31653/001/3453468.2
COWAN, LIEBOWITZ & LATMAN, P.C. 114 West 47th Street New York, NY 10036-1525 (212) 790-9200Kieran G. Doyle ([email protected])Thomas Kjellberg ([email protected])
Paul D. Polidoro ([email protected]) Watch Tower Bible and Tract Society of Pennsylvania 100 Watchtower Drive Patterson, NY 12563 (845) 306-1000
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
WATCH TOWER BIBLE AND TRACT SOCIETY OF PENNSYLVANIA,
Plaintiff,
-against-
THE TRUTH AND TRANSPARENCY FOUNDATION, RYAN C. McKNIGHT, and ETHAN G. DODGE,
Defendants.
No.
COMPLAINT
Plaintiff Watch Tower Bible and Tract Society of Pennsylvania, by its attorneys, Cowan,
Liebowitz & Latman, P.C., for its Complaint against Defendants The Truth and Transparency
Foundation, Ryan C. McKnight, and Ethan G. Dodge alleges:
NATURE OF THE ACTION
1. This is a civil action for copyright infringement in violation of the Copyright Act,
17 U.S.C. § 101 et seq. This litigation seeks relief against the ongoing wholesale infringement of
20-cv-3366
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 1 of 102
2
31653/001/3453468.2
Plaintiff’s registered copyrights in 74 original motion pictures. Defendants, without
authorization or permission from Plaintiff, have made unauthorized copies of Plaintiff’s motion
pictures, and are reproducing, publicly displaying, publicly performing and distributing
Plaintiff’s works online. Plaintiff, accordingly, seeks injunctive relief and statutory damages for
willful copyright infringement.
PARTIES
2. Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (“Watch Tower”)
is a Pennsylvania non-profit corporation with its principal place of business at 200 Watch Tower
Drive, Patterson, New York 12563.
3. Upon information and belief, Defendant The Truth and Transparency Foundation
(“TTF”) is a Nevada non-profit corporation with its principal place of business at 109 Cascade
Meadow Court, Henderson, Nevada 89011.
4. Upon information and belief, Defendant Ryan C. McKnight (“McKnight”) is an
individual residing in Henderson, Nevada. Mr. McKnight is the President and Executive
Director and a founding owner of TTF.
5. Upon information and belief, Defendant Ethan G. Dodge (“Dodge”) is an
individual residing in Pleasant Grove, Utah. Mr. Dodge is the Secretary and Technical Director
and a founding owner of TTF.
6. Upon information and belief, McKnight and Dodge had and still have primary
responsibility for the control, management and operation of the affairs of TTF, with the right and
ability to supervise the infringing activities complained of in this Complaint.
7. Upon information and belief, Defendants, while engaging and participating in the
unlawful acts set forth herein, were agents of and collaborators with one another.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 2 of 102
3
31653/001/3453468.2
8. Upon information and belief, Defendants operate and control websites located at
www.faithleaks.org and www.truthandtransparency.org.
JURISDICTION AND VENUE
9. This Court has original jurisdiction over claims arising under the Copyright Act
pursuant to 28 U.S.C. §§ 1331 and 1338.
10. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b) and (c).
11. This Court has personal jurisdiction over Defendants because, on information and
belief, Defendants, in person or through an agent,
(a) have transacted business, and have offered to supply goods, in New York,
including through their interactive website located at truthandtransparency.org, on which
merchandise is offered for sale to, and donations solicited from, New York residents;
and/or
(b) have committed tortious acts both within and outside New York, causing
injury to Watch Tower in New York.
FACTUAL BACKGROUND
12. Watch Tower over decades has created and published thousands of original works
of authorship, including literary works, works of visual art, musical works, and motion pictures,
and has secured over 3,300 federal copyright registrations for its original works. Under the
Copyright Act, Watch Tower has the exclusive rights, among other things, to “reproduce the
copyrighted work[s],” to “distribute copies or phonorecords of the copyrighted work[s] to the
public,” and in the case of its “motion pictures and other audiovisual works, to perform the
copyrighted work[s] publicly,” as well as to authorize or license others to engage in such
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 3 of 102
4
31653/001/3453468.2
activities. 17 U.S.C. § 106.
13. In mid-2018, Watch Tower learned that 487 of its copyrighted literary works were
being reproduced, displayed and distributed without license or permission by Defendants on the
faithleaks.org website.
14. On December 31, 2018, Watch Tower’s counsel notified Defendants that their
unauthorized publication of Watch Tower’s literary works on the faithleaks site was in violation
of Watch Tower’s exclusive rights under the Copyright Act, and demanded that such infringing
materials be removed from the faithleaks site.
15. Defendants, through counsel, declined Watch Tower’s demand that its literary
works be removed from the faithleaks site. Defendants did not contest Watch Tower’s
ownership of valid copyrights, or its prima facie case of infringement of those copyrights, but
instead asserted “the defense found in 17 U.S.C. § 107,” claiming that Defendants’ wholesale
reproduction and distribution of complete works, unaltered and unaccompanied by new matter,
was protected as fair use.
16. In May 2019, Watch Tower learned that a large number of motion pictures
created by Watch Tower, including the 74 motion pictures at issue here, had been uploaded to
and made available for public performance on Rutube, a Russian online video streaming service
located at rutube.ru and available to users worldwide.
17. Watch Tower submitted to Rutube notices of claimed infringement, objecting to
the unauthorized posting of its copyrighted works on the Rutube site and demanding their
removal. In response, Rutube removed the Watch Tower videos from its site.
18. Shortly thereafter, Defendants posted the Watch Tower videos that had been
“taken down” from Rutube to Defendants’ faithleaks.org site.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 4 of 102
5
31653/001/3453468.2
19. In a May 2019 article titled “2019 Jehovah’s Witness Convention Videos
Published Again After Successful Takedown Request,” published on Defendants’
truthandtransparency.org website, Defendants boasted not only about their past infringements
and refusals to comply with Watch Tower’s efforts to enforce its copyrights, but also about these
new infringements, leaving no doubt as to Defendants’ willfulness.
20. The Watch Tower videos remain available on the faithleaks site to the present
day.
WATCH TOWER’S COPYRIGHTED MOTION PICTURES AND DEFENDANTS’ INFRINGEMENTS
21. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Be a Courageous … Pioneer.” Watch Tower’s copyright in the “Be a Courageous …
Pioneer” video has been duly registered with the United States Copyright Office under
Registration No. PA0002121393, with an effective date of May 18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Be a Courageous … Pioneer” video on Defendants’
“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_23-
Be_a_Courageous%E2%80%94Pioneer-Video_1.mkv, where it is available, in its entirety and
without alteration, for public performance and for further reproduction and distribution via
download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 5 of 102
6
31653/001/3453468.2
22. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Talk 33 - Video 1 - Learn Courage From Creation (Symposium) – Horses.” Watch
Tower’s copyright in the “Talk 33 - Video 1 - Learn Courage From Creation (Symposium) –
Horses” video has been duly registered with the United States Copyright Office under
Registration No. PA0002121074, with an effective date of May 18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 33 - Video 1 - Learn Courage From Creation
(Symposium) – Horses” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:2017-No_33-
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 6 of 102
7
31653/001/3453468.2
Learn_Courage_From_Creation%E2%80%94Horses-Video_1.mkv, where it is available, in its
entirety and without alteration, for public performance and for further reproduction and
distribution via download, without restriction:
23. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Talk 40 - Video 1 - How Our Brothers Are Showing Courage In … (Symposium) - North
America.” Watch Tower’s copyright in the “Talk 40 - Video 1 - How Our Brothers Are
Showing Courage In … (Symposium) - North America” video has been duly registered with the
United States Copyright Office under Registration No. PA0002121104, with an effective date of
May 18, 2018.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 7 of 102
8
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 40 - Video 1 - How Our Brothers Are Showing
Courage In … (Symposium) - North America” video on Defendants’ “Faith Leaks” website, at
the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_40-
How_Our_Brothers_Are_Showing_Courage_In%E2%80%94North_America-Video_1.mkv,
where it is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
24. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Talk 44 - Video 1 - Future Events That Will Require Courage (Symposium) - The Cry of
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 8 of 102
9
31653/001/3453468.2
‘Peace and Security!’” Watch Tower’s copyright in the “Talk 44 - Video 1 - Future Events That
Will Require Courage (Symposium) - The Cry of ‘Peace and Security!’” video has been duly
registered with the United States Copyright Office under Registration No. PA0002121120, with
an effective date of May 18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 44 - Video 1 - Future Events That Will Require
Courage (Symposium) - The Cry of ‘Peace and Security!’” video on Defendants’ “Faith Leaks”
website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_44-
Future_Events_That_Will_Require_Courage%E2%80%94The_Cry_of_Peace_and_Security-
Video_1.mkv, where it is available, in its entirety and without alteration, for public performance
and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 9 of 102
10
31653/001/3453468.2
25. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Talk 45 - Video 1 - Future Events That Will Require Courage (Symposium) - The
Destruction of Babylon the Great.” Watch Tower’s copyright in the “Talk 45 - Video 1 - Future
Events That Will Require Courage (Symposium) - The Destruction of Babylon the Great” video
has been duly registered with the United States Copyright Office under Registration No.
