14 CV

JUDGE CASTEL

JS 44C/SDNY

REV. 4/2014

9893

CIVIL COVER SHEI

The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of

pleadings or other papers asrequired by law, except asprovided by local rules of court. This form, approved by tf^ C p

1 r\ f)(\4A

Judicial Conference oftheUnited States in September 1974, isrequired for useoftheClerk ofCourt for thepurposfeW*-'

* C\j r*f

initiating the civil docket sheet.

PLAINTIFFS

DEFENDANTS

YAINA WILLIAMS

A&E Television Networks, Lifetime Entertainment Services, FYI Television

Network, Lewis Goldstein, and John Doe

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER

ATTORNEYS (IF KNOWN)

Tonya Shy, James Walker, Granville|Shy, LLC

1691 Phoenix Blvd., Ste 390

Atlanta, GA 30349 (678) 604-7948

CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING ANDWRITE A BRIEFSTATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)

Action under 17 U.S.C. 106 and 501 for copyright infringment of reality tv series

Has this action, case, orproceeding, orone essentially the same been previously filed in SDNY at any time? NdresQjudge Previously Assigned
Ifyes, was thiscase Vol. Q Invol. [~J Dismissed. No Q Yes Q
IS THIS AN INTERNATIONAL ARBITRATION CASE?

No O

Ifyes, give date

&Case No.

Yes Q
NATURE OF SUIT

(PLACE AN [x] IN ONEBOXONLY)

ACTIONS UNDER STATUTES

PERSONAL INJURY

CONTRACT

PERSONAL INJURY

FORFEITURE/PENALTY

BANKRUPTCY

OTHERSTATUTES

[ ] 422 APPEAL

[ J 400 STATE

[ ) 367 HEALTHCARE/
[ ] no
11120
11130
[1140

INSURANCE
MARINE
MILLER ACT

[ ] 310 AIRPLANE
[ ] 315 AIRPLANE PRODUCT
LIABILITY

[ ] 320 ASSAULT, LIBEL &

NEGOTIABLE

INSTRUMENT

[J150

[]151
[1152

SLANDER

[ ] 330 FEDERAL

RECOVERY OF
OVERPAYMENT &
ENFORCEMENT
OF JUDGMENT

EMPLOYERS'
LIABILITY

[ ] 340 MARINE
[ ] 345 MARINE PRODUCT

MEDICARE ACT
RECOVERY OF
DEFAULTED
STUDENT LOANS

LIABILITY

[ ] 350 MOTOR VEHICLE

[ ] 355 MOTOR VEHICLE

(EXCL VETERANS)
[ ]153

[]160
[ ]190

[1195

[ ] 360 OTHER PERSONAL

OF VETERAN'S

[ ] 362 PERSONAL INJURY -

INJURY

MED MALPRACTICE

BENEFITS
STOCKHOLDERS

[ ] 196 FRANCHISE

[ ]220
[ ]230

ACTIONS UNDER STATUTES

ALL OTHER

TORT PRODUCT
LIABILITY

[ ] 440 OTHER CIVIL RIGHTS

(Non-Prisoner)
[ ] 441 VOTING
[ ] 442 EMPLOYMENT
[ ] 443 HOUSING/
ACCOMMODATIONS

[ ] 445 AMERICANS WITH

DISABILITIES EMPLOYMENT

[ ] 423 WITHDRAWAL
28 USC 157

PROPERTY RIGHTS

[X| 820 COPYRIGHTS

[ ] 830 PATENT
[ I 840 TRADEMARK

PERSONAL PROPERTY

[ ] 370 OTHER FRAUD

[ ] 371 TRUTH IN LENDING

SOCIAL SECURITY

REAPPORTIONMENT

[
[
[
[
[

] 410 ANTITRUST
J 430 BANKS & BANKING
] 450 COMMERCE
] 460 DEPORTATION
1470 RACKETEER INFLU
ENCED & CORRUPT
ORGANIZATION ACT

(RICO)
[ ] 480 CONSUMER CREDIT
[ ] 490 CABLE/SATELLITE TV

[ ] 850 SECURITIES/
COMMODITIES/

[ ] 380 OTHER PERSONAL

LABOR

PROPERTY DAMAGE

[ ] 385 PROPERTY DAMAGE

[ ] 710 FAIR LABOR

STANDARDS ACT

VACATE SENTENCE

[ ] 530 HABEAS CORPUS

[ ] 535 DEATH PENALTY
[ ] 540 MANDAMUS & OTHER

]861
] 862
] 863
] 864
] 865

HIA(1395ff)
BLACK LUNG (923)
DIWC/DIWW (405(g))
SSID TITLE XVI
RSI (405(g))

