Matthew A. Levin, OSB #003054 

MattLevin@MHGM.com 

MARKOWITZ, HERBOLD, GLADE 

& MEHLHAF, P.C. 

1211 SW Fifth Avenue, Suite 3000 

Portland, OR 97204-3730 

Tel: (503) 295-3085 

Fax: (503) 323-9105 

Attorneys for Plaintiffs 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

3'14 -cv -1275 

cJJe No.: - HU. 

ABS-CBN CORPORATION, a Philippine 

corporation; ABS-CBN FILM 

PRODUCTIONS, INC. d/b/a Star Cinema, a 

Philippine corporation; and ABS-CBN 

INTERNATIONAL, a California corporation, 

------

Plaintiffs, 

vs. 

JEFFREY ASHBY, an individual; LENIE 

ASHBY, an individual; jointly d/b/a 

WEBPINOYTAMBAYAN.COM; 

W ATCHFILIPINOTV.COM; 

W ATCHFILIPINOMOVIES.COM; . 

PINOY-TVKO.COM; PINOYTVKO.BIZ; 

PINOY-TUBE. COM; 

MYPINOYTUBETV.COM; 

PINOYTALAGA.COM; 

PINOYSTREAMING.COM; 

PINOYMOVIEFAN.COM; 

PINOYTVEPISODES.NET; 

PINOYTVEPISODES.INFO; and DOES 1-

100, 

Defendants. 

COMPLAINT FOR TRADEMARK 

AND COPYRIGHT INFRINGEMENT, 

AND FOR INJUNCTIVE RELIEF 

FILED UNDER SEAL 

DEMAND FOR JURY TRIAL 

ABS-CBN CORPORATION, ABS-CBN FILM PRODUCTIONS, INC. d/b/a Star 

Cinema, and ABS-CBN INTERNATIONAL (hereinafter collectively, "Plajntiffs" or "ABSCBN"), by and through their counsel, hereby sue Defendants JEFFREY ASHBY and LENIE 

ASHBY (the "Individual Defendants"), d/b/a WEBPINOYTAMBA YAN.COM, 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 1 of 65
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WATCHFILIPINOTV.COM, W ATCHFILIPINOMOVIES.COM, PINOY-TVKO.COM, 

PINOYTVKO.BIZ, PINOY-TUBE. COM, MYPINOYTUBETV.COM, PINOYTALAGA.COM, 

PINOYSTREAMING.COM, PINOYMOVIEF AN.COM, PINOYTVEPISODES.NET, and 

PINOYTVEPISODES.INFO (the "Subject Domain Names" identified on Schedule "A"), and 

DOES 1-100 (with the Individual Defendants, collectively, "Defendants"), and allege as follows: 

NATURE OF THE CASE 

1. This is an action for willful trademark and copyright piracy. ABS-CBN is the 

largest media and entertainment company in the Philippines, producing thousands of hours of 

original content every year for its numerous television stations, including daily drama teleseries, 

drama anthologies, movies, musical and variety shows, game shows, reality shows, news 

programs, current affairs programs, documentaries, music video 24/7 (Myx), AM talk radio with 

DJ live on-screen (DZMM), FM radio shows with DJ live on-screen (MOR), and public affairs 

programs. Every day, ABS-CBN's programming is broadcast worldwide through its agreements 

with dozens of cable companies' premium channels, telecom provider partnerships, Internet 

subscription services, and through its own 24-hour cable and satellite service, which offers pay0 0 per-v1ew programmmg. 

2. Defendants operate pirate websites under the Subject Domain Names identified 

on Schedule "A" hereto, including WEBPINOYTAMBA Y AN.COM, 

W ATCHFILIPINOMOVIES.COM, W ATCHFILIPINOTV.COM, PINOYTALAGA.COM, 

PINOY-TVKO.COM, PINOYTVKO.BIZ, PINOY-TUBE.COM, MYPINOYTUBETV.COM, 

PINOYSTREAMING.COM, AND PINOYMOVIEFAN.COM. On information and belief, the 

Individual Defendants, JEFFREY ASHBY and LENIE ASHBY, are the registrants, owners 

and/or operators of the Subject Domain Names and pirate websites through which Plaintiffs' 

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intellectual property in its programs and brands is being infringed on an ongoing basis. In 

addition, the Individual Defendants are believed to be the registrants, owners and/or operators of 

PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO, which, on information and belief, 

both infringed ABS-CBN's trademarks and copyrights, as stated herein. 

3. Further, at least Defendant JEFFREY ASHBY is believed to be one of the major 

players personally responsible for the theft, copying and uploading of ABS-CBN's content to 

servers for viewing through Defendants' and other pirate sites by hundreds of thousands of 

Internet users worldwide each day. In this way, Defendants are able to offer the latest ABS-CBN 

content often within minutes or hours of the original broadcast in the Philippines. Defendants 

illegally promote to the public that they offer ABS-CBN's content, including through the use of 

Plaintiffs' trademarks, and transmit full-length performances of ABS-CBN's TV shows and 

movies through their websites in order to illegally profit from ABS-CBN's intellectual property, 

without ABS-CBN's consent. 

4. In addition to infringing Plaintiffs trademarks and performing pirated copies of 

Plaintiffs' video content, Defendants are believed to distribute malware, spyware and other 

nefarious, malicious and harmful software through the websites, typically in the guise of 

software updates "needed" by the viewer in order to enhance their viewing experience of 

Plaintiffs' video content. 

5. Defendants' profits from the infringement come at an enormous cost to Plaintiffs. 

Defendants are responsible for mass infringement of Plaintiffs' copyrighted works, causing 

substantial harm to Plaintiffs, who have made significant investments of money, time and 

creative energies to produce the content, and develop the technical platform, branding, 

promotions and sales, and goodwill around their products and distribution channels. Moreover, 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 3 of 65
because ABS-CBN operates worldwide, including through partnership agreements with premium 

cable channels, through its own Internet pay subscription service, and through its own 24-hour 

pay-per-view programming, free streaming of Plaintiffs' content by Defendants deprives ABSCBN of substantial revenue that would otherwise be derived from consumers; diverts customers 

worldwide from its subscription services and confuses consumers as to the source and legitimacy 

of its content and distribution channels; harms ABS-CBN' s ability to continue to build out its 

paying customer base, particularly in international markets; and interferes with and harms ABSCBN's distribution agreements, hurting its and its partners' profits. 

6. The Defendants' websites are classic examples of pirate operations, operating 

under false and anonymous aliases. Further, Defendants have shown their complete disregard 

for Plaintiffs' rights by, among other things, ignoring Plaintiffs' notices to halt Defendants' 

illegal enterprise, which caused Defendants repeatedly to move Subject Domain Names in an 

effort to evade enforcement attempts. As a result, Plaintiffs require this Court's intervention if 

any meaningful stop is to be put to Defendants' piracy. 

JURISDICTION AND VENUE 

7. This is an action seeking damages and injunctive relief for trademark 

counterfeiting and infringement, and false designation of origin under the Lanham Act, 

15 U.S.C. § 1051 et seq.; common law unfair competition; and copyright infringement under the 

Copyright Act, 17 U.S.C. § 101 et seq. 

8. This Court has subject matter jurisdiction pursuant to 17 U.S.C. §§ 101 et seq., 

15 U.S.C. § § 1114 and 1125(a), and 28 U.S.C. §§ 1331, 1338(a) & (b). 

9. This Court has supplemental jurisdiction under 28 U.S.C. § 1367 over the state 

law claims, because the claims are so related to the trademark and copyright claims in this action 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 4 of 65
{ \ 

over which this Court has original jurisdiction that they form part of the same case or 

controversy under Article III of the United States Constitution. 

10. Venue is proper in this Court pursuant 28 U.S.C. § 139l(a), (b) and/or (c) and 

28 U.S.C. § 1400(a). Personal jurisdiction is proper as to all Defendants because the Individual 

Defendants are residents of this State, from which they operate the Subject Domain Names, 

perpetrate the infringement complained of herein, and because all Defendants directly target 

business activities towards consumers in Oregon and cause harm to ABS-CBN's business within 

this District through, at least, the websites operating under the Subject Domains. 

THE PLAINTIFFS 

11. ABS-CBN Corporation is a public Philippine corporation. 

12. ABS-CBN Film Productions, Inc. is a Philippine corporation and wholly-owned 

subsidiary of ABS-CBN Corporation. 

13. ABS-CBN International is a California corporation and a wholly-owned 

subsidiary of ABS-CBN Corporation. 

14. Plaintiff, ABS-CBN International, is, and at all times relevant hereto has been, the 

registered owner of the following trademarks, which are valid and registered on the Principal 

Register of the United States Patent and Trademark Office (collectively the "ABS-CBN Marks"): 

Trademark Registration Registration Class I Services Number Date 

IC 038- Television broadcasting ABS-CBN 2,334,131 March 28, 2000 services via satellite and cable 

IC 038- Cable television broadcast 

THE FILIPINO 1,994,383 Aug. 20, 1996 IC 041- Television show production CHANNEL and programming. 

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' 

15. The ABS-CBN Marks are used in conjunction with high quality services in-the 

categories identified above. 

16. The ABS-CBN Marks have been used in interstate commerce for many years to 

identify and distinguish ABS-CBN's high quality services, including, but not limited to, 

broadcast distribution services, for an extended period of time and serve as symbols of ABSCBN's quality, reputation, and goodwill. 

17. The ABS-CBN Marks have never been assigned or licensed to the Defendants in 

this matter. 

18. The ABS-CBN Marks are symbols of ABS-CBN's quality, reputation, and 

goodwill and have never been abandoned. 

19. ABS-CBN is also, and at all times relevant hereto has been, the owner of all rights 

in and to the following common law trademark (the "ABS-CBN Common Law Trademark"): 

Trademark 

20. The ABS-CBN Common Law Trademark is used in conjunction with high quality 

products and services, including broadcasting distribution services. 

21. The ABS-CBN Common Law Trademark has been used in interstate commerce 

for many years to identify and distinguish ABS-CBN's high quality broadcasting distribution 

services and serves as a symbol of ABS-CBN's quality, reputation, and goodwill. 

22. The ABS-CBN Common Law Trademark has never been assigned or licensed to 

the Defendants in this matter. 

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23. The ABS-CBN Common Law Trademark is a symbol of ABS-CBN's quality, 

reputation, and good will and has never been abandoned. 

24. ABS-CBN is the also the owner and/or the exclusive licensee of copyrights 

registered in the United States and in the Philippines in connection with the production and 

distribution of audio-visual content, including in the TV shows and movies in Exhibit I. 

25. ABS-CBN is the largest media and entertainment company in the Philippines. All 

of Plaintiffs' TV shows and movies are initially aired through its broadcast facilities or regional 

theaters in the Philippines. Simultaneous with, or after that original broadcast, Plaintiffs Filipinocentric content is then distributed throughout the world via customer-paid subscriptions, including 

through numerous cable companies' premium channels and telecom provider partnerships, such as 

with DirecTV, Time Warner Cable, Cox Communications, Comcast, AT&T, Verizon Services 

Corp., Braintree Cable, Cablevision, CC Communications, Centurytel, Champion Broadband, 

Charter, Duncan Cable TV, En-Touch, Frontier Communications, GCI Cable, Golden Rain 

Foundation, Groton Utilities, Hawaiian Telecom, !Cable, KPU CommVision, MCV, MTA 

Communications, Norwood Light Dept., OpenBand Media, OSN, Phonoscope, Rainier Cable TV, 

RCN, Rogers, San Bruno Cable, Service Electric, Shaw, Starhub, Summit Broadband, Sure West, 

Tacoma Public Utilities, TVMax, Wave Broadband, Windjammer Cable, Zito Media, and many 

more, including, in Oregon, Comcast and Wave Broadband. 

26. In addition, Plaintiffs' content is distributed by Plaintiffs through Internet 

subscription services, such as TFC.TV and IWANTV.COM.PH, as well as through their own 24-

hour cable and satellite service TFC (The Filipino Channel) and TFC IPTV, which offers PayPer-View programming. Most recently, on July 15,2014, ABS-CBN launched its new TFC.TV 

design. The redesigned portal is meant to provide its customers with improved navigation and 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 7 of 65
easier access to the latest ABS-CBN shows and content. In addition, the roll out is meant to 

effect changes in the Subscription Packages previously offered, including to implement a new 

Premium subscription package, which includes over 160+ Entertainment shows, 50+ News 

shows, 8+ Live shows, and 300+ Movies. 

27. ABS-CBN creates and distributes content serving Filipinos (aka "Pinoys") 

worldwide. This includes the populace of the Philippines, estimated at 92.3 million persons, as 

well as the substantial overseas community, which is estimated at between 10.5 million and 13.5 

million persons. See http://www.census.gov.ph/; http://en.wikipedia.org/wiki/Overseas_Filipino. 

