Ron Raffaelli vs. Getty Images: Complaint

8/3/2019 Ron Raffaelli vs. Getty Images: Complaint

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SCHWARCZ. RIMBERG.BOYD&RADER.LLP

6310 Sa n Vicente Bhd

Los Angeles . CA 90048

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KATHRYN LEE BOYD, ESQ. (SBN 189496)IboydrtUsrbr-law.comDARCY R. HARRIS, ESQ. (SBN 200594)dharrisrtUsrbr-law.comSHERLTSHAMTOUB, ESQ. (SBN 270022)sshamtouboasrbr-law.comSCHWARCZ, RIMBERG BOYD & RADER .~......--6310 San Vicente Boulevard, Suite 360Los Angeles, California 90048Phone: 1323) 302-9488Fax: (323) 931-4990

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GETTY IMAGES, INC.; AND DOES1 THROUGH 10, INCLUSIVE,

OR I G I N

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7 Attorneys for Plaintiff RON RAFFAELLI

8UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

RON RAFFAELLI,

Plaintiff,

vs.

Defendants.

c a ~M > . 1 2COMPLAINT1. Copyright Infringement (Unpublished

Works)2. Copyright Infringement3. Replevin4. Conversion5. Damages Under California Penal Code

4966. Declaratory Relief

DEMAND FOR JURY TRIAL

RAFFAELLI Y. GETTY IMAGES

COMPLAINT



4 images of iconic performers and classic rock musicians from the 1960s and 70s,

5 especially his extensive work depicting Jimi Hendrix, have earned him the unofficial title

6 of "the King of Rock and Roll Photography." Mr. Raffaelli brings this action for

7 violation of federal copyright laws, for conversion and for the return of his photographic

8 artwork currently in the possession of Defendant Getty Images, Inc. ("Getty Images" or

9 "Defendant"), from which it is profiting knowing that the artwork was stolen. Mr.

10 Raffaelli seeks to hold Getty Images accountable for its infringements of his copyrights

11 through, among other things, the distribution, sale and public display of iconic

12 photographic works that were stolen from the artist (the "Stolen Raffaelli Works"). Mr.

13 Raffaelli seeks not only the return of his artwork, but damages, and a declaratory

14 judgment of his ownership rights to the stolen property in the unlawful possession of

15 Defendant Getty Images.

17 Ochs Archives (hereinafter the "Archives"), which is a collection of prints and negatives,

18 including, in part, images of iconic musicians and performers from the 1960s and 70s.

19 The Archives' possession and use of certain photographs and/or imagery is steeped in

20 legal controversy. Indeed, Michael Ochs, the former owner of the Archives, is notorious

21 within the image-licensing industry for unlawfully licensing photographs and imagery

22 without the knowledge or consent of the copyright owners.

24 stolen works, and in total disregard for the consequences thereof, in 2007, Getty Images

25 purchased the Archives and thereafter commenced displaying the contents of the

26 Archives for public sale on its website <www.gettyimages.com>.

28 possession of the Stolen Raffaelli Works and was unlawfully copying, publishing,- 1 -

SCHWARCZ, R1MBERG, RAFFAELLI v. GETTY IMAGESBOYD & RADER , LLP COMPLAINT

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1 RON RAFFAELLI ("Plaintiff' or "Raffaelli") hereby alleges as follows:

2 NATURE OF THE ACTION

3 1. Plaintiff Ron Raffaelli is a world-renowned American photographer, whose

Getty Images apparently purchased the Stolen Raffaelli Works from the Michael

Nevertheless, armed with specific information that the Archives consisted of

In or about late 2009 or early 2010, Raffaelli discovered that the Getty Images had



11 defendants named herein as DOES I hrough 10, inclusive, are unknown to Plaintiff, who

12 therefore sues said defendants by such fictitious names. Plaintiff will ask leave of Court to

13 amend this Complaint and insert the true names and capacities of said defendants when

14 the same have been ascertained.

16 designated herein as a "DOE" is legally responsible in some manner for the events and

17 happenings herein alleged, and that Plaintiffs damages as alleged herein were proximately

18 caused by such Defendants.

19 JURISDICTION AND VENUE

21 infringement under the copyright laws of the United States, 17 Us. c. § 101 et seq.

22 Accordingly, this Court has subject matter jurisdiction over this action pursuant to 28

23 usc. § 1331 and 28 usc. § 1338(a) and supplemental jurisdiction of the state law

24 claims pursuant to 28 u.s .c . § 1367(a).

25 10. Venue is proper in this Judicial District under 28 U'S.C. §§ 1391 (b) and (c) and 28

26 Us.c. § 1400(a) because the claim arises in this Judicial District, the Defendant may be

27 found and transacts business in this Judicial District, and the injury suffered by Plaintiff

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1 distributing, licensing, selling and/or otherwise publicly displaying said works. Shortly

2 thereafter, and within the applicable statutory period, Raffaelli brought this action.

