WATCH TOWER BIBLE AND TRACT SOCIETY OF · rutube.ru. and available to users worldwide. 17. Watch Tower submitted to Rutube notices of claimed infringement, objecting to the unauthorized

31653/001/3453468.2

COWAN, LIEBOWITZ & LATMAN, P.C. 114 West 47th Street New York, NY 10036-1525 (212) 790-9200Kieran G. Doyle ([email protected])Thomas Kjellberg ([email protected])

Paul D. Polidoro ([email protected]) Watch Tower Bible and Tract Society of Pennsylvania 100 Watchtower Drive Patterson, NY 12563 (845) 306-1000

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

WATCH TOWER BIBLE AND TRACT SOCIETY OF PENNSYLVANIA,

Plaintiff,

-against-

THE TRUTH AND TRANSPARENCY FOUNDATION, RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

No.

COMPLAINT

Plaintiff Watch Tower Bible and Tract Society of Pennsylvania, by its attorneys, Cowan,

Liebowitz & Latman, P.C., for its Complaint against Defendants The Truth and Transparency

Foundation, Ryan C. McKnight, and Ethan G. Dodge alleges:

NATURE OF THE ACTION

1. This is a civil action for copyright infringement in violation of the Copyright Act,

17 U.S.C. § 101 et seq. This litigation seeks relief against the ongoing wholesale infringement of

20-cv-3366

Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 1 of 102

2

31653/001/3453468.2

Plaintiff’s registered copyrights in 74 original motion pictures. Defendants, without

authorization or permission from Plaintiff, have made unauthorized copies of Plaintiff’s motion

pictures, and are reproducing, publicly displaying, publicly performing and distributing

Plaintiff’s works online. Plaintiff, accordingly, seeks injunctive relief and statutory damages for

willful copyright infringement.

PARTIES

2. Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (“Watch Tower”)

is a Pennsylvania non-profit corporation with its principal place of business at 200 Watch Tower

Drive, Patterson, New York 12563.

3. Upon information and belief, Defendant The Truth and Transparency Foundation

(“TTF”) is a Nevada non-profit corporation with its principal place of business at 109 Cascade

Meadow Court, Henderson, Nevada 89011.

4. Upon information and belief, Defendant Ryan C. McKnight (“McKnight”) is an

individual residing in Henderson, Nevada. Mr. McKnight is the President and Executive

Director and a founding owner of TTF.

5. Upon information and belief, Defendant Ethan G. Dodge (“Dodge”) is an

individual residing in Pleasant Grove, Utah. Mr. Dodge is the Secretary and Technical Director

and a founding owner of TTF.

6. Upon information and belief, McKnight and Dodge had and still have primary

responsibility for the control, management and operation of the affairs of TTF, with the right and

ability to supervise the infringing activities complained of in this Complaint.

7. Upon information and belief, Defendants, while engaging and participating in the

unlawful acts set forth herein, were agents of and collaborators with one another.


3

31653/001/3453468.2

8. Upon information and belief, Defendants operate and control websites located at

www.faithleaks.org and www.truthandtransparency.org.

JURISDICTION AND VENUE

9. This Court has original jurisdiction over claims arising under the Copyright Act

pursuant to 28 U.S.C. §§ 1331 and 1338.

10. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b) and (c).

11. This Court has personal jurisdiction over Defendants because, on information and

belief, Defendants, in person or through an agent,

(a) have transacted business, and have offered to supply goods, in New York,

including through their interactive website located at truthandtransparency.org, on which

merchandise is offered for sale to, and donations solicited from, New York residents;

and/or

(b) have committed tortious acts both within and outside New York, causing

injury to Watch Tower in New York.

FACTUAL BACKGROUND

12. Watch Tower over decades has created and published thousands of original works

of authorship, including literary works, works of visual art, musical works, and motion pictures,

and has secured over 3,300 federal copyright registrations for its original works. Under the

Copyright Act, Watch Tower has the exclusive rights, among other things, to “reproduce the

copyrighted work[s],” to “distribute copies or phonorecords of the copyrighted work[s] to the

public,” and in the case of its “motion pictures and other audiovisual works, to perform the

copyrighted work[s] publicly,” as well as to authorize or license others to engage in such


4

31653/001/3453468.2

activities. 17 U.S.C. § 106.

13. In mid-2018, Watch Tower learned that 487 of its copyrighted literary works were

being reproduced, displayed and distributed without license or permission by Defendants on the

faithleaks.org website.

14. On December 31, 2018, Watch Tower’s counsel notified Defendants that their

unauthorized publication of Watch Tower’s literary works on the faithleaks site was in violation

of Watch Tower’s exclusive rights under the Copyright Act, and demanded that such infringing

materials be removed from the faithleaks site.

15. Defendants, through counsel, declined Watch Tower’s demand that its literary

works be removed from the faithleaks site. Defendants did not contest Watch Tower’s

ownership of valid copyrights, or its prima facie case of infringement of those copyrights, but

instead asserted “the defense found in 17 U.S.C. § 107,” claiming that Defendants’ wholesale

reproduction and distribution of complete works, unaltered and unaccompanied by new matter,

was protected as fair use.

16. In May 2019, Watch Tower learned that a large number of motion pictures

created by Watch Tower, including the 74 motion pictures at issue here, had been uploaded to

and made available for public performance on Rutube, a Russian online video streaming service

located at rutube.ru and available to users worldwide.

17. Watch Tower submitted to Rutube notices of claimed infringement, objecting to

the unauthorized posting of its copyrighted works on the Rutube site and demanding their

removal. In response, Rutube removed the Watch Tower videos from its site.

18. Shortly thereafter, Defendants posted the Watch Tower videos that had been

“taken down” from Rutube to Defendants’ faithleaks.org site.


5

31653/001/3453468.2

19. In a May 2019 article titled “2019 Jehovah’s Witness Convention Videos

Published Again After Successful Takedown Request,” published on Defendants’

truthandtransparency.org website, Defendants boasted not only about their past infringements

and refusals to comply with Watch Tower’s efforts to enforce its copyrights, but also about these

new infringements, leaving no doubt as to Defendants’ willfulness.

20. The Watch Tower videos remain available on the faithleaks site to the present

day.

