Case 3:21-cv-00448-DMS-KSC Document 1 Filed 03/12/21 PageID.1 Page 1 of 15
`FILED
`Mar 12 2021
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`CLERK, U.S. DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`DEPUTY
`s/ robertc
`BY
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`Karen L. Willis, J.D.
`1 220 West G Street, Suite E.
`San Diego, CA 92101
`2 TeleP.hone: (619) 206-5311
`Email: boringlegalwork@gmail.com
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`vs.
`YOUTUBE, L.L.C., a Delaware company;
`11 and DOES 1-10, inclusive.
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`Prose
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
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`HARLEM WEST MUSIC GROUP
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`Plaintiff,
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`Defendants.
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`Case No.
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`'21CV448
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`DMS
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`KSC
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`COMPLAINT FOR:
`( 1) Copyright Infringement
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`(2) Vicarious Copyright
`Infringement
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`(3) Violations of California's
`Unfair
`Competition Law
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`DEMAND FOR JURY TRIAL
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`COMPLAINT
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`Case No.
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`Case 3:21-cv-00448-DMS-KSC Document 1 Filed 03/12/21 PageID.2 Page 2 of 15
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`INTRODUCTION
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`This case involves the well-publicized results of one of the first cases brought
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`to trial under section 203 of the 197 6 Copyright Act. Plaintiff Harlem West Music
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`4 Group bring this complaint against Defendant Y ouTube, L.L.C., for damages.
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`5 Plaintiff alleges as follows:
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`1. In the case of Scorpio v. Willis (Southern District of California, Hon. Judge
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`7 Ted Moskowitz), on or about 2011, Victor Willis ("Willis") served notices of
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`terminations (the "Notices") regarding grants to Can't Stop Productions ("Can't
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`9 Stop") and Scorpio Music ("Scorpio") of his copyrights to numerous Village People
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`10 compositions for which he wrote the lyrics. On or about 2012, Can't Stop brought
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`11 an action seeking to have the notices declared invalid.
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`2. On or about 2013, the Notices were declared VALID. On or about 2014,
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`13 a Jury trial was held for Willis who sought upwards of 50% ownership in the
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`14 compositions. The results (pursuant to the jury verdict) were that Willis recaptured
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`15 33% ownership in 20 compositions including "In the Navy" and "Go West," and
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`16 50% ownership in 13 compositions including the biggest and most iconic hit
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`17 "Y.M.C.A."
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`3. On or about September 15, 2016, Willis served notices of terminations of
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`19 grants or implied grants of copyrights on Universal Music Group, Can't Stop
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`20 Productions/Music and Scorpio Music with respect to all Village People recordings
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`21 wherein Willis is the featured vocalists, and all original music Videos, including the
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`22 original iconic "Y.M.C.A." music video.
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`4. Moreover, pursuant to section 203 of the 1976 Copyright Act, the
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`24 aforementioned Notices (master recordings, and music videos) were all filed in the
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`25 U.S. Copyright Office with subsequent receipt of official Certificates of
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`26 Recordation.
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`COMPLAINT
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`Case No.
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`5. This time, none of the parties challenged Willis's Notices of Terminations
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`in a court of law. Therefore, Willis recaptured 100% of his contributions to the
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`3 copyrights (master recordings and music videos) on the effective date of termination
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`4 pursuant to the Notices.
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`6. The effective date of termination for all the Notices (grants or implied
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`6 grants of copyrights) was September 15, 2018.
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`7. Willis transferred all his rights in the recaptured copyrights to Harlem West
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`8 Music Group ("Harlem West") including the initial recaptured copyrights, the
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`9 master recordings, and music video rights as well.
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`8. Over several years, Harlem West has suffered and continued to suffer
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`irreparable harm, and financial losses as a direct consequence of YouTube's
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`12 deliberate and inexplicable failure to allow Harlem West to resume monetizing its
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`13 Village People music videos on its platform ( as an owner of the copyrights) after the
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`14 very co-owners of the copyrights filed bogus takedown orders; all of which were
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`15 removed or retracted by them.
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`9. Though there are presently no claims or takedown request on Harlem
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`17 West's Victor Willis Music Channel (and none would be valid under the
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`18 circumstances) YouTube continues to deny Harlem West's Victor Willis Music
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`19 Channel competing monetization of its Village People music videos. Instead,
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`20 YouTube only allows Harlem West's co-owners of the copyrights to monetize the
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`21 music videos therein stifling competitive use of the copyrights amongst the
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`22 copyright owners, facilitating and/or directly engaging in unfair competition.
