WA State AG Complaint - 122

The Complainant characterizes our attempts to settle our copyright infringement claims as
extortion. However, our communications with them do not in any way constitute wrongful
threats within the meaning of extortion statutes. On the contrary, demand for payment in
satisfaction of a legal claim is not wrongful conduct.
We understand that copyright law can be confusing; however, the campaign to file complaints
against us is misguided and misdirected. We encourage review of the license compliance
information provided on our web site at: http://company.gettyimages.com/license-compliance/.
Getty Images has acted appropriately and in good faith, and we are well within our legal rights
to seek damages for unauthorized use of our images.
Should you require any additional information, please do not hesitate to contact us. We remain
hopeful of reaching an amicable resolution to this matter.
Regards,
Getty Images Copyright Compliance
428610
Csup Closing Unadjusted (C-UNJ) To: steve@PiranaMedia.com
Bob Ferguson
ATTORNEY GENERAL OF WASHINGTON
Consumer Protection Division
800 Fifth Avenue, Suite 2000 Seattle, WA 98104 (206) 464-6686
April 18, 2013
Steven Neal Goodson
231 Oligi Circle
Loudon, TN 37774
RE: Getty Images
File #: 428610
Dear Steven Neal Goodson:
Our office has received a response from Getty Images declining to adjust your complaint for the
reasons outlined in the response.
We realize you may disagree with Getty Imagess position. However, our office does not have
the legal authority to force the parties to resolve their dispute. We regret that we are unable to
provide further assistance to you in this situation.
We do not have the legal authority to act as an attorney for private individuals, nor may we act
as a judge or arbitrator in individual disputes. If you would like to pursue the matter, you may
wish to contact Small Claims Court in your County. General information about Small Claims
Court, including contact information, can be found by visiting the following website:
https://www.courts.wa.gov/newsinfo/resources/ - fa=newsinfo_jury.scc&altMenu=smal
For referrals to attorneys in your area, you may call one of the following numbers:
Clark County: 360-695-0599
King County: 206-623-2551 or 211
Lewis County: 360-748-0430
Pierce County: 253-383-3432
Snohomish County: 425-388-3018
Spokane County: http://www.spokanebar.org/ (Telephone number not available)
Thurston County: http://thurstoncountybar.com/ (Telephone number not available)
If you cannot afford an attorney, and have a non-criminal legal problem, you may qualify for
assistance from the NW Justice Projects CLEAR Coordinated Legal Advice, which can be
reached Toll Free at 1-888-201-1014 or online at the following website:
WencilaF 4/18/2013
428610
http://www.nwjustice.org/about_njp/clear.html. In addition, if you are 60 or over, you may call
CLEAR SENIOR at 1-888-387-7111 regardless of income.
You may also wish to contact the Washington State Dispute Resolution Center nearest you to
see if they can assist in mediating your dispute. You can obtain additional information about the
Dispute Resolution Centers at these websites:
<http://www.courts.wa.gov/court_dir/ - fa=court_dir.dispute> <http://www.resolutionwa.org/>.
Please be aware that the Dispute Resolution Centers do not provide attorney referrals or legal
advice.
We appreciate your bringing this matter to our attention. Your complaint will remain a part of
our public record of this firms business practices.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
Enclosure
From: Copyright Compliance [mailto:Copyright.Compliance@gettyimages.com]
Sent: Thursday, April 18, 2013 1:39 PM
To: ATG MI Seattle CRC
Subject: RE: 428610 : A notice from the Washington State Attorney General'sOffice
Re: Steven Neal Goodson (Pirana Media) (the Complainant)
Your File # 428610
Our Reference # 1299249
We are in receipt of the complaint regarding the referenced matter that you forwarded to us
recently.
By way of introduction, Getty Images is a leading creator and distributor of digital content,
including still and moving images. We license thousands of images each day on our website,
www.gettyimages.com. Customers such as graphic designers, advertising agencies, and
publishers license our imagery for a variety of purposes, including but not limited to print
428610
advertising, billboards, newspaper and magazine articles, brochures and websites. Our license
information is clearly available from each page of our website, and we do not permit the use of
our imagery without a license.
Notwithstanding the license requirement, like other digital media companies, Getty Images does
fall victim to individuals pirating its intellectual property. To combat this, Getty Images uses
both employees and digital image recognition software to locate entities that have used Getty
Images imagery without paying a license fee. We recently identified the Complainant as
having used unlicensed imagery from our collections.
We sent the Complainant a letter with notification that we had found use of our imagery on their
website; that we had been unable to locate a license for such use; that use of the imagery
without a license constitutes copyright infringement; and that the Complainant must either: (i)
provide evidence that a license was issued, or (ii) pay a fee for use of the imagery. We included
an internal case reference number and provided proof of use, showing our image and associated
data, along with a screenshot of the image in use on the Complainants website. We also asked
the Complainant to contact us immediately if they believe they received our letter in error. The
unauthorized use fee is in line with what we would typically charge for a license under these
circumstances.
Even if the Complainant has removed our imagery from their website, removal alone does not
resolve this matter. Our imagery is protected by copyright. Getty Images either owns or is the
exclusive licensor for the image(s) at issue. Copyright law holds responsible anyone who copies
or publicly displays an image without authorization of the copyright holder. Copyright
infringement is based on strict liability, meaning that the act itself establishes liability and no
intent is required. Thus far the Complainant has failed to produce a valid license or raise any
valid defense to copyright infringement. The Complainants use of our imagery without a
license constitutes copyright infringement, for which we are entitled to seek damages.
Regards,
428610
428610
Rsup Closing No Adjustment (R-UNJ) To: copyright.compliance@gettyimages.com
Bob Ferguson
April 18, 2013
Getty Images
605 5th Ave S Ste 400
Seattle, WA 98104
RE: Steven Neal Goodson
File #: 428610
Dear Getty Images:
Thank you for your recent communication in response to the complaint from Steven Neal
Goodson. Steven Neal Goodson has been informed of your response and that we have closed
this complaint with regard to our informal mediation service. We have notified the complainant
of the availability of private legal remedies in the event the complainant wishes to pursue this
matter further.
Although this was not resolved to the parties mutual satisfaction, we appreciate your response.
This complaint will remain in our public records.
Please be advised even though we are closing this complaint, we may open a formal
investigation or take future action pursuant to the Consumer Protection Act at any time if the
facts and circumstances indicate that further action is warranted.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
WencilaF 4/18/2013
428610
Pirana Media
February 9, 2013
Copyright Compliance Team Certified Mail
Getty Images Inc. 7006 0100 0006 1987 5497
PO Box 84434
Seattle, WA 98124-5734
RE: Unauthorized Use Notification
Case Number:1299249 | Access Code: 0Y0emDG4 | URL: http://lc.gettyimages.com
To Whom It May Concern:
I am in receipt of your correspondence dated January 29, 2013 stating that my company website
(PiranaMedia.com) has made use of two small images which your company asserts to holding the legally
copyrighted management and licensing rights. You further infer that my company may have used these images
without a valid license from Getty Images, Inc. (Getty). Your correspondence goes on to say that I now owe
Getty Images, Inc. $2,130.00 for the unauthorized use of these two images.
Upon receipt of your correspondence, I immediately removed these two images from my website as a good faith
gesture, all without having any proof that your firm actually has any legally binding copyright or management
agreement with the original photographerss of these images. I would never knowingly use copyrighted material
and most definitely thought these were commonly available to the general public in the public domain. I can
assure you that if the alleged copyright infringement did take place, that it was entirely innocent, inadvertent and
unwilling on my part.
As a graphic artist, photographer and web designer, I have an extensive library of fonts, clipart, vector images,
templates, banners, photography and image clips that date back ten years or more and there is no way for me at
this time to realistically identify where I obtained the two images in question. I might note that the two images
had no watermark, digimarc, or exif data embedding into the image file which identified it as (i) a Getty image,
(ii) a copyrighted image, or (iii) an image with licencing requirements by a specific photographer.
I went to the Getty website (GettyImages.com) to view the two images referenced in this claim and found that the
images (measuring 1.625" x 1.0625") are readily available to any person using a screen-grab. There is no
watermark or any other type of protection until one rolls their mouse over the image when a larger photos pops
up with a watermark. Unfortunately, Getty has not done a very good job at protecting the images they represent
to manage.
I was perplexed as to the valuation that you have placed on the two small images which are approximately 180px
by 150px shown at a rate of $1,065.00 each, when your website catalog shows the images are valued at $415.00
each (screen shot attached). Additionally, it seems odd that most of your images are valued between $15 and
$50, but somehow the two pertaining to my situation have extreme value far exceeding the norm. Its as though
you have increased the price for these two simple images now that an alleged copyright issue has come to light.
231 Oligi Circle p Loudon, Tennessee 37774 p (865) 408-7475
www.PiranaMedia.com
Copyright Compliance Team
Getty Images Inc.
February 9, 2013
Page 2
To further evaluate your claim in regards to valuation, I will need the following information.
A. An exact detailed formula as to how you determined the $1,065.00 fee for each image.
B. A detailed sales history with actual prices paid and with contact information of all customers that
have purchased these two images since January 29, 2008 (60 months).
Lets be honest and admit that the fair market price for these type images is less than $10.00 each. I might add
that if Getty can ask and actually get a market price of $415.00 each (as now advertised on their website) for
these two 180px by 150px images, of this subject matter and quality, I have thousands of images I would like to
license with Getty and receive a 50% split for each transaction. Consequently, I have attached an image sheet
containing six (6) photos similar in content and size as those that are in question. They can also be viewed at the
following URL:
http://www.piranamedia.com/KeyboardImages/
For the record, these six images took me approximately ten (10) minutes to photograph, Photoshop and print.
Had I spent some additional time in Photoshop, they would have looked better. These images were done at my
desk using a Nikon D7000 camera and a 18-200mm lens, with no special lighting, backdrops, or props. These
images are so simplistic that they could have been taken with an average point-n-shoot camera which would have
achieved the same results.
Prior to this event, I have had no prior affiliation or business dealings with Getty nor have I ever been to their
website. Because of this correspondence I have been forced to spend numerous hours of carful investigation
regarding Gettys business practices and past legal claims which are similar to this situation, specifically (i) the
2008 court case titled Getty vs. Advernet, (ii) the class action lawsuit in Israel, and (iii) the fact that Getty was
"selling" images on their site that were in the public domain and they held no copyright nor management
agreement. Therefor, I must demand strict proof of your claim. Before any more discussion can take place you
will need to forward the following documentation to my attention for review.
1. Copyright registration with the United States Copyright Office and the chain of title for the image.
2. Signed Licensing and/or Management Agreement between Getty and each of the photographers.
3. Evidence which determines that the copyright is for the individual images or a group of images.
4. The exact day or period of time that Getty asserts the alleged infringement took place.
5. Contact information for both photographers, i.e., mailing address and telephone number.
6. Website or other web presence information for both photographers.
7. The specific file format in which your images are distributed for purchase (example - png / jpg / gif).
In closing, I would like to thank you for notifying me of this alleged infringement and I look forward to a fair and
amicable resolution to your claim.
Regards,
Steve N. Goodson
/3 enclosures
PiranaMedia
231 Oligi Circle, Loudon, TN 37774
(865) 408-7475
Calculator Keyboard 1
180px X 150px
180px X 150px
(Warm Tone)
180px X 150px
(Emphasis on Number Two)
180px X 150px
Telephone Keypad 1
(Left Tilt)
150px X 180px
(12 keys)
150px X 180px
[8d] [8d]
[8d]
[8d]
[5a]
[5a]
[8d]
[8d]
[5a]
[5a]
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
Name Contact Phone Toll Free Email
Getty Images
Seattle, WA 98104
(206) 925-6753 copyright.complian
ce@gettyimages.co
m
428768
4/4/2013
Respondent(s)
Complaint
Vancouver - Consumer Protection Division
Date Added Activity Type Activity
4/5/2013 Email to Respondent R 1st Letter to Respondent To:
copyright.compliance@gettyimages.com
4/5/2013 Form Letter to Complainant C 1st Letter to Complainant
4/26/2013 Email to Respondent R 2nd Letter to Respondent To:
4/26/2013 Form Letter to Complainant C 2nd Letter to Complainant
541920-Photographic Services
Assignee Egeler, Connie C
$0.00
$0.00
$0.00
Code Practice
316 Billing Issues
647 Duty to comply with laws & codes
Practice(s)
Closed
Referral(s)
Name
Contact
Phone Contact Phone Email
428768
Catalyst
Complaint Cover Page
Name Phone Day Phone Evening Email
David Royer
3472 Cumberland Ln
Frisco, TX 75033
1 of 2 428768
4/29/2013 Email from Respondent unadj
4/29/2013 Form Letter to Complainant Csup Closing Unadjusted (C-UNJ)
4/29/2013 Email to Respondent Rsup Closing No Adjustment (R-UNJ) To:
4/29/2013 Resolution-UNADJUSTED
2 of 2 428768
R 1st Letter to Respondent To: copyright.compliance@gettyimages.com
Bob Ferguson
1220 Main Street, Suite 549 Vancouver, WA 98660 (360) 759-2152
April 5, 2013
Getty Images
Seattle, WA 98104
RE: David Royer
File #: 428768
Dear Getty Images:
Our office has received the enclosed complaint from David Royer regarding your business.
We forward consumer complaints to businesses in order to afford the business an opportunity to
respond in writing. Many businesses have found this process to be beneficial. Complaints and
responses received in our office are a matter of public record.
Our office informally mediates complaints as a service to consumers and businesses. We may
not act as an advocate or private attorney for either party. However, complaints may indicate a
pattern of unfair or deceptive trade practices warranting further attention by our office. Failure
to respond to this complaint will be reflected in our public records, which are available to the
public under the Public Records Act.
Our office requests you reply in writing within 21 business days so that we may determine how
to proceed in this matter. Please address your response to me and include our file number
428768.
Thank you for your attention to this matter.
CONNIE C. EGELER
Complaint Analyst
(360) 759-2152
Fax: (360) 759-2159
vancrc@atg.wa.gov
Enclosure
ConnieE 4/5/2013
428768
Bob Ferguson
1220 Main Street, Suite 549? Vancouver, WA 98660? (360) 759-2152
April 5, 2013
David Royer
3472 Cumberland Ln
Frisco, TX 75033
RE: Getty Images
File #: 428768
Dear David Royer:
The complaint you submitted to our office has been assigned to me. I have provided a copy of