WATCH TOWER’S COPYRIGHTED MOTION PICTURES AND DEFENDANTS’ INFRINGEMENTS

21. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Be a Courageous … Pioneer.” Watch Tower’s copyright in the “Be a Courageous …

Pioneer” video has been duly registered with the United States Copyright Office under

Registration No. PA0002121393, with an effective date of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Be a Courageous … Pioneer” video on Defendants’

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_23-

Be_a_Courageous%E2%80%94Pioneer-Video_1.mkv, where it is available, in its entirety and

without alteration, for public performance and for further reproduction and distribution via

download, without restriction:


6

31653/001/3453468.2


titled “Talk 33 - Video 1 - Learn Courage From Creation (Symposium) – Horses.” Watch

Tower’s copyright in the “Talk 33 - Video 1 - Learn Courage From Creation (Symposium) –

Horses” video has been duly registered with the United States Copyright Office under



performed and distributed Watch Tower’s “Talk 33 - Video 1 - Learn Courage From Creation

(Symposium) – Horses” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:2017-No_33-


7

31653/001/3453468.2

Learn_Courage_From_Creation%E2%80%94Horses-Video_1.mkv, where it is available, in its

entirety and without alteration, for public performance and for further reproduction and

distribution via download, without restriction:


titled “Talk 40 - Video 1 - How Our Brothers Are Showing Courage In … (Symposium) - North

America.” Watch Tower’s copyright in the “Talk 40 - Video 1 - How Our Brothers Are

Showing Courage In … (Symposium) - North America” video has been duly registered with the

United States Copyright Office under Registration No. PA0002121104, with an effective date of

May 18, 2018.


8

31653/001/3453468.2


performed and distributed Watch Tower’s “Talk 40 - Video 1 - How Our Brothers Are Showing

Courage In … (Symposium) - North America” video on Defendants’ “Faith Leaks” website, at

the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_40-

How_Our_Brothers_Are_Showing_Courage_In%E2%80%94North_America-Video_1.mkv,

where it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:


titled “Talk 44 - Video 1 - Future Events That Will Require Courage (Symposium) - The Cry of


9

31653/001/3453468.2

‘Peace and Security!’” Watch Tower’s copyright in the “Talk 44 - Video 1 - Future Events That

Will Require Courage (Symposium) - The Cry of ‘Peace and Security!’” video has been duly

registered with the United States Copyright Office under Registration No. PA0002121120, with

an effective date of May 18, 2018.


performed and distributed Watch Tower’s “Talk 44 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Cry of ‘Peace and Security!’” video on Defendants’ “Faith Leaks”

website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_44-

Future_Events_That_Will_Require_Courage%E2%80%94The_Cry_of_Peace_and_Security-

Video_1.mkv, where it is available, in its entirety and without alteration, for public performance

and for further reproduction and distribution via download, without restriction:


10

31653/001/3453468.2


titled “Talk 45 - Video 1 - Future Events That Will Require Courage (Symposium) - The

Destruction of Babylon the Great.” Watch Tower’s copyright in the “Talk 45 - Video 1 - Future

Events That Will Require Courage (Symposium) - The Destruction of Babylon the Great” video

has been duly registered with the United States Copyright Office under Registration No.

PA0002121121, with an effective date of May 18, 2018.



Courage (Symposium) - The Destruction of Babylon the Great” video on Defendants’ “Faith


11

31653/001/3453468.2

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_45-

Future_Events_That_Will_Require_Courage%E2%80%94The_Destruction_of_Babylon_the_Gr

eat-Video_1.mkv, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:


titled “Talk 46-Video 1 - Future Events That Will Require Courage (Symposium) - The

Proclamation of the Hailstone Message.” Watch Tower’s copyright in the “Talk 46-Video 1 -

Future Events That Will Require Courage (Symposium) - The Proclamation of the Hailstone

Message” video has been duly registered with the United States Copyright Office under


12

31653/001/3453468.2



performed and distributed Watch Tower’s “Talk 46-Video 1 - Future Events That Will Require

Courage (Symposium) - The Proclamation of the Hailstone Message” video on Defendants’

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_46-

Future_Events_That_Will_Require_Courage%E2%80%94The_Proclamation_of_the_Hailstone

_Message-Video_1.mkv, where it is available, in its entirety and without alteration, for public




13

31653/001/3453468.2

titled “Talk 47 - Video 1 - Future Events That Will Require Courage (Symposium) - The Attack

by Gog of Magog.” Watch Tower’s copyright in the “Talk 47 - Video 1 - Future Events That

Will Require Courage (Symposium) - The Attack by Gog of Magog” video has been duly





Courage (Symposium) - The Attack by Gog of Magog” video on Defendants’ “Faith Leaks”

website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_47-

Future_Events_That_Will_Require_Courage%E2%80%94The_Attack_by_Gog_of_Magog-




14

31653/001/3453468.2


titled “Talk 48 - Video 1 - Future Events That Will Require Courage (Symposium) -

Armageddon.” Watch Tower’s copyright in the “Talk 48-Video 1 - Future Events That Will

Require Courage (Symposium) - Armageddon” video has been duly registered with the United

States Copyright Office under Registration No. PA0002121607, with an effective date of May

18, 2018.


performed and distributed Watch Tower’s “Talk 48-Video 1 - Future Events That Will Require

Courage (Symposium) - Armageddon” video on Defendants’ “Faith Leaks” website, at the URL


15

31653/001/3453468.2

https://faithleaks.org/wiki/index.php?title=File:2017-No_48-

Future_Events_That_Will_Require_Courage%E2%80%94Armageddon-Video_1.mkv, where it

is available, in its entirety and without alteration, for public performance and for further



titled “Talk 49 - Video 1 - Future Events That Will Require Courage (Symposium) - The Great

Reconstruction.” Watch Tower’s copyright in the “Talk 49 - Video 1 - Future Events That Will

Require Courage (Symposium) - The Great Reconstruction” video has been duly registered with

the United States Copyright Office under Registration No. PA0002121129, with an effective date


16

31653/001/3453468.2

of May 18, 2018.



Courage (Symposium) - The Great Reconstruction” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_49-

Future_Events_That_Will_Require_Courage%E2%80%94The_Great_Reconstruction-





17

31653/001/3453468.2

titled “Talk 50 - Video 1 - Future Events That Will Require Courage (Symposium) - The Final

Test.” Watch Tower’s copyright in the “Talk 50 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Final Test” video has been duly registered with the United States

Copyright Office under Registration No. PA0002121132, with an effective date of May 18,

2018.



