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UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

RM MEDIA LTD.,

 Plaintiff,

v.

NO DEBT, LLC d/b/a ULTIMATE 

DEBT SOLUTIONS, LLC; 

MALCOLM GILES; and DOES 1 

through 10 inclusive,

 Defendant.

Case No. ____________________

COMPLAINT FOR DAMAGES

AND INJUNCTIVE RELIEF 

FROM COPYRIGHT 

INFRINGEMENT

DEMAND FOR BENCH TRIAL

Plaintiff, RM Media Ltd. alleges as follows:

JURISDICTION AND VENUE

1. This is a civil action seeking damages and injunction relief for 

copyright infringement under the Copyright Act of the United States, 17 U.S.C. § 

101 et seq.

2. This Court has subject matter jurisdiction over Plaintiff’s claims for 

Melissa A. Higbee, Esq., SBN 24644

HIGBEE & ASSOCIATES 

1504 Brookhollow Dr., Suite 112

Santa Ana, CA 92705

(714) 617-8349

(714) 597-6559 facsimile

Attorney for Plaintiff,

RM MEDIA LTD

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 1 of 32
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copyright infringement pursuant to 28 U.S.C. § 1331 and 28 U.S.C. § 1338(a).

3. This Court has personal jurisdiction over Defendants because 

Defendants conducts business and/or resides within the State of Arizona

Defendants’ acts of infringement complained of herein occurred in the State of 

Arizona, and Defendants caused injury to Plaintiff within the State of Arizona.

4. Venue in this judicial district is proper under 28 U.S.C. § 1391(c) and 

1400(a) in that this is the judicial district in which a substantial part of the acts and 

omissions giving rise to the claims occurred. Alternatively, venue is also proper 

pursuant to 28 U.S.C. § 1400(b) because the Defendants resides and have a regular 

and established place of business in this judicial district.

 PARTIES

5. Plaintiff RM Media Ltd. (“RM Media” or “Plaintiff”) is an English 

media company specializing in commercial and stock photography licensing. 

6. Plaintiff is informed and believes, and thereon alleges, that Defendant 

No Debt, LLC d/b/a Ultimate Debt Solutions LLC (“Defendant No Debt”) is a 

limited liability company organized under the laws of Arizona with a principal 

place of business at 9170 E. Bahia Drive, Suite 203A, Scottsdale Arizona 85260.

7. Plaintiff is informed and believes, and thereon alleges, that Defendant 

Malcolm Giles (“Defendant Giles”) is the owner of Defendant No Debt.

8. On information and belief, Defendant Giles, through Defendant No 

Debt, is the owner and operator of the website www.udsdebtfree.com

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 2 of 32
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(“Defendants’ Website”), which Defendants use to promote its debt resolutions 

business. Attached hereto as Exhibit A is a true and correct copy of the registrant 

information for Defendants’ Website retrieved from the ICANN WHOIS 

Database.

9. On information and belief, Defendant Giles is responsible for posting 

the content on Defendant’s Website.

10. Plaintiff is unaware of the true names and capacities of the 

Defendants sued herein as DOES 1 through 10, inclusive, and for that reason, sues 

such Defendants under such fictitious names. Plaintiff is informed and believes 

and on that basis alleges that such fictitiously named Defendants are responsible in 

some manner for the occurrences herein alleged, and that Plaintiff’s damages as 

herein alleged were proximately caused by the conduct of said Defendants. 

Plaintiff will seek to amend the complaint when the names and capacities of such 

fictitiously named Defendants are ascertained. As alleged herein, “Defendants” 

shall mean all named Defendants and all fictitiously named Defendants.

11. For the purposes of this Complaint, unless otherwise indicated, 

“Defendant” includes all agents, employees, officers, members, directors, heirs, 

successors, assigns, principals, trustees, sureties, subrogates, representatives and 

insurers of Defendants named in this caption. 

FACTUAL ALLEGATIONS

12. RM Media is a stock photography licensing company that specializes 

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 3 of 32
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in commercial product photography and supplies unique images for web designers, 

bloggers and content writers.

13. RM Media is the assignee and sole rights holder to an original image 

of a clipboard bearing the words “Credit Limit” (“Credit Limit Image”) and an 

original image of a hand writing the word “Borrow” (“Borrow Image”) 

(collectively the “Images”). Attached hereto as Exhibit B are true and correct 

copies of the Images.

14. The Credit Limit Image is registered with the United States Copyright 

Office under registration number VAu 1-279-012, and the Borrow Image is 

registered with the United States Copyright Office under registration number VAu 

1-248-878.