3 PARTIES

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Plaintiff Ron Raffaelli is an individual residing in Kern County, Bakersfield.

Defendant Getty Images is a corporation incorporated and existing under the laws

6 of Washington, and has an office located in Los Angeles County. Getty Images regularly

7 does or solicits business or is engaging in a persistent course of conduct in Los Angeles

8 County, and purposefully avails itself of the privileges and protections of the laws of

9 California.

The true names or capacities, whether individual, corporate or otherwise, of the

Plaintiff is informed and believes and thereupon alleges that each of the Defendants

This is a civil action seeking injunctive relief and damages for copyright

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COMPLAINT



4 11. Raffaelli is a renowned photographer, best known for his iconic photography of

5 the late Jimi Hendrix ("Hendrix") during Hendrix's first and only American tour - The

6 Experience Tour. Raffaelli is also known for his photographic work for album covers

7 and posters for legendary classic rock and roll bands and artists, such as The Doors, Led

8 Zeppelin, the Rolling Stones. Over the course of a career that has spanned four decades

9 and includes a broad range of artistic expressions, Raffaelli has had a number of books

10 and countless magazine spreads of his works published.

11 12. With respect to works at issue in this litigation, in or about 1968, Raffaelli entered

12 into a collaborative arrangement with Jerry Goldstein ("Goldstein") and Steve Gold

13 ("Gold") to publish Raffaelli's photographs through the "The Visual Thing." Pursuant to

14 this collaboration, Raffaelli selected images from his pre-existing portfolio of

15 photography and camera-ready art created solely by him, to be used in album covers, tour

16 books and posters, which would be exclusively advertised, marketed, published and

17 distributed by The Visual Thing.

18 13. In exchange for their financial backing and distribution efforts, Goldstein and

19 Gold received a combined 85% of the profits generated from the sales of the Raffaelli's

20 work through The Visual Thing. Raffaelli received a significantly lower share of the

21 profits - a mere fifteen percent (15%), plus modest rent and expenses - but, Raffaelli

22 retained all his rights, including intellectual property rights, to his photography,

23 production materials, props and '.JI other items used to produce his work.

24 14. Raffaelli had exclusive control over his creative output, from the inception of the

25 artistic concept to the creation of the finished work. Raffaelli personally took the

26 photography, and produced the finished "camera ready art" which went directly from

27 Raffaelli to the appropriate printer. Indeed, Raffaelli's level of involvement and

28 commitment to his work was such that he would often be personally present at the printer- 3 -

SCHWARCZ, RIMBERG, RAFFAELLI v. GETTY IMAGESBOYD & RADER, LLP COMPLAINT

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1 took place in this Judicial District. Defendant is subject to the general and specific

2 personal jurisdiction of this Court because of its contacts with the State of California.

3 BACKGROUND



1 to supervise the first print. Thereafter, Raffaelli would retrieve his work from the printer

2 and store it at his studio. A copy would be sent to The Visual Thing for the purpose of

3 marketing and distribution. All of Raffaelli's photographs, negatives, film and finished

4 work were stored at his private studio.

5 15. Raffaelli also controlled the retention and termination of his creative staff, as well

6 as decisions regarding purchasing of supplies and materials for projects. In addition,

7 Raffaelli purchased and personally owned all the photographic equipment necessary to

8 run a working photography and graphic art studio.

9 16. Raffaelli's name was to appear on all of his work distributed by The Visual Thing

10 as the author of the work. For ir.stance, the Hendrix tour book, described below,

11 attributes the photography and layout to Raffaelli.

12 17. In or about 1969, Raffaelli interviewed for and was selected as the personal

13 photographer for the singer/song writer Jimi Hendrix. As a result, Raffaelli was given

14 unbridled access to Mr. Hendrix, including the opportunity for "behind the scenes" and

15 intimate shots of the musician. For over a year, from May 1969 to July 1970, Raffaelli

16 traveled with and authored hundreds of photos of Mr. Hendrix and his band members,

17 including photographing Mr. Hendrix's performance at the Waikiki Shell Auditorium, in

18 Honolulu HI on May 1969, among many others.

19 18. From his selection of Hendrix photography, Raffaelli created a tour book entitled,

20 Jimi Hendrix - Electric Church - A Visual Experience, for publication by The Visual

21 Thing, and selected three photographs to be produced as posters by The Visual Thing.

22 19. Shortly following Hendrix's American tour, Mr. Hendrix suffered an untimely

23 death, thereby making Raffaelli's photographs of Hendrix's only American tour iconic

24 collectables of the late musical master.

