UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS

WILLIAM FARRINGTON,

 Plaintiff, 

- against -

INFOWARS, LLC

 Defendant. 

Docket No. 1:20-cv-332

JURY TRIAL DEMANDED

COMPLAINT 

Plaintiff William Farrington (“Farrington” or “Plaintiff”) by and through his undersigned 

counsel, as and for his Complaint against Defendant InfoWars, LLC (“InfoWars” 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; and for the removal and/or alteration of copyright management information under Section 

1202(b) of the Digital Millennium Copyright Act. This action arises out of Defendant’s 

unauthorized reproduction and public display of a copyrighted photograph of EMT’s attempting

to revive Jeffrey Epstein after he committed suicide in his jail cell, owned and registered by 

Farrington, a professional photographer. Accordingly, Farrington 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). 

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3. This Court has personal jurisdiction over Defendant because Defendant resides in 

and/or transacts business in Texas. 

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

PARTIES

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

photographs to online and print media for a fee having a usual place of business at 160 Parkside 

Avenue Apt. 6A, Brooklyn, NY 11226.

6. Upon information and belief, InfoWars is a domestic limited liability company

duly organized and existing under the laws of the State of Texas, with a place of business 100 

Congress Avenue, 18th Floor, Austin, Texas 78701. Upon information and belief InfoWars is 

registered with the Texas Department of State Division of Corporations to do business in the 

State of Texas. At all times material, hereto, InfoWars has owned and operated a website at the 

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

STATEMENT OF FACTS

A. Background and Plaintiff’s Ownership of the Photograph

7. Farrington photographed EMT’s attempting to revive Jeffrey Epstein after he 

committed suicide in his jail cell (the “Photograph”). A true and correct copy of the Photograph 

is attached hereto as Exhibit A.

8. Farrington then licensed the Photograph to the New York Post. On August 10, 

2019, the New York Post ran an article that featured the Photograph titled Photos show Jeffrey 

Epstein as he’s wheeled into Downtown Hospital. See URL:

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hospital/. Farrington’s name was featured in a gutter credit identifying him as the photographer 

of the Photograph. A true and correct copy of the article is attached hereto as Exhibit B. 

9. Farrington 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. 

10. The Photograph was registered with the United States Copyright Office and was 

given registration number VA 2-172-501.

B. Defendant’s Infringing Activities

11. On August 10, 2019, InfoWars ran an article on the Website titled Jeffrey Epstein 

Found Dead in Jail Cell Despite Being on 24/7 Suicide Watch. See URL:

https://www.infowars.com/jeffrey-epstein-found-dead-in-jail-cell-despite-being-on-24-7-suicidewatch/. The article featured the Photograph. A true and correct copy of the article and a 

screenshot of the Photograph on the article are attached hereto as Exhibit C. 

12. Upon information and belief, the Photograph was posted to the article by Paul 

Joseph Watson the editor at large of InfoWars.

13. InfoWars did not license the Photograph from Plaintiff for its article, nor did 

InfoWars have Plaintiff’s permission or consent to publish the Photograph on its Website.

FIRST CLAIM FOR RELIEF

(COPYRIGHT INFRINGEMENT AGAINST DEFENDANT)

(17 U.S.C. §§ 106, 501)

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

Paragraphs 1-13 above. 

15. InfoWars infringed Plaintiff’s copyright in the Photograph by reproducing and 

publicly displaying the Photograph on the Website. InfoWars is not, and has never been, licensed 

or otherwise authorized to reproduce, publically display, distribute and/or use the Photograph. 

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16. 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. 

17. Upon information and belief, the foregoing acts of infringement by Defendant

have been willful, intentional, and purposeful, in disregard of and indifference to Plaintiff’s 

rights.

18. 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. 

19. 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).

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

17 U.S.C. § 505.

SECOND CLAIM FOR RELIEF 

INTEGRITY OF COPYRIGHT MANAGEMENT INFORMATION AGAINST 

DEFENDANT

(17 U.S.C. § 1202) 

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

Paragraphs 1-20 above.

22. Upon information and belief, in its article on the Website, Defendant copied the 

Photograph from the New York Post which contained a gutter credit underneath the Photograph 

stating, “William Farrington” and placed it on its Website without the gutter credit. 

23. Upon information and belief, InfoWars intentionally and knowingly removed 

copyright management information identifying Plaintiff as the photographer of the Photograph.

24. The conduct of InfoWars violates 17 U.S.C. § 1202(b).

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25. Upon information and belief, InfoWars’s falsification, removal and/or alteration 

of the aforementioned copyright management information was made without the knowledge or 

consent of Plaintiff. 

26. Upon information and belief, the falsification, alteration and/or removal of said 

copyright management information was made by InfoWars intentionally, knowingly and with the 

intent to induce, enable, facilitate, or conceal their infringement of Plaintiff’s copyright in the 

Photograph. InfoWars also knew, or should have known, that such falsification, alteration and/or 

removal of said copyright management information would induce, enable, facilitate, or conceal 

their infringement of Plaintiff’s copyright in the Photograph.

27. As a result of the wrongful conduct of InfoWars as alleged herein, Plaintiff is 

entitled to recover from InfoWars the damages, that he sustained and will sustain, and any gains, 

profits and advantages obtained by InfoWars because of their violations of 17 U.S.C. § 1202, 

including attorney’s fees and costs.

28. Alternatively, Plaintiff may elect to recover from InfoWars statutory damages 

pursuant to 17 U.S.C. § 1203(c) (3) in a sum of at least $2,500 up to $25,000 for each violation 

of 17 U.S.C. § 1202.

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff respectfully requests judgment as follows: 

1. That Defendant InfoWars be adjudged to have infringed upon Plaintiff’s 

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

2. The Defendant InfoWars be adjudged to have falsified, removed and/or altered 

copyright management information in violation of 17 U.S.C. § 1202. 

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3. 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;

4. That, with regard to the Second Claim for Relief, Plaintiff be awarded either: 

a) Plaintiff’s actual damages and Defendant’s profits, gains or advantages of any 

kind attributable to Defendant’s falsification, removal and/or alteration of 

copyright management information; or b) alternatively, statutory damages of at 

least $2,500 and up to $ 25,000 for each instance of false copyright management 

information and/or removal or alteration of copyright management information 

committed by Defendant pursuant to 17 U.S.C. § 1203(c);

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

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

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

17 U.S.C. § 1203(b); 

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

U.S.C. § 505;

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

9. 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

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March 26, 2020

LIEBOWITZ LAW FIRM, PLLC

By: /s/Richard Liebowitz

Richard P. Liebowitz, Esq.

11 Sunrise Plaza, Suite 305

Valley Stream, New York 11580 

Tel: (516) 233-1660

RL@LiebowitzLawFirm.com

 Attorneys for Plaintiff William Farrington

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