WA State AG & WA Bar Assoc Complaint Against Getty Images and Timothy McCormack

7/29/2019 WA State AG & WA Bar Assoc Complaint Against Getty Images and Timothy McCormack

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Status

Amount Disputed

Actual Savings

Estimated Savings

Activities

Location

NAICS

Complainant

Number

Date

Name Contact Phone Toll Free Email

McCormack Intellectual

Property Law617 Lee StSeattle, WA 98109

(206) 381-8888 legal@mccormackl

egal.com

Getty Images605 5th Ave S Ste 400Seattle, WA 98104

(206) 925-6753 [email protected]

419707

10/31/2012

Respondent(s)

Complaint

Kennewick - Consumer Protection Division

Date Added Activity Type Activity

11/2/2012 Email to Respondent R First Letter to Respondent To:[email protected]

11/2/2012 Email to Respondent R First Letter to Respondent To:[email protected]

541620-Legal Services- All other legalservices

Assignee Granados, Elena H

$0.00

$0.00

$0.00

Code Practice

640 Fees

Practice(s)

Closed

Referral(s)

Name Contact Phone Contact Phone Email

419707

CatalystComplaint Cover Page

Name Phone Day Phone Evening Email

Christopher Vallos573 Monroe BlvdPainesville, OH 44077

(440) 391-0435 (440) 391-0435 [email protected]

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Date Added Activity Type Activity

11/2/2012 Email to Complainant C First Letter to Consumer To:[email protected]

11/21/2012 Email from Respondent

11/21/2012 Email to Complainant C Response from one Respondent To:[email protected]

11/21/2012 Email to Respondent Rsup Closing No Adjustment (R-UNJ) To:[email protected]

11/21/2012 Email from Complainant See doc 419707A and B

12/3/2012 Email from Respondent See doc 419707C

12/7/2012 FAX from Respondent Fax from secondary R is the same as email sent on11/19/2012. Therefore, we will not be adding tofile as it is a duplicate.

12/11/2012 Email to Complainant Csup Closing Unadjusted (C-UNJ) To:[email protected]

12/11/2012 Email to Respondent Rsup Closing No Adjustment (R-UNJ) To:[email protected]

12/11/2012 Resolution-UNADJUSTED

12/14/2012 Email from Complainant

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Description

I am being harrased by Getty Images who is using Timothy B. McCormack ([email protected]) asthe attorney.

Case number 1091514

My website is www.otcpennystockawareness.com and they "claim" I took an image that is represented bythem. of a woman holding a tree and displayed this image on my website. They are wanting $1286 as a fee forthis.

Please help me in this matter.

Chris Vallos

Expected resolution details: This image is not on my website currently.

Complaint Description

Catalyst Report


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R First Letter to Respondent To: [email protected] McKennaATTORNEY GENERAL OF WASHINGTONConsumer Protection Division8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140

November 2, 2012


RE: Christopher VallosFile #: 419707

Dear Getty Images:

Our office has received the enclosed complaint from Christopher Vallos regarding yourbusiness.

We forward consumer complaints to businesses in order to afford the business an opportunity torespond in writing. Many businesses have found this process to be beneficial. Complaints andresponses received in our office are a matter of public record.

Our office informally mediates complaints as a service to consumers and businesses. We maynot act as an advocate or private attorney for either party. However, complaints may indicate apattern of unfair or deceptive trade practices warranting further attention by our office. Failureto respond to this complaint will be reflected in our public records, which are available to thepublic under the Public Records Act.

Our office requests you reply in writing within 21 business days so that we may determine howto proceed in this matter. Please address your response to me and include our file number419707.

Thank you for your attention to this matter.

ELENA H. GRANADOSCP Public Outreach SpecialistConsumer Protection Division(509) 734-7143Fax: (509) [email protected]

ElenaP 11/2/2012

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COMPLAINT SUMMARYConsumer Information

Name:Christopher Vallos

Address:573 Monroe BlvdPainesville, OH 44077

Day Phone:

(440) 391-0435

Evening Phone:(440) 391-0435

E-mail Address:[email protected]

Age Group (optional):59+

Do you want the Attorney General's Office to send this business a copy of your complaint -

Yes

Names and addresses of any other complainants involved:Business Information

Name of business that I am complaining about:McCormack Intellectual Property Law

Address:617 Lee St

Seattle, WA 98109

Phone:(206) 381-8888

Toll-Free:

