UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

~ ~ i ; i i i ~ i ~ ~ : ~ ~ ~ ~
Plaintiff,
-against-
BLACK ENTERTAINMENT TELEVISION, LLC
Defendants.
-------------------------------------------------------------x
511
COMPLAINT
ECFCASE
JUDGE OETKEN
Plaintiff, ARMEN DJERRAHIAN, by his attorneys, EDWARD C.
GREENBERG, LLC alleges as follows:
PARTIES
1. Plaintiff ARMEN DJERRAHIAN (hereinafter "Plaintiff' or
"DJERRAHIAN") is an individual citizen of France, who is actively engaged in the
photography business in the State of New York and elsewhere, and who resides in
Brooklyn, New York 11222.
~
2. Defendant BLACK ENTERTAINMENT TELEVISION, LLC (hereinafter
"BET") is a foreign limited liability company duly organized and existing under the laws
of the District of Columbia, is authorized to do business in the State and County ofNew
York, and has upon information and belief, an office to do business located at 1540
Broadway, New York, New York 10036.
JURISDICTION AND VENUE
3. This is a civil action for copyright infringement.
4. Jurisdiction is conferred upon this Court by 28 U.S.C. 1338.
/)
5. Venue in the Southern District ofNew York is proper pursuant to 28 U.S.C.
1400.
FACTS COMMON TO ALL CLAIMS
6. That Plaintiff DJERRAHIAN is a successful professional photographer with
many years of experience and a considerable reputation.
7. DJERRAHIAN is well known in the hip hop music business, as he has
worked with major artists including Jay-Z, Usher, 50 Cent, Eminem, Kanye West, Rick
Ross and director Spike Lee.
8. DJERRAHIAN's work has been featured on the covers of several issues of
Vibe Magazine, and on The Wild Magazine, XXL Magazine, and numerous international
publications.
9. DJERRAHIAN has shot and directed music videos and commercials,
including a music video featuring R&B recording artist Melanie Fiona, which received a
nomination for [Best] "Video of the Year" at the 2010 BET Awards, sponsored by the
defendant herein.
10. DJERRAHIAN is also a successful fashion photographer who has shot photos
for Shinola, Cazal Eyewear, Nike, Fila, Reebok, Marc Ecko, and commercials for Elle
Magazine, Revlon, Van Cleef & Arpels, and Piaget.
THE IMAGES
11. On June 27, 2012, DJERRAHIAN shot images of rap music artist "Gunplay"
and other members of the record label imprint May bach Music Group, such as those
known as Rick Ross, Meek Mill, Omarion, Stailey and Wale. A portion of such images
were published in the August/September 2012 issue of Vi be Magazine.
12. One of such images of the hip hop recording artist Richard Morales, Jr,
better known as "Gunplay", captures him holding his shirt jacket partially open to reveal
his chest and with an energetic look on his face (hereinafter the "Subject Image", a copy
of which is annexed hereto within Exhibit "A").
13. DJERRAHIAN is well known as the creator of the Subject Image, having
been credited for same when the Image was originally published in Vibe Magazine.
14. Upon information and belief, defendants knew, by actual and/or
constructive knowledge, that plaintiff was the creator of the Subject Image.
15. DJERRAHIAN duly registered the Subject Image with the United States
Copyright Office on December 25, 2013, Registration No. VA 1-899-797 (a copy of said
registration is annexed hereto as Exhibit "B").
16. Gunplay is a hip hop recording artist who has released several mixtapes, as
well as the studio albums "Medellin" and "Living Legend".
17. The Subject Image of Gunplay is iconic in the hip hop community.
18. Upon information and belief, various blogs referring to Gunplay have
purposely selected the Subject Image of him due at least in part to its value and attention
getting nature.
19. While other images of Gunplay, created by other photographers, are available
for licensing via conventional business methods, the Subject Image is not similarly
available for licensing.
20. The Subject Image creatively captures the personality Gunplay.
21. Upon information and belief, since the Subject Image's creation, the Subject
Image has helped to shape and form Gunplay's "brand" in the hip hop music community.
22. Each of the Subject Image is an important element of hip hop music culture.
23. The Image of Gunplay is upon information and belief, the definitive image of
Gunplay.