EXCHANGE

[ ] 890 OTHER STATUTORY

ACTIONS

[ ] 740 RAILWAY LABOR ACT

[ ] 751 FAMILYMEDICAL
LEAVE ACT (FMLA)
[ ] 790 OTHER LABOR
LITIGATION

[ ] 791 EMPL RET INC

SECURITY ACT
IMMIGRATION

PRISONER CIVIL RIGHTS

[ ] 462 NATURALIZATION

[ ] 550 CIVILRIGHTS
[ ] 555 PRISON CONDITION

[
[
[
[
[

RELATIONS

28 USC 2255
CIVIL RIGHTS

I 1 375 FALSE CLAIMS

28 USC 158

[ ] 690 OTHER

INJURY PRODUCT
LIABILITY

[ ] 463 ALIEN DETAINEE

[ ] 510 MOTIONS TO

FORECLOSURE

[ ]290

21 USC 881

[ ] 720 LABOR/MGMT

RENT LEASE &

EJECTMENT

TORTS TO LAND

PRODUCT LIABILITY

[ ] 368 ASBESTOS PERSONAL

SEIZURE OF PROPERTY

PRODUCT LIABILITY

LAND
CONDEMNATION

[ I 240
[I 245

[ J 365 PERSONAL INJURY

PRISONER PETITIONS

REAL PROPERTY

[ 1210

INJURY/PRODUCT LIABILITY

PRODUCT LIABILITY

RECOVERY OF
OVERPAYMENT

SUITS
OTHER
CONTRACT
CONTRACT
PRODUCT
LIABILITY

PHARMACEUTICAL PERSONAL , , 625DRUG RELATED

APPLICATION

[ ] 465 OTHER IMMIGRATION

[ ] 560 CIVIL DETAINEE

[ ] 891 AGRICULTURAL ACTS

FEDERAL TAX SUITS

[ ] 870 TAXES (U.S. Plaintiff or

Defendant)
[ ] 871 IRS-THIRD PARTY

[ ] 893 ENVIRONMENTAL
MATTERS

[ ] 895 FREEDOM OF
INFORMATION ACT

26 USC 7609

[ ] 896 ARBITRATION
[ ] 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR
APPEAL OF AGENCY DECISION

[ ] 950 CONSTITUTIONALITY OF
STATE STATUTES

ACTIONS

CONDITIONS OF CONFINEMENT

[ ] 446 AMERICANS WITH

DISABILITIES -OTHER

[ ] 448 EDUCATION

REAL PROPERTY

Checkif demanded in complaint:

CHECK IF THIS IS A CLASS ACTION

UNDER F.R.C.P. 23

DEMAND $ TBD

OTHER

DaYOU cuyM THIS case IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.'

JUDGE

DOCKET NUMBER

CheckYES only ifdemanded in complaint

JURY DEMAND: S 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*1 1 Original

ORIGIN

I I 2 Removed from

Proceeding

' ' 3 Remanded I I4 Reinstated or

StoteCourt

from

r~l a.
a all,.parties
... represented
.a
|_|

| | 5 Transferred from [_J 6 Multidistrict

Reopened

(Specify District)

LJ 7 Appeal to District

Litigation

Judgefrom

Appellate
court

Magistrate Judge
Judgment

I | b. Atleast one
party Is pro se.

(PLACEANxINONEBOXONLY)

1 U.S. PLAINTIFF

BASIS OF JURISDICTION

2 U.S. DEFENDANT \*\ 3 FEDERAL QUESTION

IF DIVERSITY, INDICATE

Q4 DIVERSITY

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)
CITIZEN OF THIS STATE

PTF

DEF

[]1

[]1

PTFDEF

CITIZEN OR SUBJECT OF A

[]3[]3

FOREIGN COUNTRY

CITIZEN OF ANOTHER STATE

[ ]2

[ ]2

INCORPORATED and PRINCIPAL PLACE

PTF

DEF

[]5

[]5

[ ]6

[ ]6

OF BUSINESS IN ANOTHER STATE

INCORPORATED or PRINCIPAL PLACE

[ ]4 [ ]4

FOREIGN NATION

OF BUSINESS IN THIS STATE

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

Yaina Williams, 5365 Holly Springs CT, BIdg #28, Indianapolis, IN 45254, Marion County

