
the current registrar, GoDaddy.com, Inc. (“GoDaddy”), as the registrant of the Internet domain
found at <pajamasmedia.com> (the “Domain”).
       6.      Pajamas Media is, and has been at all times relevant to this lawsuit, identified by
GoDaddy as the administrative and technical contact of the Domain (the content accessible
through the Domain and the Domain itself known herein as the “Website”).
       7.      Pajamas Media is, and has been at all times relevant to this lawsuit, the self-
proclaimed owner of the copyright(s) in the work(s) displayed on the Website, as evidenced by a
copyright notice on the Website: “Copyright © 2005-2011 Pajamas Media All Rights Reserved.”
       8.      Mr. Preston is, and has been at all times relevant to this lawsuit, identified by
Pajamas Media as the Austin editor, a columnist and contributor of Pajamas Media, as evidenced
by the Website.
       9.      Mr. Preston reproduced an unauthorized copy of the Righthaven-owned
photograph entitled: “TSA Agent performs enhanced pat-downs” (the “Work”), attached hereto
as Exhibit 1, and displayed said unauthorized copy (the “Infringement”), attached hereto as
Exhibit 2, on the Website.


                                        JURISDICTION
       10.     This Court has jurisdiction over the subject matter and the parties under the
copyright laws of the United States, 17 U.S.C. § 101 et seq., as well as jurisdictional provisions
of 28 U.S.C. § 1331 and 28 U.S.C. § 1338(a).
       11.     Righthaven is the owner of the copyright in and to the Work.
Case 1:11-cv-00240-CMA Document 1              Filed 01/28/11 USDC Colorado Page 3 of 7




       12.    On or about November 19, 2010, Mr. Preston willfully infringed upon
Righthaven’s copyright, by reproducing the Work on an unauthorized basis, from a source
emanating from Colorado.
       13.    On or about November 19, 2010, the Defendants displayed, and continue to
display, the Infringement on the Website.
       14.    The composition, at least in part, of the Work and the Infringement, is a
Transportation Security Administration Agent performing an enhanced pat-down search in the
Denver, Colorado airport.
       15.    The focal point of the Infringement is Denver, Colorado.
       16.    The only geographic location that is associated with, and related to, the Work is
Denver, Colorado.
       17.    The Work was originally published in The Denver Post.
       18.    The Defendants knew that the Work was originally published in The Denver Post.
       19.    The Defendants knew that the Work originally emanated from Colorado.
       20.    At all times relevant to this lawsuit, the Infringement, as publically displayed on
the Website, was and is accessible to persons in Colorado.
       21.     At all times relevant to this lawsuit, the Infringement occurred and continues to
occur in Colorado.
       22.    The Defendants’ display of the Infringement was and is purposefully directed at
Colorado residents.
       23.    The harm caused by the Infringement, was experienced, at least in part, in
Colorado.
///
///
///
Case 1:11-cv-00240-CMA Document 1                 Filed 01/28/11 USDC Colorado Page 4 of 7




                                                 VENUE
       24.     The United States District Court for the District of Colorado is an appropriate
venue, pursuant to 28 U.S.C. § 1400 (a), because the Defendants are subject to personal
jurisdiction in Colorado.
       25.     The United States District Court for the District of Colorado is an appropriate
venue, pursuant to 28 U.S.C. § 1391(b)(2), because a substantial part of the events giving rise to
the claim for relief are situated in Colorado.


                                                 FACTS
       26.     The Work constitutes copyrightable subject matter, pursuant to 17 U.S.C. §
102(a)(5).
       27.     Righthaven is the owner of the copyright in and to the Work.
       28.     The Work was originally published on or about November 18, 2010.
       29.     On December 8, 2010, the United States Copyright Office (the “USCO”) granted
Righthaven the registration to the Work, copyright registration number VA0001751279 (the
“Registration”) and attached hereto as Exhibit 3 is evidence of the Registration in the form of a
printout of the official USCO database record depicting the occurrence of the Registration.
       30.     On or about November 19, 2010, the Defendants displayed, and continue to
display, the Infringement on the Website.
       31.     The Defendants did not seek permission, in any manner, to reproduce, display, or
otherwise exploit the Work.
       32.     The Defendants were not granted permission, in any manner, to reproduce,
display, or otherwise exploit the Work.
///
///
///
Case 1:11-cv-00240-CMA Document 1             Filed 01/28/11 USDC Colorado Page 5 of 7