Courage (Symposium) - The Final Test” video on Defendants’ “Faith Leaks” website, at the

URL https://faithleaks.org/wiki/index.php?title=File:2017-No_50-

Future_Events_That_Will_Require_Courage%E2%80%94The_Final_Test-Video_1.mkv, where

it is available, in its entirety and without alteration, for public performance and for further



18

31653/001/3453468.2


titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1.” Watch Tower’s

copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1” video has

been duly registered with the United States Copyright Office under Registration No.



performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video

Presentation 1” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_003_r720P.mp4, where it is


19

31653/001/3453468.2

available, in its entirety and without alteration, for public performance and for further



titled “Talk 01 Video 1 - Chairman’s Address: ‘Love Never Fails - Why?’ (Romans 8:38, 39; 1

Corinthians 13:1-3, 8, 13).” Watch Tower’s copyright in the “Talk 01 Video 1 - Chairman’s

Address: ‘Love Never Fails - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video has





20

31653/001/3453468.2

performed and distributed Watch Tower’s “Talk 01 Video 1 - Chairman’s Address: ‘Love Never

Fails - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_006_r720P.mp4, where it is available, in its entirety and without alteration, for public



titled “Talk 01 Video 2 - Chairman’s Address: ‘Love Never Fails’ - Why?’ (Romans 8:38, 39; 1

Corinthians 13:1-3, 8, 13).” Watch Tower’s copyright in the “Talk 01 Video 2 - Chairman’s

Address: ‘Love Never Fails’ - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video has


21

31653/001/3453468.2




performed and distributed Watch Tower’s “Talk 01 Video 2 - Chairman’s Address: ‘Love Never

Fails’ - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video on Defendants’ “Faith






22

31653/001/3453468.2

titled “Talk 02 Video 1 - Symposium: Beware of Trusting in What Fails! - Wealth (Matthew

6:24).” Watch Tower’s copyright in the “Talk 02 Video 1 - Symposium: Beware of Trusting in

What Fails! - Wealth (Matthew 6:24)” video has been duly registered with the United States


2019.


performed and distributed Watch Tower’s “Talk 02 Video 1 - Symposium: Beware of Trusting in

What Fails! - Wealth (Matthew 6:24)” video on Defendants’ “Faith Leaks” website, at the URL





23

31653/001/3453468.2


titled “Talk 03 Video 1 - Symposium: Beware of Trusting in What Fails! - Status and Fame

(Ecclesiastes 2:16; Romans 12:16).” Watch Tower’s copyright in the “Talk 03 Video 1 -

Symposium: Beware of Trusting in What Fails! - Status and Fame (Ecclesiastes 2:16; Romans

12:16)” video has been duly registered with the United States Copyright Office under




What Fails! - Status and Fame (Ecclesiastes 2:16; Romans 12:16)” video on Defendants’ “Faith


24

31653/001/3453468.2





titled “Talk 04 Video 1 - Symposium: Beware of Trusting in What Fails! - Human Wisdom

(Romans 12:1, 2).” Watch Tower’s copyright in the “Talk 04 Video 1 - Symposium: Beware of

Trusting in What Fails! - Human Wisdom (Romans 12:1, 2)” video has been duly registered with


of May 17, 2019.


25

31653/001/3453468.2



What Fails! - Human Wisdom (Romans 12:1, 2)” video on Defendants’ “Faith Leaks” website, at

the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_013_r720P.mp4, where it is




titled “Talk 05 Video 1 - Symposium: Beware of Trusting in What Fails! - Strength and Beauty

(Proverbs 31:30; 1 Peter 3:3, 4).” Watch Tower’s copyright in the “Talk 05 Video 1 -


26

31653/001/3453468.2

Symposium: Beware of Trusting in What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter

3:3, 4)” video has been duly registered with the United States Copyright Office under




What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter 3:3, 4)” video on Defendants’ “Faith





27

31653/001/3453468.2


titled “Talk 06 Video 1 - DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love

(Genesis 37:1-36; 39:1; 47:12).” Watch Tower’s copyright in the “Talk 06 Video 1 -

DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1;

47:12)” video has been duly registered with the United States Copyright Office under



performed and distributed Watch Tower’s “Talk 06 Video 1 - DRAMATIC BIBLE READING:

Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1; 47:12)” video on Defendants’ “Faith





28

31653/001/3453468.2

39. 40. (a) In 2019, Watch Tower created, in-house, an original video motion

picture titled “2019 ‘Love Never Fails’! Convention—Music-Video Presentation 2Talk 23 Video

1 - Symposium: Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32).”

Watch Tower’s copyright in the “2019 ‘Love Never Fails’! Convention—Music-Video

Presentation 2” video has been duly registered with the United States Copyright Office under



performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention—Music-Video



29

31653/001/3453468.2





titled “Talk 08 Video 1 - Symposium: Love Never Fails Despite … A Loveless Upbringing

(Psalm 27:10).” Watch Tower’s copyright in the “Talk 08 Video 1 - Symposium: Love Never

Fails Despite … A Loveless Upbringing (Psalm 27:10)” video has been duly registered with the


May 17, 2019.


30

31653/001/3453468.2


performed and distributed Watch Tower’s “Talk 08 Video 1 - Symposium: Love Never Fails

Despite … A Loveless Upbringing (Psalm 27:10)” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_026_r720P.mp4, where it




titled “Talk 09 Video 1 - Symposium: Love Never Fails Despite … A Difficult Work

Environment (1 Peter 2:18-20).” Watch Tower’s copyright in the “Talk 09 Video 1 -


31

31653/001/3453468.2

Symposium: Love Never Fails Despite … A Difficult Work Environment (1 Peter 2:18-20)”

video has been duly registered with the United States Copyright Office under Registration No.




Despite … A Difficult Work Environment (1 Peter 2:18-20)” video on Defendants’ “Faith





32

31653/001/3453468.2


titled “Talk 10 Video 2 - Symposium: Love Never Fails Despite … An Ungodly School

Environment (1 Timothy 4:12).” Watch Tower’s copyright in the “Talk 10 Video 2 -

Symposium: Love Never Fails Despite … An Ungodly School Environment (1 Timothy 4:12)”





Despite … An Ungodly School Environment (1 Timothy 4:12)” video on Defendants’ “Faith





33

31653/001/3453468.2


titled “Talk 11 Video 1 - Symposium: Love Never Fails Despite … Chronic Health Problems (2

Corinthians 12:9, 10).” Watch Tower’s copyright in the “Talk 11 Video 1 - Symposium: Love

Never Fails Despite … Chronic Health Problems (2 Corinthians 12:9, 10)” video has been duly





Despite … Chronic Health Problems (2 Corinthians 12:9, 10)” video on Defendants’ “Faith


34

31653/001/3453468.2





titled “Talk 12 Video 1 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12,

13).” Watch Tower’s copyright in the “Talk 12 Video 1 - Symposium: Love Never Fails Despite

… Poverty (Philippians 4:12, 13)” video has been duly registered with the United States


2019.


