JS 44C/SDNY

REV. 4/2014

JU

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nCC f"r>.'^

CIVIL COVER SHEET

The JS-44 civil coversheet and the information contained hereinneitherreplacenorsupplementthe filing and serviceof
pleadings or otherpapersas required bylaw, except as provided bylocal rules ofcourt. This form, approved bythe
Judicial Conference ofthe United States inSeptember1974,is required foruse ofthe Clerk of Courtforthe purposeof

initiating the civil docket sheet.

n^

_^

CV 199&V

DEFENDANTS -*- ^J

PLAINTIFFS

MICHEL LEAH KECK

FX NETWORKS, LLC,

TWENTIETH CENTURY FOX HOME ENTERTAINMENT LLC, and

DOFS 1-10

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER

ATTORNEYS (IF KNOWN)

BRESSLER LAW PLLC, 3 WEST 35TH ST., 9TH FL, NEW YORK, NY
10001

TEL (917) 969-4343

CAUSE OFACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)

17 USC 101 et seq. (including Sec. 501 direct and indirect copyright infringement; Sec. 1202 copyright management info, violations)

Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? Nc&esQludge Previo|Jl4|esig'r}ed/
If yes, was this case Vol. Q Invol. []] Dismissed. No Q Yes Q
Is THISAN INTERNATIONAL ARBITRATION CASE?

No 0

(PLACE AN [x] IN ONEBOXONLY)

If yes, give date

fj-

-.
I *>

&Case No.

Yes
NATURE OF SUIT
ACTIONS UNDER STATUTES

CONTRACT

PERSONAL INJURY

PERSONAL INJURY

[ J 367 HEALTHCARE/
[
[
[
[

J no
1120
]130
1140

[]150

[ ] 151
[ ]152

INSURANCE
MARINE

( J 310 AIRPLANE
( ] 315 AIRPLANE PRODUCT

MILLER ACT

LIABILITY

NEGOTIABLE

[ J 320 ASSAULT, LIBEL &

INSTRUMENT
RECOVERY OF
OVERPAYMENT &
ENFORCEMENT
OF JUDGMENT
MEDICARE ACT
RECOVERY OF
DEFAULTED
STUDENT LOANS

SLANDER

RECOVERY OF
OVERPAYMENT
OF VETERAN'S

[ ] 365 PERSONAL INJURY

PRODUCT LIABILITY

[ J 368 ASBESTOS PERSONAL

LIABILITY

[ ] 350 MOTOR VEHICLE

[ ] 355 MOTOR VEHICLE
PRODUCT LIABILITY
INJURY

SOCIAL SECURITY

[ ] 362 PERSONAL INJURY MED MALPRACTICE

PROPERTY DAMAGE

[ ] 385 PROPERTY DAMAGE

[ ]463 ALIEN DETAINEE

ACTIONS UNDER STATUTES
CIVIL RIGHTS

OTHER CIVIL RIGHTS

(Non-Prisoner)

[ ]290

[ j442 EMPLOYMENT

CONDEMNATION
FORECLOSURE

[ ] 443 HOUSING/

RENT LEASE &

[ ] 445 AMERICANS WITH

LIABILITY
ALL OTHER

[ ] 710 FAIR LABOR

STANDARDS ACT

[ ) 720 LABOR/MGMT

VACATE SENTENCE
2B USC 2255

( ] 530 HABEAS CORPUS

[ ] 535 DEATH PENALTY
[ ] 540 MANDAMUS & OTHER

ACCOMMODATIONS

DISABILITIES EMPLOYMENT

ANTITRUST
BANKS & BANKING
COMMERCE
DEPORTATION
RACKETEER INFLU
ORGANIZATION ACT

(RICO)
[ ] 480 CONSUMER CREDIT
[ ] 490 CABLE/SATELLITE TV

] 861
1 862
] 863
] 864
] 865

HIA (1395ff)
BLACK LUNG (923)
DIWC/DIWW (405(g))
SSID TITLE XVI
RSI (405(g))

[ ] 850 SECURITIES/
EXCHANGE

( ] 890 OTHER STATUTORY

ACTIONS

[ ] 740 RAILWAY LABOR ACT

[ ] 751 FAMILY MEDICAL

LEAVE ACT (FMLA)
[ ] 790 OTHER LABOR
LITIGATION

[ ] 791 EMPL RET INC

IMMIGRATION

PRISONER CIVIL RIGHTS

[ ] 462 NATURALIZATION
[ ] 550 CIVIL RIGHTS
[ ) 555 PRISON CONDITION
[ ] 560 CIVIL DETAINEE

[
[
[
[
[

RELATIONS

SECURITY ACT

[ ] 441 VOTING

TORT PRODUCT

LABOR

PRODUCT LIABILITY

[ ) 440

TORTS TO LAND

] 410
] 430
]450
J 460
] 470

COMMODITIES/

[ ) 380 OTHER PERSONAL

[ ] 510 MOTIONS TO

[ I 240
I ]245

PROPERTY RIGHTS

REAPPORTIONMENT

[
[
(
I
[

[ ] 360 OTHER PERSONAL

[ ]195

EJECTMENT

28 USC 157

[X] 520 COPYRIGHTS

[ 1 830 PATENT
[ 1 840 TRADEMARK

[ ] 370 OTHER FRAUD

[ ] 371 TRUTH IN LENDING

CONTRACT
CONTRACT

[ ]220
[ ]230

I 1375 FALSE CLAIMS

ENCED & CORRUPT

PRISONER PETITIONS

LAND

[ 1423 WITHDRAWAL

[ ] 690 OTHER

[ ] 345 MARINE PRODUCT

OTHER

[ 1210

21 USC 881

LIABILITY

[ ] 190

REAL PROPERTY

[J 400 STATE

28 USC 158

SEIZURE OF PROPERTY

PERSONAL PROPERTY

SUITS

[ ] 196 FRANCHISE

OTHER STATUTES

LIABILITY

STOCKHOLDERS

PRODUCT
LIABILITY

BANKRUPTCY

[ J422 APPEAL

INJURY PRODUCT

EMPLOYERS'

