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In the United States District Court for the Southern District of Florida West Palm Beach Division

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In the United States District Court for the Southern District of Florida West Palm Beach Division Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 1 of 52 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION CASE NO. __________________ RICHARD H. BARNES, JR., COMPLAINT AND DEMAND FOR Plaintiff, JURY TRIAL v. LAMAR D. JACKSON, LAMAR JACKSON ENTERPRISES INCORPORATED, and RONALD DUPONT Defendants. Plaintiff RICHARD H. BARNES, JR., by and through undersigned counsel, pursuant to the applicable Federal Rules of Civil Procedure and the Local Rules of this Court, demands a trial by jury of all claims and issues so triable, and for his Complaint against the Defendants LAMAR D. JACKSON, LAMAR JACKSON ENTERPRISES INCORPORATED, and RONALD DUPONT, hereby asserts and alleges as follows: THE PARTIES Plaintiff 1. Plaintiff Richard H. Barnes, Jr. (hereinafter “BARNES”) is a highly regarded professional photographer and a resident of the state of New York residing at 23 Samson Street, Cortland, New York 13045. Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 2 of 52 2. BARNES specializes in sports photography and has photographed sporting events in the United States in a professional capacity. 3. BARNES has photographed National Collegiate Athletic Association (“NCAA”) games, including various collegiate football games, collegiate football bowl games, collegiate basketball games, collegiate soccer games, and collegiate lacrosse games, National Football League (“NFL”) games, Minor League Baseball (“MiLB”) games, and NASCAR events. 4. BARNES’s photographs have been prominently featured by numerous print and digital media outlets, including USA TODAY Sports, Sports Illustrated, National Geographic, The New Yorker, The New York Times, and many others. Defendant Lamar D. Jackson 5. Upon information and belief, Defendant, Lamar D. Jackson (hereinafter “JACKSON”), is a professional athlete who is employed by the Baltimore Ravens, a franchise of the NFL. 6. Upon information and belief, JACKSON is a resident of the state of Maryland and resides at 24 Aston Ct. Owings Mills, MD 21117. 7. Upon information and belief, JACKSON owns and/or operates multiple social media accounts through which JACKSON uploads and displays media for fans and other members of the public to view. 8. Upon information and belief, JACKSON created and/or controls the Facebook account having the username “lamarjacksonofficial” (hereinafter “FACEBOOK ACCOUNT”). 2 Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 3 of 52 9. Upon information and belief, JACKSON created and/or controls the Twitter account having the username “Lj_era8” (hereinafter “TWITTER ACCOUNT”). 10. Upon information and belief, JACKSON created and/or controls the Instagram account having the username “new_era8” (hereinafter “INSTAGRAM ACCOUNT”). 11. Upon information and belief, JACKSON created and/or controls the YouTube channel titled “Lamar Jackson” and accessible at the URL https://www.youtube.com/channel/UCtVU05SXwMQpBdA4diEUpGg (hereinafter “YOUTUBE CHANNEL”). 12. Upon information and belief, JACKSON uploads and displays photographs, video recordings, and other works to the FACEBOOK ACCOUNT. 13. Content uploaded to the FACEBOOK ACCOUNT can be viewed by members of the public at the URL https://www.facebook.com/lamarjacksonofficial/ (hereinafter “FACEBOOK PAGE”). 14. A printed version of the FACEBOOK PAGE, as retrieved on November 2, 2018, is attached hereto as EXHIBIT 1. 15. Upon information and belief, JACKSON uploads and displays photographs, video recordings, and other works to the TWITTER ACCOUNT. 16. Content uploaded to the TWITTER ACCOUNT can be viewed by members of the public at the URL https://twitter.com/lj_era8 (hereinafter “TWITTER PAGE”). 3 Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 4 of 52 17. A printed version of the TWITTER PAGE, as retrieved on October 1, 2018, is attached hereto as EXHIBIT 2. 18. Upon information and belief, JACKSON uploads and displays photographs, video recordings, and other works to the INSTAGRAM ACCOUNT. 19. Content uploaded to the INSTAGRAM ACCOUNT can be viewed by members of the public at the URL https://www.instagram.com/new_era8/?hl=en (hereinafter “INSTAGRAM PAGE”). 20. A printed version of the INSTAGRAM PAGE, as retrieved on October 1, 2018, is attached hereto as EXHIBIT 3. 21. Upon information and belief, JACKSON uploads and displays video recordings and other works to the YOUTUBE CHANNEL. 22. A printed version of the YOUTUBE CHANNEL, as retrieved on April 5, 2019, is attached hereto as EXHIBIT 4. 23. Upon information and belief, JACKSON, or someone acting at the direction of JACKSON, copied, published, displayed, distributed, created derivative works of, modified, offered for sale, and/or sold unauthorized copies of one or more of BARNES’s photographs that are protected by the Copyright Act of 1976 and are the subject of this litigation. Defendant Lamar Jackson Enterprises Incorporated 24. LAMAR JACKSON ENTERPRISES INCORPORATED (“ENTERPRISES”) is a for- profit corporation duly organized and existing under the laws of the state of Florida. 