Fax:

E-mail:

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[email protected]

Name of owner or manager (if known):

Tim McCormack

Names and addresses of any other businesses involved in your complaint:Getty Images605 5th Ave S Ste 400Seattle, WA 98104

Item or service purchased:

Cost of item or service:

Did you sign a contract -No

Date of transaction:

Salesperson's name:

Was an advertisement involved -No

Date and source of advertisement:

About Your Complaint

Have you complained to the business -No

If YES, to whom (include position) -

What response did you receive -

If you have not contacted the business, explain why:Have you filed a complaint about this business with the Attorney General's Office before -

No

If yes, list the file number assigned to that complaint:Have you contacted a private attorney -No

If YES, identify the name and address of the attorney:

Is there a court or other legal proceeding pending -

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No

If YES, please explain:

Explain your complaint in detail:I am being harrased by Getty Images who is using Timothy B. McCormack([email protected]) as the attorney.Case number 1091514My website is www.otcpennystockawareness.com and they "claim" I took an image that isrepresented by them. of a woman holding a tree and displayed this image on my website. Theyare wanting $1286 as a fee for this.Please help me in this matter.Chris VallosExpected resolution details: This image is not on my website currently.

What do you think the business should do to resolve your complaint - (circle one)OtherExplain if you have circled 'Other':

SIGNATUREI understand that by submitting this complaint to the Washington State Attorney General'sOffice my complaint and any response from the business and all communications with AttorneyGenerals Office will become public records under state law. Public records are subject topublic records disclosure requests and as a public record, my complaint and all relateddocuments may be seen by other people.

I declare, under penalty of perjury under the laws of the State of Washington, that the

information contained in this complaint is true and accurate, and that any documents attachedare true and accurate copies of the originals.

I understand that the Washington State Attorney General's Office will contact the party(ies)against which I have filed a complaint in an effort to reach an amicable resolution. I authorizethe party(ies) against which I have filed a complaint to communicate with and provideinformation related to my complaint to the Washington State Attorney General's Office.

Signature Christopher Vallos Date 10/29/2012Received via the InternetCity and State where signed Painesville, OHIO

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R First Letter to Respondent To: [email protected] McKennaATTORNEY GENERAL OF WASHINGTONConsumer Protection Division8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140

November 2, 2012

McCormack Intellectual Property Law617 Lee StSeattle, WA 98109


Dear McCormack Intellectual Property Law:

Our office has received the enclosed complaint from Christopher Vallos regarding yourbusiness.

We forward consumer complaints to businesses in order to afford the business an opportunity torespond in writing. Many businesses have found this process to be beneficial. Complaints andresponses received in our office are a matter of public record.

Our office informally mediates complaints as a service to consumers and businesses. We maynot act as an advocate or private attorney for either party. However, complaints may indicate apattern of unfair or deceptive trade practices warranting further attention by our office. Failureto respond to this complaint will be reflected in our public records, which are available to thepublic under the Public Records Act.

Our office requests you reply in writing within 21 business days so that we may determine howto proceed in this matter. Please address your response to me and include our file number419707.

Thank you for your attention to this matter.


ElenaP 11/2/2012

419707


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COMPLAINT SUMMARYConsumer Information

Name:Christopher Vallos

Address:573 Monroe BlvdPainesville, OH 44077

Day Phone:

(440) 391-0435

Evening Phone:(440) 391-0435

E-mail Address:[email protected]

Age Group (optional):59+

Do you want the Attorney General's Office to send this business a copy of your complaint -

Yes

Names and addresses of any other complainants involved:Business Information

Name of business that I am complaining about:McCormack Intellectual Property Law

Address:617 Lee St

Seattle, WA 98109

Phone:(206) 381-8888

Toll-Free:

Fax:

E-mail:

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[email protected]

Name of owner or manager (if known):

Tim McCormack

Names and addresses of any other businesses involved in your complaint:Getty Images605 5th Ave S Ste 400Seattle, WA 98104

Item or service purchased:

Cost of item or service:

Did you sign a contract -No

Date of transaction:

Salesperson's name:

Was an advertisement involved -No

Date and source of advertisement:

About Your Complaint

Have you complained to the business -No

If YES, to whom (include position) -

What response did you receive -

If you have not contacted the business, explain why:Have you filed a complaint about this business with the Attorney General's Office before -

No

If yes, list the file number assigned to that complaint:Have you contacted a private attorney -No

If YES, identify the name and address of the attorney:

Is there a court or other legal proceeding pending -

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No

If YES, please explain:

Explain your complaint in detail:I am being harrased by Getty Images who is using Timothy B. McCormack([email protected]) as the attorney.Case number 1091514My website is www.otcpennystockawareness.com and they "claim" I took an image that isrepresented by them. of a woman holding a tree and displayed this image on my website. Theyare wanting $1286 as a fee for this.Please help me in this matter.Chris VallosExpected resolution details: This image is not on my website currently.