24. Defendant BET operates the website vvww.bet.com, a website publishing
news and content about aspects of hip hop culture including information pertaining to the
lives of celebrities, music, news, and television programs on BET's television station
"Black Entertainment Television", also known as "BET".
25. Defendant disseminates entertainment, news and information by way of
the world wide web, television, and upon information and belief video.
26. BET describes itself as "the leading provider of music, entertainment, and
lifestyle information for the African American and urban online audience."
27. Defendant's target audience or demographic is "urban" and it purports to
cover urban culture including rap and hip hop music as well as other forms of
entertainment and news of interest to its predominantly urban audience.
28. That BET touts that it "has 100% brand recognition in the African-
American community", and is "one of the most trusted brands among African-
Americans.
29. Upon information and belief, BET targets "up to a half billion impressions
a month across premium publisher sites" and "specific ad network content like
entertainment, music, lifestyle and news."
30. The Subject Image is valuable to Defendant, helps to brand the defendant's
website.
THE OFFENDING USES OF THE IMAGES
31. Defendants have employed DJERRAHIAN' s Ross Image at least on its
website www.BET.com, under the heading "25 Best Twitter Moments of2013", a copy
of which is annexed hereto as Exhibit "C".
32. Defendant has employed the Subject Image on its website without a license
authorization or consent.
33. Upon information and belief, defendant's use of the Subject Image on its
website was intended to steer traffic to its website.
34. Upon information and belief, BET employed the Subject Image on its website
because the Subject Image attracts viewers, and owing to the image's notoriety,
economically illustrates, brands, and directs the viewer to other aspects and content of the
BET website.
35. Upon information and belief, other images of Gunplay are available on the
internet from photo stock licensing companies in exchange for modest licensing fees.
36. That rather than obtain an image of Gunplay from a stock photography
company, defendant selected and employed the Subject Image, without paying any
compensation to anyone in exchange for such use, and without obtaining plaintiff's
license, authorization or consent.
3 7. Defendant never sought nor obtained a license by DJERRAHIAN to use
either of the Subject Images as complained of herein.
38. DJERRAHIAN never granted defendant a license, nor provided
authorization or consent to defendant to use the Subject Image in any media whatsoever.
39. Pursuant to Federal Rule 11, Plaintiff has sought to obviate the filing of
suit.
40. On May 14, 2014, DJERRAHIAN, by his counsel, sent a written notice
letter to BET, addressed to the New York address of 1540 Broadway, New York, New
York 10036, advising it, inter alia, to remove our client's image from its website,
. . . . . . . . . . . . . . . . . . ~ ~ ~ ' that its use of the Subject Image was in violation of DJERRAHIAN' s
copyright, and that it has no right to use Subject Image in any way, shape or form
(hereinafter the "May 14, 2014 Letter", a copy of which is included within Exhibit "D",
sans its exhibits which are elsewhere attached to this Complaint).
41. The May 14, 2014 Notice Letter further sought a disclosure from
defendants of the full nature and extent of its unauthorized uses of the Subject Images so
that Plaintiff could in good faith formulate a reasonable fee to compensate him for the
unauthorized uses.
42. That no response was ever received to the May 14, 2014letter.
43. As of at least June 3, 2014, the Subject Image remained on the BET
website.
44. On June 10, 2014, DJERRAHIAN, by his counsel, sent a second written
notice letter to BET, addressed to its District of Columbia address of One BET Plaza,
1235 W Street NE, Washington, DC 20018, with an additional copy of the May 14,2014
Letter enclosed, again seeking a response to the May 14, 2014 letter (hereinafter the
"June 10, 2014 Letter", a copy of which is attached hereto as Exhibit "D", with its
referenced enclosure).
45. That BET responded to the June 20, 2014 Letter, but notwithstanding, the
parties have been unable to come to a resolution sans judicial intervention.
46. Plaintiff has sought to obviate judicial intervention and the filing of suit.
Such efforts have gone without success.
47. That defendant apparently removed the Subject Image from
www.bet.com.
48. The full nature and extent of all infringing uses of plaintiffs Subject
Image by defendant is unknown to Plaintiff as of this writing, said information being
within the sole knowledge, custody, and control of Defendants. That such details and
information are expected to be ascertained through discovery in this action.
49. Defendant has failed to disclose all manner and media in which it has
employed the subject image.