15. RM Media offers two licensing options for consumers wishing to use 

its Images.

16. Under the first option, RM Media offers the Images to consumers 

through its website where consumers can pay a licensing fee in exchange for use of 

the Images. RM Media’s entire content library is available for use through a paid 

license.

17. Under the second option, RM Media offers a limited portion of its 

content library, including the Images, under a Creative Commons Attribution –

ShareAlike license (“CC License”), which, inter alia, requires that the consumer 

“give appropriate credit, provide a link to the license, and indicate if changes were 

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 4 of 32
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made.” Attached hereto as Exhibit C is a true and correct copy of the terms of a 

Creative Commons Attribution – ShareAlike license; see also

http://rmmedia.ltd.uk/free-images/. 

18. Creative Commons licenses are developed and published by a nonprofit organization that provides free, easy-to-use copyright licenses to make a 

simple and standardized way to give the public permission to share and use 

creative work online. See www.creativecommons.org/about/. 

19. RM Media offers a limited portion of its content library through the 

CC License, as the required attribution directs consumers to RM Media’s website 

enhancing its market share and directing consumers to its larger library of paid 

content.

20. RM Media’s website contains a detailed explanation of the terms of 

the CC License with the disclaimer that using the images without following the 

terms and conditions of the license “will invalidate your license to use the image”

and “may lead to an action for copyright infringement.” See

http://rmmedia.ltd.uk/free-images/. 

21. On or about October 2017, RM Media discovered that Defendants 

were using its Images on Defendants’ Website to promote Defendants’ business. 

RM Media had no record of issuing a paid license to Defendants, nor did the photo 

give any attribution as required to qualify for a CC License. A true and correct 

copy of Defendants’ infringing use of Plaintiff’s Image is attached hereto as 

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 5 of 32
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Exhibit D.

22. On or about October 30, 2017, Plaintiff’s counsel sent a cease and 

desist letter to Defendants business address informing them that they did not 

possess a valid license and requesting, inter alia, that Defendants remove the 

Images from Defendants’ Website.

23. On or about November 29, 2017, Plaintiff’s counsel called 

Defendants’ office and spoke with one of Defendants’ employees and left a 

message for Defendant Giles.

24. On or about December 27, 2017 Plaintiff’s counsel sent follow up 

correspondence to Defendants’ business address.

25. On or about March 2, 2017, Plaintiff’s counsel again telephoned 

Defendants and spoke with one of Defendants employees. Plaintiff’s counsel 

confirmed that the address to which correspondence had been sent was accurate 

and requested that Defendant Giles return Plaintiff’s counsel’s calls.

26. As of the date of this Complaint, both of RM Media’s Images are still 

displayed on Defendants’ website at https://udsdebtfree.com/articlesub.php?articleid=5, https://www.udsdebtfree.com/deceptive-credit-cards.php, 

https://udsdebtfree.com/images/blog/credit-limit-lowering.jpg, 

https://udsdebtfree.com/article.php?articleid=4, and 

https://udsdebtfree.com/images/blog/inablitiy-to-borrow.jpg. True and correct time 

stamped screenshots of Defendants’ continued infringing use of the Images is 

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 6 of 32
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attached hereto as Exhibit E. 

27. On information and belief, Defendants’ use of the Images was 

deliberate and willful because Defendants were informed multiple times of their 

infringing use of the Images and refused to remove them from Defendants’ 

Website. Additionally, despite being on notice that the Images did not contain the 

requisite attribution required to qualify for a CC License, continued to distribute 

and display the Images knowing that the required attribution had been removed or 

altered.

FIRST CAUSE OF ACTION

COPYRIGHT INFRINGEMENT

17 U.S.C. § 501 et seq.

 (Against All Defendants)

28. Plaintiff incorporates by reference all of the above paragraphs of this 

Complaint as though fully stated herein.

29. Plaintiff did not consent to, authorize, permit, or allow in any manner 

the said use of Plaintiff’s unique and original Images. 

30. Plaintiff is informed and believes and thereon alleges that the 

Defendants willfully infringed upon Plaintiff’s copyrighted Images in violation of 

Title 17 of the U.S. Code, in that they used, published, communicated, posted, 

publicized, and otherwise held out to the public for commercial benefit, the 

original and unique Images of the Plaintiff without Plaintiff’s consent or authority,

and acquired monetary gain and market benefit as a result. Specifically, 

Defendants, after having received repeated notice from Plaintiff’s counsel that they 

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 7 of 32
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did not have a valid license, continued to display the Images on Defendants’ 

Website.