your complaint to Getty Images and requested a response within 21 business days. I will notify
you when a response is received regarding your complaint.
Our informal mediation service takes approximately 6-8 weeks. Your patience during this
process is appreciated.
Our office brings lawsuits in the name of the State of Washington, rather than on behalf of
private individuals. If a business does not respond or declines to adjust your complaint, this
office cannot require it to do so. The Consumer Protection Act does not give us authority to act
as your private attorney.
Our office obtains valuable information from individual consumer complaints. Your complaint
will become part of our public record of business practices. We maintain complaint files of
business practices that may be useful if enforcement action on behalf of the State of Washington
is warranted in the future.
If a response is not received or if your complaint is not resolved, we will inform you of
alternatives if you wish to pursue this matter further. If you need to contact me, please have
your complaint number available for reference.
Thank you for contacting our office.
CONNIE C. EGELER
Complaint Analyst
(360) 759-2152
Fax: (360) 759-2159
ConnieE 4/5/2013
428768
vancrc@atg.wa.gov
428768
R 2nd Letter to Respondent To: copyright.compliance@gettyimages.com
Bob Ferguson
April 26, 2013
Getty Images
Seattle, WA 98104
RE: David Royer
File #: 428768
Dear Getty Images:
Recently our office forwarded a copy of the complaint filed by David Royer regarding your
business and requested your position in writing on this matter. To date, we have not yet received
your written response.
Most of the businesses that participate in our informal mediation process find it to be beneficial.
Responding to consumer complaints provides you with an opportunity to respond to the
complaint and have your position on this matter considered and added to the public record. In
addition, responding to the consumers complaint allows you an opportunity to offer a
resolution to the complaint. Therefore, we are again requesting that you respond to and provide
us with your position on the complaint.
Our office acts as a neutral party in our informal mediation and cannot represent or provide
legal advice to either party. However, we maintain a record of adjusted and unadjusted
complaints that is available to the public under the Public Records Act. In addition, where our
office finds evidence of unfair or deceptive business practices, we may bring formal legal action
to stop those practices under Washington States Consumer Protection Act.
Please address your written response to me including the file number 428768 within the next
seven business days. You may respond by email, fax, or U.S. mail.
CONNIE C. EGELER
Complaint Analyst
(360) 759-2152
ConnieE 4/26/2013
428768
Fax: (360) 759-2159
vancrc@atg.wa.gov
Enclosure
428768
Bob Ferguson
April 26, 2013
David Royer
3472 Cumberland Ln
Frisco, TX 75033
RE: Getty Images
File #: 428768
Dear David Royer:
Our office has recently forwarded a second copy of your complaint to Getty Images requesting a
response to your complaint.
We have requested a response to your complaint within seven business days. If a response is not
received within that time, we will make a final attempt to contact the business for its response.
If we do not receive a response from the business, we will contact you again with possible
alternatives that may be available to you.
If you have any questions you may contact me directly at (360) 759-2152. Thank you for
contacting our office.
CONNIE C. EGELER
Complaint Analyst
(360) 759-2152
Fax: (360) 759-2159
vancrc@atg.wa.gov
ConnieE 4/26/2013
428768
Sent: Monday, April 29, 2013 11:09 AM
To: ATG MI Vancouver CRC
Re: Royer, David (DLCA Enterprises, LLC) (the Complainant)
Your File # 428768
recently.
data, along with a screenshot of the image in use on the Complainants website. The
circumstances.
While we appreciate that the Complainant may have already removed our imagery from their
website, removal alone does not resolve this matter. Our imagery is protected by copyright.
Getty Images either owns or is the exclusive licensor for the image(s) at issue. Copyright law
holds responsible anyone who copies or publicly displays an image without authorization of the
copyright holder. Copyright infringement is based on strict liability, meaning that the act itself
establishes liability and no intent is required. Thus far the Complainant has failed to produce a
valid license or raise any valid defense to copyright infringement. The Complainants use of
our imagery without a license constitutes copyright infringement, for which we are entitled to
seek damages.
ConnieE 4/29/2013
428768
As noted above, Getty Images has acted appropriately and in good faith, and we are well within
our legal rights to seek damages for unauthorized use of our images.
Regards,
Getty Images - Copyright Compliance
PLEASE NOTE OUR NEW ADDRESS:
605 Fifth Avenue South, Suite 400
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
Copyright.compliance@gettyimages.com
www.gettyimages.com
This message may contain privileged or confidential information and is intended only for the
individual named. If you are not the named addressee or an employee or agent responsible for
delivering this message to the intended recipient, you should not disseminate, distribute, or copy
this email or any attachments hereto. Please notify the sender immediately by email if you
have received this email by mistake and delete this email and any attachments from your
system without copying or disclosing the contents. Email transmission cannot be guaranteed to
be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late
or incomplete, or contain viruses. The sender therefore does not accept liability for any errors
or omissions in the contents of this message, which arise as a result of email transmission. If
verification is required, please request a hard-copy version.
Getty Images, Inc., 605 Fifth Ave. S., Ste. 400, Seattle, WA 98104, USA,
www.gettyimages.com
428768
Bob Ferguson
April 29, 2013
David Royer
3472 Cumberland Ln
Frisco, TX 75033
RE: Getty Images
File #: 428768
Dear David Royer:
King County: 206-623-2551 or 211
ConnieE 4/29/2013
428768
advice.
CONNIE C. EGELER
Complaint Analyst
(360) 759-2152
Fax: (360) 759-2159
vancrc@atg.wa.gov
Enclosure
To: ATG MI Vancouver CRC
Re: Royer, David (DLCA Enterprises, LLC) (the Complainant)
Your File # 428768
recently.
428768
circumstances.
While we appreciate that the Complainant may have already removed our imagery from their
website, removal alone does not resolve this matter. Our imagery is protected by copyright.
Getty Images either owns or is the exclusive licensor for the image(s) at issue. Copyright law
holds responsible anyone who copies or publicly displays an image without authorization of the
copyright holder. Copyright infringement is based on strict liability, meaning that the act itself
establishes liability and no intent is required. Thus far the Complainant has failed to produce a
valid license or raise any valid defense to copyright infringement. The Complainants use of
our imagery without a license constitutes copyright infringement, for which we are entitled to
seek damages.
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
428768
www.gettyimages.com
www.gettyimages.com
428768
Bob Ferguson
April 29, 2013
Getty Images
Seattle, WA 98104
RE: David Royer
File #: 428768
Dear Getty Images:
Thank you for your recent communication in response to the complaint from David Royer.
David Royer has been informed of your response and that we have closed this complaint with
regard to our informal mediation service. We have notified the complainant of the availability of
private legal remedies in the event the complainant wishes to pursue this matter further.
CONNIE C. EGELER
Complaint Analyst
(360) 759-2152
Fax: (360) 759-2159
vancrc@atg.wa.gov
ConnieE 4/29/2013
428768
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
McCormick Business Law
617 Lee Street
Seattle, WA 98109
Getty Images
Seattle, WA 98104
(206) 925-6753 copyright.complianc
e@gettyimages.com
428968
4/9/2013
Respondent(s)
Complaint
Seattle - Consumer Protection Division
561440-Collection Agencies
Assignee Wu, Andrew F
$0.00
$1,065.00
$0.00
Code Practice
404 Collection Practices
640 Fees
Practice(s)
Closed
Referral(s)
Name
Contact
428968
Catalyst
Marc Joseph Yland
2500 Rte 347 Bldg 24C
Stony Brook, NY 11790
(631) 941-0187 office@yland.com
1 of 2 428968
4/9/2013 Intake Notes c listed himself as the "R". From the summary, I
set up Mccormick Business Law as the
Respondent. Per the attachment I listed Getty
Images as a respondent. Two R's currently
assigned: Mccormick and Getty
4/9/2013 Intake Notes after SH reviewed and assigned to AW, I am
adding:
C lists McCormick, but that R may be
McCormack Intellectual Property Law. Leaving
intake note for Wu to take from here.
4/15/2013 Email to Complainant C 1st Letter to Complainant To:
office@yland.com
4/15/2013 Form Letter to Business R 1st Letter to Respondent
5/8/2013 Email from Respondent Response from Getty Images
5/8/2013 Email to Complainant C Response from one Respondent To:
office@yland.com
5/10/2013 Email from Respondent Response from McCormick Business Law
Document 428968B
5/10/2013 Email to Complainant Csup Closing Unadjusted (C-UNJ) To:
office@yland.com
5/10/2013 Form Letter to Business Rsup Closing Neutral (R-NEU)
2 of 2 428968
Description
I have been contacted by a law firm called McCormick Business Law, 617 Lee Street Seattle WA 98109.
They have put us in collections for non payment on a Getty Images copyright infringement. We have paid it
due to continued harassment. I am stoping payment on the credit card today.
Complaint Description
Catalyst Report
C 1st Letter to Complainant To: office@yland.com
Bob Ferguson
April 15, 2013
Marc Joseph Yland
2500 Rte 347 Bldg 24C
RE: McCormick Business Law and Getty Images
File #: 428968
Dear Marc Joseph Yland:
your complaint to McCormick Business Law and Getty Images and requested a response within
21 business days. I will notify you when a response is received regarding your complaint.
ANDREW F. WU
Program Specialist 2
AndrewW2 4/15/2013
428968
(206) 389-2102
Fax: (206) 389-2801
seacrc@atg.wa.gov
428968
Bob Ferguson
April 15, 2013
Getty Images
Seattle, WA 98104
RE: Marc Joseph Yland
File #: 428968
Dear Getty Images:
Our office has received the enclosed complaint from Marc Joseph Yland regarding your
business.
428968.
ANDREW F. WU
(206) 389-2102
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
AndrewW2 4/15/2013
428968
COMPLAINT SUMMARY
Consumer Information
Name:
Marc Joseph Yland
Address:
2500 Rte 347 Bldg 24C
Day Phone:
(631) 941-0187
Evening Phone:
E-mail Address:
office@yland.com
Age Group (optional):
50-59
Do you want the Attorney General's Office to send this business a copy of your complaint -
Yes
Names and addresses of any other complainants involved:
Business Information
Name of business that I am complaining about:
Address:
617 Lee Street
Seattle, WA 98109
Phone:
Toll-Free:
Fax:
E-mail:
Name of owner or manager (if known):
428968
Marc J Yland
Names and addresses of any other businesses involved in your complaint:
Getty Images
Seattle, WA 98104
Item or service purchased:
alleged copyright infringement
Cost of item or service:
1065.00
Did you sign a contract -
No
Date of transaction:
40/08/2013
Salesperson's name:
Was an advertisement involved -
No
Date and source of advertisement:
About Your Complaint
Have you complained to the business -
No
If YES, to whom (include position) -
What response did you receive -
If you have not contacted the business, explain why:
Have you filed a complaint about this business with the Attorney General's Office before -
No
If yes, list the file number assigned to that complaint:
Have you contacted a private attorney -
No
If YES, identify the name and address of the attorney:
Is there a court or other legal proceeding pending -
428968
No
If YES, please explain:
Explain your complaint in detail:
I have been contacted by a law firm called McCormick Business Law, 617 Lee Street Seattle
WA 98109. They have put us in collections for non payment on a Getty Images copyright
infringement. We have paid it due to continued harassment. I am stoping payment on the credit
card today.
What do you think the business should do to resolve your complaint - (circle one)
RFD
Explain if you have circled 'Other':
SIGNATURE
I understand that by submitting this complaint to the Washington State Attorney General's
Office my complaint and any response from the business and all communications with Attorney
Generals Office will become public records under state law. Public records are subject to
public records disclosure requests and as a public record, my complaint and all related
documents may be seen by other people.
I declare, under penalty of perjury under the laws of the State of Washington, that the
information contained in this complaint is true and accurate, and that any documents attached
are true and accurate copies of the originals.
I understand that the Washington State Attorney General's Office will contact the party(ies)
against which I have filed a complaint in an effort to reach an amicable resolution. I authorize
the party(ies) against which I have filed a complaint to communicate with and provide
information related to my complaint to the Washington State Attorney General's Office.
Signature Laurine Ermish Date 04/09/2013
Received via the Internet
City and State where signed Stony Brook, NY
428968
Bob Ferguson
800 Fifth Avenue, Suite 2000? Seattle, WA 98104-3188? (206) 464-6686
April 15, 2013
617 Lee Street
Seattle, WA 98109
File #: 428968
Dear McCormick Business Law:
Our office has received the enclosed complaint from Marc Joseph Yland regarding your
business.
428968.
ANDREW F. WU
(206) 389-2102
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
AndrewW2 4/15/2013
428968
COMPLAINT SUMMARY
Name:
Marc Joseph Yland
Address:
2500 Rte 347 Bldg 24C
Day Phone:
(631) 941-0187
Evening Phone:
E-mail Address:
office@yland.com
50-59
Yes
Address:
617 Lee Street
Seattle, WA 98109
Phone:
Toll-Free:
Fax:
E-mail:
Marc J Yland
428968
Getty Images
Seattle, WA 98104
alleged copyright infringement
1065.00
No
40/08/2013
Salesperson's name:
No
No
No
No
No
428968
I have been contacted by a law firm called McCormick Business Law, 617 Lee Street Seattle
WA 98109. They have put us in collections for non payment on a Getty Images copyright
infringement. We have paid it due to continued harassment. I am stoping payment on the credit
card today.
RFD
SIGNATURE
Signature Laurine Ermish Date 04/09/2013
City and State where signed Stony Brook, NY
428968
Sent: Thursday, May 02, 2013 5:54 PM
Re: Marc Joseph Yland (Marc J. Yland, MD, PC: Interventional & Multidisciplinary Pain
Management) (the Complainant)
Your File # 428968
recently.
circumstances.
AndrewW2 5/8/2013
428968
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
www.gettyimages.com
428968
C Response from one Respondent To: office@yland.com
Bob Ferguson
May 8, 2013
Marc Joseph Yland
2500 Rte 347 Bldg 24C
RE: McCormick Business Law and Getty Images
File #: 428968
Our office has received a response from Getty Images regarding your complaint. Attached is a
copy for your records.
When we receive a response from McCormick Business Law we will contact you again.
If the business response does not resolve the complaint, we will inform you of other alternatives
including private legal remedies.
ANDREW F. WU
(206) 389-2102
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
Re: Marc Joseph Yland (Marc J. Yland, MD, PC: Interventional & Multidisciplinary Pain
Management) (the Complainant)
Your File # 428968
AndrewW2 5/8/2013
428968
recently.
circumstances.
428968
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
www.gettyimages.com
428968
Bob Ferguson
May 8, 2013
Getty Images
Seattle, WA 98104
File #: 428968
Dear Getty Images:
Thank you for your recent communication in response to the complaint from Marc Joseph
Yland. Marc Joseph Yland has been informed of your response and that we have closed this
complaint with regard to our informal mediation service. We have notified the complainant of
the availability of private legal remedies in the event the complainant wishes to pursue this
matter further.
ANDREW F. WU
(206) 389-2102
Fax: (206) 389-2801
seacrc@atg.wa.gov
AndrewW2 5/8/2013
428968
From: Lauren Kingston [mailto:Lauren@McCormackLegal.com]
Sent: Friday, May 10, 2013 11:13 AM
Subject: Your File Number: 428968 / Our Case Number: 1220145
Dear Mr. Wu,
Attached is our response to the above referenced matter. A hard copy will follow by mail.
Sincerely,
Lauren Kingston
Attorney at Law
McCormack Intellectual Property Law
Business Law PS