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

A&E Television Networks, 235 E. 45th Street, New York, NY 10017, New York County
Lifetime Entertainment Services, 235 E. 45th Street, New York, NY 10017, New York County
FYI Television Network, 235 E. 45th Street, New York, NY 10017, New York County
Lewis Goldstein, 309 W. 49th Street 16th Floor, New York, NY, 10019, New York County
DEFENDANT(S) ADDRESS UNKNOWN
REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
RE9IBENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

Check one:

THIS ACTION SHOULD BE ASSIGNED TO:

Q WHITE PLAINS

\*\ MANHATTAN

(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTS
COMPLAINT.)
ADMITTED TO PRACTICE IN THIS DISTRICT
DATE 12/05/2014 SIGNATURE OF ATTORNEY OF RECORD

RECEIPT*

OtOWAjjCl WJ*\
V

[ ] YES (DATE ADMITTED Mo.

Attorney Bar Code #

Magistrate Judge is to be designated by the Cleii^^ibpjOliB NETBURN

Magistrate Judge
MAG-JUDGE NETBURN
Ruby J. Krajick, Clerk of Court by

is so Designated.

Deputy Clerk, DATED

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

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JUDGE WiH
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

14 CV

9898

YAINA WILLIAMS
Civil Action No.

Plaintiff,

A&E TELEVISION NETWORKS,

COMPLAINT

LIFETIME ENTERTAINMENT

SERVICES, FYI TELEVISION

NETWORK, LEWIS
GOLDSTEIN and JOHN DOE.
JURY TRIAL DEMANDED
Defendants.

Plaintiff Yaina Williams ("Plaintiff) for its complaint against Defendants Lifetime
Entertainment Services, A&E Television Networks, Lewis Goldstein, and John Doe (collectively
"Defendants"), hereby alleges:
NATURE OF THIS ACTION

1. This is a case of copyright infringement arising out of Defendants' creation and

exploitation of a "reality show" entitled Married at First Sight, whichis based on and copied
from copyrighted property authored and owned by Plaintiff.
2. Plaintiff first registered her Married at First Sight (hereinafter "Infringed Property")
with a website called TV Writer's Vault on December 19, 2011. Attached hereto as Exhibit 1

and incorporated hereinby reference is a true and correct copy of such registration. Attached
hereto as Exhibit 2 and incorporated herein by reference is a true and correct copy of such and
her treatment.

3. Starting in February 2012, long before the release of Defendants' Married at First

Sight (hereinafter "Infringing Series"), Plaintiff was notified by TV Writers Vault that a TV

executive requested her treatment for Married at First Sight. When Plaintiff accessed her Project
Status Page, an executive representative from or affiliated with Lifetime TV had downloaded her
property.

4.

Upon information and belief, access to Plaintiffs Property enabled Defendants to

create and exploit their own Married at First Sight "reality show," which is an infringement of
Plaintiffs copyrights in violation of the United States Copyright Act.

5. The characters, literary texts and ideas embodied within the Infringed Property and
the Infringing Series are owned exclusively by Plaintiff, which had planned to syndicate the
show in different markets, i.e., "Married At First Sight L.A.", "Married At First Sight NY",
"Married At First Sight Atlanta," and seven to ten various other markets.
PARTIES

6. Plaintiff, Yaina Williams, is an individual beyond the age of majority and possesses
the requisite legal capacity to bring this lawsuit.
7. Upon information and belief, Defendant A&E Television Networks (hereinafter
"A&E") is a corporation organized and existing under the laws of the state of Delaware,

registered to do business in the state of New York as a foreign limited liability company,
conducts business in the state of New York and has a principal place of business at 235 E. 45
Street, New York, NY 10017.

8. Upon information and belief, Defendant Lifetime Entertainment Services (hereinafter

"Lifetime") is a corporation that is a part of the A&E Television Network, organized and existing
under the laws of the state of Delaware, registered to do business in the state of New York as a

foreign limited liability company, conducts business in the state of New York and has a principal

place ofbusiness at 235 E. 45th Street, New York, NY 10017.