[ ] 340 MARINE

BENEFITS

[]160

INJURY/PRODUCT LIABILITY

| ] 330 FEDERAL

(EXCL VETERANS)
[]153

FORFEITURE/PENALTY

PHARMACEUTICAL PERSONAL , , 625 DRUG RELATED

APPLICATION

[ J 465 OTHER IMMIGRATION

ACTIONS

[ ) 891 AGRICULTURAL ACTS

FEDERALTAX SUITS

[ ] 870 TAXES (U.S. Plaintiff or

Defendant)
[ ] 871 IRS-THIRD PARTY

[ ] 893 ENVIRONMENTAL
MATTERS

[ ] 895 FREEDOM OF

26 USC 7609

INFORMATION ACT

[ ] 896 ARBITRATION
( J 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR
APPEAL OF AGENCY DECISION

[ ] 950 CONSTITUTIONALITY OF
STATE STATUTES

CONDITIONS OF CONFINEMENT

[ 1446 AMERICANS WITH

DISABILITIES -OTHER

[ ] 448 EDUCATION

REAL PROPERTY

Check ifdemanded incomplaint:

CHECK IF THIS IS ACLASS ACTION

UNDER F.R.C.P. 23

DEMAND $250,000+

other injunction

PPgY^O^Cl^M THIS CASE IS RELATED TO ACIVIL CASE NOW PENDING IN S.D.N.Y.?

JUDGE

DOCKET NUMBER

Check YES onlyifdemanded in complaint

JURY DEMAND: EYES LKlO

NOTE: You mustalso submitat the timeof filing the Statement of Relatednessform (Form IH-32).

(PLACE AN x INONEBOXONLY)

1 Original
Proceeding

(Zl 2

ORIGIN
Removed from

s(ate Couft

L-1 3 Remanded Lj 4 Reinstated or

LJ 5 Transferred from Q 6

Reopened

from

(Specify District)

Multidistrict

I I 7 Appeal to District

Litigation

Judge from
Magistrate Judge
Judgment

Appellate

| | 3. all parti*; represented

Court

| | b. Atleastone
party is pro se.

(PLACEAN XINONEBOXONLY)

1 U.S. PLAINTIFF

BAS|S OF JURISDICTION

Q 2 U.S. DEFENDANT fx] 3 FEDERAL QUESTION

IF DIVERSITY, INDICATE

D4 DIVERSITY

CITIZENSHIP BELOW.

(U.S. NOT A PARTY)

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

(Place an [X] in one box for Plaintiff and one box for Defendant)
PTF

DEF

CITIZEN OF THISSTATE

( ]1

| ]1

CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY

[ ]3[ |3

CITIZEN OF ANOTHERSTATE

( )2

| ]2

INCORPORATED or PRINCIPAL PLACE

[ )4 [ )4

PTF DEF

INCORPORATED and PRINCIPALPLACE

PTF

DEF

(]5

[]5

OF BUSINESS IN ANOTHER STATE

FOREIGN NATION

]6

OF BUSINESS IN THIS STATE

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)

MICHEL LEAH KECK
271 EAST 400 SOUTH

VALPARAISO, IN 46383

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)

FX NETWORKS, LLC, Fox Networks Group, P.O. Box 900, Beverly Hills, CA 90213, Los Angeles
County.

TWENTIETH CENTURY FOX HOME ENTERTAINMENT LLC, 2121 Avenue of the Stars, 7th Floor,
Los Angeles, CA 90067, Los Angeles County.
DEFENDANT(S) ADDRESS UNKNOWN
REPRESENTATION IS HEREBY MADE THAT. AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE. TO ASCERTAIN
RE31BENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

DOES 1-10

Check one:

THIS ACTION SHOULD BE ASSIGNED TO:

Q WHITE PLAINS

\x\ MANHATTAN

(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTS
COMPLAINT.)

DATE 3/17/15.

it^NATURE OF ATTORNEY OF RECORD

A/\\V-w-

\Jt\\_S><CX

ADMITTED TO PRACTICE IN THIS DISTRICT

~_

11 N0

'

[Xj YES (DATE ADMITTED Mo.MAY

RECEIPT #

Attorney Bar Code #JB8780

Magistrate Judge is to be designated by the Clerk of the Court.

t^nri"'T'"V'i L7*]

Magistrate Judge

m.:r^M

Ruby J. Krajick, Clerk of Court by

Deputy Clerk, DATED

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

liFoifm

Save

is so Designated.

Yr. 1993

IN THE UNITED STATES DISTRICT COURT

JUDGE ENGELMAYER

FOR THE SOUTHERN DISTRICT OF NEW YORK

15 CV 1

MICHEL LEAH KECK,

Plaintiff,

Civ. Act. No.

COMPLAINT

DEMAND FOR JURY TRIAL

FX NETWORKS, LLC, TWENTIETH CENTURY FOX

HOME ENTERTAINMENT LLC, and DOES 1-10,

Defendants.

COMPLAINT

Plaintiff Michel Leah Keck ("Keck"), by and via its counsel of record BRESSLER
LAW PLLC, alleges for its Complaint against FX Networks, LLC ("FX Networks"). Twentieth
Century Fox Home Entertainment LLC ("Fox Home Entertainment"), and DOES 1-10

(collectively, FX Networks, Fox Home Entertainment and DOES 1-10 are the "Defendants"):

Nature of the Action

1. This is a civil action againstDefendants for their wrongful acts of direct and

indirect copyright infringement and for their copyright management information ("CM")
violations (U.S. CopyrightAct, 17 U.S.C. 101 et seq.).

The Parties

2. Plaintiff Keck is an individual having an address at 271 East 400 South,

Valparaiso, IN 46383.

3. Defendant FX Networks is a limited liability company organized under the laws

of the State of Delaware and qualified to do business in New York. On information andbelief,

FX Networks has a mailing address at Fox Networks Group, P.O. Box 900, Beverly Hills, CA
90213-0900. Its registered agent for receipt of service of process recorded with the New York

State Department of State is CT Corporation System, 111 Eighth Avenue, New York, New York
10011.