Mailing Address
617 Lee Street
Seattle, WA 98109

Tel: 206-381-8888
Direct: 206-330-0108
Fax: 206-381-1988

Internet Address
www.McCormackLegal.com <www.McCormackLegal.com>
E: attorney@McCormackLegal.com

This e-mail may contain confidential information which is legally privileged. The information is
solely for the use of the addressee named above. If you are not the intended recipient, any
disclosure, copying, distribution or other use of the contents of this information is strictly
prohibited. If you have received this e-mail in error, please notify us by return e-mail and delete
this message. Thank you.
AndrewW2 5/10/2013
428968
Csup Closing Unadjusted (C-UNJ) To: office@yland.com
Bob Ferguson
May 10, 2013
Marc Joseph Yland
2500 Rte 347 Bldg 24C
RE: McCormick Business Law
File #: 428968
Our office has received a response from McCormick Business Law declining to adjust your
complaint for the reasons outlined in the response.
We realize you may disagree with McCormick Business Laws position. However, our office
does not have the legal authority to force the parties to resolve their dispute. We regret that we
are unable to provide further assistance to you in this situation.
King County: 206-623-2551 or 211
AndrewW2 5/10/2013
428968
advice.
ANDREW F. WU
(206) 389-2102
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
428968
Bob Ferguson
May 10, 2013
617 Lee Street
Seattle, WA 98109
File #: 428968
Dear McCormick Business Law:
Thank you for your recent response regarding the complaint from Marc Joseph Yland.
We appreciate your cooperation and assistance in this matter. The consumer has been informed
of your response, and we have closed this complaint accordingly. Your response will become
part of our public record.
The fact that we are closing this complaint does not mean that we will not investigate or take
future action pursuant to the Consumer Protection Act if the facts and circumstances indicate
that further action is warranted.
ANDREW F. WU
(206) 389-2102
Fax: (206) 389-2801
seacrc@atg.wa.gov
AndrewW2 5/10/2013
428968
[8d]
[8d]
[8d]
[5a]
[5a]
[5a]
[5a]
[8d]
[8d]

617 Lee Street
Seattle, WA 98109 USA
p.206-381-8888/f.206.381.1988
tim@McCormackLegal.com

Timothy B. McCormack
Attorney at Law

May 10, 2013

Via US Mail & Email

Mr. Andrew F. Wu
Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188

Tel: 206-389-2102
Email: seacrc@atg.wa.gov

Re: Marc Joseph Yland
Your File Number: 428968
Our Case Number: 1220145

Dear Mr. Wu:

We are in receipt of the complaint filed by Marc Joseph Yland that you forwarded to us
on April 15, 2013. Our firm acts as outside legal counsel to Getty Images in pursuing copyright
infringement claims. We appreciate having the opportunity to respond to this claim. As Getty
Images stated in their response to this matter, they are the worldwide leader in the stock
photography industry and the exclusive licensor of the imagery at issue. Getty Images is within
its rights to pursue claims of copyright infringement on behalf of the photographer of the image.
It is our understanding the complaint against Getty Images has been closed on May 8, 2013.

Further to Getty Images contact with Dr. Yland, our firm had been in contact with Dr.
Yland in an effort to resolve this matter through settlement discussions. On April 8, 2013,
Veronica at Dr. Ylands office called us to submit the settlement payment by credit card. After a
brief negotiation, we agreed to accept a reduced payment of $1,065 to satisfy the claim. The

May 10, 2013
Page 2

amount of $1,065.00 was negotiated with Dr. Marc J. Ylands office and agreed upon by both
parties in good faith.

Copyright infringement, a federal claim, is a strict liability tort. Actual damages
recoverable under copyright law include those damages sustained by the injured party, such as
lost licensing fees.

Despite Getty Images cease and desist request and our subsequent cease and desist
request, as of today May 10, 2013, Dr. Yland continues to display the image at issue on his
website at http://www.yland.com/Espanol/billing.asp without the proper license from Getty
Images. This continued use may be viewed as intentional copyright infringement and result in
additional claims. To resolve this matter to our clients satisfaction, the image must be removed
from the website. Getty Images continues to reserve all rights and remedies available for this
continued use.

McCormack Intellectual Property Law PS and Getty Images maintain that Getty Images
copyright infringement claim against Marc Joseph Yland is valid.

Should you require any additional information about this matter, please do not hesitate to
contact us.

Sincerely,

Timothy B. McCormack
Enclosure tim@mccormacklegal.com

Title: Businessman signing document, close-up (Digital Enhancement)
Creative image #: 200129126-001
License type: Rights-managed
Photographer: Richard Drury
Collection: Photographer's Choice
Credit: Richard Drury
Max file size/dimensions/dpi: 49.4 MB - 4134 x 4174 px (13.78 x 13.91 in.) - 300 dpi - RGB
Download file size may vary.
Release information: This image has a signed model release. This image is available for commercial use.
Keywords: People, Image, Well-dressed, Beginnings, Decisions, Opportunity, Desk, Agreement, Business,
Square, Indoors, Office, Human Body Part, Close-up, Digital Enhancement, Human Hand, Pen,
Signing, Contract, Part Of, Day, One Person, Young Adult, 20-29 Years, Color Image, Silver,
Signature, Young Men, One Young Man Only, One Man Only, Businessman, Photography, Adults
Only, Corporate Business. Find similar images
Availability: Availability for this image cannot be guaranteed until time of purchase.
Getty Images reserves the right to pursue unauthorized users of this image or clip. If you violate our intellectual property you
may be liable for: actual damages, loss of income, and profits you derive from the use of this image or clip, and, where
appropriate, the costs of collection and/or statutory damages up to $150,000 (USD).
Page 1 of 2 Businessman Signing Document Close Up High-Res Stock Photography | Getty Images | ...
5/10/2013 http://www.gettyimages.com/detail/photo/businessman-signing-document-close-up-high-re...
All contents copyright 1999-2013 Getty Images, Inc. All rights reserved.
Page 2 of 2 Businessman Signing Document Close Up High-Res Stock Photography | Getty Images | ...
5/10/2013 http://www.gettyimages.com/detail/photo/businessman-signing-document-close-up-high-re...
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
Getty Images
Seattle, WA 98104
ce@gettyimages.co
m
429004
4/9/2013
Respondent(s)
Complaint
Seattle - Lemon Law (Motor Veh.
Arbitration)
4/18/2013 Email from Respondent Please Activity Log 1276616 and Documents
429004
Assignee Offril, Wency V
$0.00
$0.00
$0.00
Code Practice
019 Inadequate Disclosure
316 Billing Issues
Practice(s)
Closed
Referral(s)
Name
Contact
429004
Catalyst
Maryssa Stumpf
1515 S Melrose Dr #21
Vista, CA 92081
1 of 2 429004
4/18/2013 Form Letter to Complainant Csup Closing Unadjusted (C-UNJ)
2 of 2 429004
Bob Ferguson
April 10, 2013
Maryssa Stumpf
Vista, CA 92081
RE: Getty Images
File #: 429004
Dear Maryssa Stumpf:
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
WencilaF 4/10/2013
429004
seacrc@atg.wa.gov
429004
Bob Ferguson
April 10, 2013
Getty Images
Seattle, WA 98104
RE: Maryssa Stumpf
File #: 429004
Dear Getty Images:
Our office has received the enclosed complaint from Maryssa Stumpf regarding your business.
429004.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
Enclosure
WencilaF 4/10/2013
429004
Re: Maryssa Stumpf (Missa by Design) (the Complainant)