Countries with significant resident Filipino populations overseas include: United States 

(3,494,281 persons); Saudi Arabia (1 ,267,658); UAE (931 ,562); Canada (852,401 ); Malaysia 

(686,547); Australia (391 ,705); Japan (243,136); United Kingdom (218,777); Kuwait (213,638); 

Qatar (200,016); Hong Kong (195,128); Singapore (184,498); and Italy (172,148). !d.; see also 

Commission on Filipinos Overseas, Stock Estimate of Overseas Filipinos (as of Dec. 20 12) 

(http://cfo.gov.ph/images/stories/pdf/20 12 _Stock_ Estimate_ of_ Filipinos_ Overseas.pdf). 

28. The United States hosts the largest population of Filipinos outside the Philippines. 

!d. Filipinos are estimated by the U.S. State Department to be the second-largest AsianAmerican group in the country. See http://en.wikipedia.org/wiki/Overseas_Filipino; U.S. 

Department of State, U.S. Relations With the Philippines, Bureau of East Asian and Pacific 

Affairs Fact Sheet (Jan. 31, 2014) (http://www.state.gov/r/palei/bgn/2794.htm). In addition, 

Tagalog is the fifth most spoken language in the U.S. See 

http :1 /en. wikipedia.org/wiki/Overseas _Filipino. 

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THE DEFENDANTS 

29. Defendant JEFFREY ASHBY is a resident ofthe State of Oregon. On 

information and belief, Defendant JEFFREY ASHBY is the registrant, owner and/or operator of 

the Subject Domain Names and associated websites. 

30. Defendant LENIE ASHBY is a resident ofthe State of Oregon. On information 

and belief, Defendant LENIE ASHBY is the registrant, owner and/or operator of the Subject 

Domain Names and associated websites. 

31. On information and belief, the Individual Defendants are doing business as and 

through the Subject Domain Names. 

32. The Individual Defendants personally directed and participated in, exercised 

control over, and benefited from the specific infringing and infringement-inducing conduct 

described herein, which resulted in the massive infringement of Plaintiffs' copyrights and 

trademarks. This includes, but is not limited to, operating the websites to profit from their 

infringing activities; doing so in a way intended to frustrate enforcement efforts through the use 

of false aliases; and by not implementing readily-available technologies and procedures to 

mitigate the infringement. 

33. Defendants have the capacity to be sued pursuant to Federal Rule of Civil 

Procedure 17(b). Defendants target their business activities, in part, towards consumers 

throughout the United States, including within this District, through the operation of their fully 

interactive commercial websites operating under the Subject Domain Names. Defendants are 

directly and personally contributing to, inducing and engaging in trademark and copyright 

infringement, without license or authorization. 

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34. ABS-CBN is presently·unaware ofthe true names of Does 1-100 and will amend 

this Complaint upon discovery of the identities of such fictitious Defendants. 

35. Defendants are the past and present conscious forces behind the operation of the 

commercial Internet websites operating under the Subject Domain Names. 

36. Upon information and belief, Defendants will continue to register, transfer, or 

acquire new domain names for the purpose of infringing Plaintiffs' trademarks and copyrights 

unless preliminarily and permanently enjoined. 

37. Defendants use and have registered, established or purchased and maintained the 

Subject Domain Names and the websites operating thereunder. Upon information and belief, 

Defendants have knowingly provided or knowingly caused to be provided materially false 

contact information to a domain name registrar, domain name registry, or other domain name 

registration authority in registering, maintaining, or renewing a domain name used in connection 

with the infringement. Upon information and belief, Defendants have anonymously registered 

and maintained the Subject Domain Names for the sole purpose of evading liability for their 

illegal activities. 

38. Defendants' business names (i.e., the Subject Domain Names and any other 

domain names used in connection with infringing Plaintiffs' trademarks and copyrights), are 

essential components of Defendants' infringing activities. The Subject Domain Names 

themselves are a significant part of the means by which Defendants further their infringing 

scheme and cause harm to ABS-CBN in that they cause and effect the infringement as described 

below. 

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FACTUAL ALLEGATIONS 

A. Defendants' Domains and Associated Websites. 

39. Defendants are infringing ABS-CBN's trademarks and copyrights through their 

copying, use, promotion, and/or performance of ABS-CBN's TV shows and movie content. 

40. Defendants operate their websites that serve only one purpose -to function as 

commercial online hubs for publicly providing performances of popular copyrighted content, 

including many of Plaintiffs' copyrighted works, over the Internet to many thousands of users, 

without authorization or license. 

41. On information and belief, Defendant JEFFREY ASHBY is personally and 

directly responsible for copying and uploading ABS-CBN's content to servers from which TV 

and movie videos are performed through Defendants' and many other pirate sites. 

42. In addition, Defendants infringe, and induce, cause and/or materially contribute to 

the infringing activity of others, inter alia, by: 

(i) advertising and promoting the presence and availability of ABS-CBN's content 

through 

(a) the text on their websites, including stating the TV shows and movies 

are "free," 

(b) through the use of Plaintiffs' trademarks and specific identification of 

shows and movies as ABS-CBN's, 

(c) through social media advertising, such as on Facebook and Twitter, 

including links to the infringing sites, 

(d) search engine optimization and meta tags, and 

(e) through the names ofthe domains themselves; 

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(ii) organizing ABS-CBN's content by show title to provide ready access by 

viewers to hundreds or thousands of ABS-CBN's program episodes through 

menus and folders; 

(iii) inserting the links on their websites directing users where to view the content 

and through which users can download the content; 

(iv) transmitting and facilitating the transmission of the infringing content for 

viewing by users of the websites; 

(v) on a daily basis, updating their inventory of content, often within minutes or 

hours of the broadcast in the Philippines, in order to tap into the known market for 

pirate Filipino-centric content and constantly feed consumers' desire for that 

content; and, 

(vi) by promoting and providing the content in order to drive more traffic to 

Defendants' websites and thereby increase the profits Defendants reap from 

advertising and other revenue sources. 

43. Defendants infringe, and induce, cause and/or materially contribute to the 

infringing activity of their users by promoting the presence and availability of Filipino content 

and, specifically, ABS-CBN's content, through their websites, social media, and through search 

engine optimization and metatags. For example, the coding underlying the 

WEBPINOYTAMBAYAN.COM site contains meta tags (aka "Keywords"), including 

specifically identifying ABS-CBN, which are designed to boost the site's relevance, and thus its 

rank in search engines: 

<meta name="description" content="" /><meta name="keywords" 

content="Pinoy Tambayan- Watch Pinoy Channels and Watch all the best TV 

Series from ABS-CBN, GMA 7, TV 5, Studio 23 and all the best Pinoy Teleserye 

Telenovela - Filipino stuff Online for Free! "/> 

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44. Defendants perform Plaintiffs' works through their websites as part of a large 

scale and ongoing illegal enterprise and/or effectuate and materially contribute to the 

performance of Plaintiffs' works by third parties. On information and belief, Defendants also 

copy and/or distribute Plaintiffs' works and/or effectuate and materially contribute to the copying 

and/or distribution of Plaintiffs' works by third parties. 

45. Because Defendants operate the infringing websites and broadcast the content, 

they could stop the infringement at any point. In addition, Defendants also could easily 

implement various readily available and effective technological solutions (including, without 

limitation, automated filtering using digital fingerprinting-based content-identification 

technology) to identify and prevent infringement of copyrighted content. 

46. However, Defendants do not implement means to prevent infringement because to 

do so would defeat the very purpose for which the Subject Domain Names and associated 

websites exist- i.e., to transmit copyrighted TV shows and movies associated with the 

trademarks of the largest media company in the Philippines. 

B. The Individual Infringing Domains and Associated Websites. 

Domain 1: WEBPINOYTAMBAYAN.COM 

47. The WEBPINOYTAMBA Y AN.COM domain is registered through the registrar 

Intemet.bs. The domain is registered through a proxy/privacy registration service, such, that the 

identity of the registrant is hidden. 

48. The domain was previously registered through the registrar GoDaddy until 

July 25, 2014, when it was transferred to registrar Intemet.bs following Plaintiffs' notice that the 

domain was infringing Plaintiffs' rights. 

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49. This domain is linked to at least five of the other domains identified herein 

because the html source code for the website located at WWW.WEBPINOYTAMBA Y AN.COM 

shows the individual scripts provided by the ad networks operating on the site. Within the script 

are links, images and unique tracking codes. These unique identifiers are provided to customers 

to embed within the code of their site. The unique tracking code is used by the ad network to 

attribute revenue to a particular customer. The account number of this site is associated with a 

list of"approved URLs" for this account, including: WEBPINOYTAMBAYAN.COM, 

PINOYTALAGA.COM, WATCHFILIPINOTV.COM, PINOYTVEPISODES.NET, PINOYTVKO.COM, and PINOY-TUBE.COM. 

50. On information and belief, WEBPINOYTAMBA Y AN.COM and the other 

Subject Domain Names are all registered, owned and/or operated by Defendants. 

51. WEBPINOYTAMBA Y AN.COM advertises Plaintiffs' works to the public, 

including through the use of Plaintiffs' trademarks. WEBPINOYTAMBAYAN.COM uses the 

ABS-CBN Marks and/or Common Law Mark, without authorization, to attract consumer traffic 

to its websites and promote the infringing video content viewed thereon. 

52. Further, WEBPINOYTAMBA Y AN.COM uses the ABS-CBN Marks and/or 

Common Law Mark, without authorization, to falsely suggest the infringing video content viewed 

on the websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

53. The WEBPINOYTAMBA Y AN.COM website performs Plaintiffs' copyrighted 

works, including, on information and belief, registered and unregistered works. 

54. On information and belief, WEBPINOYTAMBAYAN.COM is a "closed 

website" meaning that it does not allow users to make additions or changes to the site. On 

information and belief, the content performed on the WEBPINOYTAMBA Y AN.COM website 

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is provided by the website's operators. On information and belief, the operators of 

WEBPINOYTAMBAYAN.COM also insert the links provided on the website through which 

users view Plaintiffs' video content in a player window on the site. When a user clicks on the 

link to one of Plaintiffs' TV shows or movies, WEBPINOYTAMBA Y AN.COM then plays the 

full-length version of the video. 

55. For example, the copyright registered episode of the ABS-CBN show "Be Careful 

With My Heart" is available for viewing at: http:l/webpinoytambayan.com/2014/05/be-carefulwith-my-heart-15-may-20 14.html. When a user clicks, the WEBPINOYT AMBA Y AN.COM 

website begins to transmit the full episode for viewing. 

56. On information and belief, the large inventory of popular entertainment content 

available at WEBPINOYTAMBAYAN.COM is provided in order to attract users to the 

infringing content. By advertising, promoting and performing the copyrighted works, and 

encouraging, facilitating and assisting in the viewing of the TV shows and movies, 

WEBPINOYTAMBA YAN.COM attracts an estimated 53,331 page views each day. 

57. WEBPINOYTAMBA Y AN.COM provides full-length copies of daily 

programming and archived shows - all available at the click of a button and often made available 

within minutes or hours of the original broadcast. For example, within 41 minutes of the 

August 3, 2014 episode of ABS-CBN's "Be Careful With My Heart" airing in the Philippines, 

the show was available for viewing at WEBPINOYTAMBA Y AN.COM. 

58. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

revenues and enables WEBPINOYTAMBAYAN.COM to charge advertisers higher rates, and 

reap significant profits from the advertising services operating on the site. Moreover, the 

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wrongfully obtained consumer traffic increases the value of the Subject Domain Names 

themselves, including WEBPINOYTAMBA Y AN.COM. In these ways, the websites' business 

model, including specifically that ofWEBPINOYTAMBAYAN.COM, critically depends on 

attracting users to view Plaintiffs' highly-valued copyrighted works. 

59. On information and belief, in order to drive traffic to the website, 

WEBPINOYTAMBAYAN.COM advertises the website through social media such as Facebook 

at: https:/ /www. facebook.com/webpinoytambayan/info. 

Domain 2: WATCHFILIPINOTV.COM 

60. The WATCHFILIPINOTV.COM domain is registered through the registrar 

eNom. The domain is registered through a proxy/privacy registration service, such that the 

identity of the registrant is hidden. The domain utilizes CloudFlare, which is a proxy hosting 

service that hides the identity of the website's true host. 

61. TheW ATCHFILIPINOTV.COM domain was previously registered through the 

registrar GoDaddy until June 13, 2014, when it was transferred following Plaintiffs' notice to 

GoDaddy that the domain was infringing Plaintiffs' rights. The domain was falsely registered 

with GoDaddy to "John Stephanopolis I 123 Main Street, Gary, IN" with the email address 

"pezman077@hotmail.com." The same registrant also falsely registered the domain 

WATCHFILIPINOMOVIES.COM to "John Stephanopoulos I 123 Main Street, Gary, IN" using 

a slightly different spelling, but the same fictitious address and, in this instance, with the email 

address "pezman077@yahoo.com." These patently bogus registrations are known to be false 

because when Plaintiffs sent takedown notices pursuant to the Digital Millennium Copyright Act 

("DMCA") to the company Namecheap, which was believed to be the host for these domains, 

Namecheap revealed the registrant's true identity as Defendant JEFFREY ASHBY, at the 

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address 16989 SW 123rd Ave., Tigard, OR 97224, with the pezman077@hotmail.com email 

address. On information and belief, Defendant JEFFREY ASHBY is the owner of the email 

addresses used to falsely register these domains and his email address has been linked to other 

domains at issue in this Complaint. 