PA0002121121, with an effective date of May 18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 45 - Video 1 - Future Events That Will Require
Courage (Symposium) - The Destruction of Babylon the Great” video on Defendants’ “Faith
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 10 of 102
11
31653/001/3453468.2
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_45-
Future_Events_That_Will_Require_Courage%E2%80%94The_Destruction_of_Babylon_the_Gr
eat-Video_1.mkv, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
26. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Talk 46-Video 1 - Future Events That Will Require Courage (Symposium) - The
Proclamation of the Hailstone Message.” Watch Tower’s copyright in the “Talk 46-Video 1 -
Future Events That Will Require Courage (Symposium) - The Proclamation of the Hailstone
Message” video has been duly registered with the United States Copyright Office under
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 11 of 102
12
31653/001/3453468.2
Registration No. PA0002121124, with an effective date of May 18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 46-Video 1 - Future Events That Will Require
Courage (Symposium) - The Proclamation of the Hailstone Message” video on Defendants’
“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_46-
Future_Events_That_Will_Require_Courage%E2%80%94The_Proclamation_of_the_Hailstone
_Message-Video_1.mkv, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
27. (a) In 2018, Watch Tower created, in-house, an original video motion picture
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 12 of 102
13
31653/001/3453468.2
titled “Talk 47 - Video 1 - Future Events That Will Require Courage (Symposium) - The Attack
by Gog of Magog.” Watch Tower’s copyright in the “Talk 47 - Video 1 - Future Events That
Will Require Courage (Symposium) - The Attack by Gog of Magog” video has been duly
registered with the United States Copyright Office under Registration No. PA0002121125, with
an effective date of May 18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 47 - Video 1 - Future Events That Will Require
Courage (Symposium) - The Attack by Gog of Magog” video on Defendants’ “Faith Leaks”
website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_47-
Future_Events_That_Will_Require_Courage%E2%80%94The_Attack_by_Gog_of_Magog-
Video_1.mkv, where it is available, in its entirety and without alteration, for public performance
and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 13 of 102
14
31653/001/3453468.2
28. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Talk 48 - Video 1 - Future Events That Will Require Courage (Symposium) -
Armageddon.” Watch Tower’s copyright in the “Talk 48-Video 1 - Future Events That Will
Require Courage (Symposium) - Armageddon” video has been duly registered with the United
States Copyright Office under Registration No. PA0002121607, with an effective date of May
18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 48-Video 1 - Future Events That Will Require
Courage (Symposium) - Armageddon” video on Defendants’ “Faith Leaks” website, at the URL
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 14 of 102
15
31653/001/3453468.2
https://faithleaks.org/wiki/index.php?title=File:2017-No_48-
Future_Events_That_Will_Require_Courage%E2%80%94Armageddon-Video_1.mkv, where it
is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
29. (a) In 2018, Watch Tower created, in-house, an original video motion picture
titled “Talk 49 - Video 1 - Future Events That Will Require Courage (Symposium) - The Great
Reconstruction.” Watch Tower’s copyright in the “Talk 49 - Video 1 - Future Events That Will
Require Courage (Symposium) - The Great Reconstruction” video has been duly registered with
the United States Copyright Office under Registration No. PA0002121129, with an effective date
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 15 of 102
16
31653/001/3453468.2
of May 18, 2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 49 - Video 1 - Future Events That Will Require
Courage (Symposium) - The Great Reconstruction” video on Defendants’ “Faith Leaks” website,
at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_49-
Future_Events_That_Will_Require_Courage%E2%80%94The_Great_Reconstruction-
Video_1.mkv, where it is available, in its entirety and without alteration, for public performance
and for further reproduction and distribution via download, without restriction:
30. (a) In 2018, Watch Tower created, in-house, an original video motion picture
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 16 of 102
17
31653/001/3453468.2
titled “Talk 50 - Video 1 - Future Events That Will Require Courage (Symposium) - The Final
Test.” Watch Tower’s copyright in the “Talk 50 - Video 1 - Future Events That Will Require
Courage (Symposium) - The Final Test” video has been duly registered with the United States
Copyright Office under Registration No. PA0002121132, with an effective date of May 18,
2018.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 50 - Video 1 - Future Events That Will Require
Courage (Symposium) - The Final Test” video on Defendants’ “Faith Leaks” website, at the
URL https://faithleaks.org/wiki/index.php?title=File:2017-No_50-
Future_Events_That_Will_Require_Courage%E2%80%94The_Final_Test-Video_1.mkv, where
it is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 17 of 102
18
31653/001/3453468.2
31. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1.” Watch Tower’s
copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191509, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video
Presentation 1” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_003_r720P.mp4, where it is
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 18 of 102
19
31653/001/3453468.2
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
32. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 01 Video 1 - Chairman’s Address: ‘Love Never Fails - Why?’ (Romans 8:38, 39; 1
Corinthians 13:1-3, 8, 13).” Watch Tower’s copyright in the “Talk 01 Video 1 - Chairman’s
Address: ‘Love Never Fails - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191514, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 19 of 102
20
31653/001/3453468.2
performed and distributed Watch Tower’s “Talk 01 Video 1 - Chairman’s Address: ‘Love Never
Fails - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_006_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
33. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 01 Video 2 - Chairman’s Address: ‘Love Never Fails’ - Why?’ (Romans 8:38, 39; 1
Corinthians 13:1-3, 8, 13).” Watch Tower’s copyright in the “Talk 01 Video 2 - Chairman’s
Address: ‘Love Never Fails’ - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video has
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 20 of 102
21
31653/001/3453468.2
been duly registered with the United States Copyright Office under Registration No.
PA0002191517, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 01 Video 2 - Chairman’s Address: ‘Love Never
Fails’ - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_007_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
34. (a) In 2019, Watch Tower created, in-house, an original video motion picture
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 21 of 102
22
31653/001/3453468.2
titled “Talk 02 Video 1 - Symposium: Beware of Trusting in What Fails! - Wealth (Matthew
6:24).” Watch Tower’s copyright in the “Talk 02 Video 1 - Symposium: Beware of Trusting in
What Fails! - Wealth (Matthew 6:24)” video has been duly registered with the United States
Copyright Office under Registration No. PA0002191478, with an effective date of May 17,
2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 02 Video 1 - Symposium: Beware of Trusting in
What Fails! - Wealth (Matthew 6:24)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_009_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 22 of 102
23
31653/001/3453468.2
35. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 03 Video 1 - Symposium: Beware of Trusting in What Fails! - Status and Fame
(Ecclesiastes 2:16; Romans 12:16).” Watch Tower’s copyright in the “Talk 03 Video 1 -
Symposium: Beware of Trusting in What Fails! - Status and Fame (Ecclesiastes 2:16; Romans
12:16)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191475, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 03 Video 1 - Symposium: Beware of Trusting in
What Fails! - Status and Fame (Ecclesiastes 2:16; Romans 12:16)” video on Defendants’ “Faith
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 23 of 102
24
31653/001/3453468.2
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_011_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
36. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 04 Video 1 - Symposium: Beware of Trusting in What Fails! - Human Wisdom
(Romans 12:1, 2).” Watch Tower’s copyright in the “Talk 04 Video 1 - Symposium: Beware of
Trusting in What Fails! - Human Wisdom (Romans 12:1, 2)” video has been duly registered with
the United States Copyright Office under Registration No. PA0002191487, with an effective date
of May 17, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 24 of 102
25
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 04 Video 1 - Symposium: Beware of Trusting in
What Fails! - Human Wisdom (Romans 12:1, 2)” video on Defendants’ “Faith Leaks” website, at
the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_013_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
37. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 05 Video 1 - Symposium: Beware of Trusting in What Fails! - Strength and Beauty
(Proverbs 31:30; 1 Peter 3:3, 4).” Watch Tower’s copyright in the “Talk 05 Video 1 -
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 25 of 102
26
31653/001/3453468.2
Symposium: Beware of Trusting in What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter
3:3, 4)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191489, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 05 Video 1 - Symposium: Beware of Trusting in
What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter 3:3, 4)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_015_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 26 of 102
27
31653/001/3453468.2
38. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 06 Video 1 - DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love
(Genesis 37:1-36; 39:1; 47:12).” Watch Tower’s copyright in the “Talk 06 Video 1 -
DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1;
47:12)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191501, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 06 Video 1 - DRAMATIC BIBLE READING:
Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1; 47:12)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_018_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 27 of 102
28
31653/001/3453468.2
39. 40. (a) In 2019, Watch Tower created, in-house, an original video motion
picture titled “2019 ‘Love Never Fails’! Convention—Music-Video Presentation 2Talk 23 Video
1 - Symposium: Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32).”
