UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

Flava Works, Inc., )

)

Plaintiff, ) Case No.

)

)

v. ) COMPLAINT

)

)

John Doe #1 "MrMuscle 3M <1016dudz@gmail.com> ", ) Jury Trial 

John Doe #2 "Abrazdert74893@myemailco.com ", )

John Doe #3 "Blk Muscle <ads.almond@gmail.com> ", )

John Doe #4 "Bob Hare aka Animated GIF Man )

<agm.scans.69@comcast.net> ", )

John Doe #5 "BangerBull <alantos25@gmail.com> ", )

John Doe #6 "Mike Anthony <baltquietfire@yahoo.com> ", )

John Doe #7 "betcamus <betcamus@bellsouth.net>" )

John Doe #8 "bigd_itsme <bigd_itsme@yahoo.com> ", )

John Doe #9 "Black Chest< black.69chest@gmail.com>”, )

John Doe #10 "biblacbuck <blogger0815@hotmail.com> ", )

John Doe #11 "Corey Corey <coreydmia@yahoo.com>", )

John Doe #12 "datu white <datuwhite@gmail.com> ", )

John Doe #13 "Dylan Madrigal <dmadrigal116@gmail.com> ", )

John Doe #14 "Don C <donho999_us@yahoo.com> ", )

John Doe #15 "jonrgn@aol.com", )

John Doe #16 "Delvin Raymond <motd193@yahoo.com> )

John Doe #17 "neil kimura <ntki72@yahoo.com> )

John Doe #18 "rhythme101@yahoo.com " , )

John Doe #19 "ruff abs <ruffabs6@yahoo.com> ", )

John Doe #20 "Mozell Baptiste <slimazz@sbcglobal.net> ", )

John Doe #21 "pi so <sopi9070@gmail.com> ", )

John Doe #22 "Mister Smith <tightsqueez2000@yahoo.com> ", )

John Doe #23 "Tyler Raymond <traymond6060@yahoo.com> ", )

John Doe #24 "Why Wonder <why1dr@yahoo.com> ", )

John Doe #25 "dickies <yam.rodic@yahoo.com> ", )

John Doe #26 "efrenlee <efrenlee07@gmail.com> ", )

FF Magnat Limited d/b/a Oron.com, )

Earnwell Hong Kong LTD d/b/a Filesonic.com, )

)

Defendants. )

COMPLAINT

Case: 1:12-cv-05844 Document #: 1 Filed: 07/24/12 Page 1 of 14 PageID #:1
Plaintiff, Flava Works, Inc. (hereinafter “Plaintiff” or “Flava Works”), by and through its 

attorney, Meanith Huon, and for its Complaint against the Defendants, states as follows:

NATURE OF THE ACTION

1. This is an action for copyright infringement pursuant to the Copyright Act, 17 

U.S.C. § 101 et seq..

THE PARTIES

2. Plaintiff is a corporation incorporated under the laws of the State of Florida with a 

principal place of business in both Miami, Florida and in Chicago, Illinois.

3. On information and belief, at all relevant times, Defendants, John Does 1-26

(hereinafter collectively “John Does” or individually “John Doe 1,” “John Doe 2,” etc.), are 

individuals and/or business entities whose real identities are currently unknown and whose 

whereabouts are currently unknown. On information and belief, Defendants, John Does 1-26, 

actively contributed to this infringement by posting files, storing videos, sharing files, and/or 

posting links on the websites: Oron.com, FileFactory.com, FileMonster.com, FilePost.com, 

FileServe.com, FileSonic.com, Hotfile.com, i-Filez.com, Rapidshare.com, and Shragle.com.

4. On information and belief, Defendants, John Does 1-26 are members of the 

following Yahoo groups:

http://groups.yahoo.com/group/P-I-LOVE

http://groups.yahoo.com/group/oron-links

http://groups.yahoo.com/group/UrbanLatino

http://groups.yahoo.com/group/UrbanBrothers

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http://groups.yahoo.com/group/men4men_who_love_black_men

http://groups.yahoo.com/group/blkloverboyz/

On information and belief, the primary purpose for these six Yahoo Groups are for illegal 

copyright file sharing.