35

31653/001/3453468.2



Despite … Poverty (Philippians 4:12, 13)” video on Defendants’ “Faith Leaks” website, at the

URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_035_r720P.mp4, where it is




titled “Talk 12 Video 2 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12,

13).” Watch Tower’s copyright in the “Talk 12 Video 2 - Symposium: Love Never Fails Despite


36

31653/001/3453468.2

… Poverty (Philippians 4:12, 13)” video has been duly registered with the United States


2019.



Despite … Poverty (Philippians 4:12, 13)” video on Defendants’ “Faith Leaks” website, at the





37

31653/001/3453468.2


titled “Talk 13 Video 1 - Symposium: Love Never Fails Despite … Family Opposition (Matthew

5:44).” Watch Tower’s copyright in the “Talk 13 Video 1 - Symposium: Love Never Fails

Despite … Family Opposition (Matthew 5:44)” video has been duly registered with the United


17, 2019.



Despite … Family Opposition (Matthew 5:44)” video on Defendants’ “Faith Leaks” website, at





38

31653/001/3453468.2


titled “Talk 14 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Heavens (Psalm

8:3, 4; 33:6).” Watch Tower’s copyright in the “Talk 14 Video 1 - Symposium: Creation

Reveals Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)” video has been duly registered with


of May 17, 2019.


performed and distributed Watch Tower’s “Talk 14 Video 1 - Symposium: Creation Reveals

Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)” video on Defendants’ “Faith Leaks”


39

31653/001/3453468.2

website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_041_r720P.mp4,




titled “Talk 15 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Earth (Psalm

37:29; 115:16).” Watch Tower’s copyright in the “Talk 15 Video 1 - Symposium: Creation

Reveals Jehovah’s Love - The Earth (Psalm 37:29; 115:16)” video has been duly registered with


of May 17, 2019.


40

31653/001/3453468.2



Jehovah’s Love - The Earth (Psalm 37:29; 115:16)” video on Defendants’ “Faith Leaks” website,





titled “Talk 16 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Plants (Genesis 1:11,

29; 2:9, 15; Acts 14:16, 17).” Watch Tower’s copyright in the “Talk 16 Video 1 - Symposium:


41

31653/001/3453468.2

Creation Reveals Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)” video has





Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)” video on Defendants’ “Faith





42

31653/001/3453468.2


titled “Talk 17 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Animals (Genesis

1:27; Matthew 6:26).” Watch Tower’s copyright in the “Talk 17 Video 1 - Symposium: Creation

Reveals Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)” video has been duly





Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)” video on Defendants’ “Faith Leaks”





43

31653/001/3453468.2


titled “Talk 18 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Human Body

(Psalm 139:14; Ecclesiastes 3:11).” Watch Tower’s copyright in the “Talk 18 Video 1 -

Symposium: Creation Reveals Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes

3:11)” video has been duly registered with the United States Copyright Office under Registration

No. PA0002191446, with an effective date of May 17, 2019.



Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes 3:11)” video on Defendants’


44

31653/001/3453468.2

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-




titled “Talk 19 Video 1 - ‘Those Whom Jehovah Loves He Disciplines’ (Hebrews 12:5-11;

Psalm 19:7, 8, 11).” Watch Tower’s copyright in the “Talk 19 Video 1 - ‘Those Whom Jehovah

Loves He Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)” video has been duly registered

with the United States Copyright Office under Registration No. PA0002191504, with an

effective date of May 17, 2019.


45

31653/001/3453468.2


performed and distributed Watch Tower’s “Talk 19 Video 1 - ‘Those Whom Jehovah Loves He

Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)” video on Defendants’ “Faith Leaks” website,





titled “Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14).” Watch Tower’s

copyright in the “Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14)” video


46

31653/001/3453468.2

has been duly registered with the United States Copyright Office under Registration No.



performed and distributed Watch Tower’s “Talk 20 Video 1 - ‘Clothe Yourselves With Love’

(Colossians 3:12-14)” video on Defendants’ “Faith Leaks” website, at the URL






47

31653/001/3453468.2












48

31653/001/3453468.2


titled “Talk 21 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Those

Taking the Lead (1 Thessalonians 5:12, 13).” Watch Tower’s copyright in the “Talk 21 Video 1

- Symposium: Display Unfailing Love in the Congregation - To Those Taking the Lead (1

Thessalonians 5:12, 13)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191157, with an effective date of May 22, 2019, and

Supplementary Registration No. PA0002214841, dated August 19, 2019.


performed and distributed Watch Tower’s “Talk 21 Video 1 - Symposium: Display Unfailing


49

31653/001/3453468.2

Love in the Congregation - To Those Taking the Lead (1 Thessalonians 5:12, 13)” video on

Defendants’ “Faith Leaks” website, at the URL





titled “Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To the

Elderly (Leviticus 19:32).” Watch Tower’s copyright in the “Talk 23 Video 1 - Symposium:

Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32)” video has been


50

31653/001/3453468.2

duly registered with the United States Copyright Office under Registration No. PA0002191160,

with an effective date of May 22, 2019, and Supplementary Registration No. PA0002216893,

dated September 4, 2019.



Love in the Congregation - To the Elderly (Leviticus 19:32)” video on Defendants’ “Faith





51

31653/001/3453468.2


titled “Talk 24 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Full-

Time Ministers (1 Thessalonians 1:3).” Watch Tower’s copyright in the “Talk 24 Video 1 -

Symposium: Display Unfailing Love in the Congregation - To Full-Time Ministers (1

Thessalonians 1:3)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191146, with an effective date of May 22, 2019.