Watch Tower’s copyright in the “2019 ‘Love Never Fails’! Convention—Music-Video
Presentation 2” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191510, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention—Music-Video
Presentation 2” video on Defendants’ “Faith Leaks” website, at the URL
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 28 of 102
29
31653/001/3453468.2
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_023_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
40. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 08 Video 1 - Symposium: Love Never Fails Despite … A Loveless Upbringing
(Psalm 27:10).” Watch Tower’s copyright in the “Talk 08 Video 1 - Symposium: Love Never
Fails Despite … A Loveless Upbringing (Psalm 27:10)” video has been duly registered with the
United States Copyright Office under Registration No. PA0002191450, with an effective date of
May 17, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 29 of 102
30
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 08 Video 1 - Symposium: Love Never Fails
Despite … A Loveless Upbringing (Psalm 27:10)” video on Defendants’ “Faith Leaks” website,
at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_026_r720P.mp4, where it
is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
41. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 09 Video 1 - Symposium: Love Never Fails Despite … A Difficult Work
Environment (1 Peter 2:18-20).” Watch Tower’s copyright in the “Talk 09 Video 1 -
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 30 of 102
31
31653/001/3453468.2
Symposium: Love Never Fails Despite … A Difficult Work Environment (1 Peter 2:18-20)”
video has been duly registered with the United States Copyright Office under Registration No.
PA0002191453, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 09 Video 1 - Symposium: Love Never Fails
Despite … A Difficult Work Environment (1 Peter 2:18-20)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_028_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 31 of 102
32
31653/001/3453468.2
42. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 10 Video 2 - Symposium: Love Never Fails Despite … An Ungodly School
Environment (1 Timothy 4:12).” Watch Tower’s copyright in the “Talk 10 Video 2 -
Symposium: Love Never Fails Despite … An Ungodly School Environment (1 Timothy 4:12)”
video has been duly registered with the United States Copyright Office under Registration No.
PA0002191458, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 10 Video 2 - Symposium: Love Never Fails
Despite … An Ungodly School Environment (1 Timothy 4:12)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_031_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 32 of 102
33
31653/001/3453468.2
43. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 11 Video 1 - Symposium: Love Never Fails Despite … Chronic Health Problems (2
Corinthians 12:9, 10).” Watch Tower’s copyright in the “Talk 11 Video 1 - Symposium: Love
Never Fails Despite … Chronic Health Problems (2 Corinthians 12:9, 10)” video has been duly
registered with the United States Copyright Office under Registration No. PA0002191459, with
an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 11 Video 1 - Symposium: Love Never Fails
Despite … Chronic Health Problems (2 Corinthians 12:9, 10)” video on Defendants’ “Faith
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 33 of 102
34
31653/001/3453468.2
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_033_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
44. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 12 Video 1 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12,
13).” Watch Tower’s copyright in the “Talk 12 Video 1 - Symposium: Love Never Fails Despite
… Poverty (Philippians 4:12, 13)” video has been duly registered with the United States
Copyright Office under Registration No. PA0002191460, with an effective date of May 17,
2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 34 of 102
35
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 12 Video 1 - Symposium: Love Never Fails
Despite … Poverty (Philippians 4:12, 13)” video on Defendants’ “Faith Leaks” website, at the
URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_035_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
45. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 12 Video 2 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12,
13).” Watch Tower’s copyright in the “Talk 12 Video 2 - Symposium: Love Never Fails Despite
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 35 of 102
36
31653/001/3453468.2
… Poverty (Philippians 4:12, 13)” video has been duly registered with the United States
Copyright Office under Registration No. PA0002191461, with an effective date of May 17,
2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 12 Video 2 - Symposium: Love Never Fails
Despite … Poverty (Philippians 4:12, 13)” video on Defendants’ “Faith Leaks” website, at the
URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_036_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 36 of 102
37
31653/001/3453468.2
46. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 13 Video 1 - Symposium: Love Never Fails Despite … Family Opposition (Matthew
5:44).” Watch Tower’s copyright in the “Talk 13 Video 1 - Symposium: Love Never Fails
Despite … Family Opposition (Matthew 5:44)” video has been duly registered with the United
States Copyright Office under Registration No. PA0002191455, with an effective date of May
17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 13 Video 1 - Symposium: Love Never Fails
Despite … Family Opposition (Matthew 5:44)” video on Defendants’ “Faith Leaks” website, at
the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_038_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 37 of 102
38
31653/001/3453468.2
47. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 14 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Heavens (Psalm
8:3, 4; 33:6).” Watch Tower’s copyright in the “Talk 14 Video 1 - Symposium: Creation
Reveals Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)” video has been duly registered with
the United States Copyright Office under Registration No. PA0002191432, with an effective date
of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 14 Video 1 - Symposium: Creation Reveals
Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)” video on Defendants’ “Faith Leaks”
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 38 of 102
39
31653/001/3453468.2
website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_041_r720P.mp4,
where it is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
48. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 15 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Earth (Psalm
37:29; 115:16).” Watch Tower’s copyright in the “Talk 15 Video 1 - Symposium: Creation
Reveals Jehovah’s Love - The Earth (Psalm 37:29; 115:16)” video has been duly registered with
the United States Copyright Office under Registration No. PA0002191434, with an effective date
of May 17, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 39 of 102
40
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 15 Video 1 - Symposium: Creation Reveals
Jehovah’s Love - The Earth (Psalm 37:29; 115:16)” video on Defendants’ “Faith Leaks” website,
at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_043_r720P.mp4, where it
is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
49. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 16 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Plants (Genesis 1:11,
29; 2:9, 15; Acts 14:16, 17).” Watch Tower’s copyright in the “Talk 16 Video 1 - Symposium:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 40 of 102
41
31653/001/3453468.2
Creation Reveals Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191437, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 16 Video 1 - Symposium: Creation Reveals
Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_045_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 41 of 102
42
31653/001/3453468.2
50. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 17 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Animals (Genesis
1:27; Matthew 6:26).” Watch Tower’s copyright in the “Talk 17 Video 1 - Symposium: Creation
Reveals Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)” video has been duly
registered with the United States Copyright Office under Registration No. PA0002191444, with
an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 17 Video 1 - Symposium: Creation Reveals
Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)” video on Defendants’ “Faith Leaks”
website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_047_r720P.mp4,
where it is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 42 of 102
43
31653/001/3453468.2
51. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 18 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Human Body
(Psalm 139:14; Ecclesiastes 3:11).” Watch Tower’s copyright in the “Talk 18 Video 1 -
Symposium: Creation Reveals Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes
3:11)” video has been duly registered with the United States Copyright Office under Registration
No. PA0002191446, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 18 Video 1 - Symposium: Creation Reveals
Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes 3:11)” video on Defendants’
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 43 of 102
44
31653/001/3453468.2
“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_049_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
52. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 19 Video 1 - ‘Those Whom Jehovah Loves He Disciplines’ (Hebrews 12:5-11;
Psalm 19:7, 8, 11).” Watch Tower’s copyright in the “Talk 19 Video 1 - ‘Those Whom Jehovah
Loves He Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)” video has been duly registered
with the United States Copyright Office under Registration No. PA0002191504, with an
effective date of May 17, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 44 of 102
45
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 19 Video 1 - ‘Those Whom Jehovah Loves He
Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)” video on Defendants’ “Faith Leaks” website,
at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_051_r720P.mp4, where it
is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
53. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14).” Watch Tower’s
copyright in the “Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14)” video
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 45 of 102
46
31653/001/3453468.2
has been duly registered with the United States Copyright Office under Registration No.