62. Domains 1, 2, 4, 6, 8, and 11 are connected as stated in Paragraph 49 ofthis 

Complaint. 

63. On information and belief, WATCHFILIPINOTV.COM and the other Subject 

Domain Names are all registered, owned and/or operated by Defendants. 

64. W ATCHFILIPINOTV.COM advertises Plaintiffs' works to the public, including 

through the use ofPlaintiffs' trademarks. WATCHFILIPINOTV.COM uses the ABS-CBN 

Marks and/or Common Law Mark, without authorization, to attract consumer traffic to its 

websites and promote the infringing video content viewed thereon. 

65. Further, W ATCHFILIPINOTV.COM uses the ABS-CBN Marks and/or Common 

Law Mark, without authorization, to falsely suggest the infringing video content viewed on the 

websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

66. The WATCHFILIPINOTV.COM website performs Plaintiffs' copyrighted works, 

including, on information and belief, registered and unregistered works. 

67. On information and belief, WATCHFILIPINOTV.COM is a "closed website" 

meaning that it does not allow users to make additions or changes to the site. On information 

and belief, the content performed on theW ATCHFILIPINOTV.COM website is provided by the 

website's operators. On information and belief, the operators ofWATCHFILIPINOTV.COM 

also insert the links provided on the website through which users view Plaintiffs' video content 

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in a player window on the site. When a user clicks on the link to one of Plaintiffs' TV shows or 

movies, W ATCHFILIPINOTV.COM then plays the full-length version of the video. 

68. For example, the copyright registered episode of the ABS-CBN show "Be Careful 

With My Heart" is available for viewing at: http:l/watchfilipinotv.com/2014/05/be-careful-withmy-heart-may-15-2014/. When a user clicks, theW ATCHFILIPINOTV.COM website begins to 

transmit the full episode for viewing. 

69. On information and belief, the large inventory of popular entertainment content 

available at W ATCHFILIPINOTV.COM is provided in order to attract users to the infringing 

content. By advertising, promoting and performing the copyrighted works, and encouraging, 

facilitating and assisting in the viewing of the TV shows and movies, 

WATCHFILIPINOTV.COM attracts an estimated 9,031 page views each day. 

70. W ATCHFILIPINOTV.COM provides full-length copies of daily programming 

and archived shows- all available at the click of a button and often made available within 

minutes or hours of the original broadcast. For example, within 53 minutes of the August 3, 

2014 episode of ABS-CBN's "Be Careful With My Heart" airing in the Philippines, the show 

was available for viewing at WATCHFILIPINOTV.COM. 

71. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

revenues and enables W ATCHFILIPINOTV.COM to charge advertisers higher rates, and reap 

significant profits from the advertising services operating on the site. Moreover, the wrongfully 

obtained consumer traffic increases the value of the Subject Domain Names themselves, 

including WATCHFILIPINOTV.COM. In these ways, the websites' business model, including 

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specifically that ofW ATCHFILIPINOTV.COM, critically depends on attracting users to view 

Plaintiffs' highly-valued copyrighted works. 

72. On information and belief, in order to drive traffic to the website, 

WATCHFILIPINOTV.COM advertises the website through social media such as Facebook at: 

https://www.facebook.com/pages/WatchFilipinoTVcom/ and Twitter at 

https:/ /twitter.com/WatchF ilipino TV. 

Domain 3: WATCHFILIPINOMOVIES.COM 

73. The WATCHFILIPINOMOVIES.COM domain is registered through the registrar 

eN om. The domain is registered through a proxy/privacy registration service, such that the 

identity of the registrant is hidden. The domain utilizes CloudFlare, which is a proxy hosting 

service that hides the identity of the website's true host. 

74. The WATCHFILIPINOMOVIES.COM domain was previously registered through 

the registrar GoDaddy until June 20, 2014, when it was transferred to registrar eN om following 

Plaintiffs' notice to GoDaddy that the domain was infringing Plaintiffs' rights. The domain was 

falsely registered by Defendant JEFFREY ASHBY as stated in Paragraph 61 of this Complaint. 

75. On information and belief, W ATCHFILIPINOMOVIES.COM and the other 

Subject Domain Names are all registered, owned and/or operated by Defendants. In addition, 

WATCHFILIPINOMOVIES.COM automatically redirects users when they click on TV show 

content to Domain 2, Defendants' WATCHFILIPINOTV.COM. 

76. WATCHFILIPINOMOVIES.COM advertises Plaintiffs' works to the public, 

including through the use of Plaintiffs' trademarks. WATCHFILIPINOMOVIES.COM uses the 

ABS-CBN Marks and/or Common Law Mark, without authorization, to attract consumer traffic 

to its websites and promote the infringing video content viewed thereon. 

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77. Further, WATCHFILIPINOMOVIES.COM uses the ABS-CBN Marks and/or 

Common Law Mark, without authorization, to falsely suggest the infringing video content viewed 

on the websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

78. The WATCHFILIPINOMOVIES.COM website performs Plaintiffs' copyrighted 

works, including, on information and belief, registered and unregistered works. 

79. On information and belief, WATCHFILIPINOMOVIES.COM is a "closed website" 

meaning that it does not allow users to make additions or changes to the site. On information and 

belief, the content performed on theW ATCHFILIPINOMOVIES.COM website is provided by the 

website's operators. On information and belief, the operators ofWATCHFILIPINOMOVIES.COM 

also insert the links provided on the website through which users view Plaintiffs' video content in a 

player window on the site. When a user clicks on the link to one of Plaintiffs' movies, 

WATCHFILIPINOMOVIES.COM then plays the full-length version of the video. 

80. For example, the copyright registered ABS-CBN movie "Bakit Hindi ka Crush ng 

Crush Mo" is available for viewing at: http://www.watchfilipinomovies.com/bakit-hindi-kacrush-ng-crush-mo/. When a user clicks, theW ATCHFILIPINOMOVIES.COM website begins 

to transmit the full episode for viewing. In addition, when a user clicks on the "Pinoy TV 

Shows" tab on W ATCHFILIPINOMOVIES.COM, the user is automatically redirected to the 

W ATCHFILIPINOTV.COM site. 

81. On information and belief, the large inventory of popular entertainment content 

available at W ATCHFILIPINOMOVIES.COM is provided in order to attract users to the 

infringing content. By advertising, promoting and performing the copyrighted works, and 

encouraging, facilitating and assisting in the viewing of the movies, 

WATCHFILIPINOMOVIES.COM attracts an estimated 23,769 page views each day. 

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82. W ATCHFILIPINOMOVIES.COM provides full-length copies of daily 

programming and archived shows - all available at the click of a button and often made available 

within minutes or hours of the original broadcast. 

83. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

revenues and enables WATCHFILIPINOMOVIES.COM to charge advertisers higher rates, and 

reap significant profits from the advertising services operating on the site. Moreover, the 

wrongfully obtained consumer traffic increases the value of the Subject Domain Names 

themselves, including WATCHFILIPINOMOVIES.COM. In these ways, the websites' business 

model, including specifically that ofWATCHFILIPINOMOVIES.COM, critically depends on 

attracting users to view Plaintiffs' highly-valued copyrighted works. 

84. On information and belief, in order to drive traffic to the website, 

W ATCHFILIPINOMOVIES.COM advertises the website through social media such as 

Facebook at: https:/ /www .facebook.com/pages/Watch-Filipino-Movies. 

Domains 4 & 5: PINOY-TVKO.COM and PINOYTVKO.BIZ 

85. The PINOY-TVKO.COM domain is registered through the registrar Intemet.bs. 

The domain is registered through a proxy/privacy registration service, such that the identity of 

the registrant is hidden. 

86. The domain was previously registered through the registrar NetEarth until July 7, 

2014, when it was transferred to registrar Intemet.bs following Plaintiffs' notice to NetEarth that 

the domain was infringing Plaintiffs' rights. 

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87. The domain now redirects to PINOYTVKO.BIZ. When one goes to the PINOYTVKO.COM domain, their browser is automatically redirected to the PINOYTVKO.BIZ domain 

and infringing website. 

88. PINOYTVKO.BIZ was registered through the registrar Intemet.bs on July 6, 

2014. The domain is registered through a proxy/privacy registration service, such that the 

identity of the registrant is hidden. The domain utilizes CloudFlare, which is a proxy hosting 

service that hides the identity of the website's true host. 

89. Domains 1, 2, 4, 6, 8, and 11 are connected as stated in Paragraph 49 of this 

Complaint; Domain 4 (PINOY-TVKO.COM) redirects users, i.e., automatically sends all of its 

traffic, to Domain 5 (PINOYTVKO.BIZ). 

90. On information and belief, PINOYTVKO.BIZ and the other Subject Domain 

Names are all registered, owned and/or operated by Defendants. 

91. PINOYTVKO.BIZ advertises Plaintiffs' works to the public, including through 

the use of Plaintiffs' trademarks. PINOYTVKO.BIZ uses the ABS-CBN Marks and/or Common 

Law Mark, without authorization, to attract consumer traffic to its websites and promote the 

infringing video content viewed thereon. 

92. Further, PINOYTVKO.BIZ uses the ABS-CBN Marks and/or Common Law 

Mark, without authorization, to falsely suggest the infringing video content viewed on the 

websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

93. The PINOYTVKO.BIZ website performs Plaintiffs' copyrighted works, 

including, on information and belief, registered and unregistered works. 

94. On information and belief, PINOYTVKO.BIZ is a "closed website" meaning that 

it does not allow users to make additions or changes to the site. On information and belief, the 

Page 22 - COMPLAINT 

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content performed on the PINOYTVKO.BIZ website is provided by the website's operators. On 

information and belief, the operators ofPINOYTVKO.BIZ also insert the links provided on the 

website through which users view Plaintiffs' video content in a player window on the site. When 

a user clicks on the link to one of Plaintiffs' TV shows or movies, PINOYTVKO.BIZ then plays 

the full-length version of the video. 

95. For example, the copyright registered episode of the ABS-CBN show "Kris TV" 

is available for viewing at: http://www.pinoytvko.biz/2014/05/kris-tv-16-may-2014/. When a 

user clicks, the PINOYTVKO.BIZ website begins to transmit the full episode for viewing. 

96. On information and belief, the large inventory of popular entertainment content 

available at PINOYTVKO.BIZ is provided in order to attract users to the infringing content. By 

advertising, promoting and performing the copyrighted works, and encouraging, facilitating and 

assisting in the viewing of the TV shows and movies, PINOYTVKO.BIZ attracts an estimated 

663 page views each day. 

97. PINOYTVKO.BIZ provides full-length copies of daily programming and 

archived shows- all available at the click of a button and often made available within minutes or 

hours ofthe original broadcast. For example, within 41 minutes ofthe August 3, 2014 episode 

of ABS-CBN's "Be Careful With My Heart" airing in the Philippines, the show was available for 

viewing at PINOYTVKO.BIZ. 

98. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising revenues 

and enables PINOYTVKO.BIZ to charge advertisers higher rates, and reap significant profits from 

the advertising services operating on the site. Moreover, the wrongfully obtained consumer traffic 

increases the value of the Subject Domain Names themselves, including PINOYTVKO.BIZ. In 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 23 of 65
these ways, the websites' business model, including specifically that ofPINOYTVKO.BIZ, 

critically depends on attracting users to view Plaintiffs' highly-valued copyrighted works. 

Domain 6: PINOY-TUBE.COM 

99. The PINOY-TUBE.COM domain is registered through the registrar GoDaddy. 

The domain is registered through a proxy/privacy registration service, such that the identity of 

the registrant is hidden. In addition, PINOY-TUBE. COM redirects users when they click on 

video content to Domain 7, Defendants' MYPINOYTUBETV.COM. 

100. Domains 1, 2, 4, 6, 8, and 11 are connected as stated in Paragraph 49 of this 

Complaint. 

101. On information and belief, PINOY-TUBE.COM and the other Subject Domain 

Names are all registered, owned and/or operated by Defendants. 

102. PINOY-TUBE.COM advertises Plaintiffs' works to the public, including through 

the use of Plaintiffs' trademarks. PINOY-TUBE.COM uses the ABS-CBN Marks and/or 

Common Law Mark, without authorization, to attract consumer traffic to its websites and 

promote the infringing video content viewed thereon. 

103. Further, PINOY-TUBE.COM uses the ABS-CBN Marks and/or Common Law 

Mark, without authorization, to falsely suggest the infringing video content viewed on the 

websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

104. The PINOY-TUBE.COM website performs Plaintiffs' copyrighted works, 

including, on information and belief, registered and unregistered works. 

105. On information and belief, PINOY-TUBE.COM is a "closed website" meaning 

that it does not allow users to make additions or changes to the site. On information and belief, 

the content performed on the PINOY-TUBE.COM website is provided by the website's 

Page 24 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 24 of 65
operators. On information and belief, the operators ofPINOY-TUBE.COM also insert the links 

provided on the website through which users view Plaintiffs' video content in a player window 

on the site. When a user clicks on the link to one of Plaintiffs' TV shows or movies, PINOYTUBE.COM then plays the full-length version of the video. 