4. Defendant Fox Home Entertainment is a limited liability company organized

under the laws of the State of Delaware and qualified to do business in New York. On

information and belief, Fox Home Entertainment has a mailing address at 2121 Avenue of the

Stars, 7th Floor, Los Angeles, California, 90067. Its registered agent for receipt of service of
process recorded with the New York State Department of State is CT Corporation System, 111
Eighth Avenue, New York, New York 10011.

5. Defendants DOES 1 through 10 inclusive currently are unknown to Keck; as

such, Keck identifies those defendants in this action with fictitious names. Keck is informed and

believes that each of the defendants designated as DOES is legallyresponsible at least in part for
the events and actions constituting the conduct damaging Keck. Keck will seek to amend this
Complaint to identify and include the actual names and capacities of such defendants after Keck
has determined such data.

Jurisdiction and Venue

6. This Court has jurisdiction over the subject matter of this action pursuantto 28
U.S.C. 1331 and 1338(a) and 17 U.S.C. 501(a), as this action alleges infringement of

Page 2 of 17

registered U.S. copyright rights and other violations of the copyright laws of the United States,
17 U.S.C. \0letseq.

7. This Court has personal jurisdiction over FX Networks because it does business,
transacts business and/or is qualified to do business within the State of New York for all times
relevant to Keek's claims asserted in this action.

8. This Court has personal jurisdiction over Fox Home Entertainment because it

does business, transacts business and/or is qualified to do business within the State of New York
for all times relevant to Keek's claims asserted in this action.

9. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b)(1),

1391(c)(2) and 1400(a) because FX Networks and Fox Home Entertainment are subject to
personal jurisdiction in this district.

Facts

Michel Leah Keck and Her Original Works of Art

10. Plaintiff Michel Keck is a fine artist by profession. Since 2003, Keck has focused

her efforts toward earth-tone abstract painting, mixed media paintings and collages, and art using
recycled materials, among other media. Keck is a rare breed: the self-taught, self-represented,
successful and critically acclaimed artist. In 2006, Keck successfully opened her own online art
gallery www.michelkeck.com, as well as her own fine art publishing company. By the end of
2006, Keck sold over 1,500 original paintings to art collectors throughout the U.S., Canada,
Brazil, Japan, Australia, New Zealand, Netherlands, Ireland, Chile, France, Italy, Austria,

Page 3 of 17

Portugal, Greece, Norway, Malta, Puerto Rico and the United Arab Emirates. Keck has exhibited

original abstract art paintings and mixed media assemblages in London, New York, Chicago, Los
Angeles, Dallas, Indianapolis, High Point, Pittsburgh, Lake Tahoe and Las Vegas. Keck is
regarded as one of the most successful self-representing artists working today, and she continues
to pave the way for self-representing artists worldwide.
11. Keck is and has been for all times relevant to the claims asserted in this action the

exclusive owner of all copyright rights in and to the original works of art reproduced and
attached to this Complaint as Composite Exhibit A. each of which is registered with the U.S.

Copyright Office effective on November 10, 2014: "Sink or Swim" (U.S. Copyright Reg. No.
VA 1-933-894); "The Best Is Yet To Come" (U.S. Copyright Reg. No. VA 1-933-895); and
"I Don't Want To Hear It" (U.S. Copyright Reg. No. VA 1-933-898) (collectively, the "Works").

The "specimen" watermark has been added for this Complaint exhibit to the copies of the Works.
A true copy of each copyright registration certificate is attached to this Complaint within
Composite Exhibit A behind each Work to which it pertains.

12. Keck is the sole author of each of the Works. For all times relevant to this action,
Keck owns and has owned all copyright rights in and to each of the Works since their creation.

Each of the Works is original to Keck, is a proper subject of protection under the U.S. Copyright
Act, and is protected internationally by valid and subsisting copyright rights.

Page 4 of 17

Defendants and Their Animated Television Series Archer

13. Defendants produce, broadcast and otherwise distribute the animated television

seriesArcher, an award-winning, critically acclaimed, wildly successful adult-oriented half-hour

spy workplace spoof comedy. Archer features its main character Sterling Malory Archer, a

suave, narcissistic, self-absorbed, caustic, sniping, womanizing James Bondtype, always witha
clever quip and cocktail in hand notwithstanding the grave perilshe faces while executing his
masterspy missions for the "International Secret Intelligence Service" (or "ISIS," as the show
calls it).

14. While tackling matters of geopolitical conflict and global espionage, Sterling also

must sort his profound unresolved mother issues, not in small part because that domineering
mother - Malory Archer - runs ISIS and is Sterling's boss. Archer's mother-son conflict is a

dominanttheme pervading the series. The show repeatedly pits these two central characters

against each other concerning Sterling's feelings of childhood abandonment, his flouting of ISIS
office rules directed to expense account abuse and fraternization, Malory's unwillingness to
applaud Sterling for his indisputable master spy talents and achievements, and other matters

cultivated and calibrated to leverage and amplify the show's irreverent, snarky tone.
15. TheArcher series exhibits a distinctive and readily recognizable artistic design.
Characters' faces are based on the actual faces of actors and models. Sets are based on

photographs and other works of art. The series' design aesthetic juxtaposes camp character
illustration and animation against sophisticated, life-like sets. A 2014 interview with Archer's art

director and animation director provides a glimpse of how intricately andthoughtfully Archer is

Page 5 of 17

designed and produced. Quoted from that interview: "[T]he important thing about Archer is just
how it looks. [...] We wanted the backgrounds to have those lush painted textures." A true copy
of the interview is attached to this Complaint as Exhibit B (red text highlight boxes added at its
pages 4 and 6 for convenience).