5. On information and belief, Defendant FF Magnat Limited d/b/a Oron.com

own, operate, and/or control the Internet website. 

6. On information and belief, Oron.com is registered through Network Solutions, an

American company operating out of Herndon, Virginia. Oron.com utilizes the services of the

company CC Bill to process its payments. CC Bill is an American company operating out of 

Tempe, Arizona.

7. On information and belief, Defendant, Earnwell Hong Kong LTD operates, 

controls, and/or owns Filesonic.com.

8. On information and belief, Oron.com, FileFactory.com , FileMonster.com, 

FilePost.com, FileServe.com, FileSonic.com, Hotfile.com, i-Filez.com, Rapidshare.com, and 

Shragle.com, own, operate, and/or control websites that copy, store, distribute, display, profit from

unauthorized copyrighted materials, and/or induce and assist others to infringe copyrighted

materials. On information and belief, Rapidshare AG operates, controls, and/or owns 

Rapidshare.com.

9. On information and belief, Defendants, John Does 1-26, posted links to 

copyrighted videos that were located on the websites of Oron.com, FileFactory.com,

FileMonster.com, FilePost.com, FileServe.com, FileSonic.com, Hotfile.com, i-Filez.com, 

Oron.com, Rapidshare.com, and Shragle.com, Earnwell Hong Kong LTD, and Rapidshare AG. 

Case: 1:12-cv-05844 Document #: 1 Filed: 07/24/12 Page 3 of 14 PageID #:3
JURISDICTION AND VENUE

10. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331, § 1338 

and § 1367; pursuant to the Copyright Act.

11. Personal jurisdiction is proper over the Defendant, FF Magnat Limited d/b/a

Oron.com. Defendant has entered into a contract with CC Bill, a Tempe, Arizona company

that handles payment processing for Oron. 

12. Personal jurisdiction is proper over the Defendant, Earnwell Hong Kong LTD

d/b/a Filesonic.com. Defendant has entered into a contract with Paypay.com Company that

handles payment processing for Filesonic.com 

13. Venue is proper in this district under 28 U.S.C. § 1391(b)(2) because a substantial 

part of the events or omissions giving rise to the claim occurred, or a substantial part of property 

that is the subject of the action is situated in this district. The copyrights being infringed on are 

owned by Flava Works, Inc. Plaintiff is a corporation incorporated under the laws of the State of 

Florida with a principal place of business in both Miami, Florida and in Chicago, Illinois.

FACTUAL BACKGROUND

14. Plaintiff is a corporation that produces adult entertainment in the form of DVDs, 

magazines, websites, pictures, streaming video and various other media.

15. Plaintiff distributes its adult entertainment through various distributors and 

licensees, as well as through its websites: www.FlavaMen.com, www.CocoDorm.com,

www.CocoStore.com, www.PapiCock.com, www.RawRods.com, and www.ThugBoy.com, 

among others. 

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16. Plaintiff has applied for and/or has registered various copyrights for its works. See 

attached Exhibit A for works with registered copyrights. 

17. Plaintiff is recognized nationally and internationally as a leader in the field of 

production and distribution of adult entertainment due, in large part, to the goodwill and name 

recognition associated with its trademarks, as well as the high quality content that is associated 

with its copyrighted material.

18. On information and belief, Oron.com, FileFactory.com , FileMonster.com, 

FilePost.com, FileServe.com, FileSonic.com, Hotfile.com, i-Filez.com, Rapidshare.com, and 

Shragle.com, Earnwell Hong Kong LTD, and Rapidshare AG, operate, control, and/or own

internet websites which are accessible throughout the United States and the world. On 

information and belief, these websites sell access to large amounts of unauthorized intellectual

property to the public without paying the rightful owners of that property.