31. As a result of Defendants’ violation of Title 17 of the U.S. Code, 

Plaintiff is entitled to any actual damages pursuant to 17 U.S.C. §504(b). 

32. As a result of Defendants’ violations of Title 17 of the U.S. Code, 

Plaintiff is entitled to statutory damages in an amount up to $150,000.00 pursuant 

to 17 U.S.C. § 504(c). 

33. As a result of the Defendants’ violations of Title 17 of the U.S. Code, 

the court in its discretion may allow the recovery of full costs as well as reasonable 

attorney’s fees and costs pursuant to 17 U.S.C § 505 from Defendants.

34. Plaintiff is also entitled to injunctive relief to prevent or restrain 

infringement of his copyright pursuant to 17 U.S.C. § 502.

SECOND CAUSE OF ACTION

FALSIFICATION, REMOVAL AND ALTERATION OF COPYRIGHT 

MANAGEMENT INFORMATION 

17 U.S.C. § 1202

(Against All Defendants)

35. Plaintiff incorporates by reference all of the above paragraphs of this 

Complaint as though fully stated herein.

36. On information and belief, Defendants knew that Plaintiff created the 

Images because, inter alia, the source of the Images that Defendants used to 

produce the infringing web page specifically attributed the Images to Plaintiff.

37. On information and belief, Defendants knew that the terms of the CC 

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 8 of 32
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License required that Defendants provide proper attribution to the Images.

38. Defendants intentionally falsified copyright management information 

related to the Images with the intent to induce, enable, facilitate, or conceal an 

infringement of Plaintiff’s rights under the Copyright Act. 

39. Specifically, on Defendants’ website, Defendants continued to 

distribute and display the Images and have purposefully failed to provide the 

attribution information required to qualify for a CC License after being alerted to 

the unauthorized use of Plaintiff’s Images.

40. Defendants’ conduct constitutes a violation of 17 U.S.C. § 1202(a), 

and 1202(b).

41. Defendants’ falsification, removal and/or alteration of that copyright 

management information was done without Plaintiff’s knowledge or authorization.

42. Defendants’ falsification of said copyright management information 

was done by Defendants intentionally, knowingly, and with the intent to induce, 

enable, facilitate, or conceal Defendants’ infringement of Plaintiff’s copyright in 

the Images. Defendants also knew, or had reason to know, that such removal 

and/or alteration of copyright management information would induce, enable, 

facilitate, or conceal Defendants infringement of Plaintiff’s copyright in the 

Images.

43. Plaintiff has sustained significant injury and monetary damages as a 

result of Defendants wrongful acts as hereinabove alleged, and as a result of being 

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 9 of 32
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involuntarily associated with Defendants in an amount to be proven. 

44. In the alternative, Plaintiff may elect to recover statutory damages 

pursuant to 17 U.S.C. § 1203(c)(3) in a sum of not more than $25,000 from each 

Defendant for each violation of 17 U.S.C. § 1202.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment against Defendants as follows:

• For statutory damages against each Defendant in an amount of $150,000.00 

for each infringement pursuant to 17 U.S.C. § 504(c);

• For statutory damages against each Defendant in an amount up to 

$25,000.00 for each falsification or removal of copyright management 

information pursuant to 17 U.S.C. § 1202;

• For pre and post judgment interest at the maximum legal rate;

• For costs of litigation and reasonable attorney’s fees against each Defendant 

pursuant to 17 U.S.C. § 505; 

• For an injunction preventing each Defendants from further infringement of 

all copyrighted works of the Plaintiff pursuant to 17 U.S.C. § 502; and

• For any other relief the Court deems just and proper.

Dated: March 12, 2018 Respectfully submitted,

/s/ Melissa A. Higbee

Melissa A. Higbee, Esq. SBN 24644

HIGBEE & ASSOCIATES

1504 Brookhollow Dr., Ste 112

Santa Ana, CA 92705-5418

(714) 617-8349

(714) 597-6559 facsimile

Counsel for Plaintiff

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 10 of 32
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DEMAND FOR JURY TRIAL

Plaintiff, RM Media Ltd. hereby demands a bench trial in the above matter.