16. To better understand how closely Archer's design aesthetic tracks its real-world
underpinning, compare the "before" and "after" Archer images pasted below. Note the

substantially identical color schemes, perspectives, wall tile arrays, sink shapes, faucet shapes,
mirror frames, mirror wall mount, and reflections of the sink, faucet, door frame and wall-

mounted hand soap dispenser. On information and belief, the Archer's inclusion of these

elements in the "after" image is a conscious, deliberate design choice.

17. Archer's ISIS headquarters are housed in well-appointed office space within a
commercial building in New York City, thoughtfully designed to accommodate the unusual

Page 6 of 17

needs of a spy agency. Ms. Archer's office is a primary Archer set, pervasively featured

throughout the first four seasons of the series. Episodes feature Malory's office as the place in
which Malory briefs her subordinates on the spies' missions, monitor operations, disciplines
misbehavior, and conducts sultry videoconferences with her clandestine, geopolitically incorrect
romantic interests.

18. Archer has grown from a cult phenomenon into a wildly popular show, expanding
its audience since the pilot episode's 2009 televisionpremiere. On informationand belief, it is or

has beenthe number one rated show on FX Networks among adults age 18-49 years.
19. Archer won the Critics' Choice Television Awards for Best Animated Series in

2012, 2013 and 2014. It also won the IGN People's Choice Award for Best TV Animated Series

in 2011. Archer has received numerous other nominations, including one for the 2014 Primetime
Emmy Award for Outstanding Animated Program, and Annie Awards nominations in each of
years 2012,2013,2014 and 2015.

20. On January 8, 2015, Archer's season 6 premiere aired to an audience of

approximately 1.5 million viewers. In March 2014, Archer was renewed for a seventh season. On

information and belief, no plans have been announced to wind up production.

21. On informationand belief, Internet audiovisual content streaming services

Netflix, Hulu, and Amazon Prime provide the 62 Archer episodes aired during seasons 1-5 to

their respective subscribers for continuous, on-demand viewing, making the series episodes
highly and conveniently accessible to vastaudiences. Defendants also sell and distribute copies
of those episodes to the general public on DVD format digital discs. Viacom's Comedy Central

Page 7 of 17

purchased off-network rights to the Archer series for broadcast via its cable channel scheduled to

begin in May 2015, which will further expand the reach of and audience for Archer.

Defendants' Unauthorized Uses of Keek's Works In Archer

22. In November 2014, Keck discovered that Defendants have been using her Works
in Archer.

23. Ms. Archer's richly detailed ISIS office set features prominent framed paintings

that use the Works, or derivatives. True copies of screen captures derived from Netflix streaming
of a representative Archer episode from each of the first four seasons are attached to this
Complaint as Composite Exhibit C.

24. Neither Keck nor anyone else authorized Defendants to use the Works in any
form as part ofArcher.
25. Archer does not credit Keck as a contributor or otherwise.

26. On information and belief, FX Networks and Fox Home Entertainment operate
sophisticated media production and distribution businesses with trained staff and an excellent

working knowledge of copyright lawprinciples and rights clearance practices. Inexplicably,

Defendants used the Works as part ofArcher without even seeking thenecessary permission to
do so.

Page 8 of 17

FIRST CLAIM FOR RELIEF

Copyright Infringement

As against all Defendants

27. Keck repeats and realleges the allegations set forth in the previous paragraphs of
this Complaint as if fully set forth herein.
28. Without authorization or consent, Defendants created derivative works based on,

reproduced, publicly displayed, distributed, transmitted, and otherwise used the Works as part of
Archer.

29. On informationand belief, Defendants knew that they did not possess any rights
to use the Works as part of Archer or otherwise.

30. On information and belief, Defendants cropped, blurred and/or otherwise

manipulated the Works to conceal that those manipulated works were derived from Keek's
Works.

31. On information and belief, Defendants have received substantial benefits from

their unauthorized reproduction, public display, distribution, transmission and uses of the Works,
which contribute to the unique artistic appeal, look and feel of Archer.

32. On information and belief, Defendants performed their wrongful acts willfully
and knowingly, with intentional disregard for Keek's exclusive copyright rights in and to the

Works, and for the purposes of trade and profit, including by means of the sale and licensing of
audiovisual content, merchandise and advertising services.

Page 9 of 17

33. Keck has been damaged by Defendants' unauthorized uses of the Works,

including without limitation in the forms of diversion of trade, loss of profits, dilution of the
value of rights in the Works, and erosion of the market value of the Works, in an amount to be
determined at trial.

34. Among other relief, such wrongful conduct entitles Keck to an award of a

permanent injunction against continued use, and actual damages suffered as a result of such
infringement, plus Defendants' additional profits attributable to such infringement, in an amount
to be determined at trial, plus recovery of its costs. 17 U.S.C. 504(a)(1) and 505.

To the extent that Keek's registration of copyright rights in and to the Works is timely, Keck is
entitled to opt for an award of statutory damages in an amount up to $30,000 (or $150,000 if
infringement is willful) per work infringed, and also is entitled to an award of a reasonable
attorney's fee.

SECOND CLAIM FOR RELIEF

Secondary Copyright Infringement

As against all Defendants

35. Keck repeats and realleges the allegations set forth in the previous paragraphs of
this Complaint as if fully set forth herein.

36. On informationand belief, Defendants knew and intended that third persons and
entities would take, reproduce, transmit, distribute, publicly display, and proliferate the Works as
part ofArcher without Keek's authorization or consent.

Page 10 of 17

37. On information and belief, because Defendants contributed to and induced third

person infringement ofthe Works and knew orshould have known ofsuch infringement, they
are liable for contributory infringement of the Works.

38. On information and belief, because Defendants had the right and ability to control

reproduction, transmission, distribution, public display, and proliferation ofthe Works as part of
Archer, which benefitted Defendants commercially, they also are liable for vicarious
infringement of the Works.

39. Among other relief, such wrongful conduct entitles Keck to an award of a

permanent injunction against continued use, and actual damages sufferedas a result of such

infringement, plus Defendants' additional profits attributable to such infringement, inanamount

to be determined at trial, plus recovery of its costs. 17U.S.C. 504(a)(1) and 505. To theextent

that Keek's registration of copyright rights in and to the Works is timely, Keck is entitled to opt
for anaward of statutory damages in an amount up to $30,000 (or$150,000 if infringement is
willful) per work infringed, and also is entitled to anaward of a reasonable attorney's fee.