25 20. Following Hendrix's tour, Raffaelli continued to collaborate with The Visual

26 Thing, and produced a number of album covers, classic rock posters and tour books of

27 well-known and aspiring bands and musicians of the era, including Eric Clapton, Led

28 Zeppelin, The Rolling Stones and Creedence Clearwater Revival, among many others.- 4 -

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3 22. Shortly after the termination of the parties' collaboration, Gold, Goldstein and a

4 few men appeared at Raffaelli's studio and an altercation occurred. Although the police

5 were called, Gold and Goldstein succeeded in looting Raffaelli's studio. At the time,

6 Raffaelli believed the looted items were limited to furniture and studio equipment.

7 23. In or about early 2006, while in the process of inventorying his extensive body of

8 work, Raffaelli discovered that some of his film and material were missing, including

9 photographs of Hendrix. Raffaelli had his suspects: (1) Gold and Goldstein, or (2) Herbie

10 Worthington ("Worthington"). Although Raffaelli had not realized it at the time, Gold

11 and Goldstein could have stolen Raffaelli's photographic work during the altercation and

12 ensuing looting of Raffaelli's studio when the parties terminated their Visual Thing

13 collaboration back in 1971. Raffaelli had lost contact with Gold or Goldstein since about

14 1971 and, therefore, could not confirm his suspicions.

15 24. As to the second suspect, Worthington, Raffaelli had worked with him in the early

16 1970s, training him as a musician photographer. During this period, Worthington had

17 unrestricted access to Raffaelli's studio, and thereby to all of Raffaelli's film, negatives,

18 slides and photographs. Worthington had repeatedly asked Raffaelli to donate a portion

19 of his Hendrix photography to one Michael Ochs, who, according to Worthington,

20 intended to open a museum in dedication to the late musician. Raffaelli repeatedly

21 refused, and had never agreed to donate any of his works to Michael Ochs or any Jimi

22 Hendrix museum. By the time Raffaelli discovered that some of his work was missing,

23 in early 2006, he had lost all contact with Worthington. Thus, at this time, Raffaelli did

24 not know if the work had been stolen or merely misplaced.

25 25. In or about late 2009 or early 2010, Raffaelli learned that Michael Ochs had sold

26 the Stolen Raffaelli Works to Getty Images for a substantial profit.

27 26. Prior to this time, Raffaelli had no actual knowledge that his work had been stolen,

28 that it had been taken by either Gold and Goldstein or Worthington, that it had come into- 5 -

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1 21. In or about 1971, the parties had a falling out and the Visual Thing collaboration

2 terminated.



4 27. Getty Images is a dealer of visual content, including rare and archival imagery.

5 Either by way of acquisitions or through the work of its own photographers, Getty

6 Images licenses imagery in over 100 countries, thereby making it one of the world's

7 largest dealers of visual content.

8 28. In addition, the Getty Images Gallery, one of London's largest and most influential

9 photography galleries, showcases exhibitions taken from its archival libraries, which it

10 also makes available for purchase as fine art prints in a variety of sizes and framing

11 options.

12 29. Raffaelli is informed and believes that, in or about February 2007, Getty Images

13 purchased the Archives from Michael Ochs. In a press release about the transaction,

14 Getty Images touted that "[m]usic enthusiasts, in particular, will be thrilled by the

15 addition of this unique collection, which is arguably the best of its kind in the world."

16 Plaintiff is further informed and believes that, in April 2007, approximately 15,000

17 digitized works from the Archives were made available through Getty Images' website,

18 www.gettyimages.com. and an additional 60,000 were said to be added on a rolling basis

19 through 2007.

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1 the possession of Michael Ochs, or that Michael Ochs had sold the Stolen Raffaelli Works

2 to Getty Images.

3 GETTY IMAGES PURCHASES THE ARCHIVES

30. Plaintiff is informed and believes that, prior to its 2007 purchase of the Archives,

Getty Images was informed by an industry insider that the Archives included stolen

works. Despite this warning, and in total disregard for the consequences thereof, Getty

Images purchased the Archives with knowledge that multiple images in the Archives werestolen.

3l. Upon information and belief, a portion of the images in the Archives, as sold

through www.gettyimages.com and www.gettyimagesgallery.com, are the Stolen

Raffaelli Works. The Stolen Raffaelli Works are being copied, published, distributed,

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COMPLAINT

http://www.gettyimages.com./

http://www.gettyimages.com/

http://www.gettyimagesgallery.com%2C/

http://www.gettyimagesgallery.com%2C/

http://www.gettyimages.com/




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1 licensed, sold and/or publicly displayed without Raffaelli's consent and in violation of

2 Raffaelli's copyright. Furthermore, Raffaelli is informed believes and thereupon alleges

3 that the Getty Images Gallery showcases the Stolen Raffaelli Works as works of art in its

4 gallery, and earns profits from the sale of prints of those images.

5 32. Furthermore, Raffaelli is informed, believes and thereupon alleges that Getty

6 Images possesses additional Stolen Raffaelli Works currently not on display on

7 www.gettyimages.com.

8 33. A number of the Stolen Raffaelli Works are distinct and identifiable as they

9 consist, in part, of photographs of Hendrix taken in the two week period prior to the

10 Hendrix's performance at the Waikiki Shell Auditorium and are substantially similar to,

11 or are in fact the same as, some of the images Raffaelli ultimately selected to include in

12 the Jimi Hendrix - Electric Church - A Visual Experience tour book.