9. Upon information and belief, Defendant FYI Television Network (hereinafter

"FYI") is a corporation that is a part of the A&E Television Network, organized and existing
under the laws of the state of Delaware, registered to do business in the state of New York as a

foreign limited liability company, conducts business in the state of New York and has a principal

place ofbusiness at 235 E. 45th Street, New York, NY 10017.

10. Upon information and belief, Defendant Lewis Goldstein (hereinafter "Goldstein") is
an individual, and is the Co-Chief Marketing Officer of Lifetime Entertainment Services and
may be served with process at 309 W. 49th St 16th Floor, New York, NY10019.

11. Plaintiff is ignorant of the true name and capacity, whether individual, corporation,
association, or otherwise, of the defendant, sued herein as John Doe and therefore sues this

defendant under such fictitious name. Plaintiff is informed and believes, and accordingly alleges,
that this fictitiously named defendant, intentionally, negligently, or otherwise wrongfully
performed each of the acts and omissions alleged herein, and thereby legally caused the damages
and injuries to Plaintiff.

12. Plaintiff is informed and believes, and accordingly alleges, that the defendants named
in this Complaint, including John Doe, was the agent, ostensible agent, servant, employee,
representative, and associate of each of the other defendants, and was at all times acting within

the course and scope of his, her or its authority as agent, ostensible agent, servant, employee,
representative and associate, and with the knowledge, authorization, consent, permission or
ratification of each of the other defendants.
JURISDICTION AND VENUE

13. This Court has jurisdiction over the subject matter of this action pursuant to 28
U.S.C. 1331 and 1338(a) because this action arises under the copyright laws of the United

States, Title XVII of the United States Code, and this Court has supplemental jurisdiction
pursuant to 28 U.S.C. 1367(a) because this action includes claims that are related to the

copyright claims and those supplemental claims form part of the same case or controversy as the
copyright infringement claims.

14. Personal jurisdiction exists over each defendant because it has a place of business
in the State of New York and regularly transacts business in the State of New York.
15. Venue is proper in this District pursuant to 28 U.S.C. 1391 and 1400.
FACTS

16. Plaintiff is the creator, sole owner, and copyright holder in the "reality show"
"Married at First Sight." Plaintiff had planned to syndicate the show in different markets, i.e.,
"Married At First Sight L.A.," "Married At First Sight NY," "Married At First Sight Atlanta,"
and seven to ten various other markets based on the premise that couples would meet and marry
within a very shortened period of time.
17. Plaintiff created and developed the original characters and stories that comprise
"Married at First Sight."
18. In December 2011, Plaintiff uploaded three treatments for three realties series

including Married at First Sight on a website called TV Writer's Vault. In February 2012, long
before the release of Defendants' Married at First Sight, Plaintiff was notified by TV Writers
Vault that a TV executive requested her property for Married at First Sight. When Plaintiff
accessed her Project Status Page she found that Lewis Goldstein, an executive representative

from Lifetime TV had downloaded her property on February 4, 2012.

19. After The Infringed Property was downloaded by Lewis Goldstein from

Lifetime, there was no further contact or activity with Plaintiff by Lifetime or Goldstein.

20. July 2014, FYI Network, a cable and digital network owned by A&E Television
Networks began promoting and subsequently airing the Infringed Property.
Comparison of Plaintiffs and Defendants' Property

21. InDefendants' promotional clips on shows like "Entertainment Tonight" and in the

first episode ofDefendants' Infringing Series, the same verbiage was used as inthe Infringed
Property about how arranged marriages are common in other cultures and countries like
India. The question was posed the same: "Can lovehappen at first sight?"
22. Defendants had "experts" on the Infringing Series who matched the couples and
counseled them. There were two female experts and two males who interviewed and coached

each castmember on the show, just as outlined in the Infringed Property. Specifically stated in

the Infringed Property: that there should be a male/female coaching team and that these sessions
should be aired.

23. Plaintiffstated in the Infringed Propertythat there shouldbe an online social

interaction to build buzz for the show and to hook the audience for future shows and

seasons. Defendants' Infringing Series did thatby allowing viewers to vote for couples on their
website as well as on Twitter and Facebook just as outlined in the Infringed Property.

24. The Infringed Property also suggested that there should be three couples
chosen. There were three couples featured on Defendants' Infringing Series.