Your File # 429004
recently.
circumstances.
WencilaF 4/18/2013
429004
Regards,
429004
Bob Ferguson
April 18, 2013
Maryssa Stumpf
Vista, CA 92081
RE: Getty Images
File #: 429004
Dear Maryssa Stumpf:
King County: 206-623-2551 or 211
WencilaF 4/18/2013
429004
advice.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
Enclosure
Re: Maryssa Stumpf (Missa by Design) (the Complainant)
Your File # 429004
recently.
429004
circumstances.
Regards,
429004
Bob Ferguson
April 18, 2013
Getty Images
Seattle, WA 98104
RE: Maryssa Stumpf
File #: 429004
Dear Getty Images:
Thank you for your recent communication in response to the complaint from Maryssa Stumpf.
Maryssa Stumpf has been informed of your response and that we have closed this complaint
with regard to our informal mediation service. We have notified the complainant of the
availability of private legal remedies in the event the complainant wishes to pursue this matter
further.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
WencilaF 4/18/2013
429004
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
Getty Images
Seattle, WA 98104
ce@gettyimages.co
m
McCormack Intellectual Property
Law
617 Lee St
Seattle, WA 98109
(206) 381-8888 legal@mccormackle
gal.com
429370
4/16/2013
Respondent(s)
Complaint
Bellingham - Consumer Protection Division
Assignee Holbrook, Ruth E
$0.00
$1,628.00
$0.00
Code Practice
316 Billing Issues
Practice(s)
Closed
Referral(s)
Name
Contact
429370
Catalyst
Scott Thomas Germino
14100 SE 36th St #120
Bellevue, WA 98006
(425) 577-6280 (425) 401-6424 scott@pillarnorthwest.com
1 of 2 429370
4/16/2013 Reviewed C has questions:
Does Getty Images or this law firm have any
standing here? I see this as extortion. Am I
correct? Thank you!
Offer to send to the business but say we can't
answer his questions as that would require a legal
opinion.
4/18/2013 Email to Complainant Csup Legal Opinion Request To:
scott@pillarnorthwest.com
4/18/2013 Resolution-CLOSED
INQUIRY/INFORMATION
4/18/2013 Email from Counsel
4/18/2013 Email from Complainant
4/22/2013 Reopened
5/3/2013 Email from Respondent
5/3/2013 Email to Respondent Rsup Closing Neutral (R-NEU) To:
5/3/2013 Email to Complainant (through
Outlook)
2 of 2 429370
Description
Approximately 10 years ago I had a small web designer create a real estate website for me. She used a photo
of a home on the front page which was at the time public domain. Approximately a year ago, Getty Images
sent me a letter that they now owned the rights to the photo and I owed them $1,628 for the use of it. I
immediately contacted the web designer and she explained that they had purchased the rights to many of the
public domain photos and were then searching the web and charging these fees to the owners and having them
pay. At this time we have been contacted by an attorney with McCormack Itellecutal Property Law Business
Law PS. They are making a demand of the funds or will proceed with the suit. They area out of Seattle at 617
Lee Street, 98109. Timothy B. McCormack is the attorney who is threatening us. This doesn't seem right.
They didn't give us an opportunity to cease use. The first notice of their new ownership of the photo rights, we
pulled the photo. We paid a third party business to design the site for us and had no knowledge of what photos
they were using except that they had the rights at that time to use the photography. Does Getty Images or this
law firm have any standing here? I see this as extortion. Am I correct? Thank you!
Expected resolution details: Stop the harassment and demand for payment
Catalyst Report
Csup Legal Opinion Request To: scott@pillarnorthwest.com
Bob Ferguson
103 East Holly Street, Suite 308 Bellingham, WA 98225-4310 (360) 738-6187
April 18, 2013
14100 SE 36th St #120
Bellevue, WA 98006
RE: Getty Images and McCormack Intellectual Property Law
File #: 429370
Dear Scott Thomas Germino:
Our office has received your correspondence.
In your correspondence you write:
"Does Getty Images or this law firm have any standing here - I see this as extortion. Am I
correct - Thank you!"
The Washington State Attorney Generals Office is prohibited by law from providing legal
opinions or advice to private citizens. As a consequence, I am not in a position to provide
answers to your questions. Citizens who are in need of these services should seek the advice of
a private attorney.
What I can offer is to forward your complaint to Getty Images for their response. This office
may provide a voluntary dispute resolution service between businesses and consumers.
However, we are a neutral party in individual disputes and cannot choose sides, resolve disputed
factual issues, or impose a resolution on parties in these matters.
If you would like a copy of your complaint forwarded to Getty Images, let me know and I will
do so.
Thank you for contacting our office. Your complaint will remain in our public records.
RUTH E. HOLBROOK
RuthH 4/18/2013
429370
429370
From: Pillar Northwest [mailto:scott@pillarnorthwest.com]
Sent: Thursday, April 18, 2013 11:55 AM
To: ATG MI Bellingham CRC
Subject: Re: 429370 : A notice from the Washington State Attorney General's Office
Please forward. Thank you for your help!!
Best regards,
Scott Germino
Sent from my iPhone
AdaS 4/18/2013
429370
Bob Ferguson
April 22, 2013
Getty Images
Seattle, WA 98104
RE: Scott Thomas Germino
File #: 429370
Dear Getty Images:
Our office has received the enclosed complaint from Scott Thomas Germino regarding your
business.
429370.
RUTH E. HOLBROOK
(360) 738-6188
Fax: (360) 738-6190
belcrc@atg.wa.gov
Enclosure
RuthH 4/22/2013
429370
COMPLAINT SUMMARY
Name:
Address:
14100 SE 36th St #120
Bellevue, WA 98006
Day Phone:
(425) 577-6280
Evening Phone:
(425) 401-6424
E-mail Address:
40-49
Yes
Getty Images
Address:
Seattle, WA 98104
Phone:
(206) 925-6753
Toll-Free:
Fax:
(206) 925-5623
429370
E-mail:
Timothy McCormack
McCormack Intellectual Property Law
617 Lee St
Seattle, WA 98109
NONE
No
Salesperson's name:
No
Yes
No
No
429370
No
Approximately 10 years ago I had a small web designer create a real estate website for me. She
used a photo of a home on the front page which was at the time public domain. Approximately a
year ago, Getty Images sent me a letter that they now owned the rights to the photo and I owed
them $1,628 for the use of it. I immediately contacted the web designer and she explained that
they had purchased the rights to many of the public domain photos and were then searching the
web and charging these fees to the owners and having them pay. At this time we have been
contacted by an attorney with McCormack Itellecutal Property Law Business Law PS. They are
making a demand of the funds or will proceed with the suit. They area out of Seattle at 617 Lee
Street, 98109. Timothy B. McCormack is the attorney who is threatening us. This doesn't seem
right. They didn't give us an opportunity to cease use. The first notice of their new ownership of
the photo rights, we pulled the photo. We paid a third party business to design the site for us and
had no knowledge of what photos they were using except that they had the rights at that time to
use the photography. Does Getty Images or this law firm have any standing here - I see this as
extortion. Am I correct - Thank you!
Expected resolution details: Stop the harassment and demand for payment
Other
SIGNATURE
Signature Scott Germino Date 04/16/2013
City and State where signed Bellevue, WA
429370
C 1st Letter to Complainant To: scott@pillarnorthwest.com
Bob Ferguson
April 22, 2013
14100 SE 36th St #120
Bellevue, WA 98006
RE: Getty Images
File #: 429370
RUTH E. HOLBROOK
RuthH 4/22/2013
429370
(360) 738-6188
Fax: (360) 738-6190
belcrc@atg.wa.gov
429370
From: Scott Germino [mailto:Scott@pillarnorthwest.com]
Thank you for the follow up. I dont want other, unsuspecting folks to get caught up in this
situation.
Have a great day,
Scott Germino
Designated Broker/Owner
Pillar Northwest Real Estate
Greater Seattle Area
425-577-6281
AdaS 4/22/2013
429370
Re: Germino, Scott Thomas (The Scott Germino Team/The Scott Germino REO Team- Pillar
Northwest Real Estate) (the Complainant)
Your File # 429370
Our Reference # 1278822/ 1264341
recently.
circumstances.
AdaS 5/3/2013
429370
treats within the meaning of extortion statutes. On the contrary, demand for payment is
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
www.gettyimages.com
429370
Csup Closing Unadjusted (C-UNJ) To: scott@pillarnorthwest.com
Bob Ferguson
May 3, 2013
14100 SE 36th St #120
Bellevue, WA 98006
RE: Getty Images
File #: 429370
Our office has received a response from Getty Images regarding your complaint. A copy is
attached.
wish to contact a private attorney.
King County: 206-623-2551 or 211
RuthH 5/3/2013
429370
advice.
RUTH E. HOLBROOK
(360) 738-6188
Fax: (360) 738-6190
belcrc@atg.wa.gov
Enclosure
Re: Germino, Scott Thomas (The Scott Germino Team/The Scott Germino REO Team- Pillar
Northwest Real Estate) (the Complainant)
Your File # 429370
Our Reference # 1278822/ 1264341
recently.
429370
circumstances.
treats within the meaning of extortion statutes. On the contrary, demand for payment is
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
429370
429370
Rsup Closing Neutral (R-NEU) To: copyright.compliance@gettyimages.com
Bob Ferguson
May 3, 2013
Getty Images
Seattle, WA 98104
RE: Scott Thomas Germino
File #: 429370
Dear Getty Images:
Thank you for your recent response regarding the complaint from Scott Thomas Germino.
RUTH E. HOLBROOK
(360) 738-6188
Fax: (360) 738-6190
belcrc@atg.wa.gov
RuthH 5/3/2013
429370
Sent: Friday, May 03, 2013 2:22 PM
Thank you for your attempt. My concern is that they are purchasing rights after the fact. Then
strong arming unknowing public who were unaware that they had acquired rights to the picture
without giving any notice. I have heard this from other consumers as well. Isnt that when the
AGs office steps in - When consumers are being harmed -
In this case, we had our website designed by a small designer and 10 years later they send us a
notice that we owe them $1700. There has to be an opportunity for us to remove the photo from
our website after they purchased it - This is a great scam otherwise. Isnt this the type of
situation that the AG looks at -
Thank you again,
Scott Germino
425-577-6281
AdaS 5/3/2013
429370
From: ATG MI Bellingham CRC
To: 'Scott Germino'
Hello. What we look at is everything that comes in. What we open an investigation on and
pursue legal action on is a matter of budget, staffing, existing priorities, and the overall priorities
of the Attorney General. I cant say whether we will pursue legal action at this time or in the
future. I can say that consumer complaints provide valuable information which is used to help
us prioritize the resources we have for undertaking litigation.
Sincerely,
Ruth Holbrook
Washington State Attorney General's Office
(360) 738-6188
Please save paper by printing only when necessary
RuthH 5/3/2013
429370
Subject: RE: 429370 : A notice from the Washington State AttorneyGeneral'sOffice
Got it. Thank you again for your time!
Best regards,
Scott Germino
425-577-6281
AdaS 5/3/2013
429370
[8d] [8d]
[5a]
[5a]
[8d]
[8d]
[5a]
[5a]
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
Getty Images
Seattle, WA 98104
ce@gettyimages.co
m
Design Pics / AlaskaStock.com
2505 Fairbanks Street
Anchorage, AK 99503
(907) 276-1343 (800) 487-4285 infoweb@alaskastoc
k.com
429427
4/17/2013
Respondent(s)
Complaint
Seattle - Consumer Protection Division
Assignee Hatcher, Sandra M
$0.00
$844.35
$0.00
Code Practice
019 Inadequate Disclosure
316 Billing Issues
Practice(s)
Closed
Referral(s)
Name
Contact
429427
Catalyst
Charles Joseph Boedeker
2422 Lilyfield Dr
Trophy Club, TX 76262
(817) 490-0501 (817) 800-1640 nightvisionstore@att.net
1 of 2 429427
4/17/2013 Intake Notes c listed this as other respondents involved:
"Alaska Stock Images, Edmonton, Alberta
Canada" but that R is not currently assigned as a
respondent.
C also lists this information per intake
data/respondent info tab: "Case # 1331147 Access
Code PSQmqmYO", which might be on the
attachments - they just haven't uploaded yet for me
to check.
nightvisionstore@att.net
infoweb@alaskastock.com
4/19/2013 Email to Complainant C Response from one Respondent To:
gary@designpics.com
2 of 2 429427
Description
Getty Images alleges that I downloaded and used an image for which they claim to hold the rights. They are
demanding $844.35 as a payment. Even thought I deleted the image when notified by them, they still demand
the money. They offer no evidence that this is their image - it is not copyrighted or watermarked. They still
claim to own the rights. In fact, I obtained the image from one of my suppliers as a part of marketing their
products.
1) I did not download this picture from any web site, free or fee. It was provided to me via my supplier, ATN
Corporation.
2) I immediately deleted the image as soon as I received notification from Gety Images