                      CLAIM FOR RELIEF: COPYRIGHT INFRINGEMENT
       33.    Righthaven repeats and realleges the allegations set forth in Paragraphs 1 through
32 above.
       34.    Righthaven holds the exclusive right to reproduce the Work, pursuant to 17
U.S.C. § 106(1).
       35.    Righthaven holds the exclusive right to prepare derivative works based upon the
Work, pursuant to 17 U.S.C. § 106(2).
       36.    Righthaven holds the exclusive right to distribute copies of the Work, pursuant to
17 U.S.C. § 106(3).
       37.    Righthaven holds the exclusive right to publicly display the Work, pursuant to 17
U.S.C. § 106(5).
       38.    The Defendants reproduced the Work in derogation of Righthaven’s exclusive
rights under 17 U.S.C. § 106(1).
       39.    The Defendants created an unauthorized derivative of the Work in derogation of
Righthaven’s exclusive rights under 17 U.S.C. § 106(2).
       40.    The Defendants distributed, and continue to distribute, an unauthorized
reproduction of the Work on the Website, in derogation of Righthaven’s exclusive rights under
17 U.S.C. § 106(3).
       41.    The Defendants publicly displayed, and continue to publicly display, an
unauthorized reproduction of the Work on the Website, in derogation of Righthaven’s exclusive
rights under 17 U.S.C. § 106(5).
       42.    Pajamas Media has willfully engaged in the copyright infringement of the Work.
       43.    Mr. Preston has willfully engaged in the copyright infringement of the Work.
Case 1:11-cv-00240-CMA Document 1                 Filed 01/28/11 USDC Colorado Page 6 of 7




        44.     The Defendants’ acts as alleged herein, and the ongoing direct results of those
acts, have caused and will continue to cause irreparable harm to Righthaven in an amount
Righthaven cannot ascertain, leaving Righthaven with no adequate remedy at law.
        45.     Unless the Defendants are preliminarily and permanently enjoined from further
infringement of the Work, Righthaven will be irreparably harmed, and Righthaven is thus
entitled to preliminary and permanent injunctive relief against further infringement by the
Defendants of the Work, pursuant to 17 U.S.C. § 502.


                                      PRAYER FOR RELIEF
        Righthaven requests that this Court grant Righthaven’s claim for relief herein as follows:
        1.      Preliminarily and permanently enjoin and restrain the Defendants, and the
Defendants’ officers, agents, servants, employees, attorneys, related companies, partners, and all
persons acting for, by, with, through, or under the Defendants, from directly or indirectly
infringing the Work by reproducing the Work, preparing derivative works based on the Work,
distributing the Work to the public, and/or displaying the Work, or ordering, directing,
participating in, or assisting in any such activity;
        2.      Direct the Defendants to preserve, retain, and deliver to Righthaven in hard copies
or electronic copies:
                a.      All evidence and documentation relating in any way to the Defendants’
        use of the Work, in any form, including, without limitation, all such evidence and
        documentation relating to the Website;
                b.      All evidence and documentation relating to the names and addresses
        (whether electronic mail addresses or otherwise) of any person with whom the
        Defendants have communicated regarding the Defendants’ use of the Work; and
                c.      All financial evidence and documentation relating to the Defendants’ use
        of the Work;
Case 1:11-cv-00240-CMA Document 1              Filed 01/28/11 USDC Colorado Page 7 of 7




       3.     Direct GoDaddy, the current registrar, and any successor domain name registrar
for the Domain, to lock the Domain and transfer control of the Domain to Righthaven;
       4.     Award Righthaven statutory damages for the willful infringement of the Work,
pursuant to 17 U.S.C. § 504(c);
       5.     Award Righthaven costs, disbursements, and attorneys’ fees incurred by
Righthaven in bringing this action, pursuant to 17 U.S.C. § 505;
       6.     Award Righthaven pre- and post-judgment interest in accordance with applicable
law; and
       7.     Grant Righthaven such other relief as this Court deems appropriate.