Dated: March 12, 2018 Respectfully submitted,

/s/ Melissa A. Higbee

Melissa A. Higbee, Esq. SBN 24644

HIGBEE & ASSOCIATES

1504 Brookhollow Dr., Ste 112

Santa Ana, CA 92705-5418

(714) 617-8349

(714) 597-6559 facsimile

Counsel for Plaintiff

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 11 of 32
Exhibit	“A”

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 12 of 32
3/9/2018 | ICANN WHOIS

https://whois.icann.org/en/lookup?name=udsdebtfree.com 1/5

简体中文 English Français Русский Español العربیة Portuguese

ICANN WHOIS

Registrant Contact

Name: Malcolm Giles

Organization: No Debt LLC

Mailing Address: 9170 E Bahia Drive STE 203A, Scottsdale Arizona 85260 US

Phone: +1.8559663328

Ext:

Fax: +1.8558771084

Fax Ext:

Email:malc44@gmail.com

Admin Contact

Name: Malcolm Giles

Organization: No Debt LLC

Mailing Address: 9170 E Bahia Drive STE 203A, Scottsdale Arizona 85260 US

Phone: +1.8559663328

Ext:

Fax: +1.8558771084

Fax Ext:

Email:malc44@gmail.com

Tech Contact

Name: Malcolm Giles

Organization: No Debt LLC

Mailing Address: 9170 E Bahia Drive STE 203A, Scottsdale Arizona 85260 US

Phone: +1.8559663328

Contact Information

Showing resultsfor: udsdebtfree.com

Original Query: udsdebtfree.com

udsdebtfree.com Lookup

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 13 of 32
3/9/2018 | ICANN WHOIS

https://whois.icann.org/en/lookup?name=udsdebtfree.com 2/5

Ext:

Fax: +1.8558771084

Fax Ext:

Email:malc44@gmail.com

Registrar

WHOIS Server: whois.godaddy.com

URL: http://www.godaddy.com

Registrar: GoDaddy.com, LLC

IANA ID: 146

Abuse Contact Email:abuse@godaddy.com

Abuse Contact Phone: +1.4806242505

Status

Domain Status:clientTransferProhibited http://www.icann.org/epp#clientTransferProhibited

Domain Status:clientUpdateProhibited http://www.icann.org/epp#clientUpdateProhibited

Domain Status:clientRenewProhibited http://www.icann.org/epp#clientRenewProhibited

Domain Status:clientDeleteProhibited http://www.icann.org/epp#clientDeleteProhibited

Important Dates

Updated Date: 2017-05-09

Created Date: 2017-05-09

Registrar Expiration Date: 2018-05-09

Name Servers

NS69.DOMAINCONTROL.COM

NS70.DOMAINCONTROL.COM

Raw WHOIS Record

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 14 of 32
3/9/2018 | ICANN WHOIS

https://whois.icann.org/en/lookup?name=udsdebtfree.com 3/5

Domain Name: udsdebtfree.com

Registry Domain ID: 2122433651_DOMAIN_COM-VRSN

Registrar WHOIS Server: whois.godaddy.com

Registrar URL: http://www.godaddy.com

Updated Date: 2017-05-09T18:41:31Z

Creation Date: 2017-05-09T18:41:31Z

Registrar Registration Expiration Date: 2018-05-09T18:41:31Z

Registrar: GoDaddy.com, LLC

Registrar IANA ID: 146

Registrar Abuse Contact Email: abuse@godaddy.com

Registrar Abuse Contact Phone: +1.4806242505

Domain Status: clientTransferProhibited

http://www.icann.org/epp#clientTransferProhibited

Domain Status: clientUpdateProhibited

http://www.icann.org/epp#clientUpdateProhibited

Domain Status: clientRenewProhibited

http://www.icann.org/epp#clientRenewProhibited

Domain Status: clientDeleteProhibited

http://www.icann.org/epp#clientDeleteProhibited

Registry Registrant ID: Not Available From Registry

Registrant Name: Malcolm Giles

Registrant Organization: No Debt LLC

Registrant Street: 9170 E Bahia Drive STE 203A

Registrant City: Scottsdale

Registrant State/Province: Arizona

Registrant Postal Code: 85260

Registrant Country: US

Registrant Phone: +1.8559663328

Registrant Phone Ext: 

Registrant Fax: +1.8558771084

Registrant Fax Ext: 

Registrant Email: malc44@gmail.com

Registry Admin ID: Not Available From Registry

Admin Name: Malcolm Giles

Admin Organization: No Debt LLC

Admin Street: 9170 E Bahia Drive STE 203A

Admin City: Scottsdale

Admin State/Province: Arizona

Admin Postal Code: 85260

Admin Country: US

Admin Phone: +1.8559663328

Admin Phone Ext: 

Admin Fax: +1.8558771084

Admin Fax Ext: 

