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Marc J. Randazza, AZ Bar No.: 27861

RANDAZZA LEGAL GROUP

3625 S. Town Center Drive, Suite 150

Las Vegas, NV 89135

Telephone: 702-420-2001

Facsimile: 305-437-7662

ecf@randazza.com

Attorneys for Plaintiff,

AMA Multimedia LLC

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

AMA MULTIMEDIA, LLC, a Nevada 

limited liability company,

Plaintiff,

vs.

John Does 1-25, and

Roe Corporations 26-50,

Defendants.

Case No. 

COMPLAINT

(1)Copyright Infringement – 17 

U.S.C. § 101, et seq.;

(2)Contributory Copyright 

Infringement;

(3) Vicarious Copyright 

Infringement;

(4) Trademark Infringement – 15 U.S.C. § 1114;

(5)Unfair Competition – 15 

U.S.C. § 1125(a)

JURY DEMAND

For its Complaint against Doe Defendants 1 through 25 and Roe 

Corporation Defendants 26-50 (collectively, “Defendants”), Plaintiff AMA 

Multimedia LLC (“AMA”) hereby complains and alleges as follows:

1.0 NATURE OF THE ACTION

Plaintiff AMA is a Nevada limited liability company that produces 

high quality audiovisual works that it distributes online to paid subscribers 

of its websites. In connection with its production and sale of audiovisual 

works, AMA owns copyright registrations with the U.S. Copyright Office for 

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nearly every audiovisual work that it produces. AMA additionally owns 

trademark registrations with the United States Patent and Trademark 

Office for its brands and zealously and proactively protects its intellectual 

property.

Defendants are the registrants of the domain names <eporner.com> 

and <epornergay.com> and the owners of the EPorner website, which 

can be reached through both domain names. The EPorner website 

operates as a free mega-theater for the copyrighted works of Plaintiff 

AMA and numerous other content owners. When Defendants post videos 

owned by AMA, they leave Plaintiff’s watermark, which contains one of 

Plaintiff’s trademarked logos, on the video and combine it with an EPorner 

watermark in order to confuse and deceive consumers. Plaintiff AMA is 

informed and believes that Defendants upload some of Plaintiff’s videos 

onto the EPorner website themselves. To the extent that third parties 

upload the videos, Defendants actively encourage these third parties to 

do so. Defendants have not designated an agent for receipt of takedown notices pursuant to 17 U.S.C. § 512 and are not entitled to any of 

the protections that the Digital Millennium Copyright Act (the “DMCA”) 

could have provided.

Plaintiff seeks relief from this Court in order to put an end to 

Defendants’ rampant intellectual property infringement and asserts claims 

against Defendants for copyright infringement, contributory copyright 

infringement, vicarious copyright infringement, trademark infringement, 

and unfair competition.

/ / /

/ / /

/ / /

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2.0 JURISDICTION AND VENUE

1. This Court has jurisdiction over this case pursuant to 28 U.S.C. 

§§ 1331 and 1338, as this case arises under the U.S. Copyright Act and the 

U.S. Lanham Act.

2. This Court has personal jurisdiction over Defendants because 

the claims in this Complaint relate to their maintenance and operation of 

a website located on the World Wide Web at <eporner.com>,

<epornergay.com>, and <eprncdn.com>. This website is interactive and is 

fully accessible to residents of this District.

3. As a further ground for jurisdiction in this District, Defendants 

used the domain name registrar GoDaddy, located in Scottsdale, Arizona, 

to register the <epornergay.com> and <eprncdn.com> domain names

and domain name privacy service Domains By Proxy, located in 

Scottsdale, Arizona, to conceal their identities from the world. When 

Defendants used the services of GoDaddy and Domains By Proxy, they 

agreed that in any disputes between them and any third parties, they 

would submit to the jurisdiction of the state or federal courts of Arizona.

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

and (c).

3.0 THE PARTIES

5. Plaintiff AMA is a Nevada limited liability company with its 

principal place of business in Las Vegas, Nevada. Plaintiff is a producer 

and distributor of erotic adult entertainment over the Internet.

6. AMA owns a series of subscription-based websites that create 

and distribute adult content to subscribers who pay for its services. 

Specifically, AMA’s subscribers are issued a login ID and password after 

providing credit card information and confirming that they are over 18 

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years of age. Following issuance of the login ID and password, subscribers 

are able to access the secure portion of AMA’s websites to view adult 

materials.

7. AMA owns numerous online properties, the brands of which 

are protected by common law and federally registered trademarks. In 

particular, AMA produces adult content under the well-known “PassionHD” and “Massage Creep” brands, among others.

8. AMA has federally registered trademark rights in the following 

marks:

a. PASSION-HD.COM (registration number 4,190,291). 

b. PASSION-HD (registration number 4,251,457).

c. PORNPROS (registration number 4,081,017). 

d. PORNPROS (registration number 3,566,875). 

e. PUREMATURE (registration number 4,453,271). 

f. POVD INNOVATIVE. CUTTING EDGE. A NEW PORN 

EXPERIENCE. (registration number 4,576,025). 

g. TINY4K.COM, (registration number 4,678,642).

h. FANTASYHD (registration number 4,591,117).

i. EXOTIC4K.COM YOUNG EXOTIC GIRLS 4K ULTRA-DEF (serial 

number 86,425,774).

9. Defendants are a group of individuals and/or entities that 

possess the registrations for the <eporner.com>, <epornergay.com>, and 

<eprncdn.com> domain names and operate the EPorner website, 

accessible through both domain names.

10. Plaintiff is currently unaware of the actual names and/or 

identities of Defendants but will amend this Complaint after those 

identities are discovered through early discovery to the registrars, privacy 

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services, and/or hosting companies used by Defendants for the 

maintenance of the <eporner.com>, <epornergay.com>, and 

<eprncdn.com> domain names and the EPorner website.

4.0 ALLEGATIONS COMMON TO ALL CLAIMS

4.1 The Operation of the EPorner Website

11. Defendants registered the <eporner.com> domain name on 

or about April 8, 2008. The current registrar of the domain name is KeySystems GmbH, a domain name registrar located in Sankt Ingbert, 

Germany.

12. Because Defendants are aware that they are using the 

<eporner.com> domain name to infringe upon the rights of Plaintiff and 

other content producers, they have utilized a privacy service to hide their 

identities as registrants of the domain name, specifically Whoisproxy.com, 

Ltd., which is located in Auckland, New Zealand.

13. The hosting company used by the registrants of the 

<eporner.com> domain name is Leaseweb, which is headquartered in 

Amsterdam, the Netherlands, and which has an office in Manassas, 

Virginia.

14. Defendants registered the <epornergay.com> domain name 

on or about August 27, 2013. The current registrar of the domain name is 

GoDaddy.com, LLC, a domain name registrar located in Scottsdale, 

Arizona.

15. Because Defendants are aware that they are using the 

<epornergay.com> domain name to infringe upon the rights of Plaintiff 

and other content producers, they have used a privacy service to hide 

their identities as registrants of the domain name, specifically Domains By 

Proxy, LLC, which is located in Scottsdale, Arizona.

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16. The hosting company used by the registrants of the 

<epornergay.com> domain name is Leaseweb, which is headquartered 

in Amsterdam, Netherlands, and which has an office in Manassas, Virginia.

17. Defendants registered the <eprncdn.com> domain name on 

or about November 5, 2013. The current registrar of the domain name is 

GoDaddy.com, LLC, a domain name registrar located in Scottsdale, 

Arizona.

18. Because Defendants are aware that they are using the 

<eprncdn.com> domain name to infringe upon the rights of Plaintiff and 

other content producers, they have used a privacy service to hide their 

identities as registrants of the domain name, specifically Domains By Proxy, 

LLC, which is located in Scottsdale, Arizona.

19. The hosting company used by the registrants of the 

<eprncdn.com> domain name is Leaseweb, which is headquartered in 

Amsterdam, Netherlands, and which has an office in Manassas, Virginia.

20. When an Internet user puts the <eporner.com>,

<epornergay.com>, or <eprncdn.com> domain names into his Internet 

browser, he is taken to Defendants’ EPorner website, which operates as a 

mega-theater displaying the contents of Plaintiff and other content 

producers free of charge and with no compensation to Plaintiff or other 

content producers.

21. EPorner’s popularity rests entirely on the infringing content 

found on the site. Virtually all of the profit that Defendants make from the 

EPorner site is a result of the infringing content found on the site, including 

content belonging to Plaintiff.

22. The videos on the EPorner site, including the videos 

Defendants stole from Plaintiff, contain the watermark of the content 

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owner/producer. In addition, EPorner includes its own watermark in the 

top left hand corner of the video, which reads “HD EPorner.”

23. Because Defendants use the EPorner watermark along with 

Plaintiff’s watermarks on the EPorner site, Internet users will be confused 

and believe that Plaintiff sponsors, endorses, or approves of EPorner’s use 

of its content and trademarks, which it does not.

24. EPorner operates on the World Wide Web purporting to be a 

forum for website users to share their own original video content. 

However, belying its ostensible function as a repository for user-owned 

and generated content, most of the content on EPorner (and the most 

valuable content on EPorner) consists of infringing copies of obviously 

copyrighted works, including those of Plaintiff AMA.

25. Most video upload sites require their users to create an 

account, typically by providing (at the very least) an email address.

26. On EPorner’s upload page, it advertises that users have the 

option to upload anonymously. Therefore, if EPorner’s users are uploading 

infringing material, EPorner assists them in doing so with minimal fear of 

being identified by the intellectual property owner.

27. Upon information and belief, Defendants themselves upload 

some, if not most, of the infringing content on the EPorner website. In fact,

the site’s upload page seems to confirm this when it states “[e]very day 

we are adding dozens of new porn videos and photos.”

28. The EPorner site displays a still image from within the video on 

its website. When an Internet visitor drags his cursor over the image for a 

specific video, multiple images from within the video are shown 

sequentially, providing a preview of the video’s contents.

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29. Beneath the preview image of each video, the site displays 

the number of views, the average user rating on a 5-star scale, and the 

length of the video in minutes and seconds.

30. The longer a video is, the more views it gets on the EPorner site, 

as Internet visitors will know that they are full-length movies and not 

previews. Longer videos are most likely to be infringing.

31. When an Internet visitor clicks on the preview image, the video 

begins to play.

32. Defendants categorize several videos found on Eporner under 

the terms “Full HD Porn,” “60 FPS Porn,” or “Full HD,” and marks videos that 

fall under these categories with a special identifier visible on the preview 

image of a video. Defendants, rather than third-party users of Eporner, 

add these special identifiers.

33. In addition to posting Plaintiff’s videos on the EPorner site, 

Defendants incentivize third parties to display Plaintiffs’ copyrighted works 

as well through the EPorner webmaster program, which encourages third 

parties to populate their websites with infringing material from the EPorner 

site.

4.2 EPorner Is Not DMCA Compliant

34. The EPorner website contains a section entitled “DMCA Notice 

of Copyright Infringement,” whereby Defendants state that they have a 

designated agent to receive takedown requests whose email address is 

<dmca@eporner.com>.

35. However, a review of the Service Provider Agents list on the 

website for the U.S. Copyright Office reveals that EPorner has not 

designated an agent for receipt of takedown notices, as required by 17 

U.S.C. § 512(c)(2).

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36. Because Defendants have not registered a designated agent

with the Copyright Office as required by Section 512(c)(2), they do not 

qualify for the safe harbor provisions of 17 U.S.C. § 512(c)(1).

37. EPorner purports to have a repeat infringer policy. However, it 

is ambiguous to the point of irrelevance, as it simply states “a User’s 

access to EPorner will be terminated if, under appropriate conditions, the 

User is determined to infringe repeatedly.” 

38. Upon information and belief, Defendants make no effort to 

enforce this repeat infringer policy.

39. However, Defendants do possess actual, specific knowledge 

of infringing activity and general knowledge of the infringement occurring 

on the EPorner site, which they have chosen to ignore so that they might 

benefit at the expense of intellectual property owners, including AMA.

40. Defendants sell advertising on the EPorner website in the form 

of traditional website display ads.

41. Defendants receive revenue from the advertisements on the 

basis of the number of ads displayed and/or the number of visitors its 

advertisements direct to the advertisers’ websites.

42. Defendants’ infringing activity leads to increased Internet 

traffic on the EPorner site and thus increases advertising revenue – as an 

increasing volume of Internet traffic increases both the amount of 

advertisements displayed to users of its service and the rates that 

Defendants can charge for displaying those advertisements.

43. Defendants knowingly, intentionally, negligently, willfully, or 

with willful blindness, knows of, causes, or permits copyright infringement 

to occur on EPorner, while exercising the right and authority to control and 

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end such infringement. Defendants do this for their own financial gain and 

benefit.

5.0 CAUSES OF ACTION

5.1 First Cause of Action – Copyright Infringement (17 U.S.C. § 501)

44. Plaintiff AMA repeats and realleges each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

45. AMA is the owner of at least 80 works – among dozens of 

others – found to be copied and distributed, without authorization, on 

Defendants’ website, EPorner, which is reached through the 

<eporner.com> and <epornergay.com> domain names.

46. AMA registered each copyright with the U.S. Copyright Office 

within 90 days of publication and/or before Defendants’ infringement 

occurred.

47. The number of infringed copyrights – and the volume of 

infringement – on the EPorner website grows daily, as is Defendants’ 

intention. AMA shall file supplemental updates to this Complaint to 

document subsequently discovered infringements.

48. At all times leading to this lawsuit, AMA was the producer and 

registered owner of the works unlawfully reproduced and distributed by 

Defendants through EPorner.

49. Defendants reproduced, reformatted, and distributed AMA’s 

copyrighted works through servers and other hardware that it owned, 

operated, or controlled.

50. Defendants infringed upon AMA’s copyrights through their 

reproduction and distribution of AMA’s works through EPorner without 

AMA’s approval or authorization.

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51. Defendants knew or should have known that they did not 

have permission to exploit AMA’s works on EPorner and that their actions 

of copying, displaying, and distributing AMA’s works constituted copyright 

infringement.

52. Defendants engaged in intentional, knowing, negligent, or 

willfully blind conduct that demonstrates they engaged actively in the 

unlawful collection and distribution of AMA’s copyrighted works.

53. Defendants’ copyright infringement has increased the appeal 

of the EPorner website, which increased the visits to Defendants’ site and 

the revenue that they receive from the site.

54. Defendants’ conduct is willful pursuant to the provisions of 17 

U.S.C. § 101 et seq. At minimum, Defendants acted with willful blindness 

and reckless disregard of AMA’s registered copyrights.

55. Under 17 U.S.C. § 504, AMA may recover damages, including 

ascertainable direct losses and all profits Defendants made by their 

wrongful conduct. Alternatively, AMA may collect statutory damages.

56. As Defendants’ infringement is willful, AMA is entitled to 

statutory damages of $150,000 per infringed work. 17 U.S.C. § 504(c)(2).

5.2 Second Cause of Action – Contributory Copyright Infringement

57. Plaintiff AMA repeats and realleges each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

58. Defendants had actual or constructive knowledge of 

infringement occurring on EPorner or were willfully blind to such 

infringement.

59. Third party users of EPorner committed the infringements, who 

copied and distributed AMA’s works without AMA’s authorization.

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60. Defendants induced, caused, or materially contributed to the 

third party infringement through the EPorner website, and specifically 

through certain features of EPorner designed to encourage users to 

upload copyrighted videos onto the EPorner website.

61. Defendants additionally encouraged third parties to populate 

their websites with infringing materials contained on the EPorner site 

through the EPorner Webmaster program, including Plaintiffs’ copyrighted 

works.

62. Defendants induced, caused, or materially contributed to the 

third party infringement through Defendants’ Webmaster program, which 

was designed to encourage third parties to post Plaintiffs’ copyrighted 

works on their sites.

63. Defendants received a direct financial benefit from the third 

party copyright infringement that it materially contributed to, caused, and 

induced.

5.3 Third Claim for Relief – Vicarious Copyright Infringement

64. Plaintiff AMA repeats and realleges each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

65. Defendants had specific, or at least general, knowledge of 

copyright infringement occurring on EPorner.

66. Defendants had the right and ability to control access to, 

remove, or disable the infringing materials.

67. Defendants profited from the infringement through increased 

Internet traffic and concomitant advertising revenue it realized as a 

consequence of the infringement.

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68. Because Defendants profited from this infringement, it 

declined to use its right and ability to delete or disable any and all 

infringing content.

5.4 Fourth Claim for Relief – Trademark Infringement (15 U.S.C. § 

1114)

69. Plaintiff AMA repeats and realleges each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

70. On the EPorner site, Defendants prominently display AMA’s 

federally registered trademarks on various videos in conjunction with 

EPorner’s logo.

71. Defendants are using Plaintiff’s marks in commerce.

72. Defendants’ use of Plaintiff’s trademarks constitutes a 

reproduction, copying, counterfeiting, and colorable imitation of Plaintiff’s 

trademarks in a manner that is likely to cause confusion or mistake or to 

deceive consumers.

73. By using Plaintiff’s marks on the World Wide Web, Defendants 

intend to cause confusion, cause mistake, or deceive consumers.

74. Defendants are using Plaintiff’s trademarks in connection with 

the sale, offering for sale, or advertising of services in a manner that is likely 

to cause confusion, or to cause mistake, or to deceive consumers as to 

affiliation, connection, or association with Plaintiff or as to the origin, 

sponsorship, or approval of Defendants’ services or commercial activities 

by Plaintiff.

75. Defendants’ use of Plaintiff’s marks has created a likelihood of 

confusion among consumers who may falsely believe that Defendants’ 

business or website is associated with Plaintiff or that Plaintiff sponsors or 

approves of Defendants’ services or commercial activities.

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76. As a direct and proximate result of Defendants’ infringement, 

Plaintiff has suffered, and will continue to suffer, monetary loss and 

irreparable injury to its business, reputation, and goodwill.