PA0002191471, with an effective date of May 17, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 20 Video 1 - ‘Clothe Yourselves With Love’
(Colossians 3:12-14)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_053_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
54. (a) In 2019, Watch Tower created, in-house, an original video motion picture
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 46 of 102
47
31653/001/3453468.2
titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 3.” Watch Tower’s
copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 3” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191139, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video
Presentation 3” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_058_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 47 of 102
48
31653/001/3453468.2
55. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 21 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Those
Taking the Lead (1 Thessalonians 5:12, 13).” Watch Tower’s copyright in the “Talk 21 Video 1
- Symposium: Display Unfailing Love in the Congregation - To Those Taking the Lead (1
Thessalonians 5:12, 13)” video has been duly registered with the United States Copyright Office
under Registration No. PA0002191157, with an effective date of May 22, 2019, and
Supplementary Registration No. PA0002214841, dated August 19, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 21 Video 1 - Symposium: Display Unfailing
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 48 of 102
49
31653/001/3453468.2
Love in the Congregation - To Those Taking the Lead (1 Thessalonians 5:12, 13)” video on
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_061_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
56. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To the
Elderly (Leviticus 19:32).” Watch Tower’s copyright in the “Talk 23 Video 1 - Symposium:
Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32)” video has been
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 49 of 102
50
31653/001/3453468.2
duly registered with the United States Copyright Office under Registration No. PA0002191160,
with an effective date of May 22, 2019, and Supplementary Registration No. PA0002216893,
dated September 4, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 23 Video 1 - Symposium: Display Unfailing
Love in the Congregation - To the Elderly (Leviticus 19:32)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_065_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 50 of 102
51
31653/001/3453468.2
57. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 24 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Full-
Time Ministers (1 Thessalonians 1:3).” Watch Tower’s copyright in the “Talk 24 Video 1 -
Symposium: Display Unfailing Love in the Congregation - To Full-Time Ministers (1
Thessalonians 1:3)” video has been duly registered with the United States Copyright Office
under Registration No. PA0002191146, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 24 Video 1 - Symposium: Display Unfailing
Love in the Congregation - To Full-Time Ministers (1 Thessalonians 1:3)” video on Defendants’
“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_067_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 51 of 102
52
31653/001/3453468.2
58. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 25 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Foreign
Residents (Leviticus 19:34; Romans 15:7).” Watch Tower’s copyright in the “Talk 25 Video 1 -
Symposium: Display Unfailing Love in the Congregation - To Foreign Residents (Leviticus
19:34; Romans 15:7)” video has been duly registered with the United States Copyright Office
under Registration No. PA0002191155, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 25 Video 1 - Symposium: Display Unfailing
Love in the Congregation - To Foreign Residents (Leviticus 19:34; Romans 15:7)” video on
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 52 of 102
53
31653/001/3453468.2
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_069_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
59. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers Meeting.” Watch
Tower’s copyright in the “ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers
Meeting” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191149, with an effective date of May 22, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 53 of 102
54
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “ANNOUNCEMENT: Invitation to School for
Kingdom Evangelizers Meeting” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_071_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
60. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 26 Video 1 - Symposium: Display Unfailing Love in the Ministry - Show Your Love
for God (1 John 5:3).” Watch Tower’s copyright in the “Talk 26 Video 1 - Symposium: Display
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 54 of 102
55
31653/001/3453468.2
Unfailing Love in the Ministry - Show Your Love for God (1 John 5:3)” video has been duly
registered with the United States Copyright Office under Registration No. PA0002191683, with
an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 26 Video 1 - Symposium: Display Unfailing
Love in the Ministry - Show Your Love for God (1 John 5:3)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_073_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 55 of 102
56
31653/001/3453468.2
61. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 27 Video 1 - Symposium: Display Unfailing Love in the Ministry – ‘Love Your
Neighbor as Yourself’ (Matthew 22:39).” Watch Tower’s copyright in the “Talk 27 Video 1 -
Symposium: Display Unfailing Love in the Ministry – ‘Love Your Neighbor as Yourself’
(Matthew 22:39)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191148, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 27 Video 1 - Symposium: Display Unfailing
Love in the Ministry – ‘Love Your Neighbor as Yourself’ (Matthew 22:39)” video on
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_075_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 56 of 102
57
31653/001/3453468.2
62. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 28 Video 1 - Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s
Word (Psalm 119:97; Matthew 13:52).” Watch Tower’s copyright in the “Talk 28 Video 1 -
Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s Word (Psalm 119:97;
Matthew 13:52)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191684, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 28 Video 1 - Symposium: Display Unfailing
Love in the Ministry - Love Jehovah’s Word (Psalm 119:97; Matthew 13:52)” video on
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 57 of 102
58
31653/001/3453468.2
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_077_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
63. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4 (v2).” Watch
Tower’s copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4
(v2)” video has been duly registered with the United States Copyright Office under Registration
No. PA0002193286, with an effective date of June 5, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 58 of 102
59
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video
Presentation 4 (v2)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_082_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
64. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In …
Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 59 of 102
60
31653/001/3453468.2
9:22), Oceania (Psalm 35:18), South America (Acts 1:8).” Watch Tower’s copyright in the
“Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In … Africa
(Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians 9:22),
Oceania (Psalm 35:18), South America (Acts 1:8)” video has been duly registered with the
United States Copyright Office under Registration No. PA0002191713, with an effective date of
May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 30 Video 1 - Symposium: How Our Brothers
Are Showing Unfailing Love In … Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John
4:35), North America (1 Corinthians 9:22), Oceania (Psalm 35:18), South America (Acts 1:8)”
video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_085_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 60 of 102
61
31653/001/3453468.2
65. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 31 Video 1 - Display Unfailing Love in Your Family - Love Your Wife (Ephesians
5:28, 29).” Watch Tower’s copyright in the “Talk 31 Video 1 - Display Unfailing Love in Your
Family - Love Your Wife (Ephesians 5:28, 29)” video has been duly registered with the United
States Copyright Office under Registration No. PA0002191714, with an effective date of May
22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 31 Video 1 - Display Unfailing Love in Your
Family - Love Your Wife (Ephesians 5:28, 29)” video on Defendants’ “Faith Leaks” website, at
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 61 of 102
62
31653/001/3453468.2
the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_087_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
66. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 32 Video 1 - Display Unfailing Love in Your Family - Love Your Husband
(Ephesians 5:33; 1 Peter 3:1-6).” Watch Tower’s copyright in the “Talk 32 Video 1 - Display
Unfailing Love in Your Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191715, with an effective date of May 22, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 62 of 102
63
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 32 Video 1 - Display Unfailing Love in Your
Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)” video on Defendants’ “Faith
Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_089_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
67. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 33 Video 1 - Display Unfailing Love in Your Family - Love Your Children (Titus
2:4).” Watch Tower’s copyright in the “Talk 33 Video 1 - Display Unfailing Love in Your
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 63 of 102
64
31653/001/3453468.2
Family - Love Your Children (Titus 2:4)” video has been duly registered with the United States
Copyright Office under Registration No. PA0002191717, with an effective date of May 22,
2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 33 Video 1 - Display Unfailing Love in Your
Family - Love Your Children (Titus 2:4)” video on Defendants’ “Faith Leaks” website, at the
URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_091_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 64 of 102
65
31653/001/3453468.2
68. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part I (2 Chronicles 33:10-24;
34:1, 2).” Watch Tower’s copyright in the “The Story of Josiah: Love Jehovah; Hate What Is
Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)” video has been duly registered with the United
States Copyright Office under Registration No. PA0002191144, with an effective date of May
22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “The Story of Josiah: Love Jehovah; Hate What Is
Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)” video on Defendants’ “Faith Leaks” website, at the
URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_094_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 65 of 102
66
31653/001/3453468.2
69. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 35 Video 1 - Teach Your Children How to Show Love (2 Timothy 3:14, 15).”
Watch Tower’s copyright in the “Talk 35 Video 1 - Teach Your Children How to Show Love (2
Timothy 3:14, 15)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191678, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 35 Video 1 - Teach Your Children How to
Show Love (2 Timothy 3:14, 15)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_096_r720P.mp4, where it is
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 66 of 102
67
31653/001/3453468.2
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
70. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 35 Video 3 - Teach Your Children How to Show Love (2 Timothy 3:14, 15).”
Watch Tower’s copyright in the “Talk 35 Video 3 - Teach Your Children How to Show Love (2
Timothy 3:14, 15)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002192006, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 35 Video 3 - Teach Your Children How to
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 67 of 102
68
31653/001/3453468.2
Show Love (2 Timothy 3:14, 15)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_098_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
71. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 35 Video 4 - Teach Your Children How to Show Love (2 Timothy 3:14, 15).”
Watch Tower’s copyright in the “Talk 35 Video 4 - Teach Your Children How to Show Love (2
Timothy 3:14, 15)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002192007, with an effective date of May 22, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 68 of 102
69
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 35 Video 4 - Teach Your Children How to
Show Love (2 Timothy 3:14, 15)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_099_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
72. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 5.” Watch Tower’s
copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 5” video has
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 69 of 102
70
31653/001/3453468.2
been duly registered with the United States Copyright Office under Registration No.