3) Getty Images claims to represent the photographer, John Warden. His photos are displayed on the web site
"Alaska Stock Photos" http://www.alaskastock.com/ . They claim that the photo is under Record Locator
#926824-001.
4) Please refer to my attachments - according to Alaska Stock Photos, there is no such record.
5) Please refer to my attachments - there are no pictures on this web site which resemble, even slightly, the
picture which I am alledged to have misapproprieted. All 'Rights Managed' (RM) John Warden pictures which
are handled by Alaska Stock Images are located on this web site.
Expected resolution details: Request that they rescind their demand letter
Catalyst Report
C 1st Letter to Complainant To: nightvisionstore@att.net
Bob Ferguson
April 18, 2013
2422 Lilyfield Dr
RE: Getty Images and AlaskaStock.com
File #: 429427
Dear Charles Joseph Boedeker:
your complaint to Getty Images and AlaskaStock.com and requested a response within 21
business days. I will notify you when a response is received regarding your complaint.
SANDRA M. HATCHER
SandraH 4/18/2013
429427
(206) 389-2743
Fax: (206) 389-2801
seacrc@atg.wa.gov
429427
Bob Ferguson
April 18, 2013
Getty Images
Seattle, WA 98104
RE: Charles Joseph Boedeker
File #: 429427
Dear Getty Images:
Our office has received the enclosed complaint from Charles Joseph Boedeker regarding your
business.
429427.
SANDRA M. HATCHER
(206) 389-2743
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
SandraH 4/18/2013
429427
COMPLAINT SUMMARY
Name:
Address:
2422 Lilyfield Dr
Day Phone:
(817) 490-0501
Evening Phone:
(817) 800-1640
E-mail Address:
59+
Yes
Getty Images
Address:
Seattle, WA 98104
Phone:
(206) 925-6753
Toll-Free:
Fax:
(206) 925-5623
429427
E-mail:
unknown
AlaskaStock.com
Anchorage, AK 99503
none
n/a
No
n/a
Salesperson's name:
No
n/a
Yes
No
429427
No
No
A demand letter threatening legal action has been issued.
Getty Images alleges that I downloaded and used an image for which they claim to hold the
rights. They are demanding $844.35 as a payment. Even thought I deleted the image when
notified by them, they still demand the money. They offer no evidence that this is their image -
it is not copyrighted or watermarked. They still claim to own the rights. In fact, I obtained the
image from one of my suppliers as a part of marketing their products.
1) I did not download this picture from any web site, free or fee. It was provided to me via my
supplier, ATN Corporation.
3) Getty Images claims to represent the photographer, John Warden. His photos are displayed
on the web site "Alaska Stock Photos" http://www.alaskastock.com/ . They claim that the photo
is under Record Locator #926824-001.
5) Please refer to my attachments - there are no pictures on this web site which resemble, even
slightly, the picture which I am alledged to have misapproprieted. All 'Rights Managed' (RM)
John Warden pictures which are handled by Alaska Stock Images are located on this web site.
Other
SIGNATURE
429427
Signature Charles Boedeker Date April 16, 2013
City and State where signed Trophy Club, Texas
429427
R 1st Letter to Respondent To: infoweb@alaskastock.com
Bob Ferguson
April 18, 2013
AlaskaStock.com
Anchorage, AK 99503
File #: 429427
Dear AlaskaStock.com:
Our office has received the enclosed complaint from Charles Joseph Boedeker regarding your
business.
429427.
SANDRA M. HATCHER
(206) 389-2743
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
SandraH 4/18/2013
429427
COMPLAINT SUMMARY
Name:
Address:
2422 Lilyfield Dr
Day Phone:
(817) 490-0501
Evening Phone:
(817) 800-1640
E-mail Address:
59+
Yes
Getty Images
Address:
Seattle, WA 98104
Phone:
(206) 925-6753
Toll-Free:
Fax:
(206) 925-5623
429427
E-mail:
unknown
AlaskaStock.com
Anchorage, AK 99503
none
n/a
No
n/a
Salesperson's name:
No
n/a
Yes
No
429427
No
No
A demand letter threatening legal action has been issued.
Getty Images alleges that I downloaded and used an image for which they claim to hold the
rights. They are demanding $844.35 as a payment. Even thought I deleted the image when
notified by them, they still demand the money. They offer no evidence that this is their image -
it is not copyrighted or watermarked. They still claim to own the rights. In fact, I obtained the
image from one of my suppliers as a part of marketing their products.
1) I did not download this picture from any web site, free or fee. It was provided to me via my
supplier, ATN Corporation.
3) Getty Images claims to represent the photographer, John Warden. His photos are displayed
on the web site "Alaska Stock Photos" http://www.alaskastock.com/ . They claim that the photo
is under Record Locator #926824-001.
5) Please refer to my attachments - there are no pictures on this web site which resemble, even
slightly, the picture which I am alledged to have misapproprieted. All 'Rights Managed' (RM)
John Warden pictures which are handled by Alaska Stock Images are located on this web site.
Other
SIGNATURE
429427
Signature Charles Boedeker Date April 16, 2013
City and State where signed Trophy Club, Texas
429427
Out of office reply from AlaskaStock.com
-----Original Message-----
From: ann@alaskastock.com [mailto:ann@alaskastock.com]
Subject: Out of the Office
I will be out of the office starting Friday April 12th, returning on Monday April 22nd.
If you require immediate assistance, please contact one of the appropriate persons listed below.
For Account/ Commission related issues:
General Manager Kristi Bennell, Kristi@designpics.com, 1-877-337-5433
For FTP & Management Site related issues:
Photo and Production Manager Leah Bignell, leahb@designpics.com, 1-877-337-5433
For Submission related questions:
Project Specialist Gina Bringman, gina@alaskastock.com, 208-578-4922 direct line, 907-331-
3611 main line
Photo and Production Manager Leah Bignell (contact info above)
For Sales Department:
VP of Sales & Marketing, Laurie McCampbell, laurie@alaskastock.com, 907-268-2092
All the best,
Ann Matchett
Contributor & Content Manager
Alaska Stock Images
a division of Design Pics, Inc.
Direct Line: 907-268-2091 I Fax: 907-268-2091
Outside Alaska: 1-800-487-4285
Email: ann@alaskastock.com I Skype: ann.alaskastock
SandraH 4/18/2013
429427
Response from AlaskaStock.com
From: Gary Elsner [mailto:gary@designpics.com]
Sent: Friday, April 19, 2013 7:53 AM
Cc: 'Rick Carlson'; gina@alaskastock.com; 'Jeff Schultz (Alaska Stock)';
Laurie@alaskastock.com
Subject: RE: 429427 : A notice from the Washington State Attorney General's Office
Dear Mr. Ferguson,
Alaska Stock is a division of Design Pics and I am replying to your email sent to Alaska Stock
on their behalf.
Please be advised of the following:
1. Alaska Stock previously had no business relationship with Getty Images and Alaska Stock
has not provided images to Getty Images.
2. Alaska Stock is in the business of licensing images for commercial uses and does so by
representing photographers that contract with us for this purpose.
3. While Alaska Stock does represent images from a photographer named John Warden, the
particular image that is the subject of this dispute is not among our inventory of John Warden
images.
Accordingly, we are in no way a part to this dispute. Having done some research, we surmise
that the complaining party obtained our name as a result of a Google search that returned results
both in the photographers name as well as Alaska Stocks name.
Having said that, we have no information relevant to the facts of this matter as to whether or not
a legitimate license was obtained on behalf of Mr. Charles Joseph Boedeker and or his business
either directly or through a third party.
If in fact no license was obtained by Mr. Boedkers supplier before transferring the image to Mr.
Boedeker, the supplier and Mr. Boedeker may in fact be guilty of infringing on the copyright of
the photographer and Getty Images. I humbly suggest that your initial efforts should focus on
clarifying that issue. If in fact no license was obtained on behalf of Mr. Boedeker and/or his
companys supplier, the mere fact that upon notice, he removed the image, doesnt negate the
fact that an infringement occurred and that damages are due for the infringement. All of that
said, this is a matter between yourselves, Mr. Boedeker, and Getty Images, but does not in any
way involve Design Pics or its acquired division of Alaska Stock.
Sincerely yours,
Gary Elsner
VP, Operations
Design Pics Inc.
SandraH 4/19/2013
429427
201 482-4705
201 790-3228 (cell)
gary@designpics.com
www.designpics.com
429427
C Response from one Respondent To: nightvisionstore@att.net
Bob Ferguson
April 19, 2013
2422 Lilyfield Dr
RE: Getty Images and AlaskaStock.com
File #: 429427
Our office has received a response from AlaskaStock.com regarding your complaint. Attached
is a copy for your records.
When we receive a response from Getty Images we will contact you again.
SANDRA M. HATCHER
(206) 389-2743
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
April 19, 2013
RE: 429427 : A notice from the Washington State Attorney General's Office
Dear Mr. Ferguson,
Alaska Stock is a division of Design Pics and I am replying to your email sent to Alaska Stock
on their behalf.
Please be advised of the following:
SandraH 4/19/2013
429427
1. Alaska Stock previously had no business relationship with Getty Images and Alaska Stock
has not provided images to Getty Images.
2. Alaska Stock is in the business of licensing images for commercial uses and does so by
representing photographers that contract with us for this purpose.
3. While Alaska Stock does represent images from a photographer named John Warden, the
particular image that is the subject of this dispute is not among our inventory of John Warden
images.
Accordingly, we are in no way a part to this dispute. Having done some research, we surmise
that the complaining party obtained our name as a result of a Google search that returned results
both in the photographers name as well as Alaska Stocks name.
Having said that, we have no information relevant to the facts of this matter as to whether or not
a legitimate license was obtained on behalf of Mr. Charles Joseph Boedeker and or his business
either directly or through a third party.
If in fact no license was obtained by Mr. Boedkers supplier before transferring the image to Mr.
Boedeker, the supplier and Mr. Boedeker may in fact be guilty of infringing on the copyright of
the photographer and Getty Images. I humbly suggest that your initial efforts should focus on
clarifying that issue. If in fact no license was obtained on behalf of Mr. Boedeker and/or his
companys supplier, the mere fact that upon notice, he removed the image, doesnt negate the
fact that an infringement occurred and that damages are due for the infringement. All of that
said, this is a matter between yourselves, Mr. Boedeker, and Getty Images, but does not in any
way involve Design Pics or its acquired division of Alaska Stock.
Sincerely yours,
Gary Elsner
VP, Operations
Design Pics Inc.
201 482-4705
429427
Rsup Closing Neutral (R-NEU) To: gary@designpics.com
Bob Ferguson
April 19, 2013
Design Pics / AlaskaStock.com
Anchorage, AK 99503
File #: 429427
Dear Mr. Elsner:
Thank you for your recent response regarding the complaint from Charles Joseph Boedeker.
SANDRA M. HATCHER
(206) 389-2743
Fax: (206) 389-2801
seacrc@atg.wa.gov
SandraH 4/19/2013
429427
Thank you from Design Pics
From: Gary Elsner [mailto:gary@designpics.com]
Sent: Friday, April 19, 2013 10:20 AM
Thank you Bob. Have a good weekend.
Gary Elsner
VP, Operations
Design Pics Inc.
201 482-4705
201 790-3228 (cell)
gary@designpics.com
www.designpics.com
SandraH 4/22/2013
429427
Response from Getty Images
Re: Charles Joseph Boedeker (The Night Vision Store) (the Complainant)
Your File # 429427
recently.
circumstances.
SandraH 5/3/2013
429427
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
www.gettyimages.com
429427
Csup Closing Unadjusted (C-UNJ) To: nightvisionstore@att.net
Bob Ferguson
May 3, 2013
2422 Lilyfield Dr
RE: Getty Images
File #: 429427
wish to contact a private attorney.
SANDRA M. HATCHER
(206) 389-2743
Fax: (206) 389-2801
seacrc@atg.wa.gov
Enclosure
May 02, 2013
Re: Charles Joseph Boedeker (The Night Vision Store) (the Complainant)
Your File # 429427
SandraH 5/3/2013
429427
recently.
circumstances.
429427
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
429427
Bob Ferguson
May 3, 2013
Getty Images
Seattle, WA 98104
File #: 429427
Dear Getty Images:
Thank you for your recent communication in response to the complaint from Charles Joseph
Boedeker. Charles Joseph Boedeker has been informed of your response and that we have
closed this complaint with regard to our informal mediation service. We have notified the
complainant of the availability of private legal remedies in the event the complainant wishes to
pursue this matter further.
SANDRA M. HATCHER
(206) 389-2743
Fax: (206) 389-2801
seacrc@atg.wa.gov
SandraH 5/3/2013
429427