25. The Infringed Property outlined that the married couple should live together as a

married couple for sixmonths. On the Defendants' Infringing Series, there was a six-month
follow up in the finale episode. Defendants revealed the two couples who made it and the one
couple who divorced after six weeks.

26. The Infringed Property described a wedding put on by the show where the show

would provide everything for the couple, including wedding gown, bridesmaid dresses, and
tuxedos for the groom and his groomsmen. This was presented on Defendants' Infringing Series
as well.

27. The Infringed Property stated that there should be videos of interviews of the

potential singles that did not make it on the show. These type of interviews appeared on the
Defendants' Infringing Series.
28. The Infringed Property stated that there should be videos of the families and friends

of the final contestants. These interviews also appeared throughout the first season Defendants'

Infringing Series in several episodes. The families and friends expressed their feelings about
their loved one participating in this show and marrying a stranger. This of course added to the
drama, as discussed extensively in the Infringed Property.

29. The Infringed Property outlined the filming of pre-wedding events such as bachelor

and bacheloretteparties. The Defendants' Infringing Series showed the couples at their
respective bachelor and bachelorette parties in episode #2.

30. It was specifically discussed in the Infringed Property the building up of the dramatic
moment of the wedding where the big question is: Will they say "I Do" or not? On Defendants'

Infringing Series, they did this by leaving it as a dramatic cliff hanger at the end of episode #1.
31. The Infringed Property outlined the filming of the couple as they navigate married

life and get to know each other throughout the season, exploring questions about intimacy,
passion, and adapting to married life. Defendants' Infringing Series did this in the two episodes
in which the couples made love for the first time and were quite the buzz online on Twitter and

Facebook. In Defendants' Infringing Series, the couples were shown living their everydaylives,

same as discussed in The Infringed Property. Defendants even showed the couples interacting
with family and friends, just as specifically outlined in the Infringed Property.

32. The couples featured on Defendants' Infringing Series attended sessions with the

therapist and parts of it were filmed, just as was outlined in the Infringed Property. The therapist
coached them through difficult conflicts along the wayand helped them to bond with each other
and to open up to each other.

33. There was an episode showing the honeymoon at an island getaway as suggested in

the Infringed Property. OntheDefendants' Infringing Series, two of the couples went to tropical
islands in the Caribbean.

34. Therewas also an episode of Defendants' Infringing Series that showed the couples
moving in together, as outlined in the Infringed Property.
35. The basic criteria for the couples in the Defendants' Infringing Series are the same as

outlined in the Infringed Property: heterosexual men & women, ages 26+, single (never
married), no children, US citizens.

36. It was mentioned in the finale episode of Defendants' Infringing Series that extensive

background checks were done, as stated in the Infringed Property.

37. The twelve episodes of Defendants' Infringing Series are the same as estimatedin the
Infringed Property.

38. Couples on Defendants' Infringing Series were shown grocery shopping, as stated
they would in the Infringed Property.

39. Couples on Defendants' Infringing Series were shown going out and spending time
interactingwith friends and family, as specifically stated in the Infringed Property.

40. Couples on Defendants' Infringing Series were given therapeutic tasks, as stated in

the Infringed Property to help forge abond oftrust and love and to help them get to know each
other on a deeper level. (One example, was called the fish bowl activity. All the couples did this
task.)

41. Couples on Defendants' Infringing Series were shown decorating their new home, as
stated in the Infringed Property.

42. One couple on Defendants' Infringing Series was shown visiting an amusement park
(Coney Island, NY.), as stated in the Infringed Property.
COUNT I

DECLARATORY RELIEF

43. Plaintiffreferences and incorporates paragraphs 1-42 as if fully set forth and re
alleged herein.

44. Plaintiff request injunctive relief enjoining the Defendants from directly or indirectly

infringing Plaintiffs' rights under federal or state law in Copyrighted Property, whether now in
existence or latercreated, that is owned or controlled by Plaintiff, except pursuant to a lawful
license or with the express authority of Plaintiff.

45. Plaintiffhas been and will continue to be damaged by Defendants continuing acts of

infringement, including but not limited to, lost revenues and profits and continuing loss ofvalue
ofits copyright interests. The damages that Plaintiff has suffered and continues to suffer from
this infringement are irreparable. Plaintiff has no adequate remedy at law, and such conduct will
continue to cause irreparable harm unless restrained by this Court by the issuance of a
preliminary injunction.