19. On information and belief, Oron.com, FileFactory.com, FileMonster.com, 

FilePost.com, FileServe.com, FileSonic.com, Hotfile.com, i-Filez.com, Rapidshare.com, and 

Shragle.com, Earnwell Hong Kong LTD, and Rapidshare AG, and its users upload copyrighted

and trademarked intellectual property (movies, songs, software, or pictures, etc.) to its computer

servers.

20. On information and belief, after a file is uploaded, the aforesaid websites provides

to its users a unique Uniform Resource Locator (“URL”) which allows its users to view or

download the file from the website. The URL’s are disseminated throughout the internet by the 

aforesaid website and its users, which enable anyone with the URL to access, copy, and download

the intellectual property from the website’sservers.

21. On information and belief, in order to view, copy, or download such files from the

Case: 1:12-cv-05844 Document #: 1 Filed: 07/24/12 Page 5 of 14 PageID #:5
aforesaid websites without waiting, the customer must purchase a membership fee. On 

information and belief, some of the aforesaid websites paid members for directing web traffic to 

its site through a rewards program.

 22. On information and belief, Defendants, John Does 1-26 are members of the 

following Yahoo groups:

http://groups.yahoo.com/group/P-I-LOVE

http://groups.yahoo.com/group/oron-links

http://groups.yahoo.com/group/UrbanLatino

http://groups.yahoo.com/group/UrbanBrothers

http://groups.yahoo.com/group/men4men_who_love_black_men

http://groups.yahoo.com/group/blkloverboyz/

On information and belief, the Primary purpose for these five Yahoo Groups are for illegal 

copyrightfile sharing.

23. On information and belief, Defendants, John Does 1-26, posted links to 

copyrighted videos that were located on the websites Oron.com, FileFactory.com,

FileMonster.com, FilePost.com, FileServe.com, FileSonic.com, Hotfile.com, i-Filez.com, 

Rapidshare.com, and Shragle.com, Earnwell Hong Kong LTD, and Rapidshare AG. 

24. On information and belief, Defendants John Does 1-26 posted copyright materials 

of the Plaintiff without authorization.

25. On information and belief, Defendants John Does 1-26 sent emails to other 

members of the Yahoo Groups stating the location of the infringing materials. Exhibit “B1” to 

“B26”.

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26. On information and belief, Oron is not a legitimate file storage company. Oron’s 

affiliates reward program offered members the opportunity to make money by uploading 

copyrighted videos. Affiliates members are paid based upon the number of downloads of their 

posted materials and based upon how many other premium memberships were bought by users 

accessing Oron through the member’s links. 

27. On information and belief, at all relevant times, Filesonic.com is not a legitimate

file storage company. Filesonic.com’s affiliates reward program offered members the 

opportunity to make money by uploading copyrighted videos. Affiliates members are paid based 

upon the number of downloads of their posted materials and based upon how many other 

premium memberships were bought by users accessing Filesonic.com through the member’s 

links. 

COUNT I 

(Direct Copyright Infringement as to all Defendants – 17 U.S.C. § 501.)

1-27. Plaintiff incorporates and re-alleges paragraphs 1-27 of this Complaint as 

paragraphs 1-27 of Count I.

28. Defendants' conduct interferes with Plaintiff’s exclusive right to reproduce, 

distribute and display the copyrighted works.

29. Defendants’ conduct constitutes copyright infringement that this Court may 

remedy under Sections 106 and 501 of the Copyright Act.

30. Instances of copyright infringement occur whenever one of Defendants’ user, 

without authorization of the copyright owner, uses Defendants' website to download a 

Case: 1:12-cv-05844 Document #: 1 Filed: 07/24/12 Page 7 of 14 PageID #:7
copyrighted content file and/or images. Such acts constitute unauthorized reproduction and 

distribution and result in unauthorized copies. Defendants participate in, facilitate, materially 

contribute to and encourage these infringements.

