On October 3, 2019, Pearson Education, Inc.; Elsevier Inc.; Cengage Learning, Inc.; Bedford; Freeman & Worth Publishing Group, LLC d/b/a Macmillan Learning; and McGraw-Hill Global Education Holdings, LLC (collectively, “Plaintiffs”) filed suit alleging copyright infringement against Raheim J. Mofield, a/k/a James Reynolds, individually and d/b/a www.worldmediaincorporated.com (collectively, “Defendants”). In their complaint, Plaintiffs purport that Defendants were, “hiding behind the anonymity of the internet,” and circumvented copyright law by selling unauthorized digital copies of textbooks as well as other copyrighted works to consumers. Plaintiffs state that the Defendants violated 17 U.S.C. § 101 by infringing on the copyrights of Plaintiffs; the Plaintiffs produced a list of works that Defendants have allegedly reproduced and/or distributed in violation of Plaintiff’s copyrights (the “Works”).
According to the Plaintiffs, Defendants operate an “illegal online store” where they allegedly reproduce and distribute unauthorized copies of the Works. Plaintiffs assert that the Defendants conduct their business via email and over the Internet, “making concerted efforts to conceal their true names and physical locations” in addition to registering their domain name anonymously through a proxy. Plaintiffs claim to have sent multiple infringement notices to Defendants, and Defendants’ service provider, Google, demanding removal of the infringing material. In at least one instance, the Defendants sent a counter notification to Google claiming that Plaintiffs’ ownership of a specific work was somehow in dispute.
The alleged reproduction and distribution of the Works infringe Plaintiffs’ exclusive rights under 17 U.S.C. § 501 and violates 17 U.S.C. §§ 106(1) and 106(3). Plaintiffs assert that Defendants’ infringement is intentional and willful and Plaintiffs’ seek both monetary and injunctive relief.