THIRD CLAIM FOR RELIEF

Provision and Distribution of False Copyright Management Information (CMP

As against all Defendants

40. Keck repeats and realleges the allegations set forth in the previous paragraphs of
this Complaint as if fully set forth herein.

Page 11 of 17

41.17 U.S.C. 1202 (a) prohibits providing anddistributing false CMI: "No person

shall knowingly and with the intent to induce, enable, facilitate or conceal infringement - (1)
provide CMIthat is false, or (2) distribute or import for distribution CMI that is false.

42. 17 U.S.C. 1202 (b) prohibits removing or altering CMI and distributing CMI

knowing that it has been removed or altered without the permission ofthe copyright owner:
No person shall, withoutthe authority of the copyright owner or the law
(1) intentionally remove or alter any copyright management information,
(2) distribute or import for distribution copyright management information
knowing that the copyright management information has been removed or

altered without authority of the copyright owner or the law, or (3)

distribute, import for distribution, or publicly perform works, copies of
works, or phonorecords, knowing that copyright management information
has beenremoved or altered without authority of the copyright owner or
the law,

knowing, or, with respect to civil remedies under section 1203, having
reasonable grounds to know, that it will induce, enable, facilitate, or
conceal an infringement of any right under this title.

43. CMI includes "(1)the title and other information identifying the work, including
the information setforth on a notice of copyright, (2) thename of, andother identifying
information about, the author of a work, (3)the name of, and other identifying information
about, the copyright owner of the work, including the information set forth in a notice of

copyright, and ... (6) the terms and conditions for use of the work." 17 U.S.C. 1202(c)(1),
(2), (3) and (6).

44. On information and belief, with the intent to induce, enable, facilitate and/or

conceal infringement, Defendants removed or excluded Keek's name, her Works' titles, and her
Page 12 of 17

copyright notices, and instead applied without authorization or consent or other right
Defendants' own copyright notices and claims.

45. On information and belief, withthe intent to induce, enable, facilitate and/or
conceal infringement, Defendants provided and distributed false CMI with their unauthorized

reproduction, public display, distribution, transmission and uses ofthe Works as part ofArcher.
46. On information and belief, with the intentto induce, enable, facilitate or conceal

copyright infringement, Defendants knowingly provided and distributed false CMI when they
applied their own CMI to the Works (for example, the copyright notice), in violation of 17
U.S.C. 1202.

47. On information andbelief, knowing or having reasonable grounds to know that

Defendants would induce, enable, facilitate orconceal infringement ofexclusive rights under
Title 17 U.S.C, Defendants (1) intentionally removed oraltered CMI for the Works, (2)

provided false CMI for the Works (for example, by providing the FX Networks Copyright
Notice without authorization and consent), (3) distributed false CMI for the Works without due

authority; and (4) distributed and publicly performed and displayed copies of the Works with

false CMI without due authority, all inviolation of 17 U.S.C. 1202(b)(1), (2) and (3).
48. Such wrongful conduct damaged Keck in an amount to be determined at trial.
49. Among other relief, such wrongful conduct entitles Keck to an award of a

permanent injunction against continued CMI violations, and actual damages suffered due to such

violations, plus Defendants' additional profits attributable to the CMI violations (17 U.S.C.

1202(b)(3) and 1202(c)(2)), orif and as Keck opts in her sole discretion, statutory damages in

Page 13 of 17

an amount of up to $25,000 per CMI violation (17 U.S.C. 1203(c)(3)(b)), plus a reasonable
attorney's fee and costs (17 U.S.C. 1203(b)(4) and (5)).

Prayer for Relief

WHEREFORE, Keck respectfully requests judgment against each of the Defendants

as follows:

a. declaring Defendants liable for direct infringement of the exclusive

copyright rights in and to the Works;

b. declaring Defendants liable for contributory and vicarious infringement of

the exclusive copyright rights in and to the Works;
c. declaring Defendants liable for removal or alteration of CMI for the Works

and for provision and distribution of false CMI for the Works;

d. enjoining Defendants from unauthorized reproduction, public display,

transmission, distribution and all otheruses of the Works, from providing and distributing
false CMI for the Works, and from removing or altering CMI for the Works;

e. for Defendants' direct, contributory and vicarious copyright infringement,

awarding Keck monetary damages in an amount equal to her actual damages and
Defendants' additional profits attributable to such infringement, in an amount to be

determined at trial (17 U.S.C. 504(a)(1)), plus costs (17 U.S.C. 505), or if and as Keck

opts in her sole discretion to the extent that copyright registration of the Works is timely,
an award of statutorydamages, and also an award of a reasonable attorney's fee;

Page 14 of 17

f. for Defendants' CMI violations, awarding Keck monetary damages in an

amount equal to her actual damages and Defendants' additional profits attributable to such

CMI violations, in an amount to be determined at trial (17 U.S.C. 1202(b)(3) and

1202(c)(2)), or if and as Keck opts in her solediscretion, statutory damages in an amount

of $25,000 per CMI violation (17 U.S.C. 1203(c)(3)(b)), plus a reasonable attorney's fee
and costs (17 U.S.C. 1203(b)(4) and (5));

g. compelling Defendants to account to Keck for all profits, income, receipts

and otherbenefits derivedby them from the reproduction, distribution, transmission,

public display, promotion, and sale of products, services and media that infringe copyright
rights in and to the Works (17 U.S.C. 504(a)(1) and 501(b));

h. compelling Defendants to account to Keck for all profits, income, receipts

and otherbenefits derived by them from their removal or alteration of CMI for the Works,

andfrom theirprovision and distribution of false CMI for the Works (17 U.S.C.
1203(b)(3) and 1202(c)(2)); and

i. awarding Keck suchother and further reliefas the Courtdeems just and
proper.