13 34. Sometime after the 2007 purchase, upon information and belief, Getty Images was

14 informed that the Archives included the Stolen Raffaelli Works. Then, in about 2010 or

15 2011, Raffaelli, through his agent, contacted Getty Images and informed Defendant that

16 the Stolen Raffaelli Works belong to him and demanded their return. Despite this

17 knowledge, Getty Images continues to infringe Raffaelli's copyrights and refuses to

18 return the Stolen Raffaelli Works.

19 FIRST CAUSE OF ACTION

20 (Copyright Infringement - 17 U.S.C. § 501 - Unpublished Works)

21 35. The allegations set forth in the above paragraphs, 1 through 34, are re-alleged and

22 reincorporated by reference as if fully set forth below.

23 36. On December 29,2011, Raffaelli submitted 17 separate applications for copyright

24 registration of the unpublished Stolen Raffaelli Works. Attached as Exhibit "A" are true

25 and correct copies of the U.S. Copyright Office Deposit Shipping Slips, listing the Title,

26 Case Date, and Application Number ("Case/SR #") for each of the 17 applications. True

27 and accurate copies of the Stolen Raffaelli Works with Getty Images' corresponding

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RAFFAELLI v. GETTY IMAGECOMPLAINT





1 Editorial Numbers assigned to each are attached hereto as Exhibit "B" and are

2 incorporated herein by reference.

3 37. Raffaelli is the author of the unpublished Stolen Raffaelli Works, which to

4 Raffaelli's knowledge at this time consist of over 360 images of Jimi Hendrix, including,

5 but not limited to, group and solo images of Hendrix and his band members, bassist Noel

6 Redding and drummer Mitch Mitchell; four (4) images of Jimmy Page; three (3) images

7 of the StoneslMick Jagger; one (1) image of Three Dog Night; two (2) images of Joni

8 Mitchell; two (2) images of Creedence Clearwater Revival; four (4) images of Eric

9 Burdon; and two (2) images of Blind Faith. See Exhibit B.

10 38. Since the creation of the unpublished Stolen Raffaelli Works, Raffaelli has been

11 and remains the sole owner of all rights, title and interest in and to the copyright of the

12 unpublished Stolen Raffaelli Works.

13 39. During the statutory period, Getty Images infringed Raffaelli's copyrights by

14 copying, publishing, distributing, selling, licensing and/or publicly displaying the

15 unpublished Stolen Raffaelli Works without Raffaelli's authorization or permission.

16 40. At the time Getty Images infringed Raffaelli's copyrights, Getty Images knew that

17 the infringed works belonged to Raffaelli and that Getty Images did not have permission

18 to exploit Raffaelli's works. Prior to its purchase of the Archives, Getty Images was

19 informed that the Archives included stolen works. Sometime after its purchase of the

20 Archives, Getty Images was informed that it did not have valid title to the Stolen

21 Raffaelli Works. Thereafter, Getty Images was again informed by Raffaelli's agent that

22 the Stolen Raffaelli Works belonged to Raffaelli and Getty Images was not authorized to

23 copy, publish, distribute, sell, license and/or otherwise publicly display the said works.

24 41. Thus, Getty Images is on notice and knows that its acts constituted copyright

25 infringement. Notwithstanding this knowledge, Getty Images continues to engage in

26 copyright infringement.

27 42. Raffaelli is informed, believes and thereupon alleges that Getty Images possesses

28 additional unpublished Stolen Raffaelli Works currently not on display on- 8 -

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1 www.gettyimages.com, and reserves the right to amend his complaint to assert copyright

2 infringement on those currently undisclosed unpublished Stolen Raffaelli Works.

3 43. As a result of its wrongful conduct, Getty Images is liable to Raffaelli for

4 copyright infringement. Plaintiff has suffered, and will continue to suffer, substantial

5 losses, including but not limited to harm to his artistic, professional and business

6 reputation and goodwill.

7 44. By reason of Getty Images' acts of infringement as alleged above, Raffaelli has

8 suffered and will continue to suffer substantial damages to his business in an amount to

9 be established at trial, as well as additional general and special damages in an amount to

10 be established at trial.

11 45. Due to its acts of copyright infringement as alleged herein, Getty Images has

12 obtained direct and indirect profits it would not otherwise have realized but for its

13 infringement of the Stolen Raffaelli Works. As such, Raffaelli is entitled to disgorgement

14 from Getty Images of all profits directly and indirectly attributable to its infringement of

15 the Stolen Raffaelli Works, in an amount to be established at trial.

16 46. Raffaelli is informed and believes and thereon alleges that the above-described

17 acts of copyright infringement were committed with knowledge of or reckless disregard

18 for his copyrights, subjecting Getty Images to liability for statutory damages pursuant to

19 17 U.S.C. Section 504(c), in the amount of up to one hundred fifty thousand dollars

20 ($150,000) for each such act of infringement.

