UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA

MATT WRIGHT,

 Plaintiff, 

- against -

BUSINESS VIEW PUBLISHING, INC.

 Defendant. 

Docket No. 1:20-cv-102

JURY TRIAL DEMANDED

COMPLAINT 

Plaintiff Matt Wright (“Wright” or “Plaintiff”) by and through his undersigned counsel, 

as and for his Complaint against Defendant Business View Publishing, Inc. (“Business View 

Publishing” or “Defendant”) hereby alleges as follows:

NATURE OF THE ACTION

1. This is an action for copyright infringement under Section 501 of the Copyright 

Act. This action arises out of Defendant’s unauthorized reproduction and public display of a 

copyrighted photograph of entrepreneur Michael Dundas in a marijuana growing room, owned 

and registered by Wright, a professional photographer. Accordingly, Wright seeks monetary 

relief under the Copyright Act of the United States, as amended, 17 U.S.C. § 101 et seq. 

JURISDICTION AND VENUE

2. This claim arises under the Copyright Act, 17 U.S.C. § 101 et seq., and this Court 

has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1338(a). 

3. Upon information and belief, this Court has personal jurisdiction over Defendant

because Defendant resides and/or transacts business in Florida.

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4. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b). 

PARTIES

5. Wright is a professional photographer in the business of licensing his photographs 

for a fee having a usual place of business at 10 1⁄2 Washburn Street, Apt 3, Worcester, MA 

01610.

6. Upon information and belief, Business View Publishing is a business corporation

duly organized and existing under the laws of the State of Florida, with a place of business at

12559 New Brittany Blvd, Fort Myers, Florida 33907. Upon information and belief, Business 

View Publishing is registered with the Florida Department of State to do business in Florida. At 

all times material hereto, Business View Publishing has owned and operated a website at the 

URL: www.BusinessViewMagazine.com (the “Website”). 

STATEMENT OF FACTS

A. Background and Plaintiff’s Ownership of the Photograph

7. Wright photographed entrepreneur Michael Dundas in a marijuana growing room

(the “Photograph”). A true and correct copy of the Photograph is attached hereto as Exhibit A.

8. Wright is the author of the Photograph and has at all times been the sole owner of 

all right, title and interest in and to the Photograph, including the copyright thereto. 

9. The Photograph was registered with United States Copyright Office and was

given Copyright Registration Number VA 2-119-997.

B. Defendant’s Infringing Activities

10. Business View Publishing ran an article on the Website entitled Sira Natural: 

Premium Cannabis Products. See: https://businessviewmagazine.com/sira-naturals-premiumCase 1:20-cv-00102-MW-GRJ Document 1 Filed 05/01/20 Page 2 of 5
cannabis-products/. The article featured the Photograph. A true and correct copy of the article 

and a screenshot of the Photograph on the Website are attached hereto as Exhibit B. 

11. Business View Publishing did not license the Photograph from Plaintiff for its

article, nor did Business View Publishing have Plaintiff’s permission or consent to publish the 

Photograph on its Website.

CLAIM FOR RELIEF

(COPYRIGHT INFRINGEMENT AGAINST DEFENDANT)

(17 U.S.C. §§ 106, 501)

12. Plaintiff incorporates by reference each and every allegation contained in 

Paragraphs 1-11 above. 

13. Business View Publishing infringed Plaintiff’s copyright in the Photograph by 

reproducing and publicly displaying the Photograph on the Website. Business View Publishing is 

not, and has never been, licensed or otherwise authorized to reproduce, publically display, 

distribute and/or use the Photograph. 

14. The acts of Defendant complained of herein constitute infringement of Plaintiff’s 

copyright and exclusive rights under copyright in violation of Sections 106 and 501 of the 

Copyright Act, 17 U.S.C. §§ 106 and 501. 

15. Upon information and belief, the foregoing acts of infringement by Business 

View Publishing have been willful, intentional, and purposeful, in disregard of and indifference 

to Plaintiff’s rights.

16. As a direct and proximate cause of the infringement by the Defendant of 

Plaintiff’s copyright and exclusive rights under copyright, Plaintiff is entitled to damages and 

Defendant’s profits pursuant to 17 U.S.C. § 504(b) for the infringement.

Case 1:20-cv-00102-MW-GRJ Document 1 Filed 05/01/20 Page 3 of 5
17. Alternatively, Plaintiff is entitled to statutory damages up to $150,000 per work 

infringed for Defendant’s willful infringement of the Photograph, pursuant to 17 U.S.C. § 504(c).

18. Plaintiff further is entitled to his attorney’s fees and full costs pursuant to 

17 U.S.C. § 505

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests judgment as follows: 

1. That Defendant Business View Publishing be adjudged to have infringed upon 

Plaintiff’s copyrights in the Photograph in violation of 17 U.S.C §§ 106 and 501;

2. That Plaintiff be awarded either: a) Plaintiff’s actual damages and Defendant’s 

profits, gains or advantages of any kind attributable to Defendant’s infringement 

of Plaintiff’s Photograph; or b) alternatively, statutory damages of up to $150,000 

per copyrighted work infringed pursuant to 17 U.S.C. § 504;

3. That Defendant be required to account for all profits, income, receipts, or other 

benefits derived by Defendant as a result of its unlawful conduct;

4. That Plaintiff be awarded his costs, expenses and attorneys’ fees pursuant to 17 

U.S.C. § 505;

5. That Plaintiff be awarded pre-judgment interest; and 

6. Such other and further relief as the Court may deem just and proper. 

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury on all issues so triable in accordance with Federal 

Rule of Civil Procedure 38(b). 

Dated: Valley Stream, New York

April 30, 2020

LIEBOWITZ LAW FIRM, PLLC

Case 1:20-cv-00102-MW-GRJ Document 1 Filed 05/01/20 Page 4 of 5
By: /s/Richard Liebowitz

 Richard P. Liebowitz 

11 Sunrise Plaza, Suite 305

Valley Stream, NY 11580 

Tel: (516) 233-1660

RL@LiebowitzLawFirm.com 

 Attorneys for Plaintiff Matthew Wright

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