PA0002191679, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video
Presentation 5” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_104_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
73. (a) In 2019, Watch Tower created, in-house, an original video motion picture
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 70 of 102
71
31653/001/3453468.2
titled “Talk 36 Video 1 - Symposium: Remember How Love Behaves - Is Patient and Kind (1
Corinthians 13:4).” Watch Tower’s copyright in the “Talk 36 Video 1 - Symposium: Remember
How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video has been duly registered
with the United States Copyright Office under Registration No. PA0002192010, with an
effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 36 Video 1 - Symposium: Remember How
Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video on Defendants’ “Faith Leaks”
website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_107_r720P.mp4,
where it is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 71 of 102
72
31653/001/3453468.2
74. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 36 Video 2 - Symposium: Remember How Love Behaves - Is Patient and Kind (1
Corinthians 13:4).” Watch Tower’s copyright in the “Talk 36 Video 2 - Symposium: Remember
How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video has been duly registered
with the United States Copyright Office under Registration No. PA0002192009, with an
effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 36 Video 2 - Symposium: Remember How
Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video on Defendants’ “Faith Leaks”
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 72 of 102
73
31653/001/3453468.2
website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_108_r720P.mp4,
where it is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
75. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 37 Video 1 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not
Brag (1 Corinthians 13:4).” Watch Tower’s copyright in the “Talk 37 Video 1 - Symposium:
Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191147, with an effective date of May 22, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 73 of 102
74
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 37 Video 1 - Symposium: Remember How
Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video on Defendants’
“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_110_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
76. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 37 Video 2 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not
Brag (1 Corinthians 13:4).” Watch Tower’s copyright in the “Talk 37 Video 2 - Symposium:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 74 of 102
75
31653/001/3453468.2
Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191150, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 37 Video 2 - Symposium: Remember How
Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video on Defendants’
“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_111_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 75 of 102
76
31653/001/3453468.2
77. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 38 Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up;
Does Not Behave Indecently (1 Corinthians 13:4, 5).” Watch Tower’s copyright in the “Talk 38
Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not
Behave Indecently (1 Corinthians 13:4, 5)” video has been duly registered with the United States
Copyright Office under Registration No. PA0002191151, with an effective date of May 22,
2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 38 Video 1 - Symposium: Remember How
Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”
video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_113_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 76 of 102
77
31653/001/3453468.2
78. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 38 Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up;
Does Not Behave Indecently (1 Corinthians 13:4, 5).” Watch Tower’s copyright in the “Talk 38
Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not
Behave Indecently (1 Corinthians 13:4, 5)” video has been duly registered with the United States
Copyright Office under Registration No. PA0002191152, with an effective date of May 22,
2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 38 Video 2 - Symposium: Remember How
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 77 of 102
78
31653/001/3453468.2
Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”
video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_114_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
79. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its
Own Interests; Does Not Become Provoked (1 Corinthians 13:5).” Watch Tower’s copyright in
the “Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its Own
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 78 of 102
79
31653/001/3453468.2
Interests; Does Not Become Provoked (1 Corinthians 13:5)” video has been duly registered with
the United States Copyright Office under Registration No. PA0002191156, with an effective date
of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 39 Video 1 - Symposium: Remember How
Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1
Corinthians 13:5)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_116_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 79 of 102
80
31653/001/3453468.2
80. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its
Own Interests; Does Not Become Provoked (1 Corinthians 13:5).” Watch Tower’s copyright in
the “Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its Own
Interests; Does Not Become Provoked (1 Corinthians 13:5)” video has been duly registered with
the United States Copyright Office under Registration No. PA0002191153, with an effective date
of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 39 Video 2 - Symposium: Remember How
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 80 of 102
81
31653/001/3453468.2
Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1
Corinthians 13:5)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_117_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
81. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not Keep Account
of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6).” Watch Tower’s
copyright in the “Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 81 of 102
82
31653/001/3453468.2
Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”
video has been duly registered with the United States Copyright Office under Registration No.
PA0002191154, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 40 Video 1 - Symposium: Remember How
Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness
(1 Corinthians 13:5, 6)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_119_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 82 of 102
83
31653/001/3453468.2
82. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not Keep Account
of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6).” Watch Tower’s
copyright in the “Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not
Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”
video has been duly registered with the United States Copyright Office under Registration No.
PA0002191719, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 40 Video 2 - Symposium: Remember How
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 83 of 102
84
31653/001/3453468.2
Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness
(1 Corinthians 13:5, 6)” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_120_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
83. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 41 Video 1 - Symposium: Remember How Love Behaves - Rejoices With the Truth;
Bears All Things (1 Corinthians 13:6, 7).” Watch Tower’s copyright in the “Talk 41 Video 1 -
Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 84 of 102
85
31653/001/3453468.2
Corinthians 13:6, 7)” video has been duly registered with the United States Copyright Office
under Registration No. PA0002191722, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 41 Video 1 - Symposium: Remember How
Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)” video on
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_122_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 85 of 102
86
31653/001/3453468.2
84. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 41 Video 2 - Symposium: Remember How Love Behaves - Rejoices With the Truth;
Bears All Things (1 Corinthians 13:6, 7).” Watch Tower’s copyright in the “Talk 41 Video 2 -
Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1
Corinthians 13:6, 7)” video has been duly registered with the United States Copyright Office
under Registration No. PA0002191723, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 41 Video 2 - Symposium: Remember How
Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)” video on
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_123_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 86 of 102
87
31653/001/3453468.2
85. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 42 Video 1 - Symposium: Remember How Love Behaves - Believes All Things;
Hopes All Things 1 Corinthians 13:7).” Watch Tower’s copyright in the “Talk 42 Video 1 -
Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1
Corinthians 13:7)” video has been duly registered with the United States Copyright Office under
Registration No. PA0002191724, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 42 Video 1 - Symposium: Remember How
Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)” video on
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 87 of 102
88
31653/001/3453468.2
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_125_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
86. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 42 Video 2 - Symposium: Remember How Love Behaves - Believes All Things;
Hopes All Things 1 Corinthians 13:7).” Watch Tower’s copyright in the “Talk 42 Video 2 -
Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1
Corinthians 13:7)” video has been duly registered with the United States Copyright Office under
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 88 of 102
89
31653/001/3453468.2
Registration No. PA0002191727, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 42 Video 2 - Symposium: Remember How
Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)” video on
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_126_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
87. (a) In 2019, Watch Tower created, in-house, an original video motion picture
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 89 of 102
90
31653/001/3453468.2
titled “Talk 43 Video 1 - Symposium: Remember How Love Behaves - Endures All Things;
Love Never Fails (1 Corinthians 13:7, 8).” Watch Tower’s copyright in the “Talk 43 Video 1 -
Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1
Corinthians 13:7, 8)” video has been duly registered with the United States Copyright Office
under Registration No. PA0002191729, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 43 Video 1 - Symposium: Remember How
Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)” video on
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_128_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 90 of 102
91
31653/001/3453468.2
88. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 43 Video 2 - Symposium: Remember How Love Behaves - Endures All Things;
Love Never Fails (1 Corinthians 13:7, 8).” Watch Tower’s copyright in the “Talk 43 Video 2 -
Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1
Corinthians 13:7, 8)” video has been duly registered with the United States Copyright Office
under Registration No. PA0002191159, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 43 Video 2 - Symposium: Remember How
Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)” video on
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 91 of 102
92
31653/001/3453468.2
Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_129_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
89. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 44 Video 1 - Public Bible Discourse: True Love in a Hate-Filled World - Where?
(John 13:34, 35).” Watch Tower’s copyright in the “Talk 44 Video 1 - Public Bible Discourse:
True Love in a Hate-Filled World - Where? (John 13:34, 35)” video has been duly registered
with the United States Copyright Office under Registration No. PA0002191418, with an
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 92 of 102
93
31653/001/3453468.2
effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 44 Video 1 - Public Bible Discourse: True Love
in a Hate-Filled World - Where? (John 13:34, 35)” video on Defendants’ “Faith Leaks” website,
at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_132_r720P.mp4, where it
is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
90. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 44 Video 2 - Public Bible Discourse: True Love in a Hate-Filled World - Where?
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 93 of 102
94
31653/001/3453468.2
(John 13:34, 35).” Watch Tower’s copyright in the “Talk 44 Video 2 - Public Bible Discourse:
True Love in a Hate-Filled World - Where? (John 13:34, 35)” video has been duly registered
with the United States Copyright Office under Registration No. PA0002191141, with an
effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 44 Video 2 - Public Bible Discourse: True Love
in a Hate-Filled World - Where? (John 13:34, 35)” video on Defendants’ “Faith Leaks” website,
at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_133_r720P.mp4, where it
is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 94 of 102
95
31653/001/3453468.2
91. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25;
2 Chronicles 34:3-33; 35:1-19).” Watch Tower’s copyright in the “The Story of Josiah: Love
Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)”
video has been duly registered with the United States Copyright Office under Registration No.