50. Defendant has failed to disclose all dates and locations for where it has
employed the subject image.
51. Defendant has failed to provide any compensation to Plaintiff for its uses
of the Subject Images without a license, authorization or consent, in violation of the
exclusive rights granted to Plaintiff as the copyright holder.
52. Upon information and belief defendant is a sophisticated licensor and
licensee of intellectual property and knew that it must obtain the rights to intellectual
property created by third parties prior to its use of same.
53. Upon information and belief, defendant failed to adhere to the procedures and
protocols necessary for it to obtain the rights to use the Subject Image prior to its use of
same.
54. Plaintiff is committed to protecting his copyright in the Subject Image.
55. Plaintiff has filed actions against others in the United States District Court,
sounding in copyright infringement, for the alleged unauthorized use of the Subject
Image and other images created by plaintiff, including but not limited to index number
14-cv-3291, before Judge Oetken.
56. That the Defendant has no defenses at law to the claims set forth herein.
57. Paragraphs "1" through "55" are incorporated by reference with respect to the
below claim for relief.
FIRST CLAIM FOR RELIEF
Copyright Infringement
Under Section 501 of the Copyright Act
58. That the use of the Plaintiffs Subject Image by the Defendant in connection with
the website, www.bet.com, was and is without the plaintiffs authorization, license or
consent.
59. The Defendant has infringed the copyright in Plaintifrs Subject Image.
60. The acts of the Defendant constitute federal statutory copyright infringement
under Section 501 of the Copyright Act in violation of the rights granted to
DJERRAHIAN as copyright holder.
61. Upon information and belief, Defendant's uses of the Subject Image were willful,
intentional, malicious, and in bad faith.
62. Upon information and belief, defendant's uses of the Subject Image in violation
of Plaintifr s copyright were negligent in that it knew or should have known that it was
without a license for the use(s) complained of herein.
63. Upon information and belief, defendant had actual and/or constructive knowledge
and/or through the exercise of ordinary business care and/or the examination of public
records, knew or should have known that Plaintiff held the copyright in the Subject
Image, that defendant(s) never had a license, consent, or authorization by Plaintiff for the
use of the Subject Image on its website or in any other medium employed by defendant,
and that any such use would be in violation of Plaintiffs copyright.
64. Plaintiff is a professional photographer who earns his livelihood by licensing
rights to third parties to employ his photographic images.
65. That as a result of Defendant's acts, Plaintiff has been and will continue to be
damaged in an amount as yet to be determined.
66. The Copyright Act enables a prevailing plaintiff to elect to recover statutory
damages attorneys' fees and costs under Section 504 and 505 of the Copyright Act, 17
U.S.C. Section 101 et., seq., or as an alternative to statutory damages, his actual damages
and any additional profits of the defendants, or one or more of them, which are
attributable to the infringement as under 17 U.S.C. Sections 504 (a)-(b).
67. That Plaintiff has been harmed in an amount to be determined by this Honorable
Court.
68. That as a result of defendant's acts, Plaintiff has been and will continue to be
damaged in an amount as yet to be determined.
JURY DEMAND
51. That Plaintiff requests a trial by jury of all issues.
WHEREFORE, plaintiff demands judgment as against the defendant as follows:
ON THE FIRST CLAIM- (A) Award to plaintiff his actual damages incurred as
a result of defendant's infringements, and all profits realized as a result of its
infringements, in amounts to be determined at trial; or (B) in the alternative, at plaintiffs
election, award to plaintiff maximum statutory damages pursuant to 17 U.S.C. 504 for
each individual act of infringement, and for an order of injunction permanently enjoining
and prohibiting the defendant, including but not limited to wholly owned subsidiaries,
from employing or utilizing in any manner or media whatsoever, including all future
uses, sales, transfers, assignments, or licensing of plaintiffs copyrighted Image, pursuant
to 17 U.S.C. 502 and for an award of costs and attorneys' fees pursuant to 17 U.S.C.
505;
Prejudgment interest on all sums due;
And such other and further relief as this Court may deem just and proper inclusive
of any and all relief or remedies allowable by the statutes referenced above or applicable
hereinabove.