4 Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 5 of 52 25. ENTERPRISES has the principal address of 1557 N. Dixie Highway 4, Pompano Beach, Florida 33060, which is its principal place of business. 26. Upon information and belief, JACKSON is the President of ENTERPRISES. 27. Upon information and belief, individuals other than JACKSON are also involved in conducting the affairs of ENTERPRISES. 28. Upon information and belief, ENTERPRISES owns and/or operates ERA 8 APPAREL (“APPAREL”), a retail merchandise business with a contact address of 121 SW 7th Avenue, Boynton Beach, Florida 33435. 29. Upon information and belief, ENTERPRISES created, had created, and/or controls the online retail store for APPAREL that is accessible by members of the public at the URL https://era8apparel.com/ (hereinafter “APPAREL.COM”). 30. Upon information and belief, APPAREL.COM includes a link to the FACEBOOK ACCOUNT under the heading “FOLLOW US.” 31. Upon information and belief, APPAREL.COM includes a link to the TWITTER ACCOUNT under the heading “FOLLOW US.” 32. Upon information and belief, APPAREL.COM includes a link to the INSTAGRAM ACCOUNT under the heading “FOLLOW US.” 33. Upon information and belief, APPAREL.COM includes a link to the YouTube ACCOUNT under the heading “FOLLOW US.” 5 Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 6 of 52 34. Upon information and belief, ENTERPRISES displays and offers for sale apparel and other merchandise on APPAREL.COM. 35. Upon information and belief, ENTERPRISES offers for sale through APPAREL.COM merchandise, including apparel, fashion accessories such as hats and bags, smartphone accessories, and/or other merchandise. 36. A printed version of a page from APPAREL.COM, as retrieved on November 2, 2018, is attached hereto as EXHIBIT 5. 37. Upon information and belief, ENTERPRISES created, displayed, published, offered for sale, and/or sold one or more products through APPAREL.COM that include unauthorized derivative works of one or more of BARNES’S photographs that are protected by the copyright law of the United States and are the subject of this litigation. Defendant Ronald Dupont 38. Upon information and belief, Defendant RONALD DUPONT (hereinafter “DUPONT”), is a jeweler who operates under the Stacks Custom Jewelry store in Miami, Florida. 39. Upon information and belief, DUPONT is a resident of the state of Florida and operates his Stacks Custom Jewelry store at 17 E Flagler, Miami, Florida 33132. 40. Upon information and belief, DUPONT owns and/or operates multiple social media accounts through which DUPONT uploads and displays content for customers, prospective customers, and other members of the public to view. 6 Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 7 of 52 41. Upon information and belief, DUPONT created and/or controls the Instagram account having the username “stackscustoms” (hereinafter “STACKS INSTAGRAM ACCOUNT”). 42. Upon information and belief, DUPONT uploads and displays photographs, video recordings, and other works to the STACKS INSTAGRAM ACCOUNT. 43. Content uploaded to the INSTAGRAM ACCOUNT can be viewed by members of the public at the URL https://www.instagram.com/stackscustoms/?hl=en (hereinafter “STACKS INSTAGRAM PAGE”). 44. A printed version of the STACKS INSTAGRAM PAGE, as retrieved on February 9, 2021, is attached hereto as EXHIBIT 39. 45. Upon information and belief, DUPONT created, displayed, published, offered for sale, and/or sold one or more derivative works of one or more of BARNES’S photographs that are protected by the copyright law of the United States and are the subject of this litigation. JURISDICTION AND VENUE 46. Jurisdiction for BARNES’s claims lies with the United States District Court for the Southern District of Florida pursuant to the Copyright Act of 1976, 17 U.S.C. §§ 101, et seq., 28 U.S.C. § 1331 (conferring original jurisdiction “of all civil actions arising under the Constitution, laws, or treaties of the United States”); 28 U.S.C. § 1338(a) (conferring original jurisdiction over claims arising under any Act of Congress relating to copyrights); 18 U.S.C. § 1964(a) (conferring original jurisdiction over claims arising under 18 U.S.C. § 1962). 7 Case 9:21-cv-80722-XXXX Document 1 Entered on FLSD Docket 04/15/2021 Page 8 of 52 47. Jurisdiction for BARNES’s claims also lies with the United States District Court for the Southern District of Florida pursuant to 28 U.S.C. 1332(a)(1) (conferring original jurisdiction over claims arising between citizens of different states). 48. Defendant JACKSON is subject to personal jurisdiction in the United States District Court for the Southern District of Florida pursuant to Federal Rule of Civil Procedure 4(b) and the Florida Long Arm Statute, Fla. Stat. § 48.193(1) and (2), because JACKSON is engaged in substantial and not isolated activity within the state of Florida, specifically, through ENTERPRISES.
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