PA0002191682, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “The Story of Josiah: Love Jehovah; Hate What Is
Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)” video on Defendants’
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 95 of 102
96
31653/001/3453468.2
“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-
v19_E_141_r720P.mp4, where it is available, in its entirety and without alteration, for public
performance and for further reproduction and distribution via download, without restriction:
92. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 47 Video 1 - ‘Carefully Consider Jehovah’s Acts of Loyal Love’ (Psalm 107:43;
Ephesians 5:1, 2).” Watch Tower’s copyright in the “Talk 47 Video 1 - ‘Carefully Consider
Jehovah’s Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)” video has been duly registered
with the United States Copyright Office under Registration No. PA0002191138, with an
effective date of May 22, 2019.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 96 of 102
97
31653/001/3453468.2
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 47 Video 1 - ‘Carefully Consider Jehovah’s
Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)” video on Defendants’ “Faith Leaks”
website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_144_r720P.mp4,
where it is available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
93. (a) In 2019, Watch Tower created, in-house, an original video motion picture
titled “Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8)).” Watch Tower’s copyright in the
“Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8))” video has been duly registered with the
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 97 of 102
98
31653/001/3453468.2
United States Copyright Office under Registration No. PA0002191706, with an effective date of
May 24, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “Talk 47 Video 5 - Unfailing Love (1 Corinthians
13:8))” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_148_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
94. (a) In 2019, Watch Tower created, in-house, an original video motion picture
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 98 of 102
99
31653/001/3453468.2
titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 6.” Watch Tower’s
copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 6” video has
been duly registered with the United States Copyright Office under Registration No.
PA0002191143, with an effective date of May 22, 2019.
(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly
performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video
Presentation 6” video on Defendants’ “Faith Leaks” website, at the URL
https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_083_r720P.mp4, where it is
available, in its entirety and without alteration, for public performance and for further
reproduction and distribution via download, without restriction:
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 99 of 102
100
31653/001/3453468.2
95. Defendants McKnight and Dodge personally participated in, and supervised and
directed, the infringing acts described above. Indeed, they personally conceived of, and directed
and approved all key aspects of, TTF’s infringing activities. They were the moving force behind
those infringing acts.
96. The acts of Defendants described above were committed without the permission,
license or consent of Watch Tower.
97. Upon information and belief, the acts of Defendants described above were
committed with knowledge or in reckless disregard of Watch Tower’s exclusive rights in the
Watch Tower videos.
CLAIM FOR RELIEF (Copyright Infringement)
98. Watch Tower repeats and realleges the assertions contained in paragraphs 1
through 97 above.
99. Watch Tower is the author of, and sole proprietor of all right, title and interest in
and to the copyrights in, each of the Watch Tower videos described above. Under 17 U.S.C. §
106, Watch Tower has the exclusive right to reproduce, distribute, publicly display, publicly
perform, and prepare derivative works based on the Watch Tower videos.
100. As alleged above, Defendants have infringed the copyrights in each of the above-
described Watch Tower videos by unlawfully reproducing, distributing, publicly displaying,
publicly performing and/or distributing the Watch Tower videos.
101. As alleged above, Defendants’ infringements are willful in that they are
committed with knowledge or in reckless disregard of Watch Tower’s exclusive rights in its
copyrighted videos.
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 100 of 102
101
31653/001/3453468.2
102. Watch Tower is entitled to recover from Defendants its actual damages as well as
the profits of Defendants attributable to each of the infringements and not taken into account in
computing actual damages, pursuant to 17 U.S.C. § 504(b); or, at Watch Tower’s election, an
award of statutory damages pursuant to 17 U.S.C. § 504(c) with respect to each of the Watch
Tower videos infringed by Defendants that meets the requirements of 17 U.S.C. § 412.
103. Pursuant to 17 U.S.C. § 505, Watch Tower is also entitled to recover its costs and
attorneys’ fees from Defendants with respect to each of the Watch Tower videos infringed by
Defendants that meets the requirements of 17 U.S.C. § 412.
104. As a result of Defendants’ copyright infringements, Watch Tower has suffered,
and will continue to suffer, irreparable injury not fully compensable in monetary damages, and is
therefore entitled to an injunction enjoining Defendants from engaging in their infringing
activities.
WHEREFORE, Watch Tower prays that the Court:
1. Find that Defendants have willfully infringed Watch Tower’s registered
copyrights in the Watch Tower videos;
2. Preliminarily and permanently enjoin Defendants, their officers, agents,
employees, and related companies, and all persons acting for, with, by, through, or under them,
from copying, reproducing, publicly displaying, publicly performing, distributing, advertising,
promoting, offering for sale or selling the Watch Tower videos;
3. (a) Award to Watch Tower, pursuant to 17 U.S.C. § 504(c), its actual
damages incurred as a result of Defendants’ acts of copyright infringement, and all profits
Defendants realized as a result of such unlawful acts, in amounts to be determined at trial; or
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 101 of 102
102
31653/001/3453468.2
(b) In the alternative, with respect to each of the Watch Tower Videos infringed by
Defendants that meets the requirements of 17 U.S.C. § 412, award to Watch Tower, at its
election, statutory damages pursuant to 17 U.S.C. § 504(c);
4. Award to Watch Tower, pursuant to 17 U.S.C. § 505, its costs and attorneys’ fees
incurred as a result of Defendants’ unlawful acts; and
5. Grant such other and further relief as the Court deems necessary and proper under
the circumstances.
Dated: New York, New York April 30, 2020 Respectfully submitted, COWAN, LIEBOWITZ & LATMAN, P.C. By: s/Kieran G. Doyle Kieran G. Doyle ([email protected]) Thomas Kjellberg ([email protected]) 114 West 47th Street New York, New York 10036-1525 (212) 790-9202
Paul Polidoro Watch Tower Bible and Tract Society of Pennsylvania 100 Watchtower Drive Patterson, New York 12563
Attorneys for Plaintiff
Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 102 of 102
JS 44C/SDNY REV. 06/01/17
CIVIL COVER SHEETThe JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet.
PLAINTIFFS DEFENDANTS
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN)
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No YesJudge Previously Assigned
If yes, was this case Vol. Invol. Dismissed. No Yes If yes, give date _______________________ & Case No. ______________________
IS THIS AN INTERNATIONAL ARBITRATION CASE? No Yes
(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT
CONTRACT
[ ] 110 INSURANCE[ ] 120 MARINE[ ] 130 MILLER ACT[ ] 140 NEGOTIABLE
INSTRUMENT[ ] 150 RECOVERY OF
OVERPAYMENT &ENFORCEMENTOF JUDGMENT
[ ] 151 MEDICARE ACT[ ] 152 RECOVERY OF
DEFAULTEDSTUDENT LOANS(EXCL VETERANS)
[ ] 153 RECOVERY OFOVERPAYMENTOF VETERAN'SBENEFITS
[ ] 160 STOCKHOLDERSSUITS
[ ] 190 OTHERCONTRACT
[ ] 195 CONTRACTPRODUCTLIABILITY
[ ] 196 FRANCHISE
REAL PROPERTY
[ ] 210 LANDCONDEMNATION
[ ] 220 FORECLOSURE[ ] 230 RENT LEASE &
EJECTMENT[ ] 240 TORTS TO LAND[ ] 245 TORT PRODUCT
LIABILITY[ ] 290 ALL OTHER
REAL PROPERTY
TORTS
PERSONAL INJURY
[ ] 310 AIRPLANE[ ] 315 AIRPLANE PRODUCT
LIABILITY[ ] 320 ASSAULT, LIBEL &
SLANDER[ ] 330 FEDERAL
EMPLOYERS'LIABILITY
[ ] 340 MARINE[ ] 345 MARINE PRODUCT
LIABILITY[ ] 350 MOTOR VEHICLE[ ] 355 MOTOR VEHICLE
PRODUCT LIABILITY[ ] 360 OTHER PERSONAL
INJURY
ACTIONS UNDER STATUTES
CIVIL RIGHTS
PERSONAL INJURY
[ ] 365 PERSONAL INJURYPRODUCT LIABILITY
[ ] 368 ASBESTOS PERSONALINJURY PRODUCTLIABILITY
PERSONAL PROPERTY
[ ] 370 OTHER FRAUD[ ] 371 TRUTH IN LENDING
[ ] 380 OTHER PERSONALPROPERTY DAMAGE
[ ] 385 PROPERTY DAMAGEPRODUCT LIABILITY
PRISONER PETITIONS
[ ] 510 MOTIONS TOVACATE SENTENCE28 USC 2255
[ ] 530 HABEAS CORPUS[ ] 535 DEATH PENALTY[ ] 540 MANDAMUS & OTHER
PRISONER CIVIL RIGHTS
[ ] 550 CIVIL RIGHTS[ ] 555 PRISON CONDITION
FORFEITURE/PENALTY
21 USC 881
LABOR
[ ] 710 FAIR LABORSTANDARDS ACT
[ ] 720 LABOR/MGMTRELATIONS
[ ] 740 RAILWAY LABOR ACT[ ] 751 FAMILY MEDICAL LEAVE ACT (FMLA)
[ ] 790 OTHER LABORLITIGATION
[ ] 791 EMPL RET INCSECURITY ACT (ERISA)
IMMIGRATION
[ ] 462 NATURALIZATIONAPPLICATION
[ ] 465 OTHER IMMIGRATIONACTIONS
CONDITIONS OF CONFINEMENT
ACTIONS UNDER STATUTES
BANKRUPTCY
[ ] 422 APPEAL28 USC 158
[ ] 423 WITHDRAWAL28 USC 157
PROPERTY RIGHTS
[ ] 820 COPYRIGHTS[ ] 830 PATENT
[ ] 840 TRADEMARKSOCIAL SECURITY
[ ] 861 HIA (1395ff)[ ] 862 BLACK LUNG (923)[ ] 863 DIWC/DIWW (405(g))[ ] 864 SSID TITLE XVI[ ] 865 RSI (405(g))
FEDERAL TAX SUITS
[ ] 870 TAXES (U.S. Plaintiff orDefendant)
[ ] 871 IRS-THIRD PARTY26 USC 7609
OTHER STATUTES
[ ] 400 STATEREAPPORTIONMENT
[ ] 410 ANTITRUST[ ] 430 BANKS & BANKING[ ] 450 COMMERCE[ ] 460 DEPORTATION[ ] 470 RACKETEER INFLU-
ENCED & CORRUPTORGANIZATION ACT(RICO)
[ ] 480 CONSUMER CREDIT[ ] 490 CABLE/SATELLITE TV
[ ] 850 SECURITIES/COMMODITIES/EXCHANGE
[ ] 890 OTHER STATUTORYACTIONS
[ ] 891 AGRICULTURAL ACTS
[ ] 893 ENVIRONMENTALMATTERS
[ ] 895 FREEDOM OFINFORMATION ACT
[ ] 896 ARBITRATION[ ] 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR APPEAL OF AGENCY DECISION
Check if demanded in complaint:
CHECK IF THIS IS A CLASS ACTIONDO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13?