What do you think the business should do to resolve your complaint - (circle one)OtherExplain if you have circled 'Other':

SIGNATUREI understand that by submitting this complaint to the Washington State Attorney General'sOffice my complaint and any response from the business and all communications with AttorneyGenerals Office will become public records under state law. Public records are subject topublic records disclosure requests and as a public record, my complaint and all relateddocuments may be seen by other people.

I declare, under penalty of perjury under the laws of the State of Washington, that the

information contained in this complaint is true and accurate, and that any documents attachedare true and accurate copies of the originals.

I understand that the Washington State Attorney General's Office will contact the party(ies)against which I have filed a complaint in an effort to reach an amicable resolution. I authorizethe party(ies) against which I have filed a complaint to communicate with and provideinformation related to my complaint to the Washington State Attorney General's Office.

Signature Christopher Vallos Date 10/29/2012Received via the InternetCity and State where signed Painesville, OHIO

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C First Letter to Consumer To: [email protected] McKennaATTORNEY GENERAL OF WASHINGTONConsumer Protection Division8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140

November 2, 2012


RE: McCormack Intellectual Property Law and Getty ImagesFile #: 419707

Dear Christopher Vallos:

The complaint you submitted to our office has been assigned to me. I have provided a copy ofyour complaint to McCormack Intellectual Property Law and Getty Images and requested aresponse within 21 business days. I will notify you when a response is received regarding yourcomplaint.

Our informal mediation service takes approximately 6-8 weeks. Your patience during thisprocess is appreciated.

Our office brings lawsuits in the name of the State of Washington, rather than on behalf ofprivate individuals. If a business does not respond or declines to adjust your complaint, thisoffice cannot require it to do so. The Consumer Protection Act does not give us authority to actas your private attorney.

Our office obtains valuable information from individual consumer complaints. Your complaintwill become part of our public record of business practices. We maintain complaint files ofbusiness practices that may be useful if enforcement action on behalf of the State of Washington

is warranted in the future.

If a response is not received or if your complaint is not resolved, we will inform you ofalternatives if you wish to pursue this matter further. If you need to contact me, please haveyour complaint number available for reference.

Thank you for contacting our office.

ELENA H. GRANADOSCP Public Outreach Specialist

ElenaP 11/2/2012

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Consumer Protection Division(509) 734-7143Fax: (509) 734-7290

[email protected]

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From: Copyright Compliance [mailto:[email protected]]Sent: Monday, November 19, 2012 1:02 PMTo: ATG MI Kennewick CRCSubject: RE: 419707 : A notice from the Washington State Attorney General'sOffice

605 Fifth Avenue South, Suite 400, Seattle, Washington 98104Tel 206 925 5000 Fax 206 925 5001www.gettyimages.com

November 19, 2012

Elena H. GranadosCP Outreach SpecialistAttorney General of WashingtonConsumer Protection Division8127 W. Klamath Court Building 6, Suite AKennewick, WA 99336-2607

Via e-mail to [email protected] and Fax to (509) 734-7290

Re: Christopher VallosYour File # 419707Our File # 1091514

Dear Ms. Granados:We are in receipt of the complaint filed by Christopher Vallos that you forwarded to us onNovember 2, 2012. We appreciate the opportunity to respond to Mr. Valloss concerns.

By way of introduction, Getty Images is the leading creator and distributor of still and movingimages. More than 4,000 images per day are licensed on our website, www.gettyimages.com,which features wholly-owned content (i.e., images to which we own the copyright), as well asexclusively licensed content (i.e., third-party contributor images which are licensed exclusivelythrough us). Customers such as graphic designers, advertising agencies, and publishers license

our imagery for a variety of purposes, including but not limited to print advertising, billboards,newspaper and magazine articles, brochures and websites. Our license information is clearlyavailable from each page of our website, and we do not permit the use of our imagery without alicense.