Dated: New York, NY
October 24, 2014 Yours, etc.,
EDWA
By: Edward C. Gre er q. (ECG 5553)
By: Tamara L. Lannin, Esq. (TL 3784)
570 Lexington Ave., 19th Floor
New York, NY 10022
Tel: (212) 697-8777
Fax: (212) 697-2528
Attorneys for Plaintiff
Certificate of Registration
fh,) seai (lfthc: Copvright
in a.:c.,rdancc with 1tlc n Uuin:d CC)(Ir.
llt')IS th.11 re"tt istration has h.-en made for the l'o lrk
below. Th.:: infi1rmat inn on n ..
made a part o( the Copynght OHke
Regtst er of Ct)pyrights, United State;< ol America
Registratio Nember
VA 1-899-797
Effective date of
registration:
December 25.2013
ntle ---------------------------
Title of Work: Vibe magazine Aug/ Sept 2012 feat May bach Music Group's artists: Rick Ross, Meek
Mill. Wale, Omarion, Stailey. Gunplay
Completion/Publication ------------------
Year of Completion: 20 J 2
Author
Date of ht Publicatioa: September I, 2012

Autbor: Annen Charles Djerrahian
Pseudonym: annenexpo
Author Created: photograph(s)
Citizen of: France
Year Bom: 1969
Copyright claimant
Copyright Claimant: Annen Charles pjerrahian
Nation of ht Public:atioo: United States
Domiciled in: United States
164 Russell Street. Apt#2R, Brooklyn. NY, II 222
Rights and Pennissions
Certification
Name: Annen Charles Djerrahian
Email: nnenexpo.com
Address: 164 Russell Street, Apt#2R
Brooklyn, NY 11222
Name: Am1en Djerrahian
Date: December 25.2013
Telepbone: 646-642-163 3
Page I of 2
c
Tamara L. lannin
BY PRIORITY MAIL
I
. . I .
EDWARD c. GREENBERG, LLC
+T LAW
570 LEXINGTON AVENlJE, 19TH FLOOR
. NEW YORK, NY 10022
TELEPHONE: 697-87.77
. FACSIMILE: (212). 697-25'28
ECGLAW@G. .COM
une 10, 2014
Black Entertainment Television, LLC
At1n: Lawrence Cooper, General Counsel
One BET Plaza
1235 W Street NE
Washington, DC 20018
Re: Armen Dierrabian w/ Blilck Television, LLC
Our File: C439p/13
I .
Of Counsel:
Debra S .. Relser
Dear Mr. Cooper: . I .
We enclose an additional copy of our letter to! you dated May 14, 2014 hand delivered to
the BET office located in New York. To date, we havrle not received any fron1 you.
Please provide a meaningful response to our letter by
1
Tuesday, June 17,2014.
I .
Failing we will be to pursut our client's available remedies.
cc: Armen Djenahian via email
Encl.
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'AR.i::>c:-GREEN RG
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EDWARD C. GREENBERG, LLC
COUNSELORS AT LAW
Tamara L. Lannin
tl.ecglaw@gmail.com
BY HAND DELIVERY
570 LEXINGTON A VENUE, 19n-t FWOR
NEW YORK, NY 10022
TELEPHONE: (212) 697-8777
FACSIMILE: (212) 697 .. 2528
ecglaw@gmail.com
May 14,2014
Black Entertainment Television LLC
Attn. General Counsel
Business and Legal Affairs
1540 Broadway
New York, NY 10036
Re: Annen Djerrahian w/ BET; Onr File C439p/13
Dear Sir or Madam:
Of Counsel:
Debra S. Reiser
We serve as retained copyright litigation counsel to Mr. Annen Djerrahian,.a
photographer of considerable reputation. Thisoffice routinely litigates matters of this
nature.
. We write regarding the unauthorized uses of our client's image of the
performer ''Gunplay''. A copy of our client's image is annexed hereto as Exhibit "A"
(the "Subject Images"). Mr. Djerrabian is the sole owner of and holds the copyright in
the Subject Image, which was registered with the United States Copyright Office on
December 25, 2013, registration number VA 1-899-797. A copy of said registration is
annexed hereto as Exhibit "B".
You have employed our client's registered image at least on your website,
www. bet.com, without his license, authorization or consent. A copy of at least one
offending use is annexed hereto as Exhibit "C".
Mr. Djerrahlan is well known as the creator of the subject images.