UNDER F.R.C.P. 23 IF SO, STATE:
DEMAND $______________ OTHER ______________ JUDGE _________________________________ DOCKET NUMBER_________________
Check YES only if demanded in complaintJURY DEMAND: YES NO NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
[ ] 690 OTHER
[ ] 625 DRUG RELATEDSEIZURE OF PROPERTY
[ ] 560 CIVIL DETAINEE
DISABILITIES -OTHER[ ] 446 AMERICANS WITH
EMPLOYMENTDISABILITIES -
[ ] 445 AMERICANS WITHACCOMMODATIONS
[ ] 443 HOUSING/[ ] 442 EMPLOYMENT[ ] 441 VOTING
[ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)
[ ] 375 FALSE CLAIMS
[ ] 448 EDUCATION
[ ] 463 ALIEN DETAINEE
[ ] 362 PERSONAL INJURY -MED MALPRACTICE
[ ] 367 HEALTHCARE/PHARMACEUTICAL PERSONAL INJURY/PRODUCT LIABILITY
[ ] 950 CONSTITUTIONALITY OF STATE STATUTES
[ ] 376 QUI TAM
[ ] 835 PATENT-ABBREVIATED NEW DRUG APPLICATION
Watch Tower Bible and Tract Society of Pennsylvania The Truth and Transparency Foundation, Ryan McKnight, and Ethan Gregory Dodge
Cowan, Liebowitz & Latman, P.C. 114 West 47th Street New York, NY 10036-1525
17 U.S.C. § 101 et seq. - Copyright Infringement
✔
✖
Case 1:20-cv-03366 Document 2 Filed 04/30/20 Page 1 of 2
(PLACE AN x IN ONE BOX ONLY) ORIGIN1 Original
Proceeding2 Removed from
State Court
a. all parties represented
b. At least one party is pro se.
3 Remanded from Appellate Court
4 Reinstated or Reopened
5 Transferred from (Specify District)
6 Appeal to District Judge from Magistrate Judge
(PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE1 U.S. PLAINTIFF 2 U.S. DEFENDANT 3 FEDERAL QUESTION 4 DIVERSITY
(U.S. NOT A PARTY)CITIZENSHIP BELOW.
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
(Place an [X] in one box for Plaintiff and one box for Defendant)
PTF DEF PTF DEF PTF DEFCITIZEN OF THIS STATE [ ] 1 [ ] 1 CITIZEN OR SUBJECT OF A [ ] 3 [ ] 3 INCORPORATED and PRINCIPAL PLACE [ ] 5 [ ] 5
FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE
CITIZEN OF ANOTHER STATE [ ] 2 [ ] 2 INCORPORATED or PRINCIPAL PLACE [ ] 4 [ ] 4 FOREIGN NATION [ ] 6 [ ] 6 OF BUSINESS IN THIS STATE
PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
DEFENDANT(S) ADDRESS UNKNOWNREPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
Check one: THIS ACTION SHOULD BE ASSIGNED TO: WHITE PLAINS MANHATTAN
DATE
RECEIPT #
SIGNATURE OF ATTORNEY OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT[ ] NO[ ] YES (DATE ADMITTED Mo. _______ Yr. _______)Attorney Bar Code #
Magistrate Judge is to be designated by the Clerk of the Court.
Magistrate Judge _________________________________________________________ is so Designated.
Ruby J. Krajick, Clerk of Court by _____________ Deputy Clerk, DATED _____________________.
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
COURTHOUSE ASSIGNMENTI hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.
8
7Multidistrict Litigation (Transferred)
Multidistrict Litigation (Direct File)
✖
✖
200 Watch Tower Drive, Patterson, New York 12563 - Putnam County
The Truth and Transparency Foundation: 109 Cascade Meadow Court, Henderson, Nevada 89011 - Clark County
Ryan C. McKnight: 109 Cascade Meadow Court, Henderson, Nevada 89011 - Clark County
Ethan G. Dodge
✖
✖ 10 2003TK-0605
04/30/2020
Case 1:20-cv-03366 Document 2 Filed 04/30/20 Page 2 of 2
31653/001/3452979.1
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
WATCH TOWER BIBLE AND TRACT SOCIETY OF PENNSYLVANIA,
Plaintiff,
-against-
THE TRUTH AND TRANSPARENCY FOUNDATION, RYAN C. McKNIGHT, and ETHAN G. DODGE,
Defendants.
No.
RULE 7.1 STATEMENT
Pursuant to Rule 7.1 of the Federal Rules of Civil Procedure, the undersigned attorney of
record for Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (a private non-
governmental party) certifies that there is no parent company of Watch Tower Bible and Tract
Society of Pennsylvania, and no publicly held company owns 10% or more of its stock.
Dated: New York, New York April 30, 2020 Respectfully submitted,
COWAN, LIEBOWITZ & LATMAN, P.C.
By: s/ Kieran G. Doyle _ Kieran G. Doyle
114 West 47th Street New York, New York 10036 (212) 790-9200
20-cv-3366
Case 1:20-cv-03366 Document 3 Filed 04/30/20 Page 1 of 1
AO 121 ( 6/ ) TO:
REPORT ON THEFILING OR DETERMINATION OF AN
ACTION OR APPEALREGARDING A COPYRIGHT
In compliance with the provisions of 17 U.S.C. 508, you are hereby advised that a court action or appeal has been filedon the following copyright(s):
COURT NAME AND LOCATIONG ACTION G APPEAL
DOCKET NO. DATE FILED
PLAINTIFF DEFENDANT
COPYRIGHTREGISTRATION NO. TITLE OF WORK AUTHOR OR WORK
1
2
3
4
5
In the above-entitled case, the following copyright(s) have been included:DATE INCLUDED INCLUDED BY
G Amendment G Answer G Cross Bill G Other PleadingCOPYRIGHT
REGISTRATION NO. TITLE OF WORK AUTHOR OF WORK
1
2
3 .
In the above-entitled case, a final decision was rendered on the date entered below. A copy of the order or judgmenttogether with the written opinion, if any, of the court is attached.
COPY ATTACHED WRITTEN OPINION ATTACHED DATE RENDERED
G Order G Judgment G Yes G No
CLERK (BY) DEPUTY CLERK DATE
1) Upon initiation of action, 2) Upon filing of document adding copyright(s), 3) Upon termination of action,mail copy to Register of Copyrights mail copy to Register of Copyrights mail copy to Register of Copyrights
DISTRIBUTION:4) In the event of an appeal, forward copy to Appellate Court 5) Case File Copy
✔ USDC-Southern District of New York
20-cv-3366 4/30/2020
Watch Tower Bible and Tract Society of Pennsylvania The Truth and Transparency Foundation, Ryan C.McKnight and Ethan G. Dodge
PA0002121393 “Be a Courageous … Pioneer” Watch Tower Bible and Tract Soc.
PA0002121074 Talk 33 - Video 1 - Learn Courage From Creation... Watch Tower Bible and Tract Soc.
PA0002121104 Talk 40 - Video 1 - How Our Brothers Are Showing... Watch Tower Bible and Tract Soc.
PA0002121120 Talk 44 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.
PA0002121121 Talk 45 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.
See Attached Schedule for Complete List
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 1 of 9
COPYRIGHT REGISTRATION NO.