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Royalty Free Rights Managed Model Released Alaska Only Images/Page 48
Images by Alaska Stock.
Please call 800-487-4285 for information and licensing rights.
2505 Fairbanks Street Anchorage, AK 99503
907.276.1343 infoweb@alaskastock.com 800.487.4285
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Alaska Stock Images - Email Lightbox http://www.alaskastock.com/lbmail.asp?pbJohn~~20Warden~~20Galle...
1 oI 8 4/15/2013 3:02 PM

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2 oI 8 4/15/2013 3:02 PM

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4 oI 8 4/15/2013 3:02 PM

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Alaska Summer

317OT AI0001 001
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Pathway Oregon Winter

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bald eagle portrait against blue sky
with moon composite

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Bald Eagle Landing on Perch Displacing
Another Eagle

100OT AI0020 001
Grizzly Bear Sleeping on Paws
Close-up Captive Summer

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Game Sanctuary

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6 oI 8 4/15/2013 3:02 PM

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Mts KP AK

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DO NOT USE-NO HIGH RES
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Can't find what you're looking for? Search our site below
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7 oI 8 4/15/2013 3:02 PM
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8 oI 8 4/15/2013 3:02 PM
[8d]
[8d]
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
Getty Images
Seattle, WA 98104
ce@gettyimages.co
m
Evisionlink.com/New Vision
International
,
429592
4/19/2013
Respondent(s)
Complaint
Arbitration)
$0.00
$965.00
$0.00
Code Practice
316 Billing Issues
Practice(s)
Closed
Referral(s)
Name
Contact
429592
Catalyst
John W Beebe for Chef To Go
c/o Prout Levangie
2021 N St
Sacramento, CA 95811
(916) 443-4849
1 of 2 429592
5/9/2013 Form Letter to Complainant C Response from one Respondent
5/24/2013 Resolution-PART ADJUSTED
2 of 2 429592
Bob Ferguson
April 23, 2013
c/o Prout Levangie
2021 N St
RE: Getty Images and Evisionlink.com/New Vision International
File #: 429592
Dear John W Beebe for Chef To Go:
your complaint to Getty Images and Evisionlink.com/New Vision International and requested a
response within 21 business days. I will notify you when a response is received regarding your
complaint.
WENCY V. OFFRIL
Program Coordinator
WencilaF 4/23/2013
429592
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
429592
Bob Ferguson
April 23, 2013
Getty Images
Seattle, WA 98104
RE: John W Beebe for Chef To Go
File #: 429592
Dear Getty Images:
Our office has received the enclosed complaint from John W Beebe for Chef To Go regarding
your business.
429592.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
Enclosure
WencilaF 4/23/2013
429592
429592
Re: John W Beebe (Chef To Go) (the Complainant)
Your File # 429592
recently.
circumstances.
WencilaF 5/9/2013
429592
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
429592
Bob Ferguson
May 9, 2013
c/o Prout Levangie
2021 N St
RE: Getty Images and Evisionlink.com/New Vision International
File #: 429592
Dear John W Beebe for Chef To Go:
Our office has received a response from Getty Images regarding your complaint. Attached is a
copy for your records.
When we receive a response from Evisionlink.com/New Vision International we will contact
you again.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
Enclosure
Re: John W Beebe (Chef To Go) (the Complainant)
Your File # 429592
WencilaF 5/9/2013
429592
recently.
circumstances.
429592
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
429592
Rsup Closing Neutral (R-NEU) To: copyright.compliance@gettyimages.com
Bob Ferguson
May 9, 2013
Getty Images
Seattle, WA 98104
RE: John W Beebe for Chef To Go
File #: 429592
Dear Getty Images:
Thank you for your recent response regarding the complaint from John W Beebe for Chef To
Go.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
WencilaF 5/9/2013
429592
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
Getty Images
Seattle, WA 98104
ce@gettyimages.co
m
427941
3/20/2013
Respondent(s)
Complaint
Arbitration)
agritti@closys.com
$0.00
$1,886.19
$0.00
Code Practice
100 Misrepresentation of Terms
404 Collection Practices
Practice(s)
Closed
Referral(s)
Name
Contact
427941
Catalyst
Andy Gritti
16100 N Greenway Hayden Lp #400
Scottsdale, AZ 85260
(480) 948-6997 agritti@closys.com
1 of 2 427941
agritti@closys.com
3/28/2013 Email to Complainant Csup Limits of AGO (C-LIMITS) To:
agritti@closys.com
2 of 2 427941
Description
I am filing this complaint of harassment against Getty Images for their continued harassment. Their recent
letters claim lawsuits unless money is paid ($1886.19) for what they claims is unauthorized use of copyrighted
images. Unfortunately when asked for proof of these copyrights they claim they don't have them and can't
produce them but that we owe them money anyway.
The image in question was on a test site in Canada that was never used and we can prove it via Google analytic
s. Furthermore, the entire site which was forgotten and not used was removed. So the image they claim as their
own was not viewed by the public before it was taken down and now the ENTIRE site is non-existent
(www.closys.ca).
Expected resolution details: Drop the harassment threat of a law suit and send a letter stating so.
Catalyst Report
C 1st Letter to Complainant To: agritti@closys.com
Bob Ferguson
March 20, 2013
Andy Gritti
RE: Getty Images
File #: 427941
Dear Andy Gritti:
WENCY V. OFFRIL
Program Coordinator
WencilaF 3/20/2013
427941
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
427941
Bob Ferguson
March 20, 2013
Getty Images
Seattle, WA 98104
RE: Andy Gritti
File #: 427941
Dear Getty Images:
Our office has received the enclosed complaint from Andy Gritti regarding your business.
427941.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
Enclosure
WencilaF 3/20/2013
427941
COMPLAINT SUMMARY
Name:
Andy Gritti
Address:
Day Phone:
(480) 948-6997
Evening Phone:
E-mail Address:
agritti@closys.com
50-59
Yes
Getty Images
Address:
Seattle, WA 98104
Phone:
(206) 925-6753
Toll-Free:
Fax:
(206) 925-5623
E-mail:
427941
Janea Davis
No
Salesperson's name:
No
No
No
Yes
No
We are contacting for advisement
427941
I am filing this complaint of harassment against Getty Images for their continued harassment.
Their recent letters claim lawsuits unless money is paid ($1886.19) for what they claims is
unauthorized use of copyrighted images. Unfortunately when asked for proof of these
copyrights they claim they don't have them and can't produce them but that we owe them money
anyway.
The image in question was on a test site in Canada that was never used and we can prove it via
Google analytic s. Furthermore, the entire site which was forgotten and not used was removed.
So the image they claim as their own was not viewed by the public before it was taken down
and now the ENTIRE site is non-existent (www.closys.ca).
Expected resolution details: Drop the harassment threat of a law suit and send a letter stating so.
Other
SIGNATURE
Signature Andy Gritti Date 03/19/2013
City and State where signed Scottsdale, Arizona
427941
Sent: Thursday, March 21, 2013 3:29 PM
Re: Andi Gritti (Rowpar Pharmaceuticals) (the Complainant)
Your File # 427941
recently.
circumstances.
WencilaF 3/27/2013
427941
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
www.gettyimages.com
427941
Csup Closing Unadjusted (C-UNJ) To: agritti@closys.com
Bob Ferguson
March 27, 2013
Andy Gritti
RE: Getty Images
File #: 427941
Dear Andy Gritti:
King County: 206-623-2551 or 211
WencilaF 3/27/2013
427941
advice.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
Enclosure
Sent: Thursday, March 21, 2013 3:29 PM
Re: Andi Gritti (Rowpar Pharmaceuticals) (the Complainant)
Your File # 427941
recently.
427941
circumstances.
Regards,
427941
Bob Ferguson
March 27, 2013
Getty Images
Seattle, WA 98104
RE: Andy Gritti
File #: 427941
Dear Getty Images:
Thank you for your recent communication in response to the complaint from Andy Gritti. Andy
Gritti has been informed of your response and that we have closed this complaint with regard to
our informal mediation service. We have notified the complainant of the availability of private
legal remedies in the event the complainant wishes to pursue this matter further.
WENCY V. OFFRIL
Program Coordinator
(206) 464-6686
Fax: (206) 587-5636
seacrc@atg.wa.gov
WencilaF 3/27/2013
427941
From: Andy Gritti [mailto:agritti@closys.com]
Sent: Wednesday, March 27, 2013 1:51 PM
This is pathetic. So let me get this right. I can send them a letter telling them that they harassed
me and Im seeking a fee for my inconvenience but I dont have to show any proof. All I have
to do is send a letter and claim I have the right and have been bothered by them and I expect
payment. That is exactly what Getty Images is going. They dont have proof of holding any
copyright. They just say they have the right. When asked for them to provide such proof they
claim they dont have to. What - You dont have to resolve my dispute. What you should be
doing is making sure that companies in your state act legally. All that is asked is that they
provide proof for their claim. Take another look at this company. Youre ignoring a real
WencilaF 3/28/2013
427941
Csup Limits of AGO (C-LIMITS) To: agritti@closys.com
Bob Ferguson
March 28, 2013
Andy Gritti
RE: Getty Images
File #: 427941
Dear Andy Gritti:
We regret that our office was unable to resolve your consumer complaint. This does not
necessarily reflect on the validity of your claim, nor does it preclude you from seeking private
legal remedies.
This office may provide a voluntary dispute resolution service only for consumers and
businesses who agree to submit to our informal mediation process. This office cannot choose
sides, resolve disputed factual issues, or impose a resolution on parties in these matters.
Our office may determine that legal action on behalf of the public interest (not the interest of an
individual consumer) is warranted in the future. For purposes of taking legal action on behalf of
all Washington state consumers, your complaint will become part of our public record of this
firms business practices.
The Attorney Generals Office is authorized only to represent certain public officials and
agencies and is prohibited by law from representing private citizens on personal legal matters.
The Consumer Protection Act does not permit this office to act as your private attorney or
impose a resolution when the company refuses to make an adjustment or when there is a dispute
of facts. Our office focuses on those cases that have or may have the broadest impact on the
citizens and marketplace in Washington. Our office attempts to avoid duplicate actions of other
law enforcement offices, government agencies, or private class actions.
We hope this information is useful to you and helps you better understand the function and
limitations of our office.
Thank you for contacting our office regarding your complaint.
WencilaF 3/28/2013
427941
WENCY V. OFFRIL
Program Coordinator
427941
Status
Amount Disputed
Actual Savings
Estimated Savings
Activities
Location
NAICS
Complainant
Number
Date
Getty Images
Seattle, WA 98104
ce@gettyimages.co
m
428072
3/22/2013
Respondent(s)
Complaint
Bellingham - Consumer Protection Division
drted35@aol.com
Assignee Marcus, Jeri
$0.00
$850.00
$0.00
Code Practice
009 High Pressure Sales
013 Misrepresentation of product or service
023 Scare Tactics
Practice(s)
Closed
Referral(s)
Name
Contact
428072
Catalyst
Ted Rothstein
35 Remsen St
Brooklyn, NY 11201
(718) 852-1551 (718) 596-4633 drted35@aol.com
1 of 2 428072
3/28/2013 Email from Complainant See document 428072A attached.
3/28/2013 Other Correspondence document attached is an exact copy of 428072A
and therefore not published
drted35@aol.com
drted35@aol.com
2 of 2 428072
Description
March 22, 2013
To the Attorney General. Mr Bob Ferguson, Washington State:
Dear Mr. Ferguson:
Gettyimages (605 5th ave. S, Ste. 400, Seattle WA 98104: www.gettyimages.com) sent me a 7-page demand-
letter for $1065 March 17, 2013 (notification #1314999) for infringing a copyright image they claim to own.
This type of infrinegment is currently referred to as an "innocent infringement" by posting in image embedded
in an religious educational article I posted on my website on a subject of religion totally unrelated to my work
as orthodontist and solely for the purpose of supporting a video I had made documenting a ritual that religious
Jews carry out on a daily basis. I used a document published by a religous institution that included in it the
words reprint permission ##### and that contained the image in question.
(That document is available on request).
It cotained an image of a burning Jewish oil lamp which had no indiction of a "copyright by Gettyimages".
That same evening I removed the image and notified the source of sender of the "Demand letter" that I had
removed the document and the image . Two days later they emailed a " Settlement" offer indicating they
would accept $850 without any explanation of how they arrived at that amount. I believe this kind of action is
currently called "Speculation billing" In this letter they threatened to commence a legal action in court if I did
not agree to sum demanded by March 26. Today I contacted the AG Washington State and requested all
complaints received by the AG which I was told were voluminous, and was further advised and encouraged to
register a complaint not only with the AG Washington State, but with AG of NY State which I intend to do
without a moment's delay. Yours truly, Dr. Ted Rothstein Ps. I am sending under separate cover the document
that includes the image referred to in the Getty demand letter since I do not have access it at the computer I am
using. I will send it and incluse the refernce number that I receive upon sending this formal complaint.
Expected resolution details: I am requesting that they accept my apology for my innocent infringement and
forgo any demand for a settlement under threat of litagation.
Catalyst Report
Bob Ferguson
March 26, 2013
Getty Images
Seattle, WA 98104
RE: Ted Rothstein
File #: 428072
Dear Getty Images:
Our office has received the enclosed complaint from Ted Rothstein regarding your business.
428072.
JERI MARCUS
Complaint Analyst
(360) 738-6187
Fax: (360) 738-6190
belcrc@atg.wa.gov
Enclosure
JeriM 3/26/2013
428072
COMPLAINT SUMMARY
Name:
Ted Rothstein
Address:
35 Remsen St
Brooklyn, NY 11201
Day Phone:
(718) 852-1551
Evening Phone:
(718) 596-4633
E-mail Address:
drted35@aol.com
59+
Yes
Getty Images
Address:
Seattle, WA 98104
Phone:
(206) 925-6753
Toll-Free:
Fax:
(206) 925-5623
E-mail:
428072
Dr. Ted Rothstein
No
Salesperson's name:
No
No
No
Yes
No
428072
March 22, 2013
Dear Mr. Ferguson:
Gettyimages (605 5th ave. S, Ste. 400, Seattle WA 98104: www.gettyimages.com) sent me a 7-
page demand-letter for $1065 March 17, 2013 (notification #1314999) for infringing a
copyright image they claim to own. This type of infrinegment is currently referred to as an
"innocent infringement" by posting in image embedded in an religious educational article I
posted on my website on a subject of religion totally unrelated to my work as orthodontist and
solely for the purpose of supporting a video I had made documenting a ritual that religious Jews
carry out on a daily basis. I used a document published by a religous institution that included in
it the words reprint permission ##### and that contained the image in question.
It cotained an image of a burning Jewish oil lamp which had no indiction of a "copyright by
Gettyimages".
That same evening I removed the image and notified the source of sender of the "Demand
letter" that I had removed the document and the image . Two days later they emailed a "
Settlement" offer indicating they would accept $850 without any explanation of how they
arrived at that amount. I believe this kind of action is currently called "Speculation billing" In
this letter they threatened to commence a legal action in court if I did not agree to sum
demanded by March 26. Today I contacted the AG Washington State and requested all
complaints received by the AG which I was told were voluminous, and was further advised and
encouraged to register a complaint not only with the AG Washington State, but with AG of NY
State which I intend to do without a moment's delay. Yours truly, Dr. Ted Rothstein Ps. I am
sending under separate cover the document that includes the image referred to in the Getty
demand letter since I do not have access it at the computer I am using. I will send it and incluse
the refernce number that I receive upon sending this formal complaint.
Expected resolution details: I am requesting that they accept my apology for my innocent
infringement and forgo any demand for a settlement under threat of litagation.
Other
SIGNATURE
428072
Signature Dr. Ted Rothstein Date March 22, 2013
City and State where signed Brooklyn, NY
428072
C 1st Letter to Complainant To: drted35@aol.com
Bob Ferguson
March 26, 2013
Ted Rothstein
35 Remsen St
Brooklyn, NY 11201
RE: Getty Images
File #: 428072
Dear Ted Rothstein:
JERI MARCUS
Complaint Analyst
JeriM 3/26/2013
428072
(360) 738-6187
Fax: (360) 738-6190
belcrc@atg.wa.gov
428072
From: Drted35@aol.com [mailto:Drted35@aol.com]
Sent: Tuesday, March 26, 2013 3:50 PM
Subject: Re: 428072 : A notice from the Washington State Attorney General's Office
Dear Jeri Marcus:
Thank you for acknowledging my letter of complaint to ATG Ferguson re Gettyimages demand
letter for $1065. I look forward to hearing from you at the end of the specified time mentioned
below. I have sent both
Susan Green and Liz Williamson the document which contains the image that Gettymages is
demanding $1065 for.
Cordially, Dr. ...
Ted Rothstein DDS PhD
Specialist in Cosmetic Orthodontics
and Dentofacial Orthopedics: Adults & Children
Preferred Provider of Invisalign: Adults & Teens
Specialist in Orthodontic Jaw Wiring
American Association of Orthodontists--Life-active
35 Remsen St., Bklyn, NY 11201
7188521551 www.drted.com drted35@aol.com
AdaS 3/26/2013
428072
From: ATG MI CPR Contact AGO
Cc: Greene, Susan (ATG)
Subject: Complaint No. 428072 - FW: Document containing Image subject of Gettyimage
demand letter for $1065
RE: Complaint No. 428072
Forwarding to the CRC for Complaint Processing.
From: Greene, Susan (ATG)
To: ATG MI CPR Contact AGO
Subject: FW: Document containing Image subject of Gettyimage demand letter for $1065
Liz,
Dr. Rothstein sent the doc to me that he would like to be added to his complaint he sent to CP
3/22 re Getty Images.
Thanks for your help J
Thank you,
Susan Greene
Senior Public Records Officer
Public Records & Constituent Services
(360)586-3568
susang@atg.wa.gov
To: Greene, Susan (ATG)
Subject: Document containing Image subject of Gettyimage demand letter for $1065
Dear Susan:
I'm getting anxious about sending you the document which contains the image that
Gettyimages is demanding $1065 in their seven page legal letter I received last week.
I did receive confirmation that my complaint to the AG was received, however I have not as yet
received a complaint number.