46. Plaintiff is informed and believes that without injunctive relief by this Court,
Defendants will continue to infringe Plaintiffs' rights. Plaintiff therefore requests that after trial,

this Court issue a permanent injunction, restraining and enjoining Defendants and their agents,
employees, attorneys, representatives, and anyone acting at their direction or behalf from

copying, reproducing, distributing, or displaying, without the express or implied consent of the
Plaintiff, the copyrightable expression in the Infringing Series.
COUNT II

COPYRIGHT INFRINGEMENT

47. Plaintiff repeats and re-alleges each and every allegation in paragraphs 1 through 46
of the Complaint as if fully set forth herein.

48. The Property (including the Title, the program and each element thereof) and the

rendering and elements therein, constitutes copyrightable of all the exclusive rights to reproduce
the Title expression protected by the federal Copyright Act, 17 U.S.C. 101, et seq.
49. Plaintiffis the sole and exclusive owner of all the exclusive rights to reproduce the
Title and the Program in copies, prepare derivative Property, and display the copyrighted
Property publicly.

50. Defendants had access to the Property and gained such access by obtaining actual
copies of the Property from Plaintiff and /or a website called TV Writer's Vault. Defendants

then shared those copies of the Property among each other.

51. The Infringing Series and the various elements and episodes thereof contain the same
plot, themes, mood, setting, pace characters, sequence of events, and other concrete elements

making up the Infringed Property and therefore is substantially and strikingly similar to the
Infringed Property.

52. The Infringing Series also contains copies and derives from the Infringed Property
and identical framework of the Infringed Property.

53. Defendants have copied and intend to continue copying the Infringed Property and

the expressions contained therein in order to make and continue to make the Infringing Series,
without Plaintiffs license, authority, or consent.

54. Plaintiffis informed and believes, and on that basis alleges, that Defendants copied

the Property prior to exhibition and distribution ofthe Infringing Series bycreating a series
outline and other infringing materials in connection with the Infringing series. These items were
used in the creation of the Infringing Series and the Infringing Series was derived therefrom.
55. Defendants have distributed (and intend to continue to distribute): copyrighted

elements of the Infringed Property and the expressions contained therein in the form of the

Infringing Series to the Public and to display the copyrighted Property publicly without
Plaintiffs license, authority, or consent.

56. Byengaging in the described above, Defendants have committed and continue to
commit copyright infringement under the federal Copyright Act, 17 U.S.C. 101, et seq.

57.Defendants' copying of the Infringed Property without Plaintiffs license, authority, or

consent is a willful and conscious disregard of Plaintiffs rights underthe federal Copyright Act.

58. As a direct and proximate result of said infringement by Defendants, Plaintiff has

been damaged and continues to be damaged in an amount to be determined at trial. Plaintiff is

also entitled, under 17 U.S.C. 504(a), to statutory damages to the extent they exceed Plaintiffs
actual damages, for each of Defendants' acts of infringement.

59. Defendants' acts of infringement are willful, intentional and purposeful, in disregard
of and with indifference to Plaintiffs' rights.

10

60. As a direct and proximate result of Defendants' infringement of Plaintiff s copyright

interests, Defendants have made and continue to make profits attributable to their infringement.
The amount of these profits will be determined at the time of trial.

61. As a direct and proximateresult of Defendants' willful infringement of Plaintiffs

copyright interest, Plaintiffis entitled to recover its attorneys' fees and full costs pursuant to 17
U.S.C. 505 and otherwise according to law.
COUNT HI

CONTRIBUTORY COPYRIGHT INFRINGEMENT

62. Plaintiff re-alleges and incorporates herein by reference the allegations set forth in
paragraphs 1 through 61 inclusive, as though fully set forth herein.
63. Each Defendant is liable for contributory infringement in that it knew or should

have known of the infringing activity alleged herein, and knowingly induced, caused and/or
materially contributed to the infringing acts alleged herein, by aiding in the creation,

development and/or exploitation of all of the works alleged herein to be infringing.

64. The acts and conduct of each Defendant, as alleged herein, constitute contributory
copyright infringement.
COUNT IV

VICARIOUS COPYRIGHT INFRINGEMENT

65. Plaintiff re-alleges and incorporates herein by reference the allegations set forth in
paragraphs 1 through 64 inclusive, as though fully set forth herein.
66. Each Defendant had the right, authority, and the ability to control or supervise the
actions, failures, and omissions alleged herein that violated Plaintiffs copyrights in her
characters and stories.