31. On information and belief, Defendants, John Does 1-27 are users of the aforesaid 

Yahoo groups. 

32. On information and belief, Defendants, John Does 1-27 are users of one or more 

of the aforesaid websites who caused copies of Plaintiff’s copyrighted works to be made, 

distributed or posted on the websites.

33. On information and belief, Defendants' aforesaid activities constitute 

infringement of Plaintiff's copyrights.

34. As a result of the injury suffered by Plaintiff’s business from Defendants’ actions 

of direct copyright infringement, Plaintiff is entitled to recover actual and/or statutory damages, 

which shall be determined at trial, and costs of this action, including reasonable attorney’s fees, 

as well as injunctive relief to prevent future infringement.

COUNT II

(Contributory Copyright Infringement.)

1-27. Plaintiff incorporates and re-alleges paragraphs 1 to 20 of this Complaint as 

paragraphs 1-27 of Count II.

28. On information and belief, Defendants, John Does 1-27 posted or email 

messages to members of the aforesaid Yahoo users groups, advising all members how to locate 

copyrighted works of Flava Works that the Defendants had posted on various websites. 

Case: 1:12-cv-05844 Document #: 1 Filed: 07/24/12 Page 8 of 14 PageID #:8
Without authorization, Defendants reproduced and distributed Flava Works’ Intellectual Property 

by posting the videos on websites and sending links to the videos, thereby contributing to the 

infringement of those copyrighted works.

29. On information and belief, Defendants aided, abetted, allowed, encouraged and

otherwise materially contributed to helping those individuals to reproduce and distribute Flava 

Works’ Intellectual Property.

30. On information and belief, Defendants received direct financial benefits from the 

infringements by earning money through a rewards program.

31. Defendants' conduct constitutes contributory copyright infringement that this 

Court may remedy under Sections 106 and 501 of the Copyright Act.

32. As a result of the injury suffered by Plaintiff’s business from Defendants' actions 

of contributory copyright infringement, Plaintiff is entitled to recover actual and/or statutory 

damages, which shall be determined at trial, and costs of this action, including reasonable 

attorney’s fees, as well as injunctive relief to prevent future infringement.

Count III

(Inducement of Copyright Infringement.)

1-32. Plaintiff incorporates and re-alleges paragraphs 1-32 of Count II of this 

Complaint as paragraphs 1-32 of Count III.

33. On information and belief, Defendants received direct financial benefits from the 

infringements by earning money through the rewards program of some of the aforesaid websites.

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34. Defendants' conduct constitutes inducement copyright infringement that this 

Court may remedy under Sections 106 and 501 of the Copyright Act.

35. As a result of the injury suffered by Plaintiff’s business from Defendants' actions 

of inducement of copyright infringement, Plaintiff is entitled to recover actual and/or statutory 

damages, which shall be determined at trial, and costs of this action, including reasonable 

attorney’s fees, as well as injunctive relief to prevent future infringement.

Count IV

(Conspiracy.)

1-27. Plaintiff incorporates and re-alleges paragraphs 1 to 27 of this Complaint as 

paragraphs 1-27 of Count IV.

28. The Defendants conspired to infringe on the Plaintiff’s copyrighted works.

29. All Defendants are jointly and severally liable for the actions of their coconspirators.

WHEREFORE Plaintiff, Flava Works, Inc. respectfully requests that this Honorable 

Court enter the following:

1. A judgment in its favor of Plaintiff, Flava Works, Inc. and against the 

Defendants.