Nevertheless I have attached the document containing the image--see attached.

In response to the GettyLetter, I removed the entire article which is lengthy and in which the
WalliG 3/28/2013
428072
image (A bring oil lamp) can be found toward the end.

Cordially, Dr....
YouTube Facebook Twitter
428072
From: ATG MI CPR Contact AGO
Subject: Complaint No. 237688 - FW: Document containing Image subject of Gettyimage
demand letter for $1065
RE: Complaint No. 237688
To: ATG MI CPR Contact AGO
Subject: Fwd: Document containing Image subject of Gettyimage demand letter for $1065
Attention; Liz Williamson:

Dear Dr. Rothstein,
I obtained the following information/suggestions from my contact at the Consumer Protection
section of our office.
First, she says it takes a couple days for the complaints to get entered into the system so that she
can see them, and yours is not yet in the system.
So, option #1 is for you to fax the document to the CRC at 206.389.2801
Or #2, you can call the CRC at 1-800-551-4636 and coordinate with them how to get your
attachment to the complaint
Or #3, you can email the attachment to Liz Williamson of the Consumer Protection section and
she will get it where it needs to go her email is CPRcontact@atg.wa.gov.


From: Drted35@aol.com
To: susang@atg.wa.gov
Sent: 03/26/2013 3:09:53 P.M. Eastern Daylight Time
Subj: Document containing Image subject of Gettyimage demand letter for $1065

Dear Susan:
I'm getting anxious about sending you the document which contains the image that
WalliG 3/28/2013
428072
Gettyimages is demanding $1065 in their seven page legal letter I received last week.
I did receive confirmation that my complaint to the AG was received, however I have not as yet
received a complaint number.

Nevertheless I have attached the document containing the image--see attached.

In response to the GettyLetter, I removed the entire article which is lengthy and in which the
image (A bring oil lamp) can be found toward the end.