Notwithstanding, no one from yom company, nor an agent thereof, has ever sought or
obtained a license from Mr. Djerrahian .to employ the subject image for any purpose
whatsoever. Rather, you appear to have simply employed the photographs at you.r
election, without a license, authorization or consent from the copyright holder; this
directly violates the exclusive rights granted to the copyright holder of the images.
As you must be aware, the use of a creator's photographic image without written
consent or license is violative of the United States Code, Title 17, and The Copyright
Act. Said federal statute affords the creator a plethora of remedies including one or more
of the following: monetary relief in the form of compensatory and or statutory damages,
an award qf attorney's fees and/or an injunction directing removal of the offending
materials from the market place pending litigation.
Our client is committed to protecting his copyright and, as of the date of this
letter, is involved in a litigation regarding the unauthorized use of his images. See inter
alia, Djerrahian v. William Leonard Roberts, 1/p/k/a Rick Ross et al., 14 .. Cv-3291 (JPO)
(Southern District of New York).
This letter shall serve as notice that You immediately cease and desist any and all
unauthorized uses of our client's image. Any additional or further uses of our client's
images will be at your peril.
If you are in possession of any contract, license, agreement or writing of any kind
or nature upon which you intend to rely for the proposition that such usage is authorized
or in the alternative, conclusively establishes that our client's claim is without merit,
formal request is made herein to provide Such request is made pursuant to Federal
Rule 11 in a good faith effort to obviate litigation. Failing the production of such
license we will be constrained to assume that such usage is violative of law. In such
event, we intend to institute suit against your production and any other appropriate
defendants in the United States District Court for the Southern District of New York
forthwith.
In the event you are not in possession of any exculpatory documents, and pursuant
to our obligations under Rule 11, Rule 130 (and any other substantially equivalent rules
or formal request is made herein for the following information and
documents reflecting or demonstrating the requested information:
1. The full nature and extent of the use of our client's image, in any and all
formats, inclusive of the broadcast media and websites described herein as
well as distribution on any other websites or programs owned, operated, or
affiliated by Your company, inclusive of: a description of such uses, the
commencement of the terms of such use(s ), and location( s) of such uses or
display ..
2. Representative copies in any and all tangible form and media in which our
client's image were incorporated or employed;
3. The source of the image(s) and the identities of the persons or companies
preparing, supplying, editing, and/or producing same;
4. Copies of written agreements or documents, with any and all persons or
entities, referencing the creation, and reproduction regarding the offending
use(s) of our client's image; .
2
5. Copies of any documents in any format upon which you intend to rely for
the proposition that Mr. Djerrahian had knowledge of and/or agreed to
have his images published by Your company, inclusive of any emails or
documents of any kind by and between Your company (and/or those acting
on your behalf) and Mr. Djerrahian (and/or those acting on his behalf);
6. Copies of any purported license or assignment relating to the images
referenced herein and issued to.your company by any third party;
7. The nature and extent of any prospective license(s) you may be seeking to
allow for prospective authorized use(s), or which will provide adequate
time to remove the offending images from the web obviating plaintiff's
need to seek judicial intervention for the purposes of obtaining an
injunction prohibiting any and all uses such offending uses of his image;
8. Copies of any copyright registrations filed with any government or agency
thereof referencing, relating or -including the imagery complained of
herein;
9. Copies of written agreements or documents, with any and all persons or
entities with whom you have transferred, assigned, licensed, or provided
the image, which reference the subject images and/or any corresponding
products or publications in which the image(s) are employed;
10. The identity of all third parties to whom You supplied the image(s).
11 Data showing the web traffic and analytics for each page of Your website
that has employed our client's Image without his license, authorization or
consent.
12. Documents reflecting the sales figures and profits realized from use of our
client's image by You, including but not li:Qlited to advertising sales,
profits and revenue for Your website and/or company;
Upon receipt of such information we can fairly consider and determine an
amount of compensation which may or may not include the granting of a
limited license for prospective use or in the alternative, a brief period of time within
which to permit removal of the image from the production. It is not our client's
preference_ to commence litigation and he would prefer to resolve the matter promptly
and amicably. In order to do so, receipt of the .above requested information within seven
(7) business days of date is essential.