21 47. Further irreparable harm to Raffaelli is imminent as a result of Getty Images'

22 conduct, and Raffaelli is without an adequate remedy at law. Raffaelli is entitled to an

23 injunction restraining Getty Images from engaging in further such acts of copyright

24 infringement.

25 48. In addition, given the numerous warnings and notices received by Getty Images

26 about the Archives including stolen works and, in particular, including the Stolen

27 Raffaelli Works, and Getty Images' continued infringement, Plaintiff seeks recovery

28 punitive damages on the basis of Getty Images' willful and/or malicious conduct.- 9 -

SCHWARCZ, R IM BERG , RAFFAELLI Y. GETTY IMAGESBOYD & RADER , LLP COMPLAINT

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SCHWARCZ, RIMBERG,BOYD & RADER, LLP

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1 SECOND CAUSE OF ACTION

2 (CopyrightInfringement - 17 U.S.C. § 501)



5 50. Raffaelli brings a copyright infringement action for certain of the Stolen Raffaelli

6 Works which were contained within previously published works and are protected by

7 federal copyright. The copyright registrations for those works include: (1) K87780:

8 Crucified female suspended above 4 seated males; (2) K87790: Young Male holding 6

9 young people in hand; and (3) K87792: Worm's eye view of standing male with view of

10 4 young people between his spread legs. In addition, the tour book entitled Jimi Hendrix

11 - Electric Church - A Visual Experience containing certain of the Stolen Raffaelli Works

12 was published with a copyright notice: "Copyright - 1969." See Exhibit B.

13 51. Raffaelli is the sole owner of all rights, title and interest in and to the copyright of

14 the Stolen Raffaelli Works which were contained within previously published works.

15 52. During the statutory period, Getty Images infringed Raffaelli's copyrights by

16 copying, publishing, distributing, selling, licensing and/or publicly displaying the Stolen

17 Raffaelli Works contained within previously published works without Raffaelli's

18 authorization or permission.

19 53. At the time Getty Images infringed Raffaelli's copyrights, Getty Images knew that

20 the infringed works belonged to Raffaelli and that Getty Images did not have permission

21 to exploit Raffaelli's works. Prior to its purchase of the Archives, Getty Images was

22 informed that the Archives included stolen works. Sometime after its purchase of the

23 Archives, Getty Images was informed that it did not have valid title to the Stolen

24 Raffaelli Works. Thereafter, Getty Images was again informed by Raffaelli's agent that

25 the Stolen Raffaelli Works belonged to Raffaelli and Getty Images was not authorized to

26 copy, publish, distribute, sell, license and/or otherwise publicly display the said works.

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COMPLAINT



1 54. Thus, Getty Images is on notice and knows that its acts constituted copyright

2 infringement. Notwithstanding this knowledge, Getty Images continues to engage in

3 copyright infringement.

4 55. Raffaelli is informed, believes and thereupon alleges that Getty Images possesses

5 additional Stolen Raffaelli Works which may have been contained in previously

6 published works, and reserves the right to amend his complaint to assert copyright

7 infringement on those currently rndisclosed Stolen Raffaelli Works.

8 56. As a result of its wrongful conduct, Getty Images is liable to Raffaelli for

9 copyright infringement. Plaintiff has suffered, and will continue to suffer, substantial

10 losses, including but not limited to harm to his artistic, professional and business

11 reputation and goodwill.

12 57. By reason of Getty Images' acts of infringement as alleged above, Raffaelli has

13 suffered and will continue to suffer substantial damages to his business in an amount to

14 be established at trial, as well as additional general and special damages in an amount to

15 be established at trial.

16 58. Due to its acts of copyright infringement as alleged herein, Getty Images has

17 obtained direct and indirect profits it would not otherwise have realized but for its

18 infringement of the Stolen Raffaelli Works. As such, Raffaelli is entitled to disgorgement

19 from Getty Images of all profits directly and indirectly attributable to its infringement of

20 the Stolen Raffaelli Works, in an amount to be established at trial.

21 59. Raffaelli is informed and believes and thereon alleges that the above-described

22 acts of copyright infringement were committed with knowledge of or reckless disregard

23 for his copyrights, subjecting Getty Images to liability for statutory damages pursuant to

24 17 U.S.C. Section 504(c), in the amount of up to one hundred fifty thousand dollars

25 ($150,000) for each such act ofinfringement.

26 60. Further irreparable harm to Raffaelli is imminent as a result of Getty Images'

27 conduct, and Raffaelli is without an adequate remedy at law. Raffaelli is entitled to an

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COMPLAINT



1 injunction restraining Getty Images from engaging in further such acts of copyright

2 infringement.

3 61. In addition, given the numerous warnings and notices received by Getty Images

4 about the Archives including stolen works and, in particular, including the Stolen

5 Raffaelli Works, and Getty Images' continued infringement, Plaintiff seeks recovery

6 punitive damages on the basis of Getty Images' willful and/or malicious conduct.

7 THIRD CAUSE OF ACTION

8 Replevin



11 63. The Stolen Raffaelli Works qualify as "fine art" as defined in paragraph (1) of

12 subdivision (d) of Section 982 oithe Civil Code.