Notwithstanding the license requirement, like other digital media companies, Getty Images doesfall victim to individuals pirating its intellectual property. To combat this, Getty Images usesboth employees and digital image recognition software to locate entities that have used GettyImages imagery without paying a license fee. One such entity recently identified as havingused unlicensed imagery from our collections is OTC Penny Stock Awareness (OTC).

ElenaP 11/21/2012

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On July 7, 2011, and again on September 9, 2011, we sent OTC a letter with notification that wehad found unauthorized use of one of our images on its website,

www.OTCPennyStockAwareness.com. The image is part of Getty Images Rights-ManagedPhotographers Choice collection, # sb10066918j-001 (the Image), and can be found on ourweb site at http://www.gettyimages.com/detail/sb10066918j-001/Photographers-Choice. Weinformed OTC that use of the Image without a license constitutes copyright infringement, andthat OTC must either: (i) provide evidence that a license was issued, or (ii) pay a fee for use ofthe Image. In this instance, the fee was $780.00, and we provided an invoice in that amount,which featured a thumbnail of the Image and its image number along with a screenshot of theImage on OTCs website. The amount invoiced is in line with what typically would be chargedfor a license of the Image under these circumstances.Mr. Vallos states that he has removed the Image from the OTC website. While we appreciatethe removal, the Image is protected by copyright, and was previously displayed on that website.

Copyright law holds responsible anyone who publicly displays an image without authorizationof the copyright holder. Mr. Valloss use of the Image without a license constitutes copyrightinfringement, for which we are entitled to seek damages.

At this time, Mr. Vallos has not raised any valid defenses. Getty Images has acted appropriatelyand in good faith in pursuing the unauthorized use of our intellectual property. Should yourequire any additional information about this matter, please do not hesitate to contact us.

Regards,

Getty Images Copyright Compliance

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C Response from one Respondent To: [email protected] McKennaATTORNEY GENERAL OF WASHINGTONConsumer Protection Division8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140

November 21, 2012




Our office has received a response from Getty Images regarding your complaint. Attached is acopy for your records.

When we receive a response from McCormack Intellectual Property Law we will contact youagain.

If the business response does not resolve the complaint, we will inform you of other alternativesincluding private legal remedies.


Enclosure

From: Copyright Compliance [mailto:[email protected]]Sent: Monday, November 19, 2012 1:02 PMTo: ATG MI Kennewick CRCSubject: RE: 419707 : A notice from the Washington State Attorney General'sOffice

ElenaP 11/21/2012

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605 Fifth Avenue South, Suite 400, Seattle, Washington 98104Tel 206 925 5000 Fax 206 925 5001www.gettyimages.com

November 19, 2012

Elena H. GranadosCP Outreach SpecialistAttorney General of WashingtonConsumer Protection Division8127 W. Klamath Court Building 6, Suite AKennewick, WA 99336-2607

Via e-mail to [email protected] and Fax to (509) 734-7290

Re: Christopher VallosYour File # 419707Our File # 1091514

Dear Ms. Granados:We are in receipt of the complaint filed by Christopher Vallos that you forwarded to us onNovember 2, 2012. We appreciate the opportunity to respond to Mr. Valloss concerns.

By way of introduction, Getty Images is the leading creator and distributor of still and movingimages. More than 4,000 images per day are licensed on our website, www.gettyimages.com,which features wholly-owned content (i.e., images to which we own the copyright), as well as

exclusively licensed content (i.e., third-party contributor images which are licensed exclusivelythrough us). Customers such as graphic designers, advertising agencies, and publishers licenseour imagery for a variety of purposes, including but not limited to print advertising, billboards,newspaper and magazine articles, brochures and websites. Our license information is clearlyavailable from each page of our website, and we do not permit the use of our imagery without alicense.

Notwithstanding the license requirement, like other digital media companies, Getty Images doesfall victim to individuals pirating its intellectual property. To combat this, Getty Images usesboth employees and digital image recognition software to locate entities that have used GettyImages imagery without paying a license fee. One such entity recently identified as having

used unlicensed imagery from our collections is OTC Penny Stock Awareness (OTC).