Page 15 of 17

Dated: New York, New York

Respectfully submitted,

March 17,2015

^hua R. Bressler (JB8780)

sler Law PLLC

3WeV35th Street, 9th Floor

New York, NY 10001

Tel: (917) 969-4343

Fax:(917)591-7111

Counselfor Plaintiff
Michel Leah Keck

Page 16 of 17

DEMAND FOR JURY TRTAL

Plaintiff Michel Leah Keck hereby demands trial by jury of all issues sotriable
under the law.

Dated: New York, New York

March 17,2015

Respectfully submitted,

JoshMR. Bressler (JB8780)

Bressle^Law PLLC

3 West 35th Street, 9th Floor

New York, NY 10001

Tel: (917) 969-4343

Fax: (917)591-7111

Counselfor Plaintiff
Michel Leah Keck

Page 17 of 17

Sink or Swim

.g.wt.uU.vu

>?:). r-jads ;j r-i-.ri O: the Copyright Off!'.:;? ^-.ros'&s

Regisfcratioa Number

VA 1-933-894
Effective date of

registration:
November 10,2034

Title of Work: Sink or Swim

jwwmmwuww*m'

Year of Completion:

2008

Date of 1st Publication: April 20,2008

Nation of 1st Publication: United State

***JM**^*****M***MxmYYWYmmr\rmn

Author:

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Work made for hire:

Citizen of:

Michel Leah Keck

2-D artwork

No
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Domiciled in;

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Copfright claimant ;
Copyright Claimant: Michel Leah Keck

271 East 400 South, Valparaiso, IN, 46383,: United States

glits and Permissions

Nanae:

WWWXIWWULVJWtMAIWOUAJPCW

Michel Keck

Email: micheI@michelkeck,com
Address:

271 East400.South'

Valparaiso, IN 46383 United States

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Name: Joe G. Naylor

Date:
Applicaat's Trackiag Number:

November 10,2014
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Registration #: VA000I933894
Service Request #: 1-! 885185307

ImageRights International
Joe Grant Naylor
275 Grove Street, Suite 2-400
Newton, MA 02466 United States

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title of Work: The Best is Yet to Come

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October 31, 2007

Natioiti of 1st PubSicatioa: United States

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271 East 400 Soutli, Valparaiso, IN, 46383, United States

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Date: November 10,2014

Applicant's Trackisjg Number:

C1122-C
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Registi-atioii #;. VAOOOl933895

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Joe Grant Naylor
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Sentember 3,2008

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Michel Leah Keck

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Domiciled in: . United States

Copyright claimant
Copyright Claimant:

Michel Leah Keck

271 East 400 Soutli, Valparaiso, IN, 46383, United States

Hsgfits and Permissions

Name:

Michel Keck

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Valparaiso, IN 46383 United States

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http://www.awn.com/animationworld/animating-archer

.Animating 'Archer' | Animation World Network

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Animating 'Archer'
Art director Neal Holman and animation director Bryan Fordney explain how Floyd County
Productions brings us FX's animated gem.
By Dan Sarto andJames Gartler | Monday, April 21, 2014at 10:21am
6

In2D,CG, People, Technology,Television | ANIMATIONWorld

r
In

Lana Kane (Aisha Tyler), Archer (H.Jon Benjamin) and Cheryl Tunt(Judy Greer) share a tense momentinthe fifth
season finale of Archer Vice.Copyright FX Networks.

Adam Reed's spyseries Archer underwenta bit of a changethis season,withthe animated heroes
forced bythe FBI to jettisontheir spybusiness in exchange for lives of crime and cocaine-selling.
And country western musicproduction. As you can imagine, they've approached the crime
business withthe same bravado and dysfunction that they used to approach the spy business.

Luckily, there're still thesame people keeping things running smoothly behind-the-scenes. Floyd
County Productions hasbeentherefrom the beginning, infact, andwith five seasons undertheir
belt - and two more still to come - art director Neal Holman and animation director Bryan

Fordney practically havethe process down to a science. Overseeing a staffof sixty at their
Atlanta-based studio, the duo open up about their economicalapproach to keepingArcherand his
crewlooking so darn good, using3Dsoftwareto create the 2D worldofAdam Reed's hilariously
tight scripts.

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Ai Cher and the rest uf the ISISgang ai e the guests of GustavoCaldcron(FredArmisen)and his wifeJuliana(Laui en
Cohan).Calderon is a bigfan of Charlene but Juliana is a biggerfan Df Archer.

Dan Sarto: Tell me a little bit about how this wonderful series comes together. What are your
roles and what's your production pipeline like?

Professional Spotlight:
Jon Landau at FMX 2014

Professional Spotlight:
Chris DeFaria at FMX

Parti

2014 Part!

Professional Spotlight
Andy Serkis at FMX 2014

Carl Rosendahl at FMX

Parti

2014 Part 1

Neal Holman: Archer is not your average cartoon. Weworkvery, very quickly and the department
heads and production heads haveallworked together for so longthat our process is really
streamlined. Ascript iswritten and then things start to sort of branch outward. I will start
working with the storyboard team and while they'rebusystoryboarding a scene, my associate art
director Chad Hurd and I will be designing backgrounds and then workingwith our character
designers. Atthe same time, we're workingwith our 3Ddepartment helpingto buildthe

background designs into3Denvironments. Onthe other side of the track, the producersare
castingand doingthe voicerecordingwith our actors. By the time they are done with an audio

Professional Spotlight:

edit, we will have storyboards to put to their audio and then pass that off to our illustration and

background directors. That'swhenthey start building Archer in a junglesuit or Archer in a

tuxedo. The background department will be painting over renders from our 3Denvironments.

Bryan takesall ofthese elementsand the animaticwith audioand he'll line up all ofthe elements
to go with it and begin animating and compositing.