13 64. Getty Images on its own, and/or through Getty Images Gallery, is a dealer or

14 gallery subject to Civil Code Section 338(c)(3).

15 65. Plaintiff has the right to immediate and exclusive possession of the Stolen

16 Raffaelli Works.

17 66. The Stolen Raffaelli Works are currently in the possession of Getty Images

18 without Plaintiff s consent.

19 67. Plaintiff has demanded the return of the Stolen Raffaelli Works and Getty Images

20 has refused.

21 68. As a result, Raffaelli seeks the immediate return of the Stolen Raffaelli Works.

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FORTH CAUSE OF ACTION

Conversion



26 70. The Stolen Raffaelli Works qualify as "fine art" as defined in paragraph (1) of

27 subdivision (d) of Section 982 of the Civil Code.

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RAFFAELLI v. GETTY IMAGESCOMPLAINT



1 71. Getty Images on its own, and/or through Getty Images Gallery, is a dealer or

2 gallery subject to Civil Code Section 338(c)(3).

3 72. Plaintiff owned or possessed or had a right to possess the Stolen Raffaelli Works.

4 73. Defendants intentionally and substantially interfered with Plaintiffs rights by

5 taking possession of the Stolen Raffaelli Works, preventing Plaintiff from having access

6 to the Stolen Raffaelli Works and/or refusing to return the Stolen Raffaelli Works after

7 Plaintiff demanded their return.

8 74. Getty Images converted and appropriated the Stolen Raffaelli Works to their own

9 use in complete disregard and derogation of Raffaelli's rights, title and interest.

10 75. At no time did Plaintiff consent to Getty Images taking possession of the Stolen

11 Raffaelli Works.

12 76. As a result of Defendants' wrongful conduct, Plaintiff seeks the immediate return

13 of the Stolen Raffaelli Works.

14 FIFTH CAUSE OF ACTION

15 Damages under Cal. Penal Code § 496



18 78. Getty Images does not have good title to the Stolen Raffaelli Works.

19 79. Prior to purchasing the Archives, Getty Images was placed on notice that the

20 Archives included stolen works. Notwithstanding this knowledge, Getty Images

21 purchased the Archives.

22 80. Thereafter, Getty Images was placed on notice that the Archives contained Stolen

23 Raffaelli Works, but Getty Images refused to return the Stolen Raffaelli Works.

24 81. Getty Images has unlawfully refused Plaintiff s demand for return of the Stolen

25 Raffaelli Works in violation of California Penal Code Section 496.

26 82. Getty Images knows that the Stolen Raffaelli Works were stolen and Defendant

27 has no viable legal defense to Plaintiffs claim to the return of the Stolen Raffaelli Works.

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COMPLAINT



1 83. Plaintiff has been damaged by the unlawful withholding of his property, and is

2 therefore entitled under Penal Code Section 496( c) to a judgment against Defendant for

3 three times the amount of its actual damages, which amount shall be proven at trial.

4 SIXTH CAUSE OF ACTION

5 Declaratory Judgment



8 85. The Stolen Raffaelli Works in the possession of the Getty were unlawfully taken

9 and never returned to Raffaelli.

10 86. Getty Images does not have good title to the Stolen Raffaelli Works currently in

11 their possession and control.

12 87. Plaintiff has demanded the return of the Stolen Raffaelli Works, and Getty Images

13 has refused.

14 88. Plaintiff is entitled to a judgment declaring that it is the rightful owner of the

15 Stolen Raffaelli Works, and that Getty Images has no right, title and interest in them.

16 Prayer for Relief

17 WHEREFORE, Plaintiff prays that judgment be entered against Defendant as

18 follows:

SCHWARCZ. R1MBERG.BOYD & RADER. LLP


Los Angeles . CA 900~8

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(a)

(b)

(c)

For a preliminary and permanent injunction enjoining and restraining

Defendant and its officers, agents, employees and representatives, and all

persons acting in concert with them, from reproducing, adapting and

displaying promoting, offering for sale and/or selling, advertising about or

distributing the Stolen Raffaelli Works;

For damages permitted by federal copyright law, including without

limitation, Plaintiffs actual damages and Defendant's profits, plus interest,

as well as all statutory and punitive damages permitted;

For an order directing the Defendant to immediately deliver the original

works to Plaintiff;- 14 -

RAFFAELLI v . GETTY IMAGESCOMPLAINT



SCHWARCZ, RIMBERG,BOYD & RADER , LLP

6 3 1 0 Sa n viceme Blvd

UlS Angel es . CA 900~8

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8

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14

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2

RAFF AELLI v. GETTY IMAGES

COMPLAINT

1 (d) For treble damages pursuant to Cal. Penal Code § 496(c) in an amount to be

established at trial;

3 (e) For attorneys' fees pursuant to Cal. Penal Code §496(c);

4 (t) For an award to Plaintiff for the costs and disbursements of this action; and

5 (g) For such other and further relief as this Court deems just and proper.