106. For example, when a user clicks on the ABS-CBN copyright registered work 

"Be Careful With My Heart" on PINOY-TUBE. COM, the video begins to play at: 

http://www.mypinoytubetv.com/20 14/05/be-careful-with-my-heart-15-may-20 14/. 

107. On information and belief, the large inventory of popular entertainment content 

available at PINOY-TUBE. COM is provided in order to attract users to the infringing content. 

By advertising, promoting and performing the copyrighted works, and encouraging, facilitating 

and assisting in the viewing ofthe TV shows and movies, PINOY-TUBE.COM attracts an 

unknown number of page views each day. 

108. PINOY-TUBE.COM provides full-length copies of daily programming and 

archived shows - all available at the click of a button and often made available within minutes or 

hours of the original broadcast. For example, within 33 minutes of the August 3, 2014 episode 

of ABS-CBN's "Be Careful With My Heart" airing in the Philippines, the show was available for 

viewing at PINOY-TUBE.COM. 

109. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

revenues and enables PINOY-TUBE. COM to charge advertisers higher rates, and reap 

significant profits from the advertising services operating on the site. Moreover, the wrongfully 

obtained consumer traffic increases the value of the Subject Domain Names themselves, 

including PINOY-TUBE.COM. In these ways, the websites' business model, including 

Page 25 - COMPLAINT 

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specifically that ofPINOY-TUBE.COM, critically depends on attracting users to view Plaintiffs' 

highly-valued copyrighted works. 

Domain 7: MYPINOYTUBETV.COM 

110. The MYPINOYTUBETV.COM domain is registered through the registrar eNom. 

The domain is registered through a proxy/privacy registration service, such that the identity of 

the registrant is hidden. The domain utilizes CloudFlare, which is a proxy hosting service that 

hides the identity of the website's true host. 

111. The MYPINOYTUBETV.COM links to WEBPINOYTAMBA Y AN.COM in its 

source code. 

112. Domains 1, 2, 4, 6, 8, and 11 are connected as stated in Paragraph 49 of this 

Complaint. 

113. On information and belief, MYPINOYTUBETV.COM and the other Subject 

Domain Names are all registered, owned and/or operated by Defendants. 

114. MYPINOYTUBETV.COM advertises Plaintiffs' works to the public, including 

through the use ofPlaintiffs' trademarks. MYPINOYTUBETV.COM uses the ABS-CBN Marks 

and/or Common Law Mark, without authorization, to attract consumer traffic to its websites and 

promote the infringing video content viewed thereon. 

115. Further, MYPINOYTUBETV.COM uses the ABS-CBN Marks and/or Common 

Law Mark, without authorization, to falsely suggest the infringing video content viewed on the 

websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

116. The MYPINOYTUBETV.COM website performs Plaintiffs' copyrighted works, 

including, on information and belief, registered and unregistered works. 

Page 26- COMPLAINT 

' 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 26 of 65
117. On information and belief, MYPINOYTUBETV.COM is a "closed website" 

meaning that it does not allow users to make additions or changes to the site. On information 

and belief, the content performed on the MYPINOYTUBETV.COM website is provided by the 

website's operators. On information and belief, the operators ofMYPINOYTUBETV.COM also 

insert the links provided on the website through which users view Plaintiffs' video content in a 

player window on the site. When a user clicks on the link to one of Plaintiffs' TV shows or 

movies, MYPINOYTUBETV.COM then plays the full-length version of the video. 

118. For example, the copyright registered episode of the ABS-CBN show "Be Careful 

With My Heart," is available for viewing at: http://www.mypinoytubetv.com/2014/05/becareful-with-my-heart-15-may-2014/. When a user clicks, the MYPINOYTUBETV.COM 

website begins to transmit the full episode for viewing. 

119. On information and belief, the large inventory of popular entertainment content 

available at MYPINOYTUBETV.COM is provided in order to attract users to the infringing 

content. By advertising, promoting and performing the copyrighted works, and encouraging, 

facilitating and assisting in the viewing of the TV shows and movies, 

MYPINOYTUBETV.COM attracts an estimated 2,418 page views each day. 

120. MYPINOYTUBETV.COM provides full-length copies of daily programming and 

archived shows - all available at the click of a button and often made available within minutes or 

hours ofthe original broadcast. For example, within 33 minutes ofthe August 3, 2014 episode 

of ABS-CBN's "Be Careful With My Heart" airing in the Philippines, the show was available for 

viewing at MYPINOYTUBETV.COM. 

121. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 27 of 65
revenues and enables MYPINOYTUBETV.COM to charge advertisers higher rates, and reap 

significant profits from the advertising services operating on the site. Moreover, the wrongfully 

obtained consumer traffic increases the value of the Subject Domain Names themselves, 

including MYPINOYTUBETV.COM. In these ways, the websites' business model, including 

specifically that ofMYPINOYTUBETV.COM, critically depends on attracting users to view 

Plaintiffs' highly-valued copyrighted works. 

122. On information and belief, in order to drive traffic to the website, 

MYPINOYTUBETV.COM advertises the website through social media such as Facebook at: 

https://www.facebook.com/pages/Watch-Pinoy-TV/. 

Domain 8: PINOYTALAGA.COM 

123. The PINOYTALAGA.COM domain is registered through the registrar eNom. 

The domain is registered through a proxy/privacy registration service, such that the identity of 

the registrant is hidden. 

124. The domain was previously registered through the registrar GoDaddy until June 

13, 2014, when it was transferred to eNom following Plaintiffs' notice that the domain was 

infringing Plaintiffs' rights. 

125. Domains 1, 2, 4, 6, 8, and 11 are connected as stated in Paragraph 49 ofthis 

Complaint. 

126. On information and belief, PINOYTALAGA.COM and the other Subject Domain 

Names are all registered, owned and/or operated by Defendants. 

127. PINOYTALAGA.COM advertises Plaintiffs' works to the public, including 

through the use ofPlaintiffs' trademarks. PINOYTALAGA.COM uses the ABS-CBN Marks 

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and/or Common Law Mark, without authorization, to attract consumer traffic to its websites and 

promote the infringing video content viewed thereon. 

128. Further, PINOYTALAGA.COM uses the ABS-CBN Marks and/or Common Law 

Mark, without authorization, to falsely suggest the infringing video content viewed on the 

websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

129. The PINOYTALAGA.COM website performs Plaintiffs' copyrighted works, 

including, on information and belief, registered and unregistered works. 

130. On information and belief, PINOYTALAGA.COM is a "closed website" meaning 

that it does not allow users to make additions or changes to the site. On information and belief, 

the content performed on the PINOYTALAGA.COM website is provided by the website's 

operators. On information and belief, the operators ofPINOYTALAGA.COM also insert the 

links provided on the website through which users view Plaintiffs' video content in a player 

window on the site. When a user clicks on the link to one of Plaintiffs' TV shows or movies, 

PINOYTALAGA.COM then plays the full-length version of the video. 

131. For example, the copyright registered episode of the ABS-CBN show "Be Careful 

With My Heart," is available for viewing at: http:l/pinoytalaga.com/be-careful-with-my-heartmay-15-2014/. When a user clicks, the PINOYTALAGA.COM website begins to transmit the 

full episode for viewing. 

132. On information and belief, the large inventory of popular entertainment content 

available at PINOYTALAGA.COM is provided in order to attract users to the infringing content. 

By advertising, promoting and performing the copyrighted works, and encouraging, facilitating 

and assisting in the viewing ofthe TV shows and movies, PINOYTALAGA.COM attracts an 

estimated 3,753 page views each day. 

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133. PINOYTALAGA.COM provides full-length copies of daily programming and 

archived shows- all available at the click of a button and often made available within minutes or 

hours ofthe original broadcast. For example, within 90 minutes ofthe August 3, 2014 episode 

of ABS-CBN's "Be Careful With My Heart" airing in the Philippines, the show was available for 

viewing at PINOYTALAGA.COM. 

134. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

revenues and enables PINOYTALAGA.COM to charge advertisers higher rates, and reap 

significant profits from the advertising services operating on the site. Moreover, the wrongfully 

obtained consumer traffic increases the value of the Subject Domain Names themselves, 

including PINOYT ALAGA.COM. In these ways, the websites' business model, including 

specifically that ofPINOYTALAGA.COM, critically depends on attracting users to view 

Plaintiffs' highly-valued copyrighted works. 

Domain 9: PINOYSTREAMING.COM 

135. The PINOYSTREAMING.COM domain is registered through the registrar eNom. 

The domain is registered through a proxy/privacy registration service, such that the identity of 

the registrant is hidden. The domain was registered in Defendant JEFFREY ASHBY's name 

prior to becoming a hidden proxy registration. 

136. On information and belief, PINOYSTREAMING.COM and the other Subject 

Domain Names are all registered, owned and/or operated by Defendants. In addition, 

PINOYSTREAMING.COM automatically redirects users when they click on movie content on 

that site to Domain 3, Defendants' WATCHFILIPINOMOVIES.COM, and when users click on 

Page 30 - COMPLAINT 

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TV show content on PINOYSTREAMING.COM, they are automatically redirected to Domain 2, 

Defendants' WATCHFILIPINOTV.COM. 

137. PINOYSTREAMING.COM advertises Plaintiffs' works to the public, including 

through the use of Plaintiffs' trademarks. PINOYSTREAMING.COM uses the ABS-CBN 

Marks and/or Common Law Mark, without authorization, to attract consumer traffic to its 

websites and promote the infringing video content viewed thereon. 

138. Further, PINOYSTREAMING.COM uses the ABS-CBN Marks and/or Common 

Law Mark, without authorization, to falsely suggest the infringing video content viewed on the 

websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

139. The PINOYSTREAMING.COM website performs Plaintiffs' copyrighted works, 

including, on information and belief, registered and unregistered works. 

140. On information and belief, PINOYSTREAMING.COM is a "closed website" 

meaning that it does not allow users to make additions or changes to the site. On information 

and belief, the content performed on the PINOYSTREAMING.COM website is provided by the 

website's operators. On information and belief, the operators ofPINOYSTREAMING.COM 

also insert the links provided on the website through which users view Plaintiffs' video content 

in a player window on the site. When a user clicks on the link to one of Plaintiffs' TV shows or 

movies, PINOYSTREAMING.COM then plays the full-length version of the video. 

141. For example, when a user clicks on the ABS-CBN copyright registered work 

"She's The One" on PINOYSTREAMING.COM, the video begins to play at: 

http://www.watchfilipinomovies.com/shes-the-one/#.U-ESBeOSyYE. When a user clicks on the 

"Pinoy TV Shows" tab on PINOYSTREAMING.COM, the user is automatically redirected to 

the WATCHFILIPINOTV.COM site. 

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142. On information and belief, the large inventory of popular entertainment content 

available at PINOYSTREAMING.COM is provided in order to attract users to the infringing 

content. By advertising, promoting and performing the copyrighted works, and encouraging, 

facilitating and assisting in the viewing of the TV shows and movies, 

PINOYSTREAMING.COM attracts an unknown number of page views each day. 

143. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

revenues and enables PINOYSTREAMING.COM to charge advertisers higher rates, and reap 

significant profits from the advertising services operating on the site. Moreover, the wrongfully 

obtained consumer traffic increases the value of the Subject Domain Names themselves, 

including PINOYSTREAMING.COM. In these ways, the websites' business model, including 

specifically that ofPINOYSTREAMING.COM, critically depends on attracting users to view 

Plaintiffs' highly-valued copyrighted works. 

144. On information and belief, in order to drive traffic to the website, 

PINOYSTREAMING.COM advertises the website through social media, including through 

Facebook at the same page through which Defendants also advertise 

W A TCHFILIPINOMOVIES.COM, the website to which PINOYSTREAMING.COM redirects, 

at: https:/ /www. facebook.com/pages/Watch-Filipino-Movies/. 

Domain 10: PINOYMOVIEFAN.COM 

145. The PINOYMOVIEFAN.COM domain is registered through the registrar 

GoDaddy. The domain is registered to "Lenie Ashby I 16989 SW 123RD AVE I APT 5 I 

Portland I Oregon I 97224" with the email address "admin@sweetdreamspattems.com." 

Page 32 -COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 32 of 65
On information and belief, this is Defendant LENIE ASHBY and LENIE ASHBY is the owner 

ofthe associated email address. 

146. On information and belief, PINOYMOVIEFAN.COM and the other Subject 

Domain Names are all registered, owned and/or operated by Defendants. 

147. PINOYMOVIEFAN.COM advertises Plaintiffs' works to the public, including 

through the use ofPlaintiffs' trademarks. PINOYMOVIEFAN.COM uses the ABS-CBN Marks 

and/or Common Law Mark, without authorization, to attract consumer traffic to its websites and 

promote the infringing video content viewed thereon. 

148. Further, PINOYMOVIEFAN.COM uses the ABS-CBN Marks and/or Common 

Law Mark, without authorization, to falsely suggest the infringing video content viewed on the 

websites is authorized, genuine content approved, endorsed, and sponsored by the Plaintiffs. 

