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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

AF HOLDINGS LLC,

Plaintiff,

v.

DANIEL LEVINE, 

Defendant.

CASE NO. 1:12-CV-04235

Judge: Hon. Matthew F. Kennelly

 

 

NOTICE OF ALLEGATIONS

Plaintiff hereby notifies the Court of allegations of forgery that were made during a 

hearing in a matter pending before the U.S. District Court for the Central District of California. 

Ingenuity13 LLC v. John Doe, No. 2:12-cv-08333-OWD-JC (C.D. Cal. Mar. 11, 2013). On 

March 11, 2013, an individual by the name of Alan Cooper alleged that his signature was forged 

on two separate agreements assigning the rights of various copyrighted works to Plaintiff, 

including the assignment at issue in this matter. (See, ECF No. 1-2 at 2.) Plaintiff categorically 

denies Mr. Cooper’s allegations, which arise nearly two years after certain of the alleged conduct 

occurred. Mr. Cooper has a pecuniary interest in his allegations by virtue of a lawsuit he filed 

against Plaintiff. Cooper v. Steele, et al., No. 27-CV-13-3463 (Minn. Dist. Ct., Hennepin Cty., 

2013). 

Even if Mr. Cooper’s allegations were true—and they are not—Plaintiff’s assignments, 

including the assignment at issue in the instant action, remain valid. The formal requirements of 

a copyright assignment are “quite simple”: a writing signed by the assignor. 17 U.S.C. § 204; 

Effects Associates, Inc. v. Cohen, 908 F.2d 555, 557 (9th Cir. 1990) (“The rule is really quite 

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simple: If the copyright holder agrees to transfer ownership to another party, that party must get 

the copyright holder to sign a piece of paper saying so. It doesn't have to be the Magna Charta; a 

one-line pro forma statement will do.”); see also Order, AF Holdings LLC v. Does 1-96, No. 11-

cv-3335-JSC (N.D. Cal. Nov. 22, 2011), ECF No. 29 at 5 n.1 (“The written copyright assignment 

recites that it is between the original copyright owner, Heartbreaker Films, and Plaintiff here, AF 

Holdings, LLC. . . . As the law requires only that the assignment be signed by the assignor and 

not the assignee, this inconsistency does not prevent a prima facie showing of copyright 

ownership.”) (internal citations omitted). 

Mr. Cooper’s allegations relate to the assignee, not the assignor. The assignment at issue 

in this action satisfies the Copyright Act’s formal requirements. It is a writing signed by the 

assignor. Plaintiff’s rights in the copyrighted work in this action were transferred when the 

assignor executed the assignment. 

Plaintiff is treating Mr. Cooper’s allegations with utmost seriousness and is investigating 

their substance. Because Mr. Cooper’s allegations relate to the assignment agreement at issue in 

the instant litigation, Plaintiff respectfully brings the matter to the Court’s attention.

Respectfully submitted,

DATED: March 14, 2013

By: /s/ Paul Duffy

Paul Duffy (Bar No. 6210496)

Prenda Law Inc.

161 N. Clark St., Suite 3200

Chicago, IL 60601

Phone: 312-880-9160

Fax: 312-893-5677

E-mail: paduffy@wefightpiracy.com

Attorney for Plaintiff

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that on March 14, 2013, all counsel of record who are 

deemed to have consented to electronic service are being served a true and correct copy of the 

foregoing document using the Court’s CM/ECF system, in compliance with Local Rule 5.2(a). 

/s/ Paul Duffy

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