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`10. When Plaintiff filed takedown requests for the removal of certain videos
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`24 uploaded without permission and which constitutes copyright infringement,
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`25 . Y ouTube refused to remove the videos.
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`11. YouTube's failure takedown the offending videos as requested, as well as
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`COMPLAINT
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`Case No.
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`18. The Court has supplemental jurisdiction over the third claim ( state
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`2 claim) for relief pursuant to 28 U.S.C. § 1367 because the claim arises out of the
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`3 same nucleus of the operative federal claim.
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`19.Venue is proper in the Southern District of California pursuant to 28
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`5 U.S.C. § 13919 (b) because Plaintiff reside and operate her business within the
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`6 Southern District of California.
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`FACTURAL ALLEGATIONS
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`20. On or about September 11, 2017, 2018, Plaintiff filed a counter-
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`takedown notice with Y ouTube related a Universal Music Group ("UMG)
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`takedown request of Plaintiffs videos. Plaintiff demanded that YouTube provide
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`11 her with contact information on the person or persons acting on behalf of UMG
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`12 requesting the takedown of her videos. Defendant YouTube refused to provide
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`13 Plaintiff with the requested information. However, had the requested contact
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`14 information been provided, Plaintiff could have made direct contact with UMG
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`15 and quickly had the issue resolved.
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`Plaintiff then put YouTube on notice that, since UMG was an owner music
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`17 video but not an owner of the compositions whatsoever but which Plaintiff owns,
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`18 she would file takedown notices of all UMG Village People music videos because
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`19 she would had not and will not issue UMG the required composition license
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`20 considering that UMG had filed takedown requests on her videos. This means that
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`21 UMG, at the most, could display the videos without sound (the music
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`22 compositions).
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`21. On or about November 2018, Plaintiff demanded that YouTube
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`24 takedown all UMG relevant Village People music videos for copyright
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`infringement as Plaintiff had not and would not grant UMG a license for use of the
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`COMPLAINT
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`Case No.
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`1 compositions at YouTube (especially "Y.M.C.A.") in conjunction with their partial
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`2 ownership in Village People music videos.
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`22. On or about November 2018, Y ouTube responded that it could not
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`4 takedown the UMG music videos because Y ouTube has a special relationship with
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`5 companies like UMG through Content ID. The same Content ID that YouTube
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`6 repeatedly denied Plaintiff of course. Plaintiff responded by reminding You Tube
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`that were it to fail to remove the videos or disable the sound, it would have waived
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`its protection under the safe harbour provision of the Digital Millennium
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`9 Copyright Act (DMCA), and Plaintiff would eventually sue.
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`23.YouTube also failed to act to take down numerous other, unrelated,
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`takedown requests of offending videos engaged in copyright infringement against
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`12 Plaintiff.
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`24. Victor Willis Music Channel is a well-established video music channel at
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`14 YouTube that has operated since 2013 with over 6.2 million views.
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`25. Y ouTube approved monetization for the channel in 2014. Upon
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`16 Monetization, Harlem West earned in excess of $700-$1,200 per month for
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`17 YouTube's placements of its ads.
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`26. In 2015, Victor Willis Music Channel started receiving false copyright
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`19 claims on its account. False or bogus claims to copyrights in efforts to
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`20 commandeer monetization of popular music videos is quite common at Y ouTube.
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`27. In Plaintiffs case, each time a bogus copyright claim was filed, Plaintiff
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`22 filed the required counter-takedown notification and the false claims were
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`23 withdrawn after the claimant discovered they'd filed a claim against one of the
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`24 actual owners of the copyright.
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`28. In fact, this issue is such a nuisance with major music copyright owners
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`COMPLAINT
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`that Y ouTube assigns Content ID numbers to publishers which helps to identify
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`instances of unauthorized copyright use, to track monetization and to add
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`3 monetization to a video utilizing a particular music copyright. Though Y ouTube
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`4 has assigned Content ID numbers to Plaintiffs co-owners of her copyrights,
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`5 Y ouTube have time and time again, refused Plaintiffs request to likewise be
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`6 assigned a Content ID.
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`29. On March 29, 2018, Plaintiff received a letter from Y ouTube stating that
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`it had determined that Victor Willis Music Channel is no longer eligible for
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`9 monetization. Since it appeared to be a computer-generated message, Plaintiff was
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`10 unable to receive a human reply regarding the matter, though she tried on
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`11 numerous occas10ns.