149. The PINOYMOVIEFAN.COM website performs Plaintiffs' copyrighted works, 

including, on information and belief, registered and unregistered works. 

150. On information and belief, PINOYMOVIEFAN.COM is a "closed website" 

meaning that it does not allow users to make additions or changes to the site. On information 

and belief, the content performed on the PINOYMOVIEFAN.COM website is provided by the 

website's operators. On information and belief, the operators ofPINOYMOVIEFAN.COM also 

insert the links provided on the website through which users view Plaintiffs' video content in a 

player window on the site. When a user clicks on the link to one of Plaintiffs' movies, 

PINOYMOVIEFAN.COM then plays the full-length version ofthe video. 

151. For example, ABS-CBN's movie "Maybe This Time" is available for viewing at: 

http://www.pinoymoviefan.com/maybe-this-time/. When a user clicks, the 

PINOYMOVIEF AN.COM website begins to transmit the full movie for viewing. 

Page 33 - COMPLAINT 

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152. On information and belief, the large inventory of popular entertainment content 

available at PINOYMOVIEFAN.COM is provided in order to attract users to the infringing 

content. By advertising, promoting and performing the copyrighted works, and encouraging, 

facilitating and assisting in the viewing ofthe movies, PINOYMOVIEFAN.COM attracts an 

unknown number of page views each day. 

153. On information and belief, the infringement-driven traffic increases the volume of 

online advertising impressions and transactions, and thereby increases online advertising 

revenues and enables PINOYMOVIEF AN.COM to charge advertisers higher rates, and reap 

significant profits from the advertising services operating on the site. Moreover, the wrongfully 

obtained consumer traffic increases the value of the Subject Domain Names themselves, 

including PINOYMOVIEFAN.COM. In these ways, the websites' business model, including 

specifically that ofPINOYMOVIEFAN.COM, critically depends on attracting users to view 

Plaintiffs' highly-valued copyrighted works. 

Domains 11 & 12: PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO 

154. The PINOYTVEPISODES.NET domain is registered through the registrar 

GoDaddy. The domain is registered through a proxy/privacy registration service, such that the 

identity of the registrant is hidden. The domain utilizes CloudFlare, which is a proxy hosting 

service that hides the identity of the website's true host. The PINOYTVEPISODES.INFO 

domain is registered through the registrar GoDaddy. The domain is registered through a 

proxy/privacy registration service, such that the identity of the registrant is hidden. 

155. Domains 1, 2, 4, 6, 8, and 11 are connected as stated in Paragraph 49 ofthis 

Complaint; Domain 11 (PINOYTVEPISODES.NET) infringed Plaintiffs' trademarks and 

copyrights as stated below, and later redirected users, i.e., automatically sent all of its traffic, to 

Page 34 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 34 of 65
Domain 12 (PINOYTVEPISODES.INFO), which itself infringed Plaintiffs' trademarks and 

copyrights as stated below. 

156. On information and belief, PINOYTVEPISODES.NET and 

PINOYTVEPISODES.INFO and the other Subject Domain Names are all registered, owned 

and/or operated by Defendants. 

157. PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO advertised 

Plaintiffs' works to the public, including through the use of Plaintiffs' trademarks. 

PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO used the ABS-CBN Marks and/or 

Common Law Mark, without authorization, to attract consumer traffic to their websites and 

promote the infringing video content viewed thereon. 

158. Further, PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO used the 

ABS-CBN Marks and/or Common Law Mark, without authorization, to falsely suggest the 

infringing video content viewed on the websites was authorized, genuine content approved, 

endorsed, and sponsored by the Plaintiffs. 

159. The PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO websites 

performed many of Plaintiffs' copyrighted works including, on information and belief, registered 

and unregistered works. 

160. On information and belief, PINOYTVEPISODES.NET and 

PINOYTVEPISODES.INFO were "closed websites" meaning that they did not allow users to make 

additions or changes to the site. On information and belief, the content performed on the 

PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO websites was provided by the 

websites' operators. On information and belief, the operators ofPINOYTVEPISODES.NET and 

PINOYTVEPISODES.INFO also inserted the links provided on the websites through which users 

Page 35 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 35 of 65
viewed Plaintiffs' video content in a player window on the sites. On information and belief, when a 

user clicked on the link to one of Plaintiffs' TV shows or movies, PINOYTVEPISODES.NET and 

PINOYTVEPISODES.INFO then played the full-length version of the video. 

161. On information and belief, the large inventory of popular entertainment content 

available at PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO was provided in order 

to attract users to the infringing content. By advertising, promoting and performing the 

copyrighted works, and encouraging, facilitating and assisting in the viewing of the TV shows 

and movies, PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO attracted viewers and 

the infringement-driven traffic increased the volume of online advertising impressions and 

transactions, and thereby increased online advertising revenues, and enabled 

PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO to charge advertisers higher rates, 

and reap significant profits from the advertising services that operated on the sites. Moreover, 

the wrongfully obtained consumer traffic increased the value of the Subject Domain Names 

themselves, including PINOYTVEPISODES.NET and PINOYTVEPISODES.INFO. In these 

ways, the websites' business model critically depended on attracting users to view Plaintiffs' 

highly-valued copyrighted works. 

C. Efforts to Stop Defendants' Infringement Have Been Futile. 

162. To date, Plaintiffs' efforts to stop Defendants' infringement by contacting the 

hosting companies, service providers and/or registrars for the Defendants have proven futile. 

DMCA notices were sent to the hosts for domains where the host could be identified. However, 

DMCA notices are very limited in their effect, targeting only specific content, which can then be 

changed and replaced with other infringing content, if the notice is even complied with. Therefore, 

Plaintiffs also sent notices to the domain registrars. These notices stated that the registrar is to 

Page 36- COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 36 of 65
cancel or transfer the domain because, in each instance, the registrar's terms of service and/or 

registration agreement expressly provides that violation of applicable law, such as by trademark and 

copyright infringement, is a violation of the registrant's agreement subject to cancellation and/or 

transfer of the domains. Further, the notices to the registrars set forth the relevant requirements of 

the registrar's own binding policies, and of ICANN policies, as well a detailed listing of the 

domains, the works being infringed, the URL to the infringement for each site: 

Domain Domain Name Host Notice/Response Registrar 

Number Notice/Response 

6-02-14 DMCA to 5-19-14 DMCA to 

Highvelocity; no action ntemet.bs; no action 

aken aken 

~-06-14 DMCA to 6-17-14 notice of 

1 WEBPINOYTAMBA Y AN.COM INforce; no action taken breach of registrar 

o-16-14 DMCA to erms of 

AltusHost; no response use/registration 

agreement terms to 

GoDaddy; no action 

aken 

5-30-14 DMCA to 5-12-14 DMCA to 

GoDaddy; no action GoDaddy; no action 

aken aken 

6-06-14 DMCA to 6-17-14 notice of 

2 W A TCHFILIPINOTV.COM INamecheap; no action breach of registrar 

aken erms of 

6-30-14 DMCA to use/registration 

~1tusHost; no response agreement terms to 

GoDaddy; no action 

aken 

Page 37- COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 37 of 65
Domain Domain Name Host Notice/Response Registrar 

Number Notice/Response 

6-04-14 DMCA to 5-12-14 DMCA to 

GoDaddy; no action GoDaddy; GoDaddy 

aken suspends site, but site 

6-02-14 DMCA to lback up the next day 

CloudFlare; no action 5-16-14 GoDaddy 

aken advises that site 

6-09-14 DMCA to !moved back to 

~ltusHost; no response GoDaddy after being 

moved to another 

7-01-14 DMCA to tprovider; GoDaddy 3 W ATCHFILIPINOMOVIES.COM ~ltusHost; no response suspends site, but site 

active again within a 

few days 

6-17-14 notice of 

!breach of registrar 

erms of 

!Use/registration 

agreement terms to 

GoDaddy; no action 

aken 

6-03-14 DMCA to 7-03-14 notice of 

SoftLayer; no response !breach of registrar 

erms of 

4 PINOY-TVKO.COM juse/registration 

agreement terms to 

NetEarth One; no 

action taken 

Newly identified Newly identified 

5 PINOYTVKO.BIZ domain also associated domain also associated 

with Defendants with Defendants 

Newly identified Newly identified 

6 PINOY-TUBE.COM domain also associated domain also associated 

with Defendants with Defendants 

6-13-14 DMCA to 6-30-14 notice of 

CloudFlare; no action breach of registrar 

7 MYPINOYTUBETV.COM aken erms of 

6-17-14 DMCA to use/registration 

Sentris; no action taken agreement terms to 

eNom; no action taken 

Page 38 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 38 of 65
Domain Domain Name Host Notice/Response Registrar 

Number Notice/Response 

5-30-14 DMCA to 5-12-14 DMCA to 

GoDaddy; no action GoDaddy; no action 

aken aken 

6-02-14 DMCA to 6-17-14 notice of 

8 PINOYTALAGA.COM :AltusHost; no response !breach of registrar 

6-19-14 follow-up letter erms of 

o AltusHost; no tuse/registration 

esponse agreement terms to 

GoDaddy; no action 

aken 

Newly identified Newly identified 

9 PINOYSTREAMING.COM domain also associated domain also associated 

with Defendants with Defendants 

Newly identified Newly identified 

10 PINOYMOVIEF AN.COM domain also associated domain also associated 

with Defendants ~ith Defendants 

Newly identified Newly identified 

11 PINOYTVEPISODES.NET domain also associated domain also associated 

with Defendants ~ith Defendants 

Newly identified Newly identified 

12 PINOYTVEPISODES.INFO domain also associated ~amain also associated 

with Defendants ~ith Defendants 

163. All too frequently, this is the game to which rights holders are subjected by 

service providers in the Internet industry, such as the hosts and registrars, who attempt to avoid 

taking any action, even upon multiple, explicit notices of infringement. Worse, attempts to halt 

the infringement, such as those by Plaintiffs, are met with complete and utter disregard and 

contempt by pirates such as Defendants, who with impunity and without restriction, move to 

other registrars and hosts, as with several of the Subject Domain Names, and re-launch their 

infringing content. For these reasons, Plaintiffs have no recourse but to apply to this Court for 

relief, including injunctive relief to prevent Defendants from further infringing Plaintiffs' works 

through their current domains, as well through future domains. 

Page 39 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 39 of 65
CLAIMS FOR RELIEF 

Count One -- Trademark Counterfeiting and Infringement 

(Against All Defendants) 

164. Plaintiffs repeat and re-allege every allegation contained in paragraphs 1 through 

163 as though fully set forth herein. 

165. This is an action for trademark counterfeiting and infringement against 

Defendants based on their use of counterfeits, copies and/or colorable imitations of the ABSCBN Marks on their websites, which facilitates consumers' access to infringements of Plaintiffs' 

copyrighted materials (the "pirated content"). 

166. Specifically, Defendants are continually promoting and otherwise advertising 

their illegal broadcast distribution facilitation service using the ABS-CBN Marks, without 

authorization. 

167. Defendants' counterfeiting and infringing use of the ABS-CBN Marks is likely to 

cause and actually is causing confusion, mistake, and deception among members of the general 

public as to the origin and quality of the pirated content as well as the legitimacy of Defendants' 

illegal broadcast distribution facilitation service. 

168. Defendants' unlawful actions have caused and are continuing to cause 

unquantifiable damages to Plaintiffs and are unjustly enriching Defendants at Plaintiffs' expense. 

169. Defendants' above-described illegal actions constitute counterfeiting and 

infringement ofthe ABS-CBN Marks in violation of Plaintiffs' rights under Section 32 of the 

Lanham Act, 15 U.S.C. § 1114. 

170. Plaintiffs have suffered and will continue to suffer irreparable injury due to 

Defendants' above described activities if Defendants are not temporarily, preliminarily and 

permanently enjoined. 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 40 of 65
Count Two-- False Designation of Origin Pursuant to§ 43(a) of the Lanham Act 

(Against All Defendants) 

171. Plaintiffs repeat and re-allege every allegation contained in paragraphs 1 through 

170 as though fully set forth herein. 

172. Defendants' advertisement and promotion of their illegal distribution facilitation 

service for the pirated content is being conducted using exact copies of the ABS-CBN Marks and 

is widely advertised and promoted throughout the United States, including within many of 

Plaintiffs' important business markets such as the state of Oregon. 

173. Defendants are using the ABS-CBN Marks to advertise and promote their illegal 

distribution facilitation service for the pirated content in violation of Plaintiffs' intellectual 

property rights, and to intentionally confuse consumers into believing the pirated content and 

broadcast distribution facilitation service are sponsored and endorsed by Plaintiffs. Defendants' 

unauthorized use of the ABS-CBN Marks is designed to falsely suggest that their activities are 

sponsored and/or endorsed by Plaintiffs. Defendants' unlawful use of the ABS-CBN Marks is 

designed to make Defendants' service appear legitimate in order to attract a larger number of 

viewers which results in larger advertising revenues for the Defendants. 