The following is to formally notify you, your company, its agents, employees and
contractors not to destroy, conceal or alter any goods, information, and/or images
stored in electronic form or generated by your computer systems or electronic devices
including but not limited to its web sites. This information appears relevant to the above
matters and may be unavailable from any other source. As you may know, such
electronic inforniation can easily be inadvertently destroyed and the failure to take
reasonable measures to preserve it pending the completion of discovery can result in
sanctions being imposed against you or your company. See, e.g., Cedars Sinai Med Ctr.
v. Superior Ct. (1998) 18 Cal 4th 1, 74 Cal Rptr 2d 248; Zubulake v. UBS Warburg LLC
(SDNY 2003) 220 FRD 212,216.
3
In order to comply with the discovery requests that we will make in this matter
you may need to provide electronic evidence in its native fonnat You may also need to
provide electronic documents, along with the metadata or information about data that is
contained in those electronic documents. Even when a paper copy of a document or file
exists, we will also seek the documents or files in their electronic format so that we also
receive the information in the metadata. Our discovery requests will include certain data
on your hard drives, floppy discs, and backup files, and will include data not usually
available to the ordinary computer user, such as deleted files and file fragments.
Thus the electronic data and the storage devices in which they are kept that you
are obligated to maintain and preserve during the pendency of the discovery planned in
this case include all of the following data and devices:
1. Electronic files including deleted . files and file fragments, stored in
machine-readable format on magnetic optical or other storage media,
including hard drives or floppy disks in your client's desktop computers,
laptop computers, home personaf computers, zip drives, external hard
drives, usb keys, and the backup media used for each;
2. E-mail, both sent and received, internally or externally;
3. Telephone files and logs such as voicemail and universal mobile
telecommunications systems (UMTS) data;
4. Word processing files, including drafts and revisions;
5. Spreadsheets, including drafts and revisions;
6. Databases;
7. Electronic files in portable storage devices such as floppy discs, compact
discs, digital video discs, ZIP drives, thumb drives or pen drives;
8. Graphs charts and other data produced by project management software;
9. Data generated by calendaring, task management and personal information
management software, such as Microsoft Outlook;
10. Data created with the use of or stored on personal data assistants such as
Palm.Pilot inclusive of substantially equivalent devices;
11. Data created, derived and/or edited with the use of editing software such as
Photoshop, Adobe, and any accompanying software;
12. Data created with the use of paper and electronic mail logging and routing
software;
4
I 3. Internet and web-browser generated history files, caches, and "cookies"
generated by your client or at the workstation of each employee in your
client: s employ and on any and _all backup storage media;
14. Logs of network use by you and your distributors and/or customer's
employees, whether kept in paper or electronic format;
15. Copies of your backup tapes and the software necessary to reconstruct the
data on those tapes on each and every personal computer or workstation
and network server in your client's control and custody;
16. Electronic information in copiers, fax machines and printers;
17. Web-site files and records of any kind and all histories of those files;
18. All records of sales generated and processed through software for goods
employing the offending image.
19. Records, copies, reproductions and evidence set forth above. existing or
printed on physical paper or paper product(s ).
As previously stated, and as your legal counsel will be aware, the failure to
maintain such information, and any other electronic information which may be called
upon in discovery, can lead to severe penalties in the discretion of the Court. We strongly
urge you to retain independent legal counsel and provide him/her with a copy of this
letter and its enclosures.
We require delivery of the above sought documentation within seven (7) days of
. date. Absent an exculpatory document or license, any and all uses of our client's images
will be made at your peril. Should we fail to hear from either you or your counsel we will
file suit in the United States District Court against your company and any other
appropriate defendants without further notice.
cc: Annen Djerrahian via e mail
Encl.
5
JS 44C/SDNY
REV. 4/2014
JUDGE OETKEN
CIVIL 4
cv
51
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of
pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the
Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of
initiating the civil docket sheet.