TITLE OF WORK AUTHOR OR WORK
PA0002121124 Talk 46-Video 1 - Future Events That Will Require Courage (Symposium) - The Proclamation of the Hailstone Message
Watch Tower Bible and Tract Society of Pennsylvania
PA0002121125 Talk 47 - Video 1 - Future Events That Will Require Courage (Symposium) - The Attack by Gog of Magog
Watch Tower Bible and Tract Society of Pennsylvania
PA0002121607 Talk 48-Video 1 - Future Events That Will Require Courage (Symposium) - Armageddon
Watch Tower Bible and Tract Society of Pennsylvania
PA0002121129 Talk 49 - Video 1 - Future Events That Will Require Courage (Symposium) - The Great Reconstruction
Watch Tower Bible and Tract Society of Pennsylvania
PA0002121132 Talk 50 - Video 1 - Future Events That Will Require Courage (Symposium) - The Final Test
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191509 2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191514 Talk 01 Video 1 - Chairman’s Address: ‘Love Never Fails - Why?
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191517 Talk 01 Video 2 - Chairman’s Address: ‘Love Never Fails’ - Why?
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191478 Talk 02 Video 1 - Symposium: Beware of Trusting in What Fails! - Wealth (Matthew 6:24)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191475 Talk 03 Video 1 - Symposium: Beware of Trusting in What Fails! - Status and Fame (Ecclesiastes 2:16; Romans 12:16)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191487 Talk 04 Video 1 - Symposium: Beware of Trusting in What Fails! - Human Wisdom (Romans 12:1, 2)
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 2 of 9
PA0002191489 Talk 05 Video 1 - Symposium: Beware of Trusting in What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter 3:3, 4)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191501 Talk 06 Video 1 - DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1; 47:12)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191510 2019 ‘Love Never Fails’! Convention—Music-Video Presentation 2Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191450 Talk 08 Video 1 - Symposium: Love Never Fails Despite … A Loveless Upbringing (Psalm 27:10)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191453 Talk 09 Video 1 - Symposium: Love Never Fails Despite … A Difficult Work Environment (1 Peter 2:18-20)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191458 Talk 10 Video 2 - Symposium: Love Never Fails Despite … An Ungodly School Environment (1 Timothy 4:12)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191459 Talk 11 Video 1 - Symposium: Love Never Fails Despite … Chronic Health Problems (2 Corinthians 12:9, 10)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191460 Talk 12 Video 1 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12, 13)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191461 Talk 12 Video 2 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12, 13)
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 3 of 9
PA0002191455 Talk 13 Video 1 - Symposium: Love Never Fails Despite … Family Opposition (Matthew 5:44)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191432 Talk 14 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191434 Talk 15 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Earth (Psalm 37:29; 115:16)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191437 Talk 16 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191444 Talk 17 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191446 Talk 18 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes 3:11)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191504 Talk 19 Video 1 - ‘Those Whom Jehovah Loves He Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191471 Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191139 2019 ‘Love Never Fails’! Convention - Music-Video Presentation 3
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191157 Talk 21 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Those Taking the Lead (1 Thessalonians 5:12, 13)
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 4 of 9
PA0002191160 Suppl. Reg. PA0002216893
Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191146 Talk 24 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Full-Time Ministers (1 Thessalonians 1:3)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191155 Talk 25 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Foreign Residents (Leviticus 19:34; Romans 15:7)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191149 ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers Meeting
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191683 Talk 26 Video 1 - A0002191683: Display Unfailing Love in the Ministry - Show Your Love for God (1 John 5:3)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191148 Talk 27 Video 1 - Symposium: Display Unfailing Love in the Ministry – ‘Love Your Neighbor as Yourself’ (Matthew 22:39)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191684 Talk 28 Video 1 - Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s Word (Psalm 119:97; Matthew 13:52)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002193286 2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4 (v2)
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 5 of 9
PA0002191713 Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In … Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians 9:22), Oceania (Psalm 35:18), South America (Acts 1:8)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191714 Talk 31 Video 1 - Display Unfailing Love in Your Family - Love Your Wife (Ephesians 5:28, 29)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191715 Talk 32 Video 1 - Display Unfailing Love in Your Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191717 Talk 33 Video 1 - Display Unfailing Love in Your Family - Love Your Children (Titus 2:4)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191144 The Story of Josiah: Love Jehovah; Hate What Is Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191678 Talk 35 Video 1 - Teach Your Children How to Show Love (2 Timothy 3:14, 15)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002192006 Talk 35 Video 3 - Teach Your Children How to Show Love (2 Timothy 3:14, 15)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002192007 Talk 35 Video 4 - Teach Your Children How to Show Love (2 Timothy 3:14, 15)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191679 2019 ‘Love Never Fails’! Convention - Music-Video Presentation 5
Watch Tower Bible and Tract Society of Pennsylvania
PA0002192010 Talk 36 Video 1 - Symposium: Remember How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002192009 Talk 36 Video 2 - Symposium: Remember How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 6 of 9
PA0002191147 Talk 37 Video 1 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191150 Talk 37 Video 2 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191151 Talk 38 Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191152 Talk 38 Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191156 Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1 Corinthians 13:5)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191153 Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1 Corinthians 13:5)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191154 Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 7 of 9
PA0002191719 Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191722 Talk 41 Video 1 - Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191723 Talk 41 Video 2 - Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191724 Talk 42 Video 1 - Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191727 Talk 42 Video 2 - Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191729 Talk 43 Video 1 - Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191159 Talk 43 Video 2 - Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191418 Talk 44 Video 1 - Public Bible Discourse: True Love in a Hate-Filled World - Where? (John 13:34, 35)
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 8 of 9
PA0002191141 Talk 44 Video 2 - Public Bible Discourse: True Love in a Hate-Filled World - Where? (John 13:34, 35)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191682 The Story of Josiah: Love Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191138 Talk 47 Video 1 - ‘Carefully Consider Jehovah’s Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191706 Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8))
Watch Tower Bible and Tract Society of Pennsylvania
PA0002191143 2019 ‘Love Never Fails’! Convention - Music-Video Presentation 6
Watch Tower Bible and Tract Society of Pennsylvania
Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 9 of 9
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURTfor the
__________ District of __________
))))))))))))
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:Signature of Clerk or Deputy Clerk
Southern District of New York
WATCH TOWER BIBLE AND TRACT SOCIETY OFPENNSYLVANIA
20-cv-3366
THE TRUTH AND TRANSPARENCYFOUNDATION, RYAN C. McKNIGHT,
and ETHAN G. DODGE
The Truth and Transparency Foundation109 Cascade Meadow CourtHenderson, Nevada 89011
Kieran G. DoyleThomas KjelbergCowan, Liebowitz & Latman, P.C.114 West 47th Street21st FloorNew York, NY 10036
Case 1:20-cv-03366 Document 5 Filed 04/30/20 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
I personally served the summons on the individual at (place)
on (date) ; or
I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
I returned the summons unexecuted because ; or
Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
20-cv-3366
0.00
Case 1:20-cv-03366 Document 5 Filed 04/30/20 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURTfor the
__________ District of __________
))))))))))))
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:Signature of Clerk or Deputy Clerk
Southern District of New York
WATCH TOWER BIBLE AND TRACT SOCIETY OFPENNSYLVANIA
20-cv-3366
THE TRUTH AND TRANSPARENCYFOUNDATION, RYAN C. McKNIGHT,
and ETHAN G. DODGE
Ryan C. McKnight109 Cascade Meadow CourtHenderson, Nevada 89011
Kieran G. DoyleThomas KjelbergCowan, Liebowitz & Latman, P.C.114 West 47th Street21st FloorNew York, NY 10036
Case 1:20-cv-03366 Document 6 Filed 04/30/20 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
I personally served the summons on the individual at (place)
on (date) ; or
I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
I returned the summons unexecuted because ; or
Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
20-cv-3366
0.00
Case 1:20-cv-03366 Document 6 Filed 04/30/20 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURTfor the
__________ District of __________
))))))))))))
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:Signature of Clerk or Deputy Clerk
Southern District of New York
WATCH TOWER BIBLE AND TRACT SOCIETY OFPENNSYLVANIA
20-cv-3366
THE TRUTH AND TRANSPARENCYFOUNDATION, RYAN C. McKNIGHT,
and ETHAN G. DODGE
Ethan G. Dodge12597 Cresthaven DriveGroveland, CA 95321-9316
Kieran G. DoyleThomas KjelbergCowan, Liebowitz & Latman, P.C.114 West 47th Street21st FloorNew York, NY 10036
Case 1:20-cv-03366 Document 7 Filed 04/30/20 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
I personally served the summons on the individual at (place)
on (date) ; or
I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
I returned the summons unexecuted because ; or
Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
20-cv-3366
0.00
Case 1:20-cv-03366 Document 7 Filed 04/30/20 Page 2 of 2