Love in the Congregation - To Full-Time Ministers (1 Thessalonians 1:3)” video on Defendants’





52

31653/001/3453468.2


titled “Talk 25 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Foreign

Residents (Leviticus 19:34; Romans 15:7).” Watch Tower’s copyright in the “Talk 25 Video 1 -

Symposium: Display Unfailing Love in the Congregation - To Foreign Residents (Leviticus

19:34; Romans 15:7)” video has been duly registered with the United States Copyright Office




Love in the Congregation - To Foreign Residents (Leviticus 19:34; Romans 15:7)” video on


53

31653/001/3453468.2






titled “ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers Meeting.” Watch

Tower’s copyright in the “ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers

Meeting” video has been duly registered with the United States Copyright Office under



54

31653/001/3453468.2


performed and distributed Watch Tower’s “ANNOUNCEMENT: Invitation to School for

Kingdom Evangelizers Meeting” video on Defendants’ “Faith Leaks” website, at the URL





titled “Talk 26 Video 1 - Symposium: Display Unfailing Love in the Ministry - Show Your Love

for God (1 John 5:3).” Watch Tower’s copyright in the “Talk 26 Video 1 - Symposium: Display


55

31653/001/3453468.2

Unfailing Love in the Ministry - Show Your Love for God (1 John 5:3)” video has been duly





Love in the Ministry - Show Your Love for God (1 John 5:3)” video on Defendants’ “Faith





56

31653/001/3453468.2


titled “Talk 27 Video 1 - Symposium: Display Unfailing Love in the Ministry – ‘Love Your

Neighbor as Yourself’ (Matthew 22:39).” Watch Tower’s copyright in the “Talk 27 Video 1 -

Symposium: Display Unfailing Love in the Ministry – ‘Love Your Neighbor as Yourself’

(Matthew 22:39)” video has been duly registered with the United States Copyright Office under




Love in the Ministry – ‘Love Your Neighbor as Yourself’ (Matthew 22:39)” video on






57

31653/001/3453468.2


titled “Talk 28 Video 1 - Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s

Word (Psalm 119:97; Matthew 13:52).” Watch Tower’s copyright in the “Talk 28 Video 1 -

Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s Word (Psalm 119:97;

Matthew 13:52)” video has been duly registered with the United States Copyright Office under




Love in the Ministry - Love Jehovah’s Word (Psalm 119:97; Matthew 13:52)” video on


58

31653/001/3453468.2






titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4 (v2).” Watch

Tower’s copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4

(v2)” video has been duly registered with the United States Copyright Office under Registration

No. PA0002193286, with an effective date of June 5, 2019.


59

31653/001/3453468.2



Presentation 4 (v2)” video on Defendants’ “Faith Leaks” website, at the URL





titled “Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In …

Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians


60

31653/001/3453468.2

9:22), Oceania (Psalm 35:18), South America (Acts 1:8).” Watch Tower’s copyright in the

“Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In … Africa

(Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians 9:22),

Oceania (Psalm 35:18), South America (Acts 1:8)” video has been duly registered with the


May 22, 2019.


performed and distributed Watch Tower’s “Talk 30 Video 1 - Symposium: How Our Brothers

Are Showing Unfailing Love In … Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John

4:35), North America (1 Corinthians 9:22), Oceania (Psalm 35:18), South America (Acts 1:8)”

video on Defendants’ “Faith Leaks” website, at the URL





61

31653/001/3453468.2


titled “Talk 31 Video 1 - Display Unfailing Love in Your Family - Love Your Wife (Ephesians

5:28, 29).” Watch Tower’s copyright in the “Talk 31 Video 1 - Display Unfailing Love in Your

Family - Love Your Wife (Ephesians 5:28, 29)” video has been duly registered with the United


22, 2019.


performed and distributed Watch Tower’s “Talk 31 Video 1 - Display Unfailing Love in Your

Family - Love Your Wife (Ephesians 5:28, 29)” video on Defendants’ “Faith Leaks” website, at


62

31653/001/3453468.2





titled “Talk 32 Video 1 - Display Unfailing Love in Your Family - Love Your Husband

(Ephesians 5:33; 1 Peter 3:1-6).” Watch Tower’s copyright in the “Talk 32 Video 1 - Display

Unfailing Love in Your Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)” video has




63

31653/001/3453468.2



Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)” video on Defendants’ “Faith





titled “Talk 33 Video 1 - Display Unfailing Love in Your Family - Love Your Children (Titus

2:4).” Watch Tower’s copyright in the “Talk 33 Video 1 - Display Unfailing Love in Your


64

31653/001/3453468.2

Family - Love Your Children (Titus 2:4)” video has been duly registered with the United States


2019.



Family - Love Your Children (Titus 2:4)” video on Defendants’ “Faith Leaks” website, at the





65

31653/001/3453468.2


titled “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part I (2 Chronicles 33:10-24;

34:1, 2).” Watch Tower’s copyright in the “The Story of Josiah: Love Jehovah; Hate What Is

Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)” video has been duly registered with the United


22, 2019.


performed and distributed Watch Tower’s “The Story of Josiah: Love Jehovah; Hate What Is

Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)” video on Defendants’ “Faith Leaks” website, at the





66

31653/001/3453468.2


titled “Talk 35 Video 1 - Teach Your Children How to Show Love (2 Timothy 3:14, 15).”

Watch Tower’s copyright in the “Talk 35 Video 1 - Teach Your Children How to Show Love (2

Timothy 3:14, 15)” video has been duly registered with the United States Copyright Office under



performed and distributed Watch Tower’s “Talk 35 Video 1 - Teach Your Children How to

Show Love (2 Timothy 3:14, 15)” video on Defendants’ “Faith Leaks” website, at the URL



67

31653/001/3453468.2











68

31653/001/3453468.2











69

31653/001/3453468.2











70

31653/001/3453468.2











71

31653/001/3453468.2

titled “Talk 36 Video 1 - Symposium: Remember How Love Behaves - Is Patient and Kind (1

Corinthians 13:4).” Watch Tower’s copyright in the “Talk 36 Video 1 - Symposium: Remember

How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video has been duly registered




performed and distributed Watch Tower’s “Talk 36 Video 1 - Symposium: Remember How

Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video on Defendants’ “Faith Leaks”





72

31653/001/3453468.2


titled “Talk 36 Video 2 - Symposium: Remember How Love Behaves - Is Patient and Kind (1

Corinthians 13:4).” Watch Tower’s copyright in the “Talk 36 Video 2 - Symposium: Remember

How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video has been duly registered





Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video on Defendants’ “Faith Leaks”


73

31653/001/3453468.2





titled “Talk 37 Video 1 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not

Brag (1 Corinthians 13:4).” Watch Tower’s copyright in the “Talk 37 Video 1 - Symposium:

Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video has




74

31653/001/3453468.2



Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video on Defendants’





titled “Talk 37 Video 2 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not

Brag (1 Corinthians 13:4).” Watch Tower’s copyright in the “Talk 37 Video 2 - Symposium:


75

31653/001/3453468.2

Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video has





Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video on Defendants’





76

31653/001/3453468.2


titled “Talk 38 Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up;

Does Not Behave Indecently (1 Corinthians 13:4, 5).” Watch Tower’s copyright in the “Talk 38

Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not

Behave Indecently (1 Corinthians 13:4, 5)” video has been duly registered with the United States


2019.



Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”






77

31653/001/3453468.2


titled “Talk 38 Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up;

Does Not Behave Indecently (1 Corinthians 13:4, 5).” Watch Tower’s copyright in the “Talk 38

Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not

Behave Indecently (1 Corinthians 13:4, 5)” video has been duly registered with the United States


2019.




78

31653/001/3453468.2

Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”






titled “Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its

Own Interests; Does Not Become Provoked (1 Corinthians 13:5).” Watch Tower’s copyright in

the “Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its Own


79

31653/001/3453468.2

Interests; Does Not Become Provoked (1 Corinthians 13:5)” video has been duly registered with


of May 22, 2019.



Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1

Corinthians 13:5)” video on Defendants’ “Faith Leaks” website, at the URL





80

31653/001/3453468.2


titled “Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its

Own Interests; Does Not Become Provoked (1 Corinthians 13:5).” Watch Tower’s copyright in

the “Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its Own

Interests; Does Not Become Provoked (1 Corinthians 13:5)” video has been duly registered with


of May 22, 2019.




81

31653/001/3453468.2

Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1

Corinthians 13:5)” video on Defendants’ “Faith Leaks” website, at the URL





titled “Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not Keep Account

of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6).” Watch Tower’s

copyright in the “Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not


82

31653/001/3453468.2

Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”





Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness

(1 Corinthians 13:5, 6)” video on Defendants’ “Faith Leaks” website, at the URL





83

31653/001/3453468.2


titled “Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not Keep Account

of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6).” Watch Tower’s

copyright in the “Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not

Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”






84

31653/001/3453468.2

Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness

(1 Corinthians 13:5, 6)” video on Defendants’ “Faith Leaks” website, at the URL





titled “Talk 41 Video 1 - Symposium: Remember How Love Behaves - Rejoices With the Truth;

Bears All Things (1 Corinthians 13:6, 7).” Watch Tower’s copyright in the “Talk 41 Video 1 -

Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1


85

31653/001/3453468.2

Corinthians 13:6, 7)” video has been duly registered with the United States Copyright Office




Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)” video on






86

31653/001/3453468.2


titled “Talk 41 Video 2 - Symposium: Remember How Love Behaves - Rejoices With the Truth;

Bears All Things (1 Corinthians 13:6, 7).” Watch Tower’s copyright in the “Talk 41 Video 2 -

Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1





Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)” video on






87

31653/001/3453468.2


titled “Talk 42 Video 1 - Symposium: Remember How Love Behaves - Believes All Things;

Hopes All Things 1 Corinthians 13:7).” Watch Tower’s copyright in the “Talk 42 Video 1 -

Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1

Corinthians 13:7)” video has been duly registered with the United States Copyright Office under




Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)” video on


88

31653/001/3453468.2






titled “Talk 42 Video 2 - Symposium: Remember How Love Behaves - Believes All Things;

Hopes All Things 1 Corinthians 13:7).” Watch Tower’s copyright in the “Talk 42 Video 2 -

Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1

Corinthians 13:7)” video has been duly registered with the United States Copyright Office under


89

31653/001/3453468.2




Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)” video on







90

31653/001/3453468.2

titled “Talk 43 Video 1 - Symposium: Remember How Love Behaves - Endures All Things;

Love Never Fails (1 Corinthians 13:7, 8).” Watch Tower’s copyright in the “Talk 43 Video 1 -

Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1





Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)” video on






91

31653/001/3453468.2


titled “Talk 43 Video 2 - Symposium: Remember How Love Behaves - Endures All Things;

Love Never Fails (1 Corinthians 13:7, 8).” Watch Tower’s copyright in the “Talk 43 Video 2 -

Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1





Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)” video on


92

31653/001/3453468.2






titled “Talk 44 Video 1 - Public Bible Discourse: True Love in a Hate-Filled World - Where?

(John 13:34, 35).” Watch Tower’s copyright in the “Talk 44 Video 1 - Public Bible Discourse:

True Love in a Hate-Filled World - Where? (John 13:34, 35)” video has been duly registered



93

31653/001/3453468.2



performed and distributed Watch Tower’s “Talk 44 Video 1 - Public Bible Discourse: True Love

in a Hate-Filled World - Where? (John 13:34, 35)” video on Defendants’ “Faith Leaks” website,





titled “Talk 44 Video 2 - Public Bible Discourse: True Love in a Hate-Filled World - Where?


94

31653/001/3453468.2

(John 13:34, 35).” Watch Tower’s copyright in the “Talk 44 Video 2 - Public Bible Discourse:

True Love in a Hate-Filled World - Where? (John 13:34, 35)” video has been duly registered




performed and distributed Watch Tower’s “Talk 44 Video 2 - Public Bible Discourse: True Love

in a Hate-Filled World - Where? (John 13:34, 35)” video on Defendants’ “Faith Leaks” website,





95

31653/001/3453468.2


titled “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25;

2 Chronicles 34:3-33; 35:1-19).” Watch Tower’s copyright in the “The Story of Josiah: Love

Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)”




performed and distributed Watch Tower’s “The Story of Josiah: Love Jehovah; Hate What Is

Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)” video on Defendants’


96

31653/001/3453468.2





titled “Talk 47 Video 1 - ‘Carefully Consider Jehovah’s Acts of Loyal Love’ (Psalm 107:43;

Ephesians 5:1, 2).” Watch Tower’s copyright in the “Talk 47 Video 1 - ‘Carefully Consider

Jehovah’s Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)” video has been duly registered




97

31653/001/3453468.2


performed and distributed Watch Tower’s “Talk 47 Video 1 - ‘Carefully Consider Jehovah’s

Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)” video on Defendants’ “Faith Leaks”





titled “Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8)).” Watch Tower’s copyright in the

“Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8))” video has been duly registered with the


98

31653/001/3453468.2


May 24, 2019.


performed and distributed Watch Tower’s “Talk 47 Video 5 - Unfailing Love (1 Corinthians

13:8))” video on Defendants’ “Faith Leaks” website, at the URL






99

31653/001/3453468.2












100

31653/001/3453468.2

95. Defendants McKnight and Dodge personally participated in, and supervised and

directed, the infringing acts described above. Indeed, they personally conceived of, and directed

and approved all key aspects of, TTF’s infringing activities. They were the moving force behind

those infringing acts.

96. The acts of Defendants described above were committed without the permission,

license or consent of Watch Tower.

97. Upon information and belief, the acts of Defendants described above were

committed with knowledge or in reckless disregard of Watch Tower’s exclusive rights in the

Watch Tower videos.