Admin Email: malc44@gmail.com

Registry Tech ID: Not Available From Registry

Tech Name: Malcolm Giles

Tech Organization: No Debt LLC

Tech Street: 9170 E Bahia Drive STE 203A

Tech City: Scottsdale

Tech State/Province: Arizona

Tech Postal Code: 85260

Tech Country: US

Tech Phone: +1.8559663328

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 15 of 32
3/9/2018 | ICANN WHOIS

https://whois.icann.org/en/lookup?name=udsdebtfree.com 4/5

Tech Phone Ext: 

Tech Fax: +1.8558771084

Tech Fax Ext: 

Tech Email: malc44@gmail.com

Name Server: NS69.DOMAINCONTROL.COM

Name Server: NS70.DOMAINCONTROL.COM

DNSSEC: unsigned

URL of the ICANN WHOIS Data Problem Reporting System:

http://wdprs.internic.net/

>>> Last update of WHOIS database: 2018-03-09T21:00:00Z <<<

For more information on Whois status codes, please visit

https://www.icann.org/resources/pages/epp-status-codes-2014-06-16-

en

The data contained in GoDaddy.com, LLC's WhoIs database,

while believed by the company to be reliable, is provided "as is"

with no guarantee or warranties regarding its accuracy. This

information is provided for the sole purpose of assisting you

in obtaining information about domain name registration records.

Any use of this data for any other purpose is expressly forbidden

without the prior written

permission of GoDaddy.com, LLC. By submitting an inquiry,

you agree to these terms of usage and limitations of warranty. In

particular,

you agree not to use this data to allow, enable, or otherwise make

possible,

dissemination or collection of this data, in part or in its

entirety, for any

purpose, such as the transmission of unsolicited advertising and

and solicitations of any kind, including spam. You further agree

not to use this data to enable high volume, automated or robotic

electronic

processes designed to collect or compile this data for any purpose,

including mining this data for your own personal or commercial

purposes. 

Please note: the registrant of the domain name is specified

in the "registrant" section. In most cases, GoDaddy.com, LLC 

is not the registrant of domain names listed in this database.

Note: WHOIS consumers who are now receiving masked data can find

instructions on how to apply for whitelisting here: 

https://www.godaddy.com/help/masking-contact-information-sharedvia-whois-automated-access-points-27421

Submit a Complaint for WHOIS

WHOIS Inaccuracy Complaint Form

WHOIS Service Complaint Form

WHOIS Compliance FAQs

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 16 of 32
3/9/2018 | ICANN WHOIS

https://whois.icann.org/en/lookup?name=udsdebtfree.com 5/5

NOTICE, DISCLAIMERS AND TERMS OF USE:

All results shown are captured from registries and/or registrars and are framed in real-time. ICANN

does not generate, collect, retain or store the results shown other than for the transitory duration

necessary to show these results in response to real-time queries.* These results are shown for the sole

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does collect, generate, retain and store information regarding registrations in the .int TLD.

© 2018 Internet Corporation for Assigned Names and Numbers     Privacy Policy

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 17 of 32
Exhibit	“B”

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 18 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 19 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 20 of 32
Exhibit	“C”

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 21 of 32
11/16/2017 Creative Commons — Attribution-ShareAlike 3.0 Unported — CC BY-SA 3.0

https://creativecommons.org/licenses/by-sa/3.0/ 1/1

This is a human-readable summary of (and not a substitute for) the license.

Under the following terms:

Notices:

Creative Commons License Deed

Attribution-ShareAlike 3.0 Unported (CC BY-SA 3.0)

You are free to:

Share — copy and redistribute the material in any medium or format

Adapt — remix, transform, and build upon the material

for any purpose, even commercially.

The licensor cannot revoke these freedoms as long as you follow the license terms.

Attribution — You must give appropriate credit, provide a link to the license, and indicate if

changes were made. You may do so in any reasonable manner, but not in any way that

suggests the licensor endorses you or your use.

ShareAlike — If you remix, transform, or build upon the material, you must distribute your

contributions under the same license as the original.

No additional restrictions — You may not apply legal terms or technological measures that

legally restrict others from doing anything the license permits.

You do not have to comply with the license for elements of the material in the public domain

or where your use is permitted by an applicable exception or limitation.

No warranties are given. The license may not give you all of the permissions necessary for

your intended use. For example, other rights such as publicity, privacy, or moral rights may

limit how you use the material.

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 22 of 32
Exhibit	“D”

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 23 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 24 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 25 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 26 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 27 of 32
Exhibit	“E”

Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 28 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 29 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 30 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 31 of 32
Case 2:18-cv-00806-JAT Document 1 Filed 03/12/18 Page 32 of 32