Plaintiff, Getty Images brings this action to recover damages resulting from copyright infringements by Defendant, F.H.L. Logistics, Inc. (“F.H.L. Logistics”) of a photographic image exclusively licensed to Getty Images. Defendant, F.H.L. Logistics has reproduced, displayed, distributed and otherwise misused the protected image on its website, www.fhllogistics.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, F.H.L. Logistics is a corporation organized under the laws of the State of Florida, with its principal place of business in Doral, Florida. F.H.L. does business in the city and the county of Doral, Miami-Dade County, Florida. F.H.L. Logistics is the registered owner of the website www.fhllogistics.com. Upon information and belief, F.H.L. Logistics 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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