                                  DEMAND FOR JURY TRIAL
       Righthaven requests a trial by jury pursuant to Rule 38 of the Federal Rules of Civil
Procedure.
       Dated this twenty-eighth day of January, 2011.


                                                    By: /s/ Steven G. Ganim
                                                    STEVEN G. GANIM, ESQ.
                                                    Righthaven LLC
                                                    9960 West Cheyenne Avenue, Suite 210
                                                    Las Vegas, Nevada 89129-7701
                                                    Tel: (702) 527-5900
                                                    Fax: (702) 527-5909
                                                    sganim@righthaven.com
                                                    SHAWN A. MANGANO, ESQ.
                                                    SHAWN A. MANGANO, LTD.
                                                    9960 West Cheyenne Avenue, Suite 170
                                                    Las Vegas, Nevada 89129-7701
                                                    Tel: (702) 304-0432
                                                    Fax: (702) 922-3851
                                                    shawn@manganolaw.com

                                                    Attorneys for Plaintiff Righthaven LLC
Case 1:11-cv-00240-CMA Document 1-1   Filed 01/28/11 USDC Colorado Page 1 of 5
Case 1:11-cv-00240-CMA Document 1-1   Filed 01/28/11 USDC Colorado Page 2 of 5
Case 1:11-cv-00240-CMA Document 1-1   Filed 01/28/11 USDC Colorado Page 3 of 5
Case 1:11-cv-00240-CMA Document 1-1   Filed 01/28/11 USDC Colorado Page 4 of 5
Case 1:11-cv-00240-CMA Document 1-1   Filed 01/28/11 USDC Colorado Page 5 of 5
Case 1:11-cv-00240-CMA Document 1-2   Filed 01/28/11 USDC Colorado Page 1 of 4




                   EXHIBIT 2
Case 1:11-cv-00240-CMA Document 1-2   Filed 01/28/11 USDC Colorado Page 2 of 4
Case 1:11-cv-00240-CMA Document 1-2   Filed 01/28/11 USDC Colorado Page 3 of 4
Case 1:11-cv-00240-CMA Document 1-2   Filed 01/28/11 USDC Colorado Page 4 of 4
Case 1:11-cv-00240-CMA Document 1-3   Filed 01/28/11 USDC Colorado Page 1 of 2
Case 1:11-cv-00240-CMA Document 1-3   Filed 01/28/11 USDC Colorado Page 2 of 2
                 Case 1:11-cv-00240-CMA Document 1-4                                                     Filed 01/28/11 USDC Colorado Page 1 of 2
 OJS 44 (Rev. 12/07)                                                          CIVIL COVER SHEET
 The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
 by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating
 the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

 I. (a) PLAINTIFFS                                                                                              DEFENDANTS
RIGHTHAVEN LLC, a Nevada limited-liability company                                                               PAJAMAS MEDIA, INC., a California corporation; and
                                                                                                                 BRYAN PRESTON, an individual,
      (b) County of Residence of First Listed Plaintiff               Clark (Nevada)                            County of Residence of First Listed Defendant
                                (EXCEPT IN U.S. PLAINTIFF CASES)                                                                                (IN U.S. PLAINTIFF CASES ONLY)
                                                                                                                        NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
                                                                                                                               LAND INVOLVED.