11

67. Each Defendant obtained a direct financial benefit, interest, advantage, and/or
economic consideration from the direct infringement of Defendants alleged herein.
68. The acts and conduct of each Defendant, as alleged herein, constitute vicarious
copyright infringement.
PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests the following relief:

(a) Declare the Defendants have infringed Plaintiffs copyrighted property;
(b) Pursuant to 17 U.S.C 502, preliminarily and permanently enjoin Defendants, their
officers, agents, servants, employees and attorneys, all persons in active concert or participation
with them, from infringing Plaintiffs copyrighted property in any manner, and from reproducing
preparing derivative works from the copyrighted property;
(c) Enter judgment against all Defendants, jointly and severally, in an amount equal to
actual damages as determined by the Court; or

(d) Enter judgment against all Defendants, jointly and severally, and order Defendants to
turn over all contracts executed, pay statutory damages, including treble damages for willful
infringement.

(e) Enter judgment against all Defendants, jointly and severally, and order that Plaintiff
be awarded the costs and expenses of bringing and prosecuting this action, including reasonable
attorney's fees; and
(f) For all such other relief which this Honorable Court deems just and proper.

12

Respectfully submitted,

M.ii
JQ
Tonya Sh;
Pro Hac Vice Motion Pending
Georgia State Bar No. 613315
James L. Walker, Jr.- Of Counsel
Georgia State Bar No. 260643
GRANVILLE/SHY, LLC
1691 Phoenix Blvd, Suite 390
Atlanta, GA 30349

Tel: (678) 604-7948

Fax:(404)745-0926
[email protected]

13

EXHIBIT 1

EXHIBIT 2

AUTHOR NAME: Yaina Cantrell

TITLE: "MARRIED AT 1st SIGHT'

GENRE: Reality Series

LOGLINE: It's "Dharma & Greg" meets "Platinum Weddinas"

One

iSd^sHoS
rJr^
honey*,
adreafhouse?
their
f?;2? hiWSe
TnS S
J is,Ve?tingl
they have
to get married
after

inSShQ
months

and llve together for at least 6

SYNOPSIS:

Quickie marriages in America is nothing new. People marry

quick & in a hurry for all sorts of reasons: unplanned
pregnancies, financial convenience, green card... oh yes, and
for love too. Arranged marriages happen too, although more
frequently in other countries such as China and India.

This

reality show is a combination of the two. We arrange for

couples to meet, date, and marry all in one whirlwind month!
Does love at first sight exist? Well, "Married At 1st Sight"

will attempt to answer that question!

In each of the first three episodes, we will show 3 blind

dates.

First, we will see the 3 single men and 3 single women

move into separate quarters of a big dream house (which also

happens to be one of the prizes). There will be a male &
female matchmaking/date coaching team who will judge the
contestants and couples. We will show previous sessions of
each contestant meeting with a matchmaker/date coach. There
will also be outtakes from videos of contestants who did not
make the cut.

Each man and woman will go out on a 12-hour blind date. The
date will be a combination of unique experiences specifically
designed to help create a spark. Love at first sight is what
we are aiming for here! For the adventurous couple, a
romantic helicopter tour over a scenic cityscape; and then a
hike through unchartered territory to get to a romantic
picnic. For the foody couple, a romantic cooking class
preparing & eating a sensuous meal full of culinary
aphrodisiacs; and then delivering the leftovers to a shelter
to feed the homeless. No matter the scenario, if the date
challenges the couple and forces them to rely on each other in
order to complete a task, then a bond should naturally occur
bringing them closer.

At the end of each of these episodes, the television audience

will be invited to vote for their favorite couple to win the
grand prize and get married.

Each contestant will be

interviewed by a matchmaker/date coach, scoring their dates

and discussing their feelings. The audience will be able to

vote on the show's website, via text, or phone. There will

also be website, Twitter and Facebook fan pages, keeping the

pulse of the show. Fans of the show will post their feedback
on Facebook & Twitter. We will also post video outtakes of
the show every day to keep the audience engaged and to build

the anticipation for the next episode.

Contest Rules & Eligibility:

1. Single men & women ages 30-49, never married, and childless
are eligible to compete.

2. Prior to the show, each contestant must submit to and pass

an extensive background/criminal check. And they will be
dusted for prints... In other words, they must pass a complete
physical and STD tests.