174. Defendants, upon information and belief, have used in connection with their 

advertisement and promotion of their illegal broadcast distribution facilitation service, false 

designations of origin and false descriptions and representations, including words or symbols 

which tend to falsely describe or represent such distribution services and have facilitated access 

to the general viewing public with full knowledge of the falsity of such designations of origin 

and such descriptions and representations, all to Plaintiffs' detriment. 

175. Defendants have authorized infringing uses ofthe ABS-CBN Marks in the 

advertisement and promotion of Defendants' illegal broadcast distribution facilitation service for 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 41 of 65
pirated content. Defendants have misrepresented to members of the consuming public that the 

pirated content to which Defendants are facilitating access is genuine and authorized content of 

Plaintiffs, and that Defendants broadcast distribution facilitation service for such content is 

sponsored and/or endorsed by Plaintiffs. 

176. Additionally, Defendants are using counterfeits and infringements of the ABSCBN Marks in order to unfairly compete with Plaintiffs and others for space within search 

engine organic results, thereby depriving Plaintiffs of a valuable marketing tool which would 

otherwise be available to Plaintiffs and reducing the visibility of Plaintiffs' legitimate, genuine 

content on the World Wide Web. 

177. Defendants' above-described actions are in violation of Section 43(a) of the 

Lanham Act, 15 U.S.C. § 1125(a). 

178. Plaintiffs have no adequate remedy at law, and have sustained injury and damages 

caused by Defendants' conduct. Absent an entry of an injunction by this Court, Plaintiffs will 

continue to suffer irreparable injury to their goodwill and business reputation, as well as 

monetary damages. 

Count Three -- Common Law Unfair Competition 

(Against All Defendants) 

179. Plaintiffs repeat and re-allege every allegation contained in paragraphs 1 through 

178 as though fully set forth herein. 

180. This is an action against Defendants based on their (i) promotion, advertisement, 

distribution, and facilitation of access to the pirated content using marks which are identical, both 

visually and phonetically, to the ABS-CBN Marks, and (ii) creation and maintenance of an illegal 

ongoing forum in which viewers may access public performances of and copy the pirated content, 

Page 42 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 42 of 65
operating parallel to Plaintiffs' own Internet pay subscription service through which Plaintiffs 

promote their genuine content, in violation of Oregon's common law ofunfair competition. 

181. Specifically, and as described above, Defendants are promoting, advertising and 

otherwise facilitating access to and copying of the pirated content using Plaintiffs' ABS-CBN 

Marks for the purpose of creating a veneer oflegitimacy for Defendants' operation. Also, for the 

purpose of earning a profit at the Plaintiffs' expense, Defendants are using counterfeits and 

infringements of the ABS-CBN Marks to unfairly compete with Plaintiffs and others for (i) space in 

search engine results across an array of search terms, and (ii) visibility on the World Wide Web. 

182. Plaintiffs are suffering damages and irreparable injury as a result of the 

Defendants' wrongful actions. 

Count Four -- Direct Infringement of Copyright 

(Against All Defendants) 

183. Plaintiffs repeat and reallege every allegation contained in paragraphs 1 through 

182 as if fully set forth herein. 

184. Plaintiffs have registered and own or control the copyrights and/or exclusive 

rights under copyright in connection with TV shows and movies, including but not limited to the 

works identified in Exhibit 1. In addition, Plaintiffs are the owners of unregistered copyrights in 

numerous TV shows and movies first aired in the Philippines and made available and infringed 

by Defendants. 

185. Defendants perform Plaintiffs' works through their websites as part of a large 

scale and ongoing illegal enterprise and/or effectuate and materially contribute to the 

performance of Plaintiffs' works by third parties. 

186. Further, on information and belief, Defendant JEFFREY ASHBY is personally 

and directly responsible for copying and uploading ABS-CBN's content to servers and 

Page 43 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 43 of 65
performing, copying and distributing those works, in collaboration with Defendant LENIE 

ASHBY, through Defendants' and other pirate websites. 

187. On information and belief, Defendants also copy and/or distribute Plaintiffs' 

works and/or effectuate and materially contribute to the copying and/or distribution of Plaintiffs' 

works by third parties. 

188. Without authorization from any Plaintiff, or right under law, Defendants are 

directly liable for infringing Plaintiffs' copyrighted works pursuant to 17 U.S.C. §§ 106(1), (3) 

and/or (4). 

189. Defendants have actual and constructive knowledge, or should have knowledge, 

oftheir infringement ofPlaintiffs' copyrighted works for at least the reasons that: 

(i) Defendants insert and provide links to, organize by show title, and perform the 

infringing content, and do so for the purpose of users' viewing; 

(ii) Defendants advertise and promote the content, including through the use of 

Plaintiffs' marks, on the websites, through social media, through search engine 

optimization and meta tags, and through the domain names themselves; 

(iii) As the largest media and entertainment company in the Philippines, 

Plaintiffs' content is highly popular in Filipino communities and Defendants 

profit as a direct result of broadcasting that content; and, 

(iv) Because Defendants used false registration aliases and as a result of the 

multiple notices of infringement sent to Defendants' service providers as shown 

above, which caused Defendants multiple times to move Subject Domain Names 

in an effort to evade enforcement attempts. 

Page 44 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 44 of 65
190. The foregoing acts of infringement have been willful, intentional, and purposeful, 

in disregard of and indifferent to Plaintiffs' rights. 

191. As a direct and proximate result of Defendants' infringement of Plaintiffs' 

exclusive rights, Plaintiffs are entitled to damages as well as Defendants' profits pursuant to 

17 U.S.C. § 504(b). 

192. Alternatively, Plaintiffs are entitled to the maximum statutory damages, in the 

amount of$150,000 per infringement, pursuant to 17 U.S.C. § 504(c), or such other amount as 

may be proper pursuant to 17 U.S.C. § 504(c). 

193. Plaintiffs further are entitled to their attorneys' fees and full costs pursuant to 

17 U.S.C. § 505. 

194. In addition, because ofthe ongoing infringement of numerous of Plaintiffs' works 

and because the significant threat of future infringement as evidenced herein, injunctive relief 

against Defendants is necessary to stop the infringement through the Subject Domain Names, as 

well as through other domains owned now or in the future by the Defendants. 

Count Five -- Secondary Infringement of Copyright 

(Against All Defendants) 

195. Plaintiffs repeat and reallege every allegation contained in paragraphs 1 through 

194 as if fully set forth herein. 

196. Defendants perform Plaintiffs' works through their web sites as part of a large 

scale and ongoing illegal enterprise and/or effectuate and materially contribute to the 

performance of Plaintiffs' works by third parties. 

197. Further, on information and belief, Defendant JEFFREY ASHBY is personally 

and directly responsible for copying and uploading ABS-CBN's content to servers and 

performing, copying and distributing those works, in collaboration with Defendant LENIE 

Page 45 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 45 of 65
ASHBY, through Defendants' and other pirate websites and thus inducing, encouraging, and/or 

materially contributing to other infringers. 

198. On information and belief, Defendants also copy and/or distribute Plaintiffs' 

works and/or effectuate and materially contribute to the copying and/or distribution of Plaintiffs' 

works by third parties. 

199. Without authorization from any Plaintiff, or right under law, Defendants are 

directly liable for third-parties' infringement of Plaintiffs' copyrighted works pursuant to 

17 U.S.C. §§ 106(1), (3) and/or (4). 

200. Defendants have actual and constructive knowledge, or should have knowledge, 

of their infringement of Plaintiffs' copyrighted works for at least the reasons that: 

(i) Defendants insert and provide links to, organize by show title, and perform the 

infringing content, and do so for the purpose of users' viewing; 

(ii) Defendants advertise and promote the content, including through the use of 

Plaintiffs' marks, on the websites, through social media, through search engine 

optimization and meta tags, and through the domain names themselves; 

(iii) As the largest media and entertainment company in the Philippines, 

Plaintiffs' content is highly popular in Filipino communities and Defendants 

profit as a direct result ofbroadcasting that content; and, 

(iv) Because Defendants used false registration aliases and as a result ofthe 

multiple notices of infringement sent to Defendants' service providers as shown 

above, which caused Defendants multiple times to move Subject Domain Names 

in an effort to evade enforcement attempts. 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 46 of 65
201. Defendants infringe, and induce, cause and/or materially contribute to the 

infringing activity of others, inter alia, by: 

(i) advertising and promoting the presence and availability of ABS-CBN's content 

through 

(a) the text on their websites, including stating the TV shows and movies 

are "free", 

(b) the use of Plaintiffs' trademarks and specific identification of shows 

and movies as ABS-CBN's, 

(c) social media advertising, such as on Facebook and Twitter, including 

links to the infringing sites, 

(d) search engine optimization and meta tags, and 

(e) the names ofthe domains themselves; 

(ii) organizing ABS-CBN's content by show title to provide ready access by 

viewers to hundreds or thousands of ABS-CBN's program episodes through 

menus and folders; 

(iii) inserting the links on their websites directing users where to view the content 

and through which users can download the content; 

(iv) transmitting and facilitating the transmission of the infringing content for 

viewing by users of the websites; 

(v) on a daily basis, updating their inventory of content, often within minutes or 

hours of the broadcast in the Philippines, in order to tap into the known market for 

pirate Filipino-centric content and constantly feed the consumers' desire for that 

content; and, 

Page 47- COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 47 of 65
(vi) promoting and providing the content, Defendants drive more traffic to their 

site and increase the profits they reap from advertising and other revenue. 

202. Defendants have the right and the ability to supervise and control their websites 

and others' infringing activity as set forth above. Because Defendants operate the infringing 

websites and broadcast the content, they could stop the infringement at any point. In addition, 

Defendants also could easily implement various readily available and effective technological 

solutions (including, without limitation, automated filtering using digital fingerprinting-based 

content-identification technology) to identify and prevent infringement of copyrighted content. 

203. Defendants derive a financial benefit directly attributable to their users' 

infringement of Plaintiffs' copyrights. Popular, copyrighted works act as a draw that attracts 

users and advertising to the Subject Domain Names and associated websites, resulting in 

revenues from ad impressions tied to page views, and other sources. 

204. Defendants have taken affirmative steps to foster infringement by providing the 

website and performing the content, viewed through video player embedded on their websites, 

with the object of promoting the illegal viewing of Plaintiffs' copyrighted TV shows and movies; 

by providing detailed programming directories, with the look and feel of television guides; by 

presenting the TV shows and movies in association with ABS-CBN's trademarks and by 

including images of the title pages of the shows; and by promoting the websites and their pirated 

content through the websites themselves, search engine optimization, and social media, such as 

Face book. 

205. Defendants do not merely respond to user requests in a passive, content-neutral, 

and automated manner. To the contrary, as set forth above, Defendants control the selection and 

provision of the content and are the sole causes making that content broadly available and 

Page 48 -COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 48 of 65
accessible to the public. Without the active and material contributions from Defendants, the 

massive infringement complained of herein could not have taken place. 

206. Defendants target the known demand for pirated versions of Plaintiffs' content in 

this District and throughout the world. 

207. Defendants are the direct and proximate causes of the harm to Plaintiffs alleged 

herein. 

208. The foregoing acts of infringement by Defendants have been willful, intentional, 

and purposeful, in disregard of and indifferent to Plaintiffs' rights. 

209. As a direct and proximate result of Defendants' and their users' infringement of 

Plaintiffs' exclusive rights, Plaintiffs are entitled to damages as well as Defendants' profits 

pursuant to 17 U.S.C. § 504(b ). 

210. Alternatively, Plaintiffs are entitled to the maximum statutory damages from 

Defendants, in the amount of$150,000 per infringement, pursuant to 17 U.S.C. § 504(c), or such 

other amount as may be proper pursuant to 17 U.S.C. § 504(c). 

211. Plaintiffs further are entitled to recover their attorneys' fees and full costs 

pursuant to 17 U.S.C. § 505. 

212. In addition, because of Defendants' ongoing infringement of numerous of 

Plaintiffs' works and because the significant threat of future infringement as evidenced herein, 

injunctive relief against Defendants is necessary to stop the infringement through the Subject 

Domain Names, as well as through other domains owned now or in the future by the Defendants. 

WHEREFORE, Plaintiffs pray for judgment against Defendants as follows: 

A. Entry of temporary, preliminary, and permanent injunctions pursuant to 15 U.S.C. 

§ 1116, 17 U.S.C. § 502(a), and Federal Rule of Civil Procedure 65 enjoining Defendants, their 

Page 49 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 49 of 65
agents, representatives, servants, employees, and all those acting in concert or participation 

therewith, including Internet search engines, Web hosts, domain-name registrars, and domain 

name registries or their administrators, from: 

( 1) advertising, promoting, performing, copying, broadcasting, performing, 

distributing and/or infringing in any manner ABS-CBN's copyrighted 

works and/or content that currently exists or which exists in the future; 

(2) infringing, counterfeiting, or diluting the ABS-CBN Marks, or any mark 

similar thereto, in connection with the advertisement, promotion, or 

distribution of pirated content; 

(3) using any logo, trade name or trademark or trade dress that may be 

calculated to falsely advertise the pirated content of Defendants as being 

sponsored by, authorized by, endorsed by, or in any way associated with 

Plaintiffs; 

( 4) falsely representing themselves as being connected with Plaintiffs, through 

sponsorship or association, or engaging in any act that is likely to falsely 

cause members of the public to believe any pirated content or services of 

Defendants are in any way endorsed by, approved by, and/or associated 

with Plaintiffs; 

(5) using any reproduction, counterfeit, infringement, copy or colorable 

imitation of the ABS-CBN Marks in connection with the publicity, 

promotion, advertising, or distribution of any pirated content by 

Defendants; 

Page 50 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 50 of 65
(6) affixing, applying, annexing or using in connection with the promotion, 

distribution, or advertisement of any pirated content, a false description or 

representation, including words or other symbols tending to falsely 

describe or represent Defendants' pirated content as being connected with 

Plaintiffs, or in any way endorsed by Plaintiffs; 

· (7) engaging in search engine optimization strategies using colorable 

imitations of the ABS-CBN name or trademarks; and 

(8) otherwise unfairly competing with Plaintiffs. 