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`30. Accordingly, Plaintiff followed the instructions in the computer-
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`13 generated email and re-applied for monetization as the computer-generated
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`14 message suggested.
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`31. However, Plaintiff re-applied for monetization on at least four occasions
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`16 within the past two years to no avail. Each time Plaintiff received a computer-
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`17 generated message from YouTube indicating that "Your channel was not accepted
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`18 for monetization." The computer-generated message further states: "refused
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`19 content. Channel uses someone else's content without making changes that add
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`20 significant value. "
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`32. Actually, Victor Willis Music Channel only uses music, compositions,
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`22 and videos owned, or partially owned by Plaintiff. There are no existing claims by
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`23 anyone related to Victor Willis Music Channel. Moreover, all prior claims filed
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`24 were all released as far back as 2019. Yet Y ouTube has continued to deny Victor
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`25 Willis Music Channel monetization for the same videos it used to monetize prior to
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`26 March 29, 2018.
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`COMPLAINT
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`Case No.
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`3 3. On or about March 2019, Plaintiff discovered that Y ouTube had
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`2 conspired with Plaintiffs co-owners of the copyrights (Universal Music Group,
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`3 and Scorpio Music Group) to deny Plaintiff her right to exploit the music videos
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`4 pursuant to Section 203 of the 1976 Copyright Act., termination and recapture
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`5 prov1s1ons.
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`34. Moreover, on or about March 2018, defendant YouTube, without
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`7 knowledge nor permission from Plaintiff, allowed or aided Scorpio Music's access,
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`8 or hack into Victor Willis Music Channel in efforts to commandeer Plaintiffs
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`9 Y ouTube Channel Village People music videos and other music videos for
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`10 purposes of control and monetization. All in efforts to deny and/or frustrate
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`11 Plaintiffs right to compete with her co-owners right to exploit the copyrights, who
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`12 no longer had exclusive right to do so.
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`35. Plaintiff inadvertently discovered the hack on or about June of 2019 after
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`14 noticing that Victor Willis Music Channel video's ( especially the iconic hit
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`15 "Y.M.C.A." written by Plaintiffs husband, Victor Willis) appeared not as
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`16 belonging to Victor Willis Music Channel, but Scorpio Music's Village People
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`17 Music Channel, though it was actually Plaintiffs uploaded music video. The site
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`18 had been hacked in-to or commandeered by Scorpio Music, Plaintiffs co-owner of
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`the copyright who once own 100% of the copyright prior to Plaintiff terminating
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`20 and recapturing upwards of 50% ownership from Scorpio Music.
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`36. On or about March 2019, Plaintiff made contact with her co-owner of
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`the copyrights (Scorpio Music) notifying them that she had discovered their
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`takeover of Victor Willis Music Channel. Plaintiff then demanded that Scorpio
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`24 Music immediately get out of Victor Willis Music Channel or else. Scorpio Music
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`25 acknowledged their access to Plaintiffs music channel and immediately assigned
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`26 one of its techs to extricate Scorpio Music from the Plaintiffs music channel. This
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`COMPLAINT
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`1 process took about two weeks to complete before all music videos at Victor Willis
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`2 Music Channel were returned to its rightful header.
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`3 7. On information and belief, though Y ouTube knew Plaintiff to be one
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`4 of owners of the music videos and compositions just like Scorpio Music and
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`5 Universal had partial ownership, Y ouTube aided or facilitated Scorpio Music's
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`6 hacking or access into Victor Willis Music Channel without the knowledge nor
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`7 permission of Plaintiff.
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`38. All of YouTube's actions including the removal of Victor Willis Music
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`9 Channel monetization; the denial of Plaintiffs numerous requests for a Content ID
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`10 number, the aiding of hacking, or allowing Scorpio Music direct access to Victor
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`11 Willis Music Channel without Plaintiffs knowledge or permission; allowing the
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`12 filing of bogus copyright claims by Believe Music (on behalf of Scorpio Music),
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`13 Universal Music (all since retracted or released) were designed to stifle Plaintiffs
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`14 right to compete with her co-owners at Y ouTube to exploit her recaptured share of
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`15 ownership of the compositions and music videos at Y ouTube. All constituting
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`16 unfair competition in violation of California's Unfair Competition Law; and
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`17 conspiracy to engage in unfair competition.
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`39. The unfair competition by Y ouTube has resulted in the loss of an
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`19 amount exceeding $100,000 in lost revenue or significantly more since March
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`20 2018.
