Complaint
(Copyright Infringement)


Summary

This template is a complaint that alleges copyright infringement of a federally registered copyrighted work under Section 501 of the Copyright Act (17 U.S.C. § 501). This template includes practical guidance, drafting notes, and alternate and optional clauses. This complaint assumes that the plaintiff owns a valid copyright, that the plaintiff's work is registered, and that counsel has a good faith basis to pursue the claim of infringement in accordance with Fed. R. Civ. P. 11. For a work to be copyrightable and hence valid, it must be a work of authorship (i.e., the appropriate subject matter), original, minimally creative, and fixed in a tangible medium of expression. 17 U.S.C. § 102(a). For more on these requirements, see Copyright Fundamentals. As to registration, a registration certificate must actually issue before you can file suit. See Fourth Estate Pub. Benefit Corp. v. Wall-Street.com, LLC, 139 S. Ct. 881, 888 (2019). This complaint does not include any other claims aside ...