2. For a temporary restraining order, preliminary injunction, and permanent 

injunction against Defendants and their aliases, his agents, servants, 

representatives, employees, attorneys, parents, subsidiaries, related companies, 

partners, successors, predecessors, assigns, and all persons acting for, with, by, 

Case: 1:12-cv-05844 Document #: 1 Filed: 07/24/12 Page 10 of 14 PageID #:10
through, or under Defendants and each of them during the pendency of this action 

as preliminary injunction and permanently thereafter from:

a. Restraining and enjoining Defendants from posting on any website(s) 

material that infringes Flava Works’ Intellectual Property, as well as from 

facilitating the posting on any website(s) by third parties infringing material 

and/or links which enable the easy access to Flava Works’ Intellectual Property 

that is located on third party websites;

b. Restraining and enjoining Defendants from otherwise distributing, 

reproducing, using, copying, streaming, making available for download, or 

otherwise exploiting Flava Works’ Intellectual Property, including Plaintiff’s 

copyrighted works, trademarks, trade dress, or any other product or symbol 

with the indicia of Plaintiff’s ownership, through use of their website(s) or 

otherwise;

c. Restraining and enjoining Defendants from doing any other act, through 

his website(s) or otherwise, which shall confuse, deceive, cause mistake, etc. 

among the relevant trade and general public as to the association, sponsorship 

and/or approval between Plaintiff and any website(s);

d. Restraining and enjoining Defendants from otherwise Using, copying or 

otherwise exploiting Plaintiff’s copyrights and copyrighted works;

e. Restraining and enjoining Defendants from otherwise using, disclosing. 

converting, appropriating. retaining. selling, transferring or copying any property 

of Plaintiffs;

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f. Restraining and enjoining Defendants from otherwise Using any of the 

Plaintiff's marks attached hereto or any colorable imitation of any of the marks 

in connection with the distribution of images and content at Defendants' website;

g. Restraining and enjoining Defendants from otherwise doing any other act 

or thing likely to, or calculated to, induce the belief that Defendants or 

Defendants' business is in any way affiliated, connected associated with Plaintiff, 

or Plaintiff's business;

h. Restraining and enjoining Defendants from otherwise unfairly 

competing with plaintiffs in any manner.

3. Requiring Defendants to submit to the Court and to serve upon Plaintiff a report, 

written under oath, setting forth in detail the manner and form in which Defendant 

has complied with the terms of this injunction;

4. Disgorging Defendants of any profits they may have made as a result of his 

infringement of Flava Works’ Intellectual Property;

5. Awarding Plaintiff the actual damages sustained by Plaintiff as a result of 

Defendants' infringement of Flava Works’ Intellectual Property, the amount of 

which is to be determined at trial;

6. Awarding Plaintiff compensatory and punitive damages, as deemed just and 

proper by this Court, as a result of the willful misconduct on the part of the

Defendants;

7. Awarding Plaintiff the costs of this action, together with reasonable attorney’s 

fees;

8. Awarding Plaintiff statutory damages pursuant to the Copyright Act.

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9. Awarding Plaintiff enhanced statutory damages, pursuant to 15 U.S.C. § 504(c)(2) 

of the Copyright Act, for Defendants' willful infringement of Plaintiff’s 

copyrighted works;

10. Requiring Defendants to deliver up for destruction all DVDs, DVD covers, labels, 

letterhead, business cards, signs, prints, packages, wrappers, receptacles, 

advertisements and the like in their possession bearing the name or mark of any of 

the Plaintiff’s trademarks or any other reproduction, counterfeit, copy or colorable 

imitation of the Plaintiff’s trademarks.

12. Awarding any such other and further relief as this Court deems just, reasonable 

and equitable.

 

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury of all issues properly triable by jury in this action, 

pursuant to Rule 38 of the Federal Rules of Civil Procedure.

DATED: Respectfully Submitted,

July 24, 2012

By: __/s/Meanith Huon__________

Meanith Huon

Case: 1:12-cv-05844 Document #: 1 Filed: 07/24/12 Page 13 of 14 PageID #:13
Meanith Huon

ARDC No.: 6230996

PO Box 441

Chicago, Illinois 60690

Phone: (312) 405-2789

E-mail: huon.meanith@gmail.com

IL ARDC. No.: 6230996

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