PLAINTIFFS
ARMEN DJERRAHIAN
DEFENDANTS ocr 2'4


BLACK ENTERTAINMENT TELEVISION, LLC l'f
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
EDWARD C. GREENBERG, LLC, 570 LEXINGTON AVENUE, 19TH
FLOOR, NEW YORK, NY 10022, 212-697-8777
ATTORNEYS (IF KNOWN)
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
17 U.S.C. 501-505 (Copyright Infringement)
Has this action, case, or proceeding, or one essentially the same been previously filed in SONY at any time? Ndates0Judge Previously Assigned
If yes, was this case Vol. 0 lnvol. D Dismissed. No
Yes D If yes, give date----------& Case No.----------
Is THIS AN INTERNATIONAL ARBITRATION CASE? Yes 0
(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT
CONTRACT
[ 1110
[ 1120
[ 1130
! 1140
[ 1150
[ 1151
[ 1152
[ 1153
[ 1160
[ 1190
[ 1195
INSURANCE
MARINE
MILLER ACT
NEGOTIABLE
INSTRUMENT
RECOVERY OF
OVERPAYMENT &
ENFORCEMENT
OF JUDGMENT
MEDICARE ACT
RECOVERY OF
DEFAULTED
STUDENT LOANS
(EXCL VETERANS)
RECOVERY OF
OVERPAYMENT
OF VETERAN'S
BENEFITS
STOCKHOLDERS
SUITS
OTHER
CONTRACT
CONTRACT
PRODUCT
LIABILITY
[ 1196 FRANCHISE
REAL PROPERTY
[ ]210 LAND
CONDEMNATION
[ )220 FORECLOSURE
[ ] 230 RENT LEASE &
EJECTMENT
[ )240 TORTS TO LAND
[ )245 TORT PRODUCT
LIABILITY
[ ]290 ALL OTHER
REAL PROPERTY
TORTS
PERSONAL INJURY
[ ]310 AIRPLANE
[ ]315AIRPLANE PRODUCT
LIABILITY
[ 1320 ASSAULT, LIBEL &
SLANDER
[ I 330 FEDERAL
EMPLOYERS'
LIABILITY
[ 1 340 MARINE
I I 345 MARINE PRODUCT
LIABILITY
I 1 350 MOTOR VEHICLE
I 1 355 MOTOR VEHICLE
PRODUCT LIABILITY
I 1 360 OTHER PERSONAL
INJURY
[ 1 362 PERSONAL INJURY
MED MALPRACTICE
ACTIONS UNDER STATUTES
CIVIL RIGHTS
PERSONAL INJURY FORFEITURE/PENAL TV
[ ] 367 HEAL THCARE/
PHARMACEUTICAL PERSONAL [ 1625 DRUG RELATED
INJURY/PRODUCT LIABILITY SEIZURE OF PROPERTY
I I 365 21 USC 881
[ I 368 ASBESTOS PERSONAL [ 1
690
OTHER
INJURY PRODUCT
LIABILITY
PERSONAL PROPERTY
[ I 370 OTHER FRAUD
[ 1371 TRUTH IN LENDING
[ I 380 OTHER PERSONAL
PROPERTY DAMAGE
[ I 385 PROPERTY DAMAGE
PRODUCT LIABILITY
PRISONER PETITIONS
[ 1463 ALIEN DETAINEE
LABOR
[ 1710 FAIR LABOR
STANDARDS ACT
[ I 720 LABORIMGMT
RELATIONS
[ ]740 RAILWAY LABOR ACT
[ I 510 MOTIONS TO [ 1 751 FAMILY MEDICAL
VACATE SENTENCE LEAVE ACT (FMLA)
28 usc 2255
[ I 530 HABEAS CORPUS [ I 790 OTHER LABOR
[ I 535 DEATH PENALTY LITIGATION
[ 1440 OTHER CIVIL RIGHTS [ ] 540 MANDAMUS & OTHER [ I 791 EMPL RET INC
(Non-Prisoner) SECURITY ACT
[ 1 441 VOTING
IMMIGRATION
[ 1442 EMPLOYMENT PRISONER CIVIL RIGHTS
[ 1443 HOUSING/ [ 1462 NATURALIZATION
ACCOMMODATIONS [ 1550 CIVIL RIGHTS APPLICATION
[ 1445 AMERICANS WITH [ J 555 PRISON CONDITION [ 1465 OTHER IMMIGRATION
DISABILITIES [ 1560 CIVIL DETAINEE ACTIONS
EMPLOYMENT CONDITIONS OF CONFINEMENT
[ 1446 AMERICANS WITH
DISABILITIES -OTHER
[ ]448 EDUCATION
Check if demanded in complaint:
ACTIONS UNDER STATUTES
BANKRUPTCY
[ 1422 APPEAL
28 usc 158
[ 1423 WITHDRAWAL
28 usc 157
PROPERTY RIGHTS
[XI 820 COPYRIGHTS
[ 1830 PATENT
[ 1 840 TRADEMARK
SOCIAL SECURITY
[ ]861 HIA (1395ff)