CLAIM FOR RELIEF (Copyright Infringement)

98. Watch Tower repeats and realleges the assertions contained in paragraphs 1

through 97 above.

99. Watch Tower is the author of, and sole proprietor of all right, title and interest in

and to the copyrights in, each of the Watch Tower videos described above. Under 17 U.S.C. §

106, Watch Tower has the exclusive right to reproduce, distribute, publicly display, publicly

perform, and prepare derivative works based on the Watch Tower videos.

100. As alleged above, Defendants have infringed the copyrights in each of the above-

described Watch Tower videos by unlawfully reproducing, distributing, publicly displaying,

publicly performing and/or distributing the Watch Tower videos.

101. As alleged above, Defendants’ infringements are willful in that they are

committed with knowledge or in reckless disregard of Watch Tower’s exclusive rights in its

copyrighted videos.


101

31653/001/3453468.2

102. Watch Tower is entitled to recover from Defendants its actual damages as well as

the profits of Defendants attributable to each of the infringements and not taken into account in

computing actual damages, pursuant to 17 U.S.C. § 504(b); or, at Watch Tower’s election, an

award of statutory damages pursuant to 17 U.S.C. § 504(c) with respect to each of the Watch

Tower videos infringed by Defendants that meets the requirements of 17 U.S.C. § 412.

103. Pursuant to 17 U.S.C. § 505, Watch Tower is also entitled to recover its costs and

attorneys’ fees from Defendants with respect to each of the Watch Tower videos infringed by

Defendants that meets the requirements of 17 U.S.C. § 412.

104. As a result of Defendants’ copyright infringements, Watch Tower has suffered,

and will continue to suffer, irreparable injury not fully compensable in monetary damages, and is

therefore entitled to an injunction enjoining Defendants from engaging in their infringing

activities.

WHEREFORE, Watch Tower prays that the Court:

1. Find that Defendants have willfully infringed Watch Tower’s registered

copyrights in the Watch Tower videos;

2. Preliminarily and permanently enjoin Defendants, their officers, agents,

employees, and related companies, and all persons acting for, with, by, through, or under them,

from copying, reproducing, publicly displaying, publicly performing, distributing, advertising,

promoting, offering for sale or selling the Watch Tower videos;

3. (a) Award to Watch Tower, pursuant to 17 U.S.C. § 504(c), its actual

damages incurred as a result of Defendants’ acts of copyright infringement, and all profits

Defendants realized as a result of such unlawful acts, in amounts to be determined at trial; or


102

31653/001/3453468.2

(b) In the alternative, with respect to each of the Watch Tower Videos infringed by

Defendants that meets the requirements of 17 U.S.C. § 412, award to Watch Tower, at its

election, statutory damages pursuant to 17 U.S.C. § 504(c);

4. Award to Watch Tower, pursuant to 17 U.S.C. § 505, its costs and attorneys’ fees

incurred as a result of Defendants’ unlawful acts; and

5. Grant such other and further relief as the Court deems necessary and proper under

the circumstances.

Dated: New York, New York April 30, 2020 Respectfully submitted, COWAN, LIEBOWITZ & LATMAN, P.C. By: s/Kieran G. Doyle Kieran G. Doyle ([email protected]) Thomas Kjellberg ([email protected]) 114 West 47th Street New York, New York 10036-1525 (212) 790-9202

Paul Polidoro Watch Tower Bible and Tract Society of Pennsylvania 100 Watchtower Drive Patterson, New York 12563

Attorneys for Plaintiff


JS 44C/SDNY REV. 06/01/17

CIVIL COVER SHEETThe JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet.

PLAINTIFFS DEFENDANTS

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN)

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

Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No YesJudge Previously Assigned

If yes, was this case Vol. Invol. Dismissed. No Yes If yes, give date _______________________ & Case No. ______________________

IS THIS AN INTERNATIONAL ARBITRATION CASE? No Yes

(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT

CONTRACT

[ ] 110 INSURANCE[ ] 120 MARINE[ ] 130 MILLER ACT[ ] 140 NEGOTIABLE

INSTRUMENT[ ] 150 RECOVERY OF

OVERPAYMENT &ENFORCEMENTOF JUDGMENT

[ ] 151 MEDICARE ACT[ ] 152 RECOVERY OF

DEFAULTEDSTUDENT LOANS(EXCL VETERANS)

[ ] 153 RECOVERY OFOVERPAYMENTOF VETERAN'SBENEFITS

[ ] 160 STOCKHOLDERSSUITS

[ ] 190 OTHERCONTRACT

[ ] 195 CONTRACTPRODUCTLIABILITY

[ ] 196 FRANCHISE

REAL PROPERTY

[ ] 210 LANDCONDEMNATION

[ ] 220 FORECLOSURE[ ] 230 RENT LEASE &

EJECTMENT[ ] 240 TORTS TO LAND[ ] 245 TORT PRODUCT

LIABILITY[ ] 290 ALL OTHER

REAL PROPERTY

TORTS

PERSONAL INJURY

[ ] 310 AIRPLANE[ ] 315 AIRPLANE PRODUCT

LIABILITY[ ] 320 ASSAULT, LIBEL &

SLANDER[ ] 330 FEDERAL

EMPLOYERS'LIABILITY

[ ] 340 MARINE[ ] 345 MARINE PRODUCT

LIABILITY[ ] 350 MOTOR VEHICLE[ ] 355 MOTOR VEHICLE

PRODUCT LIABILITY[ ] 360 OTHER PERSONAL

INJURY

ACTIONS UNDER STATUTES

CIVIL RIGHTS

PERSONAL INJURY

[ ] 365 PERSONAL INJURYPRODUCT LIABILITY

[ ] 368 ASBESTOS PERSONALINJURY PRODUCTLIABILITY

PERSONAL PROPERTY

[ ] 370 OTHER FRAUD[ ] 371 TRUTH IN LENDING

[ ] 380 OTHER PERSONALPROPERTY DAMAGE

[ ] 385 PROPERTY DAMAGEPRODUCT LIABILITY

PRISONER PETITIONS

[ ] 510 MOTIONS TOVACATE SENTENCE28 USC 2255

[ ] 530 HABEAS CORPUS[ ] 535 DEATH PENALTY[ ] 540 MANDAMUS & OTHER

PRISONER CIVIL RIGHTS

[ ] 550 CIVIL RIGHTS[ ] 555 PRISON CONDITION

FORFEITURE/PENALTY

21 USC 881

LABOR

[ ] 710 FAIR LABORSTANDARDS ACT

[ ] 720 LABOR/MGMTRELATIONS

[ ] 740 RAILWAY LABOR ACT[ ] 751 FAMILY MEDICAL LEAVE ACT (FMLA)