On July 7, 2011, and again on September 9, 2011, we sent OTC a letter with notification that wehad found unauthorized use of one of our images on its website,www.OTCPennyStockAwareness.com. The image is part of Getty Images Rights-ManagedPhotographers Choice collection, # sb10066918j-001 (the Image), and can be found on ourweb site at http://www.gettyimages.com/detail/sb10066918j-001/Photographers-Choice. Weinformed OTC that use of the Image without a license constitutes copyright infringement, andthat OTC must either: (i) provide evidence that a license was issued, or (ii) pay a fee for use ofthe Image. In this instance, the fee was $780.00, and we provided an invoice in that amount,

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which featured a thumbnail of the Image and its image number along with a screenshot of theImage on OTCs website. The amount invoiced is in line with what typically would be chargedfor a license of the Image under these circumstances.

Mr. Vallos states that he has removed the Image from the OTC website. While we appreciatethe removal, the Image is protected by copyright, and was previously displayed on that website.Copyright law holds responsible anyone who publicly displays an image without authorizationof the copyright holder. Mr. Valloss use of the Image without a license constitutes copyrightinfringement, for which we are entitled to seek damages.

At this time, Mr. Vallos has not raised any valid defenses. Getty Images has acted appropriatelyand in good faith in pursuing the unauthorized use of our intellectual property. Should yourequire any additional information about this matter, please do not hesitate to contact us.

Regards,

Getty Images Copyright Compliance

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Rsup Closing No Adjustment (R-UNJ) To: [email protected] McKennaATTORNEY GENERAL OF WASHINGTONConsumer Protection Division8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140

November 21, 2012



Dear Getty Images:

Thank you for your recent communication in response to the complaint from ChristopherVallos. Christopher Vallos has been informed of your response and that we have closed thiscomplaint with regard to our informal mediation service. We have notified the complainant ofthe availability of private legal remedies in the event the complainant wishes to pursue thismatter further.Although this was not resolved to the parties mutual satisfaction, we appreciate your response.This complaint will remain in our public records.Please be advised even though we are closing this complaint, we may open a formalinvestigation or take future action pursuant to the Consumer Protection Act at any time if thefacts and circumstances indicate that further action is warranted.

ELENA H. GRANADOSCP Public Outreach SpecialistConsumer Protection Division(509) 734-7143

Fax: (509) [email protected]

ElenaP 11/21/2012

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From: Chris Vallos [mailto:[email protected]]Sent: Wednesday, November 21, 2012 9:42 AMTo: ATG MI Kennewick CRCSubject: RE: 419707 : A notice from the Washington State Attorney General'sOffice

Mr. Mckenna,

I also filed a grievance with the WSBA office of Disceplinary Counsel against (TimothyMcCormack) the attorney handling the claim with Getty Images. WSBA File no 12-03039

I am attaching the WSBA letter requesting information from Timothy McCormack and GettyImages on this matter.

According to the WSBA letter, Mr. McCormack and Getty Images has 30 days from the date theletter was sent (November 1, 2012)

The amount that they are demanding ($1286) is ridiculous.

Chris Vallos

ElenaP 11/21/2012

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From: Lauren Kingston [mailto:[email protected]]Sent: Thursday, November 29, 2012 10:36 AMTo: ATG MI Kennewick CRCCc: McCormack LegalSubject: RE: 419707 : A notice from the Washington State Attorney General'sOffice

Dear Ms. Granados,

Attached is our response to the complaint referenced below, your file number 419707. A hardcopy will follow by mail.

Please contact me if you have any questions.

Sincerely,

Lauren KingstonAttorney at LawMcCormack Intellectual Property LawBusiness Law PSMailing Address617 Lee StreetSeattle, WA 98109Tel: 206-381-8888Direct: 206-330-0108Fax: 206-381-1988Internet Addresswww.McCormackLegal.com E: [email protected] e-mail may contain confidential information which is legally privileged. The information issolely for the use of the addressee named above. If you are not the intended recipient, anydisclosure, copying, distribution or other use of the contents of this information is strictlyprohibited. If you have received this e-mail in error, please notify us by return e-mail and delete

this message. Thank you.

ElenaP 12/3/2012

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Csup Closing Unadjusted (C-UNJ) To: [email protected] McKennaATTORNEY GENERAL OF WASHINGTONConsumer Protection Division8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140

December 11, 2012




Our office has received a response from McCormack Intellectual Property Law declining toadjust your complaint for the reasons outlined in the response.

We realize you may disagree with McCormack Intellectual Property Law and Getty Imagessposition. However, our office does not have the legal authority to force the parties to resolvetheir dispute. We regret that we are unable to provide further assistance to you in this situation.