3. The winning couple must marry after only 1 date.

4. The couple must agree to at least one pre-marital counselinq
session.

5. They also have to see a marriage counselor twice a week

after the wedding.

6. The winning couple must complete all steps. They have to

live together for 6 months or forfeit the prize. If they
back out before the wedding, they forfeit all prizes.
On the fourth episode, the winning couple will be revealed
Anticipation will rise as a montage of clips of all the dates,
interviews, and confessionals is shown.

The winner will be

determined by 50% audience votes and 50% Matchmakers' votes.

The couple with the most points wins. The Matchmakers will
announce the winners: the female matchmaker will announce the
female winner, and the male date coach will announce the male
winner. A runner-up couple will be announced too. Should the
winning couple not fulfill their duties, the runners-up will

fotE n?A

Thei winninf couple will receive the dream house,

?^b0,000, a dream wedding and honeymoon.

We will show

interviews of the other contestants as they move out of the

prize house. But, this is just the beginning!
In the next few episodes, the couple will meet with a

celebrity wedding planner to plan their dream wedding. They

will have only 2-3 weeks to pull this shindig together. We
will introduce the families and friends of the brave couple as

well.

Let the drama begin.'

l!

POTENTIAL CONFLICTS & DRAMA:

.Surely, some family & friends of the contestants will raise

objections to this quickie marriage.

Tensions are sure to

rise for the winning couple as they approach their big day,
and we will film every wacky minute of it!

,Pre-wedding events may showcase more drama. There may be a

rehearsal & rehearsal dinner, bridal shower, bachelor &

bachelorette parties.

These events could also bring out

more insight into the motivations of the now engaged couple.

Will they say "I do"?

That's the question!

Imagine all the

anticipation & trepidation as the big day approaches... All

leading to the moment when they stand at the altar, face to
face Will they or won't they? What a dramatic moment that
will

be!

The newlyweds will be filmed constantly throughout their

quickie wedding and marriage. Will they last 6 months?
What juicy drama will erupt as they get to know each other

and adapt to married life? Will the honeymoon be filled

5. The Newlyweds will attend couples and private therapy
with passion or full of regret?

sessions twice a week.

A few scenes (not in their entirety

due to confidentiality) will be aired! The therapist will

give the happy couple exercises to help them get to know

each other, bond, and fall in love; and help them to

SonfliSts?1^ barriers' obstacles, and to resolve potential

The next several episodes will complete the season. Dependina
on how long the couple lasts, there may be approximately 8-10

more episodes. We will see the couple on their honeySoL a

private island getaway or a big city tour, Paris o? NYC Sr Las
l^??' babyl
.Then'
we Wil1getting
Sh?w th*
couPieeach
in other,
their natSral
SStn^
^V^ng
together,
to
know
and
making love happen or tearing it down. In each episode we
can present the couple with exciting activities, as Sell Is
therapeutic tasks aimed at helping to forge a bond of trust
and love.

Examples include:

decorating parts of their new

home attending religious services together (if applic'ableT

wfSJ^pnSl day.with a child (niece or nephew), g?ijg out

park, etc?

glng grOCery shPPing, going to an'amusement

And if they don't say "I do" then the runner-up couple will

Jg!nlgain..PriZe

^ int the bg hUSe- And so ^ will

judge asm
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

YAINA WILLIAMS

Plaintiff,

14 GV
Civil Action No.

v.

A&E TELEVISION NETWORKS,

LIFETIME ENTERTAINMENT

MOTION FOR AD
PRO HAC VIC

SERVICES, FYI TELEVISION

NETWORK, LEWIS
GOLDSTEIN and JOHN DOE.
Defendants.

Pursuant to Rule 1.3 ofthe Local Rules ofthe United States for the Southern and Eastern

Districts ofNew York, I.Tonya Shy, hereby move this Court for an Order for admission to

practice Pro Hac Vice to appear as counsel for PlaintiffYaina Williams in the above-captioned
action.

Iam in good standing ofthe bar(s) ofthe state(s) ofGeorgia and there are no pending
disciplinary proceedings against me in any state or federal court.
Dated: December 5,2014

Respectfully Submitted,

Tonya Shy

GRANVILLE/SHY, LLC
1691 Phoenix Blvd, Suite 390
Atlanta, GA 30349

Tel: (678) 604-7948

Fax: (404) 745-0926

[email protected]