B. Entry oftemporary, preliminary and permanent injunctions pursuant to 28 U.S.C 

§ 1651(a), The All Writs Act, enjoining Defendants and all third parties from creating, 

maintaining, operating, joining, participating in, including providing financial, technical or other 

support to, the World Wide Web based illegal marketplace used to copy, distribute, perform, 

advertise, or promote pirated content bearing counterfeits or infringements of the ABS-CBN 

Marks. 

C. Entry of an order pursuant to 28 U.S.C § 1651(a), The All Writs Act, that, upon 

Plaintiffs' request, those in privity with Defendants and those with notice of the injunction, 

including any Internet search engines, Web hosts, domain-name registrars, and domain name 

registries or their administrators that are provided with notice of the injunction, cease facilitating 

access to any or all domain names and websites through which Defendants engage in the 

(i) copying, distribution, performance, promotion or other infringement through pirated content 

or (ii) any uses the ABS-CBN Marks. 

D. Entry of an order that, upon Plaintiffs' request, the top level domain (TLD) 

Registry(ies) for the Subject Domain Names or their administrators place the Subject Domain 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 51 of 65
Names on Registry Hold status for the remainder of the registration period for any such domain 

names, thus removing them from the TLD zone files maintained by the Registries or its 

administrators which link the Subject Domain Names to the IP addresses where the associated 

websites are hosted. 

E. Entry of an order canceling or deleting, or, at Plaintiffs' election, transferring the 

Subject Domain Names and any other domain names used by Defendants to engage in their 

infringing activities at issue to Plaintiffs' control so that they may no longer be used for illegal 

purposes. 

G. Entry of an order requiring Defendants, jointly and severally, to account to and 

pay Plaintiffs for all profits and damages resulting from Defendants' trademark counterfeiting 

and infringing activities and that the award to Plaintiffs be trebled, as provided for under 15 

U.S.C. § 1117, or, at Plaintiffs' election with respect to Count I, that Plaintiffs be awarded 

statutory damages from each Defendant in the amount of two million dollars ($2,000,000.00) per 

each counterfeit trademark used, as provided by 15 U.S.C. § 1117(c)(2) ofthe Lanham Act. 

H. Entry of an order requiring: 

(1) that Defendants, jointly and severally pay Plaintiffs for all damages 

sustained by Plaintiffs in consequence of Defendants' copyright 

infringement together with appropriate interest thereon; 

(2) that Defendants account to Plaintiffs for, and disgorge to Plaintiffs, and to 

pay to Plaintiffs, all the gains, profits, savings and advantages realized by 

Defendants from their acts of copyright infringement descried above; 

(3) that Plaintiffs be awarded, at their election, statutory damages within the 

provisions of 17 U.S.C. § 504(c), enhanced to reflect the willful nature of 

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Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 52 of 65
Defendants' infringement, instead of an award of actual damages or 

profits; and 

( 4) that Plaintiffs be awarded their costs and disbursements incurred in this 

action, including reasonable attorneys' fees pursuant to 17 U.S.C. § 505. 

I. Entry of an order requiring Defendants, jointly and severally, to pay Plaintiffs' 

attorneys' fees, and full costs and disbursements in this action. 

J. Entry of an order requiring all funds, up to and including the total amount of 

judgment, in payment accounts or advertising revenue accounts used in connection with the 

Subject Domain Names, and any other accounts, to be surrendered to Plaintiffs' in partial 

satisfaction of the monetary judgment entered herein. 

K. Entry of an order requiring Defendants to pay prejudgment interest according to 

law. 

L. Entry of an order for such other and further relief as the Court may deem proper 

and just. 

DEMAND FOR A JURY TRIAL 

In accordance with Fed. R. Civ. P. 38, Plaintiffs demand a trial by jury on all issues so 

triable. -/L 

DATED this L day of August, 2014. 

newmal6\398640 

Page 53 - COMPLAINT 

MARKOWITZ, HE ... vs..J'-JILJ 

&MEHLHAF,P 

By: 

thew A. Levin, OSB #003054 

(503) 295-3085 

Of Attorneys for Plaintiffs 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 53 of 65
SCHEDULE A 

SUBJECT DOMAIN NAMES 

Domain Number Domain Name 

1 WEBPINOYTAMBA Y AN.COM 

2 W A TCHFILIPINOTV.COM 

3 WATCHFILIPINOMOVIES.COM 

4 PINOY-TVKO.COM 

5 PINOYTVKO.BIZ 

6 PINOY-TUBE. COM 

7 MYPINOYTUBETV.COM 

8 PINOYTALAGA.COM 

9 PINOYSTREAMING.COM 

10 PINOYMOVIEFAN.COM 

11 PINOYTVEPISODES.NET 

12 PINOYTVEPISODES.INFO 

Page 54 - COMPLAINT 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 54 of 65
EXHIBIT 1: 

PLAINTIFFS' COPYRIGHT REGISTRATIONS 

1 of 11 

Ex 1 to Complaint- UNDER SEAL 

Page 1 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 55 of 65
Title 

Be Careful With My Heart 

05.15.2014 

Be Careful With My Heart 

07.24.2014 

The Legal Wife 05.15.2014 

Got to Believe 05.15.2014 

Way Back Home 

The Healing 

One More Try 

The Mistress 

Unofficially Yours 

Suddenly It's Magic 

24/7 In Love 

Every Breath You Take 

In the Name of Love 

A Mother's Story 

Four Sisters and a Wedding 

She's the One 

A Moment in Time 

Bakit Hindi ka Crush ng 

Crush Mo 

Corazon ang Unang Aswang 

For the First Time 

ASAP 05.18.2014 

Annaliza 03.21.2014 

Galema Anak ni Zuma 

03.28.2014 

Honesto 03.14.2014 

Kris TV 05.16.2014 

It's Showtime 05.16.2014 

TV Patrol 05.16.2014 

U.S. Registrations 

Copyright Registration 

Number 

PA 1-894-169 

PA 1-904-232 

PA 1-894-175 

PA 1-894-174 

PA 1-895-945 

PA 1-895-944 

PA 1-895-950 

PA 1-895-948 

P A 1-896-459 

P A 1-895-946 

PA 1-895-947 

P A 1-895-953 

PA 1-895-943 

P A 1-895-954 

PA 1-895-949 

PA 1-895-746 

PA 1-895-745 

PA 1-895-749 

PA 1-895-751 

PA 1-896-598 

PA 1-896-458 

PA 1-896-461 

P A 1-896-462 

P A 1-896-465 

P A 1-896-464 

PA 1-896-467 

P A 1-896-469 

2 of 11 

Copyri2ht Re2istration Date 

May 16,2014 

July 25, 2014 

May 16, 2014 

May 16, 2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 27,2014 

May 28,2014 

May 28,2014 

May 28,2014 

May 28,2014 

May 29,2014 

May 30,2014 

May 30,2014 

May 30,2014 

May 30,2014 

May 30,2014 

May 30,2014 

May 30,2014 

Ex 1 to Complaint- UNDER SEAL 

Page 2 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 56 of 65
Philippine Registrations (TV Shows) 

Title- TV shows 

Aalog-alog 

Abangan Ang Susunod Na Kabanata 

Agimat: Tiagong Akyat 

Agua Bendita 

Ang Tv Art Bank 

Angelito: Batang Ama 

Arriba! Arriba! 

ASAP 

ASAP Fanatic 

Assignment 

At Home Ka Dito 

ATBP (A wit Titik At Bilang Na Pambata) 

Attagirl 

Balitang K 

Banana Split 

Bando (Carabao) (Oki Doki Doc Animal 

Character) 

Berks 

Bertha (Pig) (Oki Doki Doc Animal 

Character) 

Bida Si Mister Bida Si Misis 

Bihag (Into The Mountain) 

Bituin 

Bituing Walang Ningning 

Boogie (Dog) (Oki Doki Doc Animal 

Character) 

Bora: Sons ofthe Beach 

Born Diva 

Boy & Kris 

Budoy 

Calla Lily 

Compafiero Y Compafiera 

Crazy For You 

Cristy Per Minute 

Da Pilya En Da Pilot 

Dahil May Isang Ikaw 

Darating Ang Umaga 

Dong Puno Live 

Dyosa 

E- Media 

Earth link 

Eh Kasi Bata 

Copyright Registration Number 

L20I0-54 

E-93-0I5 

L 20IO-I7 

L 20IO-I68 

A 95-I084 

L-20 I2-00320 

E-200I-OI7 

R-95-082 

L-2004-362 

E 97-020 

L 20I0-5I 

E-95-066 

L-2002-08 

E 96-075 

L 20I0-09 

G 98-III 

L-2003-004 

G 98-I09 

L-2003-005 

L-2003-006 

L-2003-007 

L 20I0-6I 

G 98-IIO 

L-2005-I49 

L-2004-394 

L20I0-03 

L-20 I2-00323 

L 20I 0-66 

E 97-046 

L 20I0-70 

R-95-084 

L-2002-09 

L 20I0-96 

L-2003-065 

E 97-050 

L 20I 0-92 

G200I-333 

E 97-02I 

E-93-037 

3 of II 

Ex 1 to Complaint- UNDER SEAL 

Page 3 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 57 of 65
Title- TV shows 

EK! Channel 

Entertainment Live 

Esep Esep 

ETK (Entertainment Konek) 

Eto Na Ang Susunod Na Kabanata 

Eva Fonda 

F 

Feel At Home 

Filipiniana 

Fluffy (Sheep) (Oki Doki Doc Animal 

Character) 

Gaby's Extraordinary Files 

Game K N B? 

Game Na Game Na 

George and Cecil 

G-Mik! 

Goin Bulilit 

Gokada Go 

Gudtaym 

Gulong Ng Palad 

Gus Abelgas: Nag-uulat 

Hiram 

Home Along The Riles 

Homeboy 

IAmKC 

Idol 

Idol 

lisa Pa Lamang 

lkaw Ang Lahat Sa Akin 

Ikaw Ay Pag-ibig 

Isyu I OI 

It Might Be You 

John En Shirley 

Judy Ann Drama Special 

Jullie 

K2BU 

Ka Pete Na! Totally Outrageous Behaviour 

Kabalikat: Loren Legarda 

Kahit lsang Saglit 

Kamao: Matira Matibay 

Kambal Sa Uma 

Kampanerang Kuba 

Katapat: Mayor Fred Lim 

Katorse 

Copyri2ht Registration Number 

L-2004-363 

L 2010-08 

0-99-166 

L-2005-1 06 

L-2002-1 0 

L 2010-93 

E-99-021 

E-2000-042 

E 99-018 

G 98-112 

L 2010-85 

L-2002-11 

E-95-067 

E 2010-03 

E-99-019 

L-2005-147 

L 2010-75 

L2010-58 

L2010-55 

L-2002-155 

L-2004-413 

E-93-020 

L-2005-107 

L 20I 0-86 

L 20IO-I70 

M 20IO-I84 

L20I0-9I 

L-2005-2I6 

L-20I2-00322 

L-200I-I2I 

L-2004-036 

L-2007-I22 

E-2000-07 

E 97-024 

L-2002-1I9 

L 20I 0-81 

L 200I-I22 

L 20I 0-90 

L-2005-I50 

L 20IO-I64 

L-2005-214 

E 99-009 

L 20IO-I6 

4 of II 

Ex 1 to Complaint- UNDER SEAL 

Page 4 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 58 of 65
Title- TV shows 

Kay Tagal Kang Hinintay 

Klasmeyts 

Knowledge Power 

Kokey 

Koochie (Bird) (Oki Doki Doc Animal 

Character) 

Kris & Tell 

Kris TV 

Krystala 

Kun_g_ Fu Kids 

Labs KoSi Babe 

Let's Go 

Ligaw Na Bulaklak 

Little Big Star 

Little Big Superstar 

Lobo 

Lovers In Paris 

Love spell 

M.l.B. 

M.R.S. (Most Requested Show) 

M3: Malay Mo Madevelop 

Ma_g_andang Gabi Bayan 

Magandang Umaga Bayan (MUB) 

Maging Sino Ka Man - Book 1 

Maging Sino Ka Man - Book 2 

Ma_g_karibal 

Maid in Heaven 

Mana Mana 

Mangarap Ka 

Mara Clara 

Margarita 

Maria Flordeluna 

Marina 

Martin Late_@Nite 

Mary D'Potter 

MATH-Tinik 

May Bukas Pa 

Mel & Jay 

Mga Angel Na Walang Langit 

Mini Ha! Ha! Ha! 

