Plaintiff Getty Images brings this action to recover damages resulting from
copyright infringements by Defendant Gestalt Ventures, Inc., dlb/a Elemental Consulting ("Elemental Consulting") of a photographic image exclusively licensed to Getty Images.
Defendant Elemental Consulting has reproduced, displayed, distributed and otherwise misused the protected image on its website, www.goelemental.com, without authorization and without paying Getty Images the required commercial license fee. Defendant's conduct violates the rights of Getty Images and the rights of the photographer that Getty Images represents.
Plaintiff Getty Images is a New York corporation with its principal place of
business in New York, New York.
Defendant Gestalt Ventures is a Texas corporation with its principal place of business in San Antonio, Texas. Gestalt Ventures has registered the assumed name of Elemental
Consulting with the Bexar County Clerk in San Antonio, Texas. Elemental Consulting is the registered owner of the website www.goelemental.com. Upon information and belief, Elemental Consulting directly participated in the wrongful conduct alleged in this Complaint, and/or had the right and ability to supervise, direct and control the wrongful conduct of others, and derived a direct financial benefit from that wrongful conduct.
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