Dated: January 19,2012 SCHWARCZ, RIMBERG, BOYD &RADERLLP

By-

Attorneys for PlaintiffR

DEMAND FOR JURY TRIAL

Plaintiff RON RAFFAELLI hereby respectfully demands a trial by jury for all

claims and issues raised in his Complaint to which he is or may be entitled to a jury trial.

Dated: January 19,2012 SCHWARCZ, RIMBERG, BOYD &RADERLLP ')

Attorneys for Plaintiff RON RAFFAELLI

- 15 -



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UNITED S\wtES DISTRICT COURT, CENTRAL DIST~ OF CALIFORNIACIVIL COVER SHEET

(b) Attorneys (Finn Name, Address and Telephone Number. Ifyou are representingyourself, provide same.)

Kathryn Lee Boyd (SBN 189496), Schwarcz, Rimberg, Boyd & Rader LLP6310 San Vicente Blvd. , Sui te 360, Los Angeles CA 90048Tel: 323·302·9488

Attorneys (If Known)

I (a) PLAINTIFFS (Check box if you are representing yourself 0)RON RAFFAELLI

DEFENDANTSGETTY IMAGES, INC.

OR IG IN

o I u.s.Government Plaintiff i 3 Federal Question (U.S.Goverrunent Not a Party) Citizen of This State

PTF DEF PTF DEF01 01 Incorporated or Principal Place 04 04

of Business in this State

02 02 Incorporated and Principal Place 05 05of Business in Another State

II. BASIS OF JURISDICTION (Place an X in one box only.) Ill. CITIZENSHIP OF PRINCIPAL PARTIES· For Diversity Cases Only(Place an X in one box for plainti ff and one for defendant. )

02 U.S. Government Defendant 04 Diversity (Indicate Citizenship Citizen of Another Stateof Par ties in I tem III)

Citizen or Subject of a Foreign Country 03 03 Foreign Nation 06 06

IV. ORIGIN (Place an X in one box only.)

"'I Original 02 Removed from 03 Remanded from 04 Reinstated or 0 5 Transferred from another district (specify): 06 Multi-Proceeding State Court Appellate Court Reopened District

Litigation

o 7 Appeal to DistricJudge fromMagistrate Judge

V. REQUESTED IN COMPLAINT: JURY DEMAND: ",Yes 0 No (Check 'Yes' only if demanded in complaint.)

CLASS ACTION under F.R.C.P. 23: 0 Yes !iNo riMONEY DEMANDED IN COMPLAINT: $ according to proof

VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a hriefstatement of cause. Do not cite jurisdictional statutes unless diversity.)

I . Copyright Infr ingement 17U.S.c . s 501; 2. Replevin; 3 . Convers ion; 4. Damages Under Cal . Penal Code s 496; 5. Declaratory Rel ief

VII. NATURE OF SUIT (Place an X in one box only.)

. OTHER srxruras CONTRACT TORTS 1TORTS 1 PRISONER -1 LABORi ! . .

0400 State Reapportionment 0110 Insurance PERSONAL INJURY PERSONAL PETITIONS i 0710 Fair Labor Standards0410 Antitrust 0120 Marine 0310 Airplane PROPERTY 0510 Motions to Act0430 Banks and Banking 0130 Miller Act 0315 Airplane Product 0370 Other Fraud Vacate Sentence 0720 Labor/Mgmt.0450 Commerce/ICC 0140 Negotiable Instrument Liability 0371 Truth in Lending Habeas Corpus Relations

Rates/etc. 0150 Recovery of D 320 Assault , Libel & 0380 Other Personal 0530 General 0730 LaborlMgmt.0460 Deportation Overpayment & Slander Property Damage 0535 Death Penalty Reporting &0470 Racketeer Influenced Enforcement of D 330 Fed. Employers' 0385 Property Damage 0540 Mandamus/ Disclosure Act

and Corrupt Judgment Liability Product Liability Other 0740 Railway Labor ActOrganizations 0151 Medicare Act 0340 Marine BANKRUPTCY 0550 Civil Rights 0790 Other Labor

0345 Marine Product,

0480 Consumer Credit 0152 Recovery of DefaultedLiability

0422 Appeal 28 USC o 555 Prison Condition Litigation0490 Cable/Sat TV Student Loan (Excl, 158 FORFEITURE / ! 0791 Empl. Ret. Inc.0810 Selective Service Veterans)

0350 Motor Vehicle0423 Withdrawal 28 PENALTY

iSecurity Act0355 Motor Vehicle I

0850 Securities/Commodities/ 0153 Recovery of Product LiabilityUSC 157 0610 Agriculture r I :PROPERTY RIGHTS

Exchange Overpayment of D 360 Other Personal CIVIL RIGHTS j 0620 Other Food & 820 Copyrights0875 Customer Challenge 12 Veteran's Benefits Injury 0441 Voting Drug 0830 Patent