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`FIRST CLAIM FOR RELEIF
`Copyright Infringement
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`40. Plaintiff reincorporate by reference paragraphs 1-39 as if set forth
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`4 herein.
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`41. Plaintiff is an exclusive copyright owner of the works identified in
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`7 paragraphs 1-38. These works have been reproduced, distributed, displayed, and
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`8 publicly performed on YouTube without Plaintiffs authorization.
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`42. By engaging in acts causing these infringing works to be reproduced,
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`11 distributed, displayed, and publicly performed on the internet, Defendant is
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`12 violating Plaintiffs exclusive rights in violation of 17 U.S.C. § 106, including
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`sections 106(1), 106(3), 106(5), 106(6), and 17 U.S.C. § 501.
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`43. By refusing to takedown the offending videos as requested by Plaintiff,
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`16 Defendant waived its safe harbor under the provisions of the Digital Millennium
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`Copyright Act (DMCA).
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`44. Defendant's infringements have been willful, intentional, purposeful,
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`20 and in disregard of and indifferent to the Plaintiffs rights.
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`45. As a direct and proximate result of Defendant's infringement of
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`23 Plaintiffs exclusive copyrights, Plaintiff is entitled to the maximum statutory
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`24 damages pursuant to 17 U.S.C. § 504( c ). Alternatively, at the election of Plaintiff
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`COMPLAINT
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`Case No.
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`and pursuant to 17 U.S.C. § 504(b), Plaintiff is entitled to Defendants' profits from
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`the acts of infringement, to be proven at trial.
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`46. Plaintiff is entitled to her costs, including reasonable attorneys' fees (if
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`incurred), pursuant to 17 U.S.C. § 505.
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`47. Defendant's conduct is causing and, unless enjoined by this Court, will
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`continue to cause Plaintiff great and irreparable injury that cannot fully be
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`9 compensated. Pursuant to 17 U.S.C. § 502, Plaintiff is entitled to a permanent
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`injunction requiring Defendant to employ reasonable methodologies to prevent or
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`limit infringement of Plaintiff copyrights.
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`SECOND CLAIM FOR RELEIF
`Vicarious Copyright Infringement
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`48.Plaintiffs reincorporate by reference paragraphs 1-47 as if set forth
`herein.
`49. The Y ouTube users identified in this complaint, and in general, have
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`infringed and are infringing Plaintiffs rights in her registered copyrighted musical
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`l 9 and/or audiovisual works by, inter alia, uploading and downloading infringing
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`20 copies of Plaintiffs copyrighted works onto and from YouTube's website and
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`publicly performing, displaying, distributing, and reproducing, or purporting to
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`23 authorize the public performance, display, distribution, or reproduction of such
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`24 copyrighted works or infringing videos, all without authorization. Certain
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`YouTube users are therefore directly infringing Plaintiffs exclusive rights of
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`COMPLAINT
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`reproduction, distribution, public performance, and public display under U.S.C. §§
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`2 106(1), (3), (4), and (5).
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`SO.Defendant is vicariously liable for the infringing acts of YouTube users.
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`5 Defendant' have both the right and the ability to supervise YouTube users'
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`infringing conduct and to prevent YouTube users from infringing Plaintiff's
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`copyrighted works but failed to do so. Y ouTube significantly and directly benefit
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`51. Defendant's infringement is willful, intentional, purposeful, and in
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`disregard of an indifferent to Plaintiff's rights.
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`52. As a direct and proximate result of Defendant's infringement of
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`14 Plaintiff's exclusive copyrights, Plaintiff is entitled to the maximum statutory
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`damages pursuant to 17 U.S.C. § 504(c). Alternatively, at the election of Plaintiff
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`17 pursuant to 17 U.S.C. § 504(b ), Plaintiff shall be entitled to Defendant's profits
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`18 from the acts of infringement, to be proven at trial.
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`53. Plaintiff is entitled to costs, including reasonable attorneys' fees (if
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`incurred) pursuant to 17 U.S.C. § 505.
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`54. Defendants' conduct is causing and, unless enjoined by this Court, will
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`continue to cause Plaintiff great and irreparable injury that cannot fully be
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`25 compensated. Pursuant to 17 U.S.C. § 502, Plaintiff is entitled to a permanent
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`COMPLAINT
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`Case No.