Bryan Fordney: Another unique thing about the Archer pipelineis that the animation process is
actually done separate from the drawing. Thedrawings are done based on the storyboardsand
the illustration director also sort of directs drawing sequences. We use Adobe After Effects for the
character acting, which is almost more similarto 3Danimation than it is to traditional animation
because we are essentially creating rigs, like3D character puppets, but we are doing it in 2D. That
allows us to workveryquickly and it allows us to add various subtleties that we wouldn't be able to

Professional Spotlight:

Inside Out-Teaser

Alex McDowell at FMX

Trailer

2014 Parti

do with traditional animation.

Pam Poovey(AmberNash)makes a deal that puts everyone in danger.

DS:So the backgrounds are done using 3D software tools?

NH: Yes. The way we get a design going is Chad Hurd and I will work on something that we think
best suits the needs of the scripts and the aesthetic that Adam is going for in his scene. We'llget
his thoughts on it and once a design is locked, we give it to our 3D team and they build that
environment. Once it's built, we can put our camera anywhere inside it and kickout a render and

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http://www.awn.com/animationworld/animating-archer

Animating 'Archer' | Animation World Network

then pass it onto our background team,our painters, who pain over that render. So, it's notjust
an out-of-the-box render that goes straightto television. It goes through our paintersfirst so it
looks more like a paintingthan it does a stale 3Drender.
DS: Now,am I mistaken or is some of the 3D animation done somewhere else in the Midwest?

BF: Trinity Animation does a lot of 3Dworkwith us, like the 3DenvironmentbuildsI'mtalking
about. We rely on them pretty heavily. They're at Lee'sSummit, Missouri.

RayGillette(Adam Reed) and Krieger(Lucky Yates)move some dangerous cargo.

DS: What program do you use for the 2D characters?

NH: Adobe Illustrator is where we're building all of the elements for the character rigs. We'll draw
Archer standing in a tuxedo, but that one illustration of Archer in his tuxedo is split up into several
different layers, so that his hand is on a layer, his forearm is on a layer, his bicep is on a layer, etc.
In After Effects, we'll linkthose three layers together, so that when I move the bicep, the forearm
and the hand move with it. It becomes like a puppet rig.

Career Connections

Multimedia Producer

a dummy head on it because the actual head is a really complicated rig that takes a long time to
develop and we stick on everybody that we draw.

MULTIMEDIA SOFTWARE ENGINEER

NH: It's all about economy and getting the most of what you are doing. There's a lot of smoke

Web Designer

Redbird Flight Simulations

BF: The heads themselves are like a whole other beast, though. When we draw on a body, we put

and mirrors. Wetry to make it look likea lot of animation, but we're very economical. Ifwe are
goingto build a head then that head rig is going to be reallygood. We'll build it once and use it
throughout the year. Weare tryingto use everybit of everythingand nothing reallygoes away.
Any body that Archer is drawn in, likea suit or polo shirt or whatever, you will see repurposed on
drones in the background throughout the season. Nothinggoes to waste here with our

NVIDIA

CGHTechnologies, Inc.

Art Director
2eCreative

Designer

illustrations and our rigs!

2eCreative

Multiple Full-Timeand Visiting Full-TimeFaculty

Ringling College of Art and Design

Recent Comments

Fudge

Season 7 airs in March something. We should be

gettig a trailer either next week or the week after
Rainbow and Nickelodeon Announce 'Winx Club' Season
Seven

11 k pi

ii

lu n,l"

|-ik iar Cyril Figgis (Chris Parnell)and Ray.

DS: But on the flip side, when you look at the finished episodes, it doesn't look like a minimalist
visual presentation. It looks very stylized.

*S**!:w^

NH: That's the goal.

are too ego-maniacal to learn from her. She's

Letting artists do art...

Bonnie is the single best producer at

Dreamworks today. Too bad the other producers

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http://www.awn.com/animationworld/animating-archer

Animating 'Archer' | Animation World Network

BF: There has to bea balance, but we really do feel like theimportant thing about Archer isjust I

confident enough in her own skin to let others

how it looks.

do what they were...

Bonnie Arnold Talks'How to Train Your Dragon 2'

DS: Right, right. He isall about his looks! Turning thesubject toAdam Reed for a second, does he
send you a finished script and then you work with him onthe creation ofthestoryboards?
BF: We usually get a script that isn't quite locked, but notfarfrom it. When he's ready to get FX's

response, that's thedraft we getandstartbuilding from. Adam isjustsuch a strong writer thatwe
can go ahead and startmoving forward with the major builds. And after that, once we have done
a pass ofAct One, wewill send him a PDF ofthestoryboards along with some notes toguide him
through itandhe'll sendback whatever feedback he has. After all theseseasons, I have a pretty
decentidea ofwhatAdam isgoing for whenhe writes a scriptor a scene, so the notes havebeen
pretty minimal.

As a matter of fact I loved and still LOVEthe old

cartoons -Thejetsons, The Flintstones, Wacky

Racers, Scooby Doo, Hannah-Barbera as a
whole. I don't think they are weak pieces of art,
their...

There isanother storyboard revision afterweadd inthe audio. In mostshows, storyboard goes

ADVANCEMENT IN ANIMATION WRmNG

straight to audio andthatisa luxury thatwe don't have because ofourschedule. We generally
finish storyboards fora full episode intwo weeks and two days, andthat'smoving really quickly
forfour people. Sometimes when the audio comes in, an actor's read will be much different than
how wewere reading it when weweredoing the boards, so we have to make revisions. Oneofthe
best thingsabout our production isthat we canturn on a dime and still keepthings movepretty
fluidly.
Could it have been a browser issue? We didn't

NH: Also, wedon'tjuststart one episode, work it until it isdoneandthenstart another - theyare
all overlapping invarious stages. So, while one episode is being written, the previous episode is
being storyboarded and the episodebeforethat is being built and the episode beforethat is being
animated. We generally havefour or sometimes five episodes going in production at one time.

receive any other reports about the feed not

working properly, but we're sorry you weren't
able to watch the show!
Wau:h ihe 42 nd Annual Annie Awards Live!

Amazing1 Congratulations to Everybody,

especially all Those Employees from PDI.
Your Contributions were well Worth-It.:)
'Huwto Train Your Dragon 2' lups 42nd Annual An
Awards

::x:

;:;>: Amir All

AllIranian Animators have boycotted this

Festival. Everyone knows it's PERSIAN GULF, I
don't know what's with these Arab countries?!!
Animate Dubai - Call for Animation

Cheryl is more than a match for a group of bikers.

DS: What's the total timeframe for the production of an episode?

NH: I think it's ten weeks, is that right Bryan?
BF:Yes, that sounds about right.

Featured Poll
Who do you think will the Oscar for Best
Achievement in Visual Effects?

DS: Do you do the post yourselvesat Floyd CountyProductions?

.S Captain America: The Winter Soldier - Dan

DeLeeuw, Russell Earl, Bryan Grilland Dan Sudick

NH: Astrangethingabout this show is that the postworkis done inAfter Effects, the same
program that we use to do the character animation.

: Dawn of the Planet of the Apes -Joe Letteri, Dan

Lemmon, Daniel Barrett and ErikWinquist

BF: Theediting isdone in Final Cutbyan editor, but we often haveto makeadjustments in After

:; Guardians of the Galaxy - Stephane Ceretti,

Nicolas Aithadi, Jonathan Fawkner and Paul

Effects for timing and everything.

Corbould

NH:The onlything that's really not done in-house is the recording and audio mixing.

Hunter and Scott Fisher

:;. Interstellar-Paul Franklin, Andrew Lockley, Ian

; X-Men: Days of Future Past - Richard Stammers,

Lou Pecora, Tim Crosbie and Cameron Waldbauer

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Animating 'Archer' | Animation World Network

Theunflinching voiceof reason - Malory Archer(Jessica Walter).

http://www.awn.com/animarionworld/animating-archer

Bonnie Arnold Talks'How to Train Your Dragon 2'

1 comment 1 day ago

DS: Adam Reed told me recently that the team at Floyd County regularly managesto make the
gags in the script so much funnier than he ever imagined...

ADVANCEMENT IN ANIMATION WRITING'

NH: Well, one example that comes to mindis episode402,1think...the one with Lucas Troy, who

Watch the 42nd Ann ual Annie Awards Live!'

was Timothy Olyphant last season....

2 comments 2 days ago

DS:Oh, yes, his close buddy...

NH: ...Archer's best friend. That episode ends with a just a silent shot of Archer, Lanaand the car.
Thecomedy in it comesfromArcher's facial expression - that tellsthe wholestory. Wejust stay

ontheirfaces as theythinkaboutthe horrorsthey've justgonethrough. It was kind offunny in

the script, butjustseeingthe wayBryan's team really soldthat makes it stand out in my mind as
one of the best examples of our character acting.

BF: Yeah, the cool thing about that was it was the last step in the production. One of our
animatorsjust decided, "OhI'mgoingto makethese really hilarious frowny faces on these

1 comment 2 days ago

'How to Train Your Dragon 2'tops 42nd Annual

Annie Awards

1 comment 3 days ago

Animate Dubai - Call for Animation*

8 comments 3 days ago

The Animation Pimp:ATaleTold by an Idiot"

4 comments 1 week ago

characters at the very end." It really wasn't planned out that way.

NH: Becausewe have such talented improvactors on our cast, I think a lot of people believethe

show is primarily improv and I'd say...95% of it iswritten. What seem like improvised jokesare
actually written on the pageand that speaksto Adam's natural talent as a writer. Heis really
incredible. We're a littlespoiledin that we get Adam Reed scriptsevery two to three weeks. When
we have to shift and work on other projects, I always hold [the other writers] to that same
standard and there is always a disconnect at first, because they are not Adam.
BF: There is a real confidence in the scripts. Like, ifwe are confused partway through the

production because, "This joke justisn't working," andthenwelook back at the script we're like,
"Oh. That's because we didn't do it by the script!"

Archer takes a break from love making and narco-trafficking...but only for a short while.

DS:The stuff is brilliant on a lot of different levels. I think the visual design of this show so

beautifully complimentsthe tone and the comedythat I cannot think of another visualstyle that
would make it any better.

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Animating 'Archer' | Animation World Network

NH: Yeah. Whenwe were doingthe pilotwe wanted something with reallybold linework,thick
heavy lines. Wejust didn'twant to looklike another Family Guy or Simpsons. Alot of the cartoons
that we were seeing had this razor thin line work and that's not to knock those cartoons - it was
just something we didn't reallywant to followsuit with. Wewanted something that would be
different and give a more graphic appeal to the characters. We wanted the backgrounds to have
these lush painted textures. At first it was lookingmore likea '60s comic book but it has sort of
morphedfrom there.

DS: Last question - what are the biggest challenges you face day-to-day and week-to-week in
bringing Archer together?

NH:Some of it is dealing with how best to do really cinematic sequences with limited animation
and limited time. That is something I actually really enjoy because it gives you constraints to work

against. Wedefinitely don't have an unlimited budget and we definitely don't have unlimited
time...but we swing for the fences in our storyboards and really try to make the biggest, baddest
car chase we can and then boil that down into logistical elements that we can actually do. It's one

thing to board a giant fight scene and it's quite another to plan it out to where you can do it
without killing all of your animators.

BF:Yeah, and on these big action episodes, you're really trying to find a balance between the
action-packed sequences and the natural comedy of the voiceover work, which is the core of the
show. With normal episodes, that just comes along naturally, but when we get to these crazy
episodes with tons of adventure, it's vital to find a balance.

Dan Sarto is Publisher and Editor-in-Chief of Animation World Network.

James Gartler is a Canadian writer with a serious passion for animation in all its forms. Hiswork
has appeared in the pages of Sci FiMagazine, and at the websites EW.comand Newsarama.com.

^Tags Archer Floyd County Productions FX TV Animation

:= More From ANIMATIONWorld:
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2 Comments

Carl Pinson -

Verycool and informative.Thanks for the cool interview!

Eclwina

Thank you for this. Archer is one hot mess. And I mean that in a good way.

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