Cordially, Dr....
428072
Bob Ferguson
April 2, 2013
Getty Images
Seattle, WA 98104
RE: Ted Rothstein
File #: 428072
Dear Getty Images:
Our office has received the enclosed complaint from Ted Rothstein regarding your business.
428072.
JERI MARCUS
Complaint Analyst
(360) 738-6187
Fax: (360) 738-6190
belcrc@atg.wa.gov
Enclosure
JeriM 4/2/2013
428072
COMPLAINT SUMMARY
Name:
Ted Rothstein
Address:
35 Remsen St
Brooklyn, NY 11201
Day Phone:
(718) 852-1551
Evening Phone:
(718) 596-4633
E-mail Address:
drted35@aol.com
59+
Yes
Getty Images
Address:
Seattle, WA 98104
Phone:
(206) 925-6753
Toll-Free:
Fax:
(206) 925-5623
E-mail:
428072
Dr. Ted Rothstein
No
Salesperson's name:
No
No
No
Yes
No
428072
March 22, 2013
Dear Mr. Ferguson:
Gettyimages (605 5th ave. S, Ste. 400, Seattle WA 98104: www.gettyimages.com) sent me a 7-
page demand-letter for $1065 March 17, 2013 (notification #1314999) for infringing a
copyright image they claim to own. This type of infrinegment is currently referred to as an
"innocent infringement" by posting in image embedded in an religious educational article I
posted on my website on a subject of religion totally unrelated to my work as orthodontist and
solely for the purpose of supporting a video I had made documenting a ritual that religious Jews
carry out on a daily basis. I used a document published by a religous institution that included in
it the words reprint permission ##### and that contained the image in question.
It cotained an image of a burning Jewish oil lamp which had no indiction of a "copyright by
Gettyimages".
That same evening I removed the image and notified the source of sender of the "Demand
letter" that I had removed the document and the image . Two days later they emailed a "
Settlement" offer indicating they would accept $850 without any explanation of how they
arrived at that amount. I believe this kind of action is currently called "Speculation billing" In
this letter they threatened to commence a legal action in court if I did not agree to sum
demanded by March 26. Today I contacted the AG Washington State and requested all
complaints received by the AG which I was told were voluminous, and was further advised and
encouraged to register a complaint not only with the AG Washington State, but with AG of NY
State which I intend to do without a moment's delay. Yours truly, Dr. Ted Rothstein Ps. I am
sending under separate cover the document that includes the image referred to in the Getty
demand letter since I do not have access it at the computer I am using. I will send it and incluse
the refernce number that I receive upon sending this formal complaint.
Expected resolution details: I am requesting that they accept my apology for my innocent
infringement and forgo any demand for a settlement under threat of litagation.
Other
SIGNATURE
428072
Signature Dr. Ted Rothstein Date March 22, 2013
City and State where signed Brooklyn, NY
428072
C 1st Letter to Complainant To: drted35@aol.com
Bob Ferguson
April 2, 2013
Ted Rothstein
35 Remsen St
Brooklyn, NY 11201
RE: Getty Images
File #: 428072
Dear Ted Rothstein:
JERI MARCUS
Complaint Analyst
JeriM 4/2/2013
428072
(360) 738-6187
Fax: (360) 738-6190
belcrc@atg.wa.gov
428072
Re: Dr. Ted Rothstein (the Complainant)
Your File # 428072
recently.
circumstances.
AdaS 4/18/2013
428072
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
www.gettyimages.com
428072
Csup Closing Unadjusted (C-UNJ) To: drted35@aol.com
Bob Ferguson
May 1, 2013
Ted Rothstein
35 Remsen St
Brooklyn, NY 11201
RE: Getty Images
File #: 428072
Dear Ted Rothstein:
King County: 206-623-2551 or 211
JeriM 5/1/2013
428072
advice.
JERI MARCUS
Complaint Analyst
(360) 738-6187
Fax: (360) 738-6190
belcrc@atg.wa.gov
Enclosure
Re: Dr. Ted Rothstein (the "Complainant")
Your File # 428072
recently.
428072
Images imagery without paying a license fee. We recently identified the Complainant as having
used unlicensed imagery from our collections.
circumstances.
Regards,
Seattle, WA 98104
T: (206) 925-5000
F: (206) 925-5001
www.gettyimages.com
this email or any attachments hereto. Please notify the sender immediately by email if you have
received this email by mistake and delete this email and any attachments from your system
without copying or disclosing the contents. Email transmission cannot be guaranteed to be
secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or
428072
incomplete, or contain viruses. The sender therefore does not accept liability for any errors or
omissions in the contents of this message, which arise as a result of email transmission. If
www.gettyimages.com
428072
Bob Ferguson
May 1, 2013
Getty Images
Seattle, WA 98104
RE: Ted Rothstein
File #: 428072
Dear Getty Images:
Thank you for your recent communication in response to the complaint from Ted Rothstein. Ted
Rothstein has been informed of your response and that we have closed this complaint with
regard to our informal mediation service. We have notified the complainant of the availability of
private legal remedies in the event the complainant wishes to pursue this matter further.
JERI MARCUS
Complaint Analyst
(360) 738-6187
Fax: (360) 738-6190
belcrc@atg.wa.gov
JeriM 5/1/2013
428072
http://www.m.drted.com/Tefillin.htm
Removed 03/18/13
Upon receipt of 7 page letter from gettyimages r 031813 and speaking with rep who
notified me of the url (see above) where the image is located.
The above page with image included was removed at 8:45 031813 upon request to the
ixwebhosting representative.
Back to Resume Back to Home Page Back to Site Additions

Dr. Ted Presents: Wrapping with Rabbi Aaron
Shalom: Atheists, agnostics, and the just plain curious are welcome here. This film is an
educational documentary on the application and use of "Tefillin" during prayer among Orthodox
Jews. Dr. Ted invited Rabbi Aaron Raskin of Congregation B'nai Avraham, Brooklyn, NY to
demonstrate in real time how Orthododox Jewish men don two prayer boxes: one on their arm
and one on their head, as the prologue to reciting /("davening" the Hebrew word for reciting) the
morning prayers. Read on below to learn the origin and meaning of the ritual as well as the
controversies surrounding this little known ritual (even among Jewish people) which is practiced
by, and largely known, mostly to Orthodox Jewish people...one of the three major divisions of
Judaism. You will learn what is in the prayer boxes along with a transliteration from Hebrew to
English. Shalom, Dr. Ted Rothstein, June 12, 2009.
A documentary film on the application and use of Tefillin during prayer among
Orthodox Jews
Tefillin: Part I Tefillin: Part II
Questions put to the Rabbi**
Aired Monday, May 18, 2009: BCAT 1: TimeWarner cable channel 34 /
Cablevision 67 / RCN 82 / Verizon 42 and streams on briconline.org/bcat
Click on the link below to learn about the prayer that is said when the boxes are in place
on your arm and head and the prayers that are written on parchment inside the black boxes.
Tefillin
...and so much more below
[ AN OVERVIEW OF THE "MITZVAH" OF DONNING TEFILLIN FOR THE
MORNING PRAYER: ] Each of the two boxes that are ceremonially wrapped
around the arm and head of one who practices this rite (see photo below)
contains the same four scriptural passages see Tefillin , but the box worn on the
head contains four separate parchments while the box on the arm has all four
scriptural passages on one parchment.] I will ask the Rabbi why that is so.
Donning Tefillin is done on weekdays and Sunday when davening
(praying/reciting) the morning prayers. It takes about 5 minutes to attach by
wrapping the Tefillin upon and around the arm and the head. The arm (the left
arm if you are right-handed and the right arm if you are left-handed) is wrapped
first, followed by a brief prayer after which one remains silent until the main
prayer is completed. If one inadvertently speaks one must recite another one
line prayer before continuing on to the main prayer. The main prayer takes about
one minute to recite. The entire ceremony of placing the Tefillin, saying the
prayer and removing the boxes, rewrapping them and replacing them in the
deep-blue or crimson velvet-covered special cloth case, in which they are kept,
takes about 15 minutes. The donning of Tefillin is a mitzvah (scriptural
commandment) that many orthodox Jews, in particular, the group of people who
are known as the Lubavitcher Hasidim, Donning Tefillin in essence is a
commemoration and reminder/indication of the exodus of the Jewish people from
Egypt where they were slaves for about 225 years. The Mitzvah of donning
Tefillin fulfills the reminder. By and large the great majority of Jewish people are
entirely unfamiliar with this traditional ritual in which one reaffirms that The lord
our G-d "Hashem" --"The Name", the lord is one. And, you should love your G-d
with all your soul and all your might. Moreover, it behooves you to teach your
children to do the same. Indeed you should go so far as to place this reminder
on the doorpost of your house, and moreover, wear this reminder on your arm
and your forehead. The most adherent observers of this ritual are to be found
among those who practice Orthodox Judaism. Other, more modern subdivisions,
are known as Reform and Conservative divisions have assimilated the religion in
to a more main stream way of American life. Indeed, in real life the practice of
Judaism ranges far and wide across a broad spectrum of practices and beliefs.
One has only to mention those Jews who follow the "Jews for Jesus"" movement
to realize how far-ranging is the daily practice of Judaism. Traditionally, at the
conclusion of the prayer each day one sets a side a charitable contribution. For
some, performing the prayer opens a direct channel to the "Author" of all. One
recites the prayer with heartfelt emotions and when one is done it is as though at
that moment the heavens sent forth a ray of divine light which infuses your being.
Although the daughter(s) of the great medieval Talmudic scholar, Rabbi Shlomo Yitzchaki,
better known by the acronym, Rashi, (who had no sons) were purportedly permitted to don
Tefillin, it is very controversial among the orthodox to accept the idea of women wearing the
phylacteries. The reason for this will be provided by Rabbi Aaron.
Out of respect for my rabbi and other orthodox rabbis who might be put off (to say the least) by
seeing a photograph of an observant Jewish female (Dani Shapiro) wearing Tefillin and a typical
prayer shawl (Talit) as well, I have provided a link to that photograph. LINK.
image from Google images
Main Entry:
PHY-LAC-TERY
Pronunciation:
\f-lak-t(-)r\
Function:
noun
Inflected Form(s):
plural phylacteries
Etymology:
Middle English philaterie, from Medieval Latin philaterium, alteration of Late Latin
phylacterium, from Greek phylaktrion amulet, phylactery, from phylassein to
guard, from phylak-, phylax guard
Date:
14th century
1 : either of two small square leather boxes containing slips inscribed with scriptural
passages and traditionally worn on the left arm and on the head by observant Jewish men
and especially adherents of Orthodox Judaism during morning weekday prayers 2 : amulet
[phylactery illustration]
TE-FIL-LIN
Pronunciation:
\t-fi-ln also -lm\
Function:
noun plural but sometimes singular in construction
Etymology:
Late Hebrew tphln, from Aramaic, attachments
Date:
1613
: the phylacteries worn by Jews
Learn more about "tefillin" and related topics at Britannica.com

Tefillin

The are about 13.5 million Jewish people in the world. By far the largest population of
Jewish people can be found in Israel. 5.7 million are located in North America of which 5.2
million reside in the United States. New York City contains about 2 million Jewish persons
and about 500,000 Jewish people dwell in Brooklyn.

Tefillin are two small black boxes with black straps attached to them; Jewish men
are required to place one box on their head and tie the other one on their arm each
weekday morning. Tefillin are biblical in origin, and are commanded within the
context of several laws outlining a Jew's relationship to God. "And you shall love
the Lord your God with all your heart, with all your soul, and with all your might.
Take to heart these instructions with which I charge you this day. Impress them
upon your children. Recite them when you stay at home and when you are away,
when you lie down and when you get up. Bind them as a sign on your hand and let
them serve as a frontlet between your eyes" (Deuteronomy 6:5-8).
Certain Jewish groups including probably the Sadducees, and definitely the
medieval Karaites understood the last verse to be figurative; it means only that
one should always be preoccupied with words of Torah, as if they were in front of
one's eyes. The Pharisees, however, took the text literally; the words of the Torah
are to be inscribed on a scroll and placed directly between one's eyes and on one's
arm. Tefillin are wrapped around the arm seven times, and the straps on the head are
adjusted so they fit snugly.
The text that is inserted inside the two boxes of Tefillin is hand-written by a scribe,
and consists of the four sets of biblical verses in which Tefillin are commanded
(Exodus 13:1-10, 11-16; Deuteronomy 6:4-9, 11:13-21). Because each pair of
Tefillin is hand-written and hand-crafted, it is relatively expensive, and a well-made
pair costs several hundred dollars.
The word Tefillin is commonly translated as "phylacteries," though the Hebrew
term is more often used. I have never met a Jew who puts on Tefillin who calls them
"phylacteries."
Putting on Tefillin is the first mitzvah assumed by a Jewish male upon his Bar
Mitzvah. Usually, boys are trained to start wearing them one to two months before
their thirteenth Hebrew birthday. During the training period, boys don Tefillin, but
do not recite a blessing. Subsequent to the Bar Mitzvah, a specific blessing,
"Blessed are You, Lord our God, King of the universe, who has sanctified us with
His commandments and commanded us to put on Tefillin, " is recited whenever
they are worn. Many Jews say an additional blessing and prayer upon putting on
Tefillin.
Tefillin are worn each weekday morning, but not on the Sabbath or on most Jewish
holidays. On the fast day of Tisha Be'Av, and on that day only, they are put on
during the afternoon instead of the morning service.
Among observant Jews, Tefillin is a mitzvah of the greatest significance. Recently,
an eighty-nine-year-old rabbi told me that, in the seventy-six years since his Bar
Mitzvah, he had not missed putting on Tefillin even once. Since the Holocaust,
stories have circulated of Jews who managed to smuggle Tefillin into Nazi

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