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`injunction requiring Defendants to employ reasonable methodologies to prevent or
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`limit infringement of Plaintiffs copyrights
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`THIRD CLAIM FOR RELIEF
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`(Violations of California's Unfair Competition Law)
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`California Business & Professions Code § 17200
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`55. Plaintiff repeat and re-allege all allegations contained in paragraphs 1
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`through 54 inclusive, as though fully set forth herein.
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`56. By providing substantial assistance to third parties, namely Universal
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`Music Group, and Scorpio Music Group to make false claims of copyright
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`infringement against Victor Willis Music Channel only to later have them withdraw
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`or release such claims, made it appear that Plaintiff music channel was somehow
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`uploading music videos that she has no right to exploit. But YouTube knew the
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`truth. YouTube, Scorpio Music, and Universal Music all knew Plaintiff had
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`recaptured ownership of the music videos copyrights, master recordings, and
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`compositions, thus entitled, as a co-owner, to compete with Scorpio and UMG to
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`exploit the compositions, music videos and master recordings, yet Y ouTube sought
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`to aid the parties in stifling Plaintiffs competition therein engaging in unfair
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`competition against plaintiff in violation of California's Unfair Competition Act.
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`57. Y ouTube engaged in direct unfair business tactics when it refused to
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`grant Plaintiff a Content ID number as it did for her co-owners of the copyrights
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`when it knew Plaintiff to be a music publisher and co-owner of the copyrights to
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`songs related to existing Content IDs in a number of iconic songs meeting or
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`exceeding YouTube's minimum requirement for the issuance of a Content ID
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`number.
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`5 8. Y ouTube informed Plaintiff that she must manually process
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`COMPLAINT
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`Case 3:21-cv-00448-DMS-KSC Document 1 Filed 03/12/21 PageID.13 Page 13 of 15
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`takedown requests of unauthorized use of the copyrights causing undue burden,
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`2 while issuing to Plaintiff's co-owners of the copyrights (Scorpio Music and
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`3 Universal Music) Content IDs enabling them to electronically track unauthorized
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`4 use of the copyrights.
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`59. YouTube's denial of Plaintiff a Content ID substantially interferes with
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`6 Plaintiffs right to exploit her copyrights. The denial of Plaintiff, a Content ID by
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`7 Y ouTube stifles competition between the co-owners in the exploitation of the
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`8 copyrights at Y ouTube. Moreover, Y ouTube' s denial of Plaintiff a Content ID
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`9 places her in a unfair disadvantage to protect her copyrights at Y ouTube.
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`60. YouTube engaged in direct unfair business tactics when it, without
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`reasonable cause took away Plaintiff's monetizing privileges and refused re-instate
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`12 Plaintiffs monetizing privileges.
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`61. All constituting unfair competition under Section 17200.
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`62. Accordingly, Plaintiff seeks any, and all available damages awards,
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`including restitution.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff pray for the following relief:
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`a. An award to Plaintiff for damages, including but not limited to infringement
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`damages, compensatory, statutory, and punitive damages, as permitted by
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`law in an amount to be proven at trial but no less than $100,000;
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`b. An award of punitive damages in an amount to be determined;
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`c. An award of reasonable attorneys' fees (if incurred);
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`d. For any such other relief as the Court may deem just and proper.
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`COMPLAINT
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`Case 3:21-cv-00448-DMS-KSC Document 1 Filed 03/12/21 PageID.14 Page 14 of 15
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`DEMAND FOR A JURY TRIAL
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`In accordance with Fed. R. Civ. P. 38, Plaintiffs hereby demand a trial by
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`jury on all issues so triable.
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`DATED: March 11, 2021
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`Respectfully submitted,
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`~WILLIS
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`COMPLAINT
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`Case 3:21-cv-00448-DMS-KSC Document 1 Filed 03/12/21 PageID.15 Page 15 of 15
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`DUPLICATE
`Court Name: USDC California Southern
`DMsion: 3
`Receipt NlJ\ber: CASl28260
`Cash1er ID: akukura
`Transact101 Date: 03/12/2021
`Payer Name: Karen Willis
`CIVIL FILI~ FEE- NON-PRISONER
`For: Karen Willis
`Case/Party: D-CAS-3-21-CV-000448-001
`Amount :
`$402 . 00
`---------------------
`QfCK
`Check/Money Order NLVn: 5340
`Amt Tendered: $402.00 - - -
`1402.00
`Total Due:
`Total Tendered: 402.00
`Change hat:
`0.00
`
`There will be a fee of $53.00
`charged for any returned check.
`
`,· V:
`
`..
`•,
`
`