      (c) Attorney’s (Firm Name, Address, and Telephone Number)                                                  Attorneys (If Known)

STEVEN G. GANIM, ESQ.; Righthaven LLC; 9960 West Cheyenne
Avenue, Suite 210; Las Vegas, Nevada 89129-7701; Tel: (702)
527-5900 OF JURISDICTION (Place an “X” in One Box Only)
 II. BASIS                                               III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an “X” in One Box for Plaintiff
                                                                                                             (For Diversity Cases Only)                                         and One Box for Defendant)
 ’ 1     U.S. Government                  ’ 3 Federal Question                                                                        PTF         DEF                                          PTF      DEF
           Plaintiff                            (U.S. Government Not a Party)                           Citizen of This State         ’ 1         ’ 1      Incorporated or Principal Place      ’ 4     ’ 4
                                                                                                                                                           of Business In This State

 ’ 2     U.S. Government                  ’ 4 Diversity                                                 Citizen of Another State          ’ 2     ’    2   Incorporated and Principal Place     ’ 5      ’ 5
           Defendant                                                                                                                                          of Business In Another State
                                                   (Indicate Citizenship of Parties in Item III)
                                                                                                        Citizen or Subject of a           ’ 3     ’    3   Foreign Nation                       ’ 6      ’ 6
                                                                                                          Foreign Country
 IV. NATURE OF SUIT                       (Place an “X” in One Box Only)
           CONTRACT                                              TORTS                                    FORFEITURE/PENALTY                          BANKRUPTCY                     OTHER STATUTES
 ’   110 Insurance                        PERSONAL INJURY                  PERSONAL INJURY              ’ 610 Agriculture                   ’ 422 Appeal 28 USC 158           ’   400 State Reapportionment
 ’   120 Marine                       ’    310 Airplane                 ’ 362 Personal Injury -         ’ 620 Other Food & Drug             ’ 423 Withdrawal                  ’   410 Antitrust
 ’   130 Miller Act                   ’    315 Airplane Product               Med. Malpractice          ’ 625 Drug Related Seizure                28 USC 157                  ’   430 Banks and Banking
 ’   140 Negotiable Instrument                 Liability                ’ 365 Personal Injury -               of Property 21 USC 881                                          ’   450 Commerce
 ’   150 Recovery of Overpayment      ’    320 Assault, Libel &               Product Liability         ’ 630 Liquor Laws                     PROPERTY RIGHTS                 ’   460 Deportation
        & Enforcement of Judgment              Slander                  ’ 368 Asbestos Personal         ’ 640 R.R. & Truck                  ’ 820 Copyrights                  ’   470 Racketeer Influenced and
 ’   151 Medicare Act                 ’    330 Federal Employers’             Injury Product            ’ 650 Airline Regs.                 ’ 830 Patent                              Corrupt Organizations
 ’   152 Recovery of Defaulted                 Liability                      Liability                 ’ 660 Occupational                  ’ 840 Trademark                   ’   480 Consumer Credit
         Student Loans                ’    340 Marine                    PERSONAL PROPERTY                    Safety/Health                                                   ’   490 Cable/Sat TV
         (Excl. Veterans)             ’    345 Marine Product           ’ 370 Other Fraud               ’ 690 Other                                                           ’   810 Selective Service
 ’   153 Recovery of Overpayment               Liability                ’ 371 Truth in Lending                      LABOR                     SOCIAL SECURITY                 ’   850 Securities/Commodities/
         of Veteran’s Benefits        ’    350 Motor Vehicle            ’ 380 Other Personal            ’ 710 Fair Labor Standards          ’ 861 HIA (1395ff)                        Exchange
 ’   160 Stockholders’ Suits          ’    355 Motor Vehicle                  Property Damage                 Act                           ’ 862 Black Lung (923)            ’   875 Customer Challenge
 ’   190 Other Contract                        Product Liability        ’ 385 Property Damage           ’ 720 Labor/Mgmt. Relations         ’ 863 DIWC/DIWW (405(g))                  12 USC 3410
 ’   195 Contract Product Liability   ’    360 Other Personal                 Product Liability         ’ 730 Labor/Mgmt.Reporting          ’ 864 SSID Title XVI              ’   890 Other Statutory Actions
 ’   196 Franchise                             Injury                                                        & Disclosure Act               ’ 865 RSI (405(g))                ’   891 Agricultural Acts
        REAL PROPERTY                        CIVIL RIGHTS                PRISONER PETITIONS             ’ 740 Railway Labor Act               FEDERAL TAX SUITS               ’   892 Economic Stabilization Act
 ’   210 Land Condemnation            ’    441 Voting                   ’ 510 Motions to Vacate         ’ 790 Other Labor Litigation        ’ 870 Taxes (U.S. Plaintiff       ’   893 Environmental Matters
 ’   220 Foreclosure                  ’    442 Employment                     Sentence                  ’ 791 Empl. Ret. Inc.                      or Defendant)              ’   894 Energy Allocation Act
 ’   230 Rent Lease & Ejectment       ’    443 Housing/                    Habeas Corpus:                     Security Act                  ’ 871 IRS—Third Party             ’   895 Freedom of Information
 ’   240 Torts to Land                        Accommodations            ’ 530 General                                                             26 USC 7609                         Act
 ’   245 Tort Product Liability       ’    444 Welfare                  ’ 535 Death Penalty                   IMMIGRATION                                                     ’   900Appeal of Fee Determination
 ’   290 All Other Real Property      ’    445 Amer. w/Disabilities -   ’ 540 Mandamus & Other          ’ 462 Naturalization Application                                              Under Equal Access
                                              Employment                ’ 550 Civil Rights              ’ 463 Habeas Corpus -                                                         to Justice
                                      ’    446 Amer. w/Disabilities -   ’ 555 Prison Condition               Alien Detainee                                                   ’   950 Constitutionality of
                                              Other                                                     ’ 465 Other Immigration                                                       State Statutes
                                      ’    440 Other Civil Rights                                            Actions