[ ] 790 OTHER LABORLITIGATION

[ ] 791 EMPL RET INCSECURITY ACT (ERISA)

IMMIGRATION

[ ] 462 NATURALIZATIONAPPLICATION

[ ] 465 OTHER IMMIGRATIONACTIONS

CONDITIONS OF CONFINEMENT

ACTIONS UNDER STATUTES

BANKRUPTCY

[ ] 422 APPEAL28 USC 158

[ ] 423 WITHDRAWAL28 USC 157

PROPERTY RIGHTS

[ ] 820 COPYRIGHTS[ ] 830 PATENT

[ ] 840 TRADEMARKSOCIAL SECURITY

[ ] 861 HIA (1395ff)[ ] 862 BLACK LUNG (923)[ ] 863 DIWC/DIWW (405(g))[ ] 864 SSID TITLE XVI[ ] 865 RSI (405(g))

FEDERAL TAX SUITS

[ ] 870 TAXES (U.S. Plaintiff orDefendant)

[ ] 871 IRS-THIRD PARTY26 USC 7609

OTHER STATUTES

[ ] 400 STATEREAPPORTIONMENT

[ ] 410 ANTITRUST[ ] 430 BANKS & BANKING[ ] 450 COMMERCE[ ] 460 DEPORTATION[ ] 470 RACKETEER INFLU-

ENCED & CORRUPTORGANIZATION ACT(RICO)

[ ] 480 CONSUMER CREDIT[ ] 490 CABLE/SATELLITE TV

[ ] 850 SECURITIES/COMMODITIES/EXCHANGE

[ ] 890 OTHER STATUTORYACTIONS

[ ] 891 AGRICULTURAL ACTS

[ ] 893 ENVIRONMENTALMATTERS

[ ] 895 FREEDOM OFINFORMATION ACT

[ ] 896 ARBITRATION[ ] 899 ADMINISTRATIVE

PROCEDURE ACT/REVIEW OR APPEAL OF AGENCY DECISION

Check if demanded in complaint:

CHECK IF THIS IS A CLASS ACTIONDO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13?

UNDER F.R.C.P. 23 IF SO, STATE:

DEMAND $______________ OTHER ______________ JUDGE _________________________________ DOCKET NUMBER_________________

Check YES only if demanded in complaintJURY DEMAND: YES NO NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).

[ ] 690 OTHER

[ ] 625 DRUG RELATEDSEIZURE OF PROPERTY

[ ] 560 CIVIL DETAINEE

DISABILITIES -OTHER[ ] 446 AMERICANS WITH

EMPLOYMENTDISABILITIES -

[ ] 445 AMERICANS WITHACCOMMODATIONS

[ ] 443 HOUSING/[ ] 442 EMPLOYMENT[ ] 441 VOTING

[ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)

[ ] 375 FALSE CLAIMS

[ ] 448 EDUCATION

[ ] 463 ALIEN DETAINEE

[ ] 362 PERSONAL INJURY -MED MALPRACTICE

[ ] 367 HEALTHCARE/PHARMACEUTICAL PERSONAL INJURY/PRODUCT LIABILITY

[ ] 950 CONSTITUTIONALITY OF STATE STATUTES

[ ] 376 QUI TAM

[ ] 835 PATENT-ABBREVIATED NEW DRUG APPLICATION

Watch Tower Bible and Tract Society of Pennsylvania The Truth and Transparency Foundation, Ryan McKnight, and Ethan Gregory Dodge

Cowan, Liebowitz & Latman, P.C. 114 West 47th Street New York, NY 10036-1525

17 U.S.C. § 101 et seq. - Copyright Infringement

✔

✖


(PLACE AN x IN ONE BOX ONLY) ORIGIN1 Original

Proceeding2 Removed from

State Court

a. all parties represented

b. At least one party is pro se.

3 Remanded from Appellate Court

4 Reinstated or Reopened

5 Transferred from (Specify District)

6 Appeal to District Judge from Magistrate Judge

(PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE1 U.S. PLAINTIFF 2 U.S. DEFENDANT 3 FEDERAL QUESTION 4 DIVERSITY

(U.S. NOT A PARTY)CITIZENSHIP BELOW.

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

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

PTF DEF PTF DEF PTF DEFCITIZEN OF THIS STATE [ ] 1 [ ] 1 CITIZEN OR SUBJECT OF A [ ] 3 [ ] 3 INCORPORATED and PRINCIPAL PLACE [ ] 5 [ ] 5

FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE

CITIZEN OF ANOTHER STATE [ ] 2 [ ] 2 INCORPORATED or PRINCIPAL PLACE [ ] 4 [ ] 4 FOREIGN NATION [ ] 6 [ ] 6 OF BUSINESS IN THIS STATE

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

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

DEFENDANT(S) ADDRESS UNKNOWNREPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

Check one: THIS ACTION SHOULD BE ASSIGNED TO: WHITE PLAINS MANHATTAN

DATE

RECEIPT #

SIGNATURE OF ATTORNEY OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT[ ] NO[ ] YES (DATE ADMITTED Mo. _______ Yr. _______)Attorney Bar Code #

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

Magistrate Judge _________________________________________________________ is so Designated.

Ruby J. Krajick, Clerk of Court by _____________ Deputy Clerk, DATED _____________________.

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

COURTHOUSE ASSIGNMENTI hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.

8

7Multidistrict Litigation (Transferred)

Multidistrict Litigation (Direct File)

✖

✖

200 Watch Tower Drive, Patterson, New York 12563 - Putnam County

The Truth and Transparency Foundation: 109 Cascade Meadow Court, Henderson, Nevada 89011 - Clark County

Ryan C. McKnight: 109 Cascade Meadow Court, Henderson, Nevada 89011 - Clark County

Ethan G. Dodge

✖

✖ 10 2003TK-0605

04/30/2020


31653/001/3452979.1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

WATCH TOWER BIBLE AND TRACT SOCIETY OF PENNSYLVANIA,

Plaintiff,

-against-

THE TRUTH AND TRANSPARENCY FOUNDATION, RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

No.

RULE 7.1 STATEMENT

Pursuant to Rule 7.1 of the Federal Rules of Civil Procedure, the undersigned attorney of

record for Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (a private non-

governmental party) certifies that there is no parent company of Watch Tower Bible and Tract

Society of Pennsylvania, and no publicly held company owns 10% or more of its stock.

Dated: New York, New York April 30, 2020 Respectfