Verified Complaint, 29-30. In violation of IRI s right to control the publication of its copyrighted works, Lighthouse has publicly distributed portions of the Handbook. The posting of portions of the Handbook on the Internet greatly facilitates further infringements and makes it virtually impossible for IRI to identify recipients of unauthorized copies. IRI has no adequate electronic medium or remedy at law to redress or mitigate all of the injuries that Lighthouse has caused and intends to cause by their conduct. IRI will continue to suffer irreparable harm until Lighthouse s actions are enjoined by this court.
Injunctive relief is designed to reestablish the status quo before the infringing activity began.
IRI s verified complaint clearly meets each of these requirements as they are applied in copyright infringement actions. A TRO and a preliminary injunction should issue in favor of IRI in order to restore the pre-infringement control of IRI over publication of its copyrighted Handbook. Autoskill v. Nat. Verified Complaint, 16-17. Lighthouse has copied the copyrighted Handbook Lighthouse overtly and deliberately acknowledges its access to and possession of electronic versions of substantial portions of the Handbook.