U SC 3410 0160 Stockholders'Suits 0362 Personal Injury- 0442 Employment 0625 Drug Related 0840 Trademark0890 Other Statutory Actions 0190 Other Contract Med Malpractice 0443 Housing/ Acco- Seizure of . socIALSECURITY0891 Agricultural Act 0195 Contract Product 0365 Personal Injury. mmodations Property 21 USC o 861 HIA (I 395ft)0892 Economic Stabilization Liability Product Liability 0444 Welfare 881 0862 Black Lung (923)

Act o 196 Franchise 0368 Asbestos Personal 0445 American with 0630 Liquor Laws 0863 DIWC/DlWW

0893 Envirorunental Matters REAL PROPERTY Injury Product Disabilities . 0640 R.R. & Truck (405(g))0894 Energy Allocation Act 0210 Land Condemnation Liability Employment 0650 Airline Regs 0864 SS10Title XVI0895 Freedom ofInfo. Act 0220 Foreclosure IMMIGRATION i 0446 American with 0660 Occupational 0865 RSI(405(g»0900 Appeal of Fee Determi- 0230 Rent Lease & Ejectment 0462 Naturalization Disabilities- Safety /Health FEDERAL TAX SUITS

nation Under Equal 0240 Torts to Land Application Other 0690 Other 0870 Taxes (U.S. PlaintiffAccess to Justice 0245 Tort Product Liabil ity 0463 Habeas Corpus. 0440 Other Civil or Defendant)

0950 Constitutionality of 0290 All Other Real Proper ty Alien Detainee Rights 0871 IRS·Third Party 26State Statutes 0465 Other Immigrat ion US C 7609

Actions

FOR OFFICE USE ONLY: Case Number: _

AFTER COMPLETING THE FRONT SIDE OF FORM CV·71, COMPLETE THE INFORMATION REQUESTED BELOW.

, C V 1 2 0563

CV·71 (05/08) CIVIL COVER SHEET Page I o



UNITED ~ES DISTRICT COURT, CENTRAL DISTWOF CALIFORNIACIVIL COVER SHEET

VIII(a). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed" !iNo DYesIf yes, list case number(s): _

VIII (b) . RELATED CASES: Have any cases been previously filed in this court that are related to the present case? ! i N o DYesIf yes, list case number(s): _

Civil cases are deemed related if a previously filed case and the present case:

(Check all boxes that apply) D A. Arise from the same or closely related transact ions , happenings , or events ; or

D B. Call for determinat ion of the same or substantia lly rela ted or s imilar questions of law and fact ; orDC. For other reasons would entail substant ia l dupl icat ion of labor ifheard by different judges; or

D D. Involve the same patent, trademark or copyright, and one of the factors ident ified above in a, b or c also is present.

IX. VENUE: (When completing the following information, use an additional sheet if necessary.)

(a) List the County in this District; California County outside of this District; State ifother than California; or Foreign Country, in which EACH named plaintiff resides.if'th d th o h k bCheck here I e government, I ts agencies or employees ISa name. plainti ff. If ISbox ISc ec ed, go to Item ( ).

County in this District:" California County outside of this District; State, ifother than California; or Foreign Country

Kern County (Bakersfield)

(b) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named defendant resides.

D Check here if the government, its agencies or employees is a named defendant. If this box is checked, go to item (c).

County in this District:" California County outside of this District; State, if other than California; or Foreign Country

Los Angeles County

(c) Lis t the County in this Dis tr ic t; California County outs ide of this Distr ic t; State if other than California ; or Foreign Country, in which EACH claim arose.Note' In land condemnation cases use the location of the tract of land involved

County in this District:" California County outside of this District; State, ifother than California; or Foreign Country

Los Angeles County

X .

Notice to Counsel/Parties: The CV-71 (JS-44) Civil Cover Sheet and the inti nation contained herein neither replace nor supplement the filing and service of pleadingsor other papers as required by law. This fonn, approved by the Judicial Confere ce of the United States inSeptember 1974, isrequired pursuant to Local Rule 3-1 isnot filedbut is used by the Clerk of the Court for the purpose ofs ta tis tics, venue and ini iatingthe civil docket sheet. (For more detailed instructions, see separate instructions sheet.)

Key to Statistical codes relating to Social Security Cases:

Nature of Suit Code Abbreviation Substantive Statement of Cause of Act ion

861 HIA All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended.Also, include claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under theprogram. (42 U.S.C. 1935FF(b))

862 BL All cla ims for "Black Lung" benefi ts under Title 4, Par t B, of the Federal Coal Mine Health and Safety Act of 1969.(30 U.S.c . 923)

863 DIWC All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, asamended; plus all claims filed for child's insurance benefits based on disability. (42 U.S.c. 405(g))

863 D1WW All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social SecurityAct, as amended. (42 U.S.c. 405(g»

864 SS1D All claims for supplemental security income payments based upon disability filed under Title 16of the Social Security

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Ron Raffaelli vs. Getty Images: Complaint

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