Case: 1:15-cv-02097-CAB Doc #: 1 Filed: 10/08/15 1 of 4. PageID #: 1

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
THOMAS P. MACZUZAK
32 North Parkway Drive
Eastlake, Ohio 44095

Plaintiff,
v.
JOHN DOE (real name unknown)
(real address unknown)
Defendant.

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CASE NO.
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JUDGE:
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) COMPLAINT 
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) COPYRIGHT INFRINGEMENT
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 Case: 1:15-cv-02097-CAB Doc #: 1 Filed: 10/08/15 2 of 4. PageID #: 2

Now comes plaintiff, Thomas P Maczuzak, for his
complaint against the defendant does hereby state and aver
as follows:
NATURE OF THE ACTION
1. This is a civil action arising under the laws of the
United States, specifically under 17 USC § 501 for
copyright infringement.
PARTIES
2. Multiple websites have published the copyright
infringing images marked Exhibit 'A’ though 'F’ (hereafter,
the “Images”) on their websites; and, Google.com and
Bing.com each display the Images in its search results.
JURISDICTION AND VENUE
3. The Court has subject matter jurisdiction pursuant to 17
USC § 501 for copyright infringement law of the United
States.
4. The Court has personal jurisdiction over the Defendants.
On information and belief, defendant has conducted acts of
copyright infringement.
5. Venue is proper in this District. On information and
belief, Defendants are subject to personal jurisdiction in
this District and the acts complained of herein take place
within this District.
FACTS

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 Case: 1:15-cv-02097-CAB Doc #: 1 Filed: 10/08/15 3 of 4. PageID #: 3

6. Plaintiff is the authorized copyright agent for the
infringing Images.
7.

Plaintiff is the copyright owner of the Images.

8.

That use and publication of the Images on the infringing

websites is unauthorized and is a DMCA infringement on
Plaintiff’s ownership rights.
9. The Images published on the websites were widely
distributed and published to third parties.

COUNT I – COPYRIGHT INFRINGEMENT
10. All prior paragraphs and averments are included as if
fully restated herein.
11. Defendants use of the Images is directly resulting in
severe harm to Plaintiff resulting in defamation,
disparagement and invasion of privacy to Plaintiff.
12. As a direct result of Defendant’s use of the Images,
Plaintiff has been severely harmed, ridicules, and suffered
direct loss to reputation, loss of business, shame and
dishonor and egregious harm and damage.

WHEREFORE:

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 Case: 1:15-cv-02097-CAB Doc #: 1 Filed: 10/08/15 4 of 4. PageID #: 4

Plaintiffs pray for relieve as follows:
1. An order demanding Google.com and Bing.com to remove
search results containing the Images from when keywords “Tom
Maczuzak”, “Thomas Maczuzak”, “Lily Maczuzak”, “Li Li
Maczuzak” and “LiLi Maczuzak”.

Respectfully submitted,
Thomas P. Maczuzak, Esq.

Thomas P. Maczuzak #0079464
Attorney for Plaintiff
32 N Parkway Drive, Eastlake,
Ohio 44095
(440)342-3035

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