[ I 862 BLACK LUNG (923)
[ 1863 DIWC/DWW'/ (405(g))
[ ] 864 SSID TITLE XVI
[ I 865 RSI (405(g))
FEDERAL TAX SUITS
[ 1870 TAXES (U.S. Plaintiff or
Defendant)
[ 1871 IRS-THIRD PARTY
26 usc 7609
OTHER STATUTES
[ 1375 FALSE CLAIMS
[ 400 STATE
REAPPORTIONMENT
[ 141 0 ANTITRUST
[ 1430 BANKS & BANKING
[ ]450 COMMERCE
[ 1460 DEPORTATION
[ 1470 RACKETEER INFLU
ENCED & CORRUPT
ORGANIZATION ACT
(RICO)
[ 1480 CONSUMER CREDIT
[ 1 490 CABLE/SA TEL LITE TV
( I 850 SECURITIES/
COMMODITIES/
EXCHANGE
( 1890 OTHER STATUTORY
ACTIONS
( ) 891 AGRICULTURAL ACTS
( I 893 ENVIRONMENTAL
MATTERS
[ 1 895 FREEDOM OF
INFORMATION ACT
[ ] 896 ARBITRATION
[ I 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR
APPEAL OF AGENCY DECISION
950 CONSTITUTIONALITY OF
STATUTES
D
CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.?
DEMAND $ _____ OTHER _____ JUDGE ____________ DOCKET
Check YES only if demanded in co!!!Piaint
JURY DEMAND: lR1 YES LNO NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
(PLACE AN x IN ONE BOX ONLY)
[!! 1 Original
Proceeding
0 2 Removed from 0 3
State Court
D a. all parties represented
D b. At least one
party is prose.
Remanded
from
Appellate
Court
ORIGIN
D 4 Reinstated or
Reopened
D 5 Transferred from D 6 Multidistrict
(Specify District) litigation
D 7 Appeal to District
Judge from
Magistrate Judge
Judgment
(PLACE AN x /NONE BOX ONLY) BASIS OF JURISDICTION
0 1 U.S. PLAINTIFF 2 U.S. DEFENDANT (!] 3 FEDERAL QUESTION 04 DIVERSITY
IF DIVERSITY, INDICATE
CITIZENSHIP BELOW.
(U.S. NOT A PARTY)
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
{Place an [X] in one box for Plaintiff and one box for Defendant)
PTF DEF
CITIZEN OF THIS STATE
PTF DEF
{ ] 1 [ ] 1 CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY
PTF DEF
{] 3[ ]3 INCORPORATED and PRINCIPAL PLACE [] 5 [] 5
OF BUSINESS IN ANOTHER STATE
CITIZEN OF ANOTHER STATE [ ] 2 [ ] 2 INCORPORATED or PRINCIPAL PLACE [ ] 4 [ ]4 FOREIGN NATION [] 6 [] 6
OF BUSINESS IN THIS STATE
PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
ARMEN DJERRAHIAN, 164 Russell Street, Brooklyn, NY 11222, Kings County
DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
BLACK ENTERTAINMENT TELEVISION, LLC, 1540 Broadway, New York, New York 10036, New York
County
DEFENDANT(S) ADDRESS UNKNOWN
REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
RESiftENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
Check one: THIS ACTION SHOULD BE ASSIGNED TO: 0 WHITE PLAINS MANHATTAN
(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTS
COMPLAINT.)
DATE SIGNA RE OF ATTORNEY OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT
[]NO
'/"/ [)(! YES(DATEADMITTED Mo.1_0 __
RECEIPT# /.., Attorney Bar Code# EG 5553
Magistrate ge is to be esignate the Cl rk of the

U'' JUI)Gf. GCii\NsrflN
Magistrate Judge i1Jl\U is so Designated.
Ruby J. Krajick, Clerk of Court by _____ Deputy Clerk, DATED---------
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
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