 V. ORIGIN                  (Place an “X” in One Box Only)                                                                                                                                    Appeal to District
 ’ 1 Original            ’ 2 Removed from                    ’ 3 Remanded from                     ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict
                                                                                                                         another district                                           ’ 7 Judge from
                                                                                                                                                                                        Magistrate
     Proceeding                 State Court                             Appellate Court                Reopened                               Litigation
                                                                                                                         (specify)                                                            Judgment
                                             Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
                      17 U.S.C. § 501
 VI. CAUSE OF ACTION Brief description of cause:
                      Copyright Infringement
 VII. REQUESTED IN   ’ CHECK IF THIS IS A CLASS ACTION    DEMAND $                                                                                      CHECK YES only if demanded in complaint:
      COMPLAINT:         UNDER F.R.C.P. 23           150,000.00                                                                                         JURY DEMAND:         ’ Yes     ’ No
 VIII. RELATED CASE(S)
                                                (See instructions):
       IF ANY                                                           JUDGE                                                                   DOCKET NUMBER

 DATE                                                                       SIGNATURE OF ATTORNEY OF RECORD
  01/28/2011                                                              /s/ Steven G. Ganim, Esq.
 FOR OFFICE USE ONLY

     RECEIPT #                   AMOUNT                                        APPLYING IFP                                       JUDGE                           MAG. JUDGE



                   Print                                 Save As...                            Export as FDF                         Retrieve FDF File                                Reset
                Case 1:11-cv-00240-CMA Document 1-4                                 Filed 01/28/11 USDC Colorado Page 2 of 2
JS 44 Reverse (Rev. 12/07)


                      INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

                                                                  Authority For Civil Cover Sheet
   The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use
of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint
filed. The attorney filing a case should complete the form as follows:
I.       (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use only
the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giving
both name and title.
         (b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the time
of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases,
the county of residence of the “defendant” is the location of the tract of land involved.)
         (c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section “(see attachment)”.
II.     Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an “X” in one
of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an “X” in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box
1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of the
different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III.    Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this section
for each principal party.
IV.     Nature of Suit. Place an “X” in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is sufficient
to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature of suit, select
the most definitive.
V.       Origin. Place an “X” in one of the seven boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition
for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this box
is checked, do not check (5) above.
Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge’s decision.
VI.    Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional statutes
unless diversity.          Example:               U.S. Civil Statute: 47 USC 553
                                                  Brief Description: Unauthorized reception of cable service
VII.     Requested in Complaint. Class Action. Place an “X” in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases if any. If there are related pending cases, insert the docket numbers
and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case 1:11-cv-00240-CMA Document 1-5   Filed 01/28/11 USDC Colorado Page 1 of 1

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:1468
posted:2/3/2011
language:English
pages:21