Minsan Lan_g Kita libigin 

Mission X 

Momay 

Morning Girls 

Copyright Registration Number 

L-2002-135 

L-2002-118 

E-99-020 

L 2010-80 

G 98-113 

L-2001-150 

L-2012-00321 

L-2004-414 

L 2010-82 

E-99-057 

L2010-59 

L 2010-07 

L 2010-73 

L 2010-74 

L2010-52 

L 2010-94 

L 2010-67 

E 99-011 

L-2005-108 

L 2010-167 

E-93-024 

L-2003-068 

L 2010-64 

L 2010-65 

L 2010-165 

L-2004-375 

E-93-041 

L-2004-415 

E-93-043 

L 2010-83 

L 2010-69 

L-2004-054 

E-99-010 

L-2002-050 

E 99-022 

L 2010-14 

E-93-042 

L-2005-217 

E 97-053 

L 2011-46 

L-2002-051 

L 2010-173 

L-2002-120 

5 of 11 

Ex 1 to Complaint- UNDER SEAL 

Page 5 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 59 of 65
Title- TV shows Copyright Registration Number 

Morning Star L-2005-028 

Mr. Cupido E-93-038 

MTB _{Masl!Yan_g_ Tanghali Bayan) L-2003-066 

Mula Sa Puso E-97-025 

Music Uplate Live! L 2010-171 

My Girl L2010-150 

My Juan & Only L 2010-53 

Nagsimula Sa Puso L 2010-166 

Nginiig L-2004-083 

Noah L 2010-172 

Ok Fine, Whatever! L-2002-121 

Onli In Da Pilipins E 97-042 

Only You L 2010-15 

Palibhasa Lalake E-93-040 

Palos L 2010-88 

Pangarap Na Bituin L 2010-79 

Patayin Sa Sindak si Barbara L 2010-84 

Pi eta L 2010-10 

Pilipinas, Game KaNa Ba? L-2005-029 

Pinoy Mano Mano The Celebrity Boxing 

Challenge L 2010-02 

Pirated CD L-2004-395 

Precious Hearts Romances L 2010-12 

Precious Hearts Romances: Ang Lalaking 

Nagmahal Sa Akin (Ep I to 5) L 2010-100 

Precious Hearts Romances: My Cheating 

Heart L 2010-104 

Precious Hearts Romances: Somewhere In My 

Heart 

Princess Sarah 

Prinsesa Ng Banyera 

Private I 

Pwedeng Pwede 

QPIDS 

Quizon A venue 

Ready Get Set Go 

Recuerdo De Amor 

Richard Loves Lucy 

Rosalka 

Rounin 

Ruffa and Ai 

Ryan Ryan Musikahan 

Sa DuloNg Walang Hanggan 

Sa Linggo Na Po Sila 

L 2010-103 

L 2010-06 

L 2010-05 

L-2004-037 

E-99-058 

L-2005-213 

L-2005-215 

E-95-069 

L-2001-123 

E-99-012 

L 2010-169 

L2010-56 

L 2010-13 

E-93-035 

L-2001-070 

E-93-029 

6 of 11 

Ex 1 to Complaint- UNDER SEAL 

Page 6 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 60 of 65
Title- TV shows Copyright Reeistration Number 

Sa Puso Ko, Iingatan Ka L-2001-093 

Sa Sandaling Kailangan Mo Ako E-99-013 

Saan KaMan Naroroon E-99-036 

Sana Maulit Muli L 2010-72 

Sana'y Wala Nang Wakas L-2003-130 

Sandara's Romance L-2004-364 

Sang Linggo Na Po Sila R-95-085 

Sarap TV E-98-061 

SCQ Reload L-2004-365 

Search for The Star In A Million L-2005-148 

Sharon E-99-024 

Showbiz Lingo E-93-026 

Showbiz News Ngayon L 2010-11 

Showbiz No. I L-2005-030 

Showbiz Sabado (S2) L-2003-067 

Showtime L 2010-95 

Sineserye Presents: Hiram Na Mukha L 2010-77 

Sineserye Presents: May Minamahal L 2010-89 

Sineserye Presents: Natutulog Ba Ang Diyos L 2010-76 

Sineserye Presents: Palimos N_g_ Pa_g_-ibi_g_ L 2010-78 

Spice Boys E 97-043 

Spirits L-2005-031 

Sports Unlimited E-97-054 

Star Dance: The Search for The Dance Idol L-2005-146 

Star Drama Theater Presents: Aiko E-95-059 

Star Drama Theater Presents: Carmina E-95-060 

Star Drama Theater Presents: Lorna E-95-061 

Star Drama Theater Presents: Nora E-95-062 

Star Drama Theater Presents: Oropesa E-95-063 

Star Drama Theater Presents: Sheryl E-95-064 

Star Drama Theater Presents: ZsaZsa E-95-065 

Star In A Million L-2004-055 

Star Magic Presents: Abt Ur Luv L 2010-62 

Star Magic Presents: Abt Ur Luv, Ur Lyf2 L 2010-68 

Star Studio E-2000-24 

Superinggo L 2010-63 

Super lnggo At Ang Super Tropa L 2010-174 

Super Laff-In Characters (Don Tats, Bayani, 

Mi Ong, Juliet, Luwa1hati, and Adobo) G 97-135 

Tabing Ilog E-99-025 

Tanging Yaman L 2010-102 

Tanging Yaman- The Series L-2002-122 

Tarajing Pot Pot E-99-026 

Tatak Pilipino E-93-039 

7 of 11 

Ex 1 to Complaint- UNDER SEAL 

Page 7 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 61 of 65
Title- TV shows 

Teysi Ng Tahanan 

That's My Doc 

The Buzz 

The Correspondents 

The Correspondents 

The Marice! Drama Special 

The Sharon Cuneta Show 

The Weekend News 

Til Death Do Us Part 

True Crime 

TV Patrol 

U Can Dance 

Usapang_ Business 

Verum Est 

Victim 

Volta 

Walang Kapalit 

W ansapanata ym 

Whattamen 

Y Speak 

Yes Yes Show 

Your Honor 

Your Son_g_ Presents 

Your Song Presents: Babalik Kang Muli 

Your Song Presents: Boystown 

Your Song Presents: Gaano Kita Kamahal 

Your Son_g_ Presents: Someone To Love 

Ysabella 

Copyright Registration Number 

E-93-030 

L 2010-04 

0-99-144 

E 99-006 

E-99-006 

E-93-048 

E-93-025 

R-97-143 

L-2005-109 

L-2001-124 

E-94-006 

L 2010-60 

E 97-051 

L-2002-156 

L-2004-084 

L 2010-87 

L 2010-71 

E-97-057 

L-2002-12 

L-2004-396 

L-2004-085 

L-2001-125 

L2010-57 

L 2010-99 

L 2010-97 

L 2010-98 

L 2010-101 

L-2007-123 

8 of 11 

Ex 1 to Complaint- UNDER SEAL 

Page 8 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 62 of 65
Philippine Registrations (Movies) 

Title- Movies 

9 Mornings 

A Love Story 

Abel Villarama: Armado 

Agent X44 

Ala Eh Con Bisoy, Hale Hale Hoy 

Alamat Ng !sang Pag-lbig 

All About Love 

Alyas Pogi Ang Pagbabalik 

Ama, Ina, Anak 

Anak 

Ang Cute Ng Ina Mo 

Ang Koolits Mo 

Ang Lalaki Sa Buhay Ni Selya 

Bagong Buwan 

Bata, Bata ... Paano Ka Ginawa? 

Bcuz OfU 

Birador 

Can This Be Love 

Caregiver 

Cedie, Ang Munting Prinsipe 

Close To You 

D' Anothers 

Dahil Mahal Na Mahal Kita 

Dekada "70 

Don't Give Up On Us 

Dream boy 

Dubai 

Esperanza: The Movie 

Ex-Con 

Feng Shui 

First Day High 

Forevermore 

Gimik: The Reunion 

Girl Boxer 

Got To Believe 

Hanggang Saan Ang Bukas 

Hangga't May Hininga 

Hey Babe 

Hindi Pa Tapos Ang Labada Darling 

Copyright 

Reeistration Number 

E 2003-008 

E 2009-35 

E 98-036 

E 2009-30 

E 2002-045 

E 96-050 

E 2009-26 

E 2000-02 

E 96-007 

E 2002-025 

E 2009-37 

E 98-029 

E 2002-037 

E 2002-02 

E 2202-036 

E 2005-02 

E 2002-046 

E 2005-031 

E 2009-34 

E 96-001 

E 2009-31 

E 2005-028 

E 2002-026 

E 2001-031 

E 2009-23 

E 2005-029 

E 2005-030 

E 2001-03 

E 2001-010 

E 2004-03 

E 2009-36 

E 2002-027 

E 2002-028 

E 200I-032 

E 2002-029 

E 96-05I 

E 96-078 

E 2000-03 

M 95-00I 

9 of II 

Ex 1 to Complaint- UNDER SEAL 

Page 9 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 63 of 65
Title- Movies 

Home Along Da Riles Da Movie 

Hostage 

Hulin_g El Bimbo 

Huwag Kang Lilingon 

lsa, Dalawa, Takbo 

ISPRIKITIK (Walastik Kung Pumitik) 

lsusumbong Kita Sa Tatay Ko 

I've Fallen For You 

Jologs 

Kahit Isang Saglit 

Kahit Sa Langaw Di Kita Padadapuan 

Kailangan Kita 

Kasal Kasali Kasalo 

Kokey 

Kung Ako Na Lang Sana 

Kung Ika'y_ IsangPanaginip 

La Vida Rosa 

Labs Kita ... Okey Ka Lang 

Lahar 

Maalaala Mo Kaya ... The Movie 

Madrasta 

Magandang Hatinggabi 

Magic Temple 

Mahal Na Kung Mahal 

May Minamahal 

Mila 

Minsan Lang_ Kitan_g Iibigin 

Minsan, Minahal Kita 

Moral2 

Mula Sa Puso 

My Big Love 

Mystrio, Uno ... Dos ... Tres ... Pilyos 

Nagmula Sa Lupa 

Narinig MoNa Ba Ang_ Latest? 

Nasaan KaMan 

Ngayong Nandito Ka 

Notoryus 

Now That I Have You 

One More Chance 

Otso-Otso Pamela-Mela-Wan 

Paano Kita Iibigin 

Copyright 

Re~g_istration Number 

M 95-005 

E 200I-OII 

E 96-052 

E 200I-OI2 

E 96-002 

E 2000-04 

2000-044 

E 2009-40 

E 2002-03 

E 2002-030 

E 200I-013 

E 2002-005 

E 2009-32 

E 96-053 

E 2004-04 

E 2002-04 

E 2002-07 

E 98-030 

E 96-054 

M 95-003 

E 96-047 

E 98-03I 

E 96-003 

E 2002-03I 

M 95-002 

E 2001-033 

M 95-006 

E 2002-032 

E 2003-006 

E 2002-033 

E 2009-27 

E 2002-047 

E 96-014 

E 2001-014 

E 2005-027 

E 2003-007 

E 98-037 

E 2005-03 

E 2009-41 

E 2005-04 

E 2009-38 

10 of II 

Ex 1 to Complaint- UNDER SEAL 

Page 10 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 64 of 65
Title- Movies 

Pera 0 Bayong 

Picture Mom 

Pinay Pie 

Ronquillo Tubong Cavite Laking Tondo 

Sakal Sakali Saklolo 

Sarah ... Ang Munting Prinsesa 

Soltera 

Starcruise 

Sukob 

Supahpapalicious 

Suspek 

Tanging Ina 

Tanging Yaman 

Tar-San 

The Lucky Ones 

Tigasin 

Tik Tak Toys, My Kolokotoys 

Tong Tatlong Tatay Kong Pakitong Kitong 

Trip 

Tunay Na Tunay 

Type Kita, Walang Kokontra 

Videoke King 

Wag Kang Lilingon 

Wansapanataym,The Movie 

Weder Weder La'ng 'Y an 

When Love Begins 

You Are The One 

You Got Me 

Copyright 

Reeistration Number 

E 2002-034 

E 2003-009 

E 2004-05 

M 95-004 

E 2009-39 

E 95-026 

E 2000-05 

E 2004-097 

E 2009-28 

E 2009-43 

E 2002-038 

E 2003-010 

E 2001-015 

E 2001-04 

E 2009-24 

E 2000-06 

E 2002-039 

E 2002-048 

E 2001-016 

E 2002-035 

E 2002-040 

E 2001-034 

E 2009-25 

2000-045 

E 2001-05 

E 2009-42 

E 2009-33 

E 2009-29 

11 of 11 

Ex 1 to Complaint- UNDER SEAL 

Page 11 of 11 

Case 3:14-cv-01275-BR Document 1 Filed 08/07/14 Page 65 of 65