UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS

ALEX PROIMOS,

 Plaintiff, 

- against -

THRIVEWORKS SOLUTIONS, LLC

 Defendant. 

Docket No. 1:20-cv-662

JURY TRIAL DEMANDED

COMPLAINT 

Plaintiff Alex Proimos (“Proimos” or “Plaintiff”) by and through his undersigned 

counsel, as and for his Complaint against Defendant Thriveworks Solutions, LLC (“Thriveworks 

Solutions” 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 a homeless man in Paris, France, owned and registered by Proimos, a

professional photographer. Accordingly, Proimos 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 Texas.

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

PARTIES

5. Proimos 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 14 Lancaster 

Avenue, Sydney, 2119 Australia.

6. Upon information and belief, Thriveworks Solutions is a limited liability 

company, with a place of business at 9300 Research Blvd, Suite 320, Austin, Texas 78759. At all 

times material hereto, Thriveworks Solutions has owned and operated a website at the URL:

www.Thriveworks.com (the “Website”). 

STATEMENT OF FACTS

A. Background and Plaintiff’s Ownership of the Photograph

7. Proimos photographed a homeless man in Paris, France (the “Photograph”). A 

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

8. Proimos 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 2-183-531.

B. Defendant’s Infringing Activities

10. Thriveworks Solutions ran an article on the Website entitled 5 Uplifting News 

Stories That Will Restore Your Faith in Humanity. A screenshot of the Photograph on the 

Website is attached hereto as Exhibit B. 

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11. Thriveworks Solutions did not license the Photograph from Plaintiff for its article, 

nor did Thriveworks Solutions 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. Thriveworks Solutions infringed Plaintiff’s copyright in the Photograph by 

reproducing and publicly displaying the Photograph on the Website. Thriveworks Solutions 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 Thriveworks 

Solutions 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.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests judgment as follows: 

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1. That Defendant Thriveworks Solutions 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 Plaintiff’s actual damages and Defendant’s profits, 

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

Plaintiff’s Photograph;

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 punitive damages for copyright infringement;

5. That Plaintiff be awarded attorney’s fees and costs;

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

7. 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

June 24, 2020

LIEBOWITZ LAW FIRM, PLLC

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 Alex Proimos

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