5.5 Fifth Claim for Relief – Unfair Competition (15 U.S.C. § 1125(a))

77. Plaintiff AMA repeats and realleges each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

78. Defendants’ use in commerce of marks identical and/or 

confusingly similar to Plaintiff’s trademarks in connection with Defendants’ 

services and website constitutes a false designation of origin and/or a 

false and misleading description or representation of fact, which is likely to 

cause confusion, cause mistake, or deceive as to affiliation, connection, 

or association with Plaintiff, or as to the origin, sponsorship, or approval of 

Defendants’ services or commercial activities by Plaintiff.

79. Defendants’ use in commerce of Plaintiff’s marks and/or marks 

confusingly similar to Plaintiff’s marks with the knowledge that Plaintiff 

owns and has used, and continues to use, its trademarks constitutes 

intentional conduct by Defendants to make false designations of origin 

and false descriptions about Defendants’ services and commercial 

activities.

80. As a direct and proximate result of such unfair competition, 

Plaintiff has suffered, and will continue to suffer, monetary loss and 

irreparable injury to its business, reputation, and goodwill.

6.0 PRAYER FOR RELIEF

AMA respectfully requests that the Court hereby:

A. Enter an order permitting early discovery from Leaseweb; 

Whoisproxy.com, Inc.; Domains by Proxy, LLC; Key-Systems 

GbmH; Godaddy.com, LLC; OVH Hosting; and Grand Slam 

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Media, Inc., so that Plaintiff AMA may amend the Complaint 

with the true and correct names of Defendants;

B. Enter a judgment that Defendants willfully infringed AMA’s 

rights in federally registered copyrights pursuant to 17 U.S.C. § 

501 through direct, contributory, and vicarious acts;

C. Issue declaratory and injunctive relief against Defendants, their 

agents, representatives, employees, attorneys, successors, and 

assigns, and all others acting with or on behalf of Defendants, 

and further to enjoin and restrain Defendants from copying, 

posting, or making any other infringing use or distribution of 

AMA’s audiovisual works, pursuant to 17 U.S.C. § 502;

D. Issue injunctive and declaratory relief against Defendants, their 

agents, representatives, employees, attorneys, successors, and 

assigns, and all others acting with or on behalf of Defendants, 

enjoining and restraining them from engaging in further acts of 

copyright infringement; and if they are unable to comply, the 

Court should issue an order shutting down EPorner completely;

E. Issue injunctive and declaratory relief against Defendants, their 

agents, representatives, employees, attorneys, successors, and 

assigns, and all others acting with or on behalf of Defendants, 

enjoining and restraining them from engaging in further acts of 

trademark infringement and unfair competition; and if they 

are unable to comply, the Court should issue an order shutting 

down EPorner completely;

F. Enter an order of impoundment pursuant to 17 U.S.C. §§ 503 

and 509(a) impounding all infringing digital copies of Plaintiff’s 

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audiovisual works and other materials, which are in 

Defendants’ possession or under its control in any form;

G. Enter an order enjoining Defendants from disposition of any 

domain names registered to it, or other property, until full and 

final settlement or payment of any and all money damage 

judgments;

H. Enter an order requiring a full and complete accounting of all 

amounts due and owed to AMA as a result of Defendants’ 

illegal or improper activity, whether criminal or civil in nature;

I. Enter an order directing Defendants to pay AMA statutory 

damages of maximum enhanced statutory damages of 

$150,000 per infringed work pursuant to 17 U.S.C. § 504(c)(2), 

for Defendants’ willful infringement of AMA’s copyrights;

J. Enter an order directing Defendants to pay AMA both the 

costs of the action and reasonable attorneys’ fees incurred by 

it in prosecuting this action under 17 U.S.C. § 505;

K. Enter an order directing Defendants to pay pre- and postjudgment interest at the highest legal rate; and

L. Grant AMA whatever further relief in law or in equity that the 

Court deems appropriate.

/ / /

/ / /

/ / /

/ / /

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DEMAND FOR JURY TRIAL

Plaintiff hereby respectfully demands a jury trial for all issues triable 

by jury.

Dated: August 24, 2015

Respectfully Submitted,

RANDAZZA LEGAL GROUP

/s/ Marc J. Randazza 

Marc J. Randazza, AZ Bar No. 27861

Randazza Legal Group

3625 S. Town Center Drive, Suite 150

Las Vegas, NV 89135

Attorneys for Plaintiff,

AMA Multimedia, LLC

Case 2:15-cv-01674-ROS Document 1 Filed 08/24/15 Page 17 of 17