We do not have the legal authority to act as an attorney for private individuals, nor may we actas a judge or arbitrator in individual disputes. If you would like to pursue the matter, you maywish to contact Small Claims Court in your County. General information about Small ClaimsCourt, including contact information, can be found by visiting the following website:

https://www.courts.wa.gov/newsinfo/resources/ - fa=newsinfo_jury.scc&altMenu=smal

For referrals to attorneys in your area, you may call one of the following numbers:

Clark County: 360-695-0599King County: 206-623-2551 or 211Lewis County: 360-748-0430Pierce County: 253-383-3432Snohomish County: 425-388-3018Spokane County: http://www.spokanebar.org/ (Telephone number not available)Thurston County: http://thurstoncountybar.com/ (Telephone number not available)

If you cannot afford an attorney, and have a non-criminal legal problem, you may qualify forassistance from the NW Justice Projects CLEAR Coordinated Legal Advice, which can be

ElenaP 12/11/2012

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reached Toll Free at 1-888-201-1014 or online at the following website:

http://www.nwjustice.org/about_njp/clear.html. In addition, if you are 60 or over, you may call

CLEAR SENIOR at 1-888-387-7111 regardless of income.

You may also wish to contact the Washington State Dispute Resolution Center nearest you tosee if they can assist in mediating your dispute. You can obtain additional information about theDispute Resolution Centers at these websites:

.

Please be aware that the Dispute Resolution Centers do not provide attorney referrals or legaladvice.

We appreciate your bringing this matter to our attention. Your complaint will remain a part ofour public record of this firms business practices.


Enclosure

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Rsup Closing No Adjustment (R-UNJ) To: [email protected] McKennaATTORNEY GENERAL OF WASHINGTONConsumer Protection Division8127 W. Klamath Court Building 6, Suite A Kennewick, WA 99336-2607 (509) 734-7140

December 11, 2012

McCormack Intellectual Property Law617 Lee StSeattle, WA 98109


Dear McCormack Intellectual Property Law:

Thank you for your recent communication in response to the complaint from ChristopherVallos. Christopher Vallos has been informed of your response and that we have closed thiscomplaint with regard to our informal mediation service. We have notified the complainant ofthe availability of private legal remedies in the event the complainant wishes to pursue thismatter further.Although this was not resolved to the parties mutual satisfaction, we appreciate your response.This complaint will remain in our public records.Please be advised even though we are closing this complaint, we may open a formalinvestigation or take future action pursuant to the Consumer Protection Act at any time if thefacts and circumstances indicate that further action is warranted.

ELENA H. GRANADOSCP Public Outreach SpecialistConsumer Protection Division(509) 734-7143

Fax: (509) [email protected]

ElenaP 12/11/2012

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From: Chris Vallos [mailto:[email protected]]Sent: Tuesday, December 11, 2012 8:37 PMTo: ATG MI Kennewick CRCSubject: RE: 419707 : A notice from the Washington State Attorney General'sOffice

Mr. McKenna,

I am still waiting for Mr. McCormack to respond to the questions from Washington State BarAssociationOffice of Disciplinary Counsel (WSBA File No. 12-02039) dated November 1, 2012 (seeattached letter from WSBA)

This issue is being resolved by the Washington State Bar Association.

Until Getty Images and/or Mr. McCormack provides detailed answers to the below, I will nolonger have communications with Getty Images and/or Mr. McCormack

1. Who is the "author" of the work - Provide a brief description of the work.2. Who is the original copyright claimant -3. provide proof that Getty is the "author" and copyright claimant in the cited work. IfGetty is not the author and original copyright claimant, provide documentation thatshows when Getty acquired any exclusive rights in the work, from whom the right wereacquired, and whether the rights include the right to enforce alleged copyright violations.4. Was the work registered - If so, provide proof of any registration from the United StatesRegister of Copyrights.5. provide the date(s) of Mr. Vallos's alleged infringement of the work. Provide proof thatan alleged infringement occurred on that date. If not included above, provide proof thatGetty held exclusive right to enforce an infringement claim on the date(s) of the allegedinfringement.6. List any copyright infringement actions you filed for Getty in the last five years'

Chris Vallos

ElenaP 12/14/2012

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Documents

WA State AG & WA Bar Assoc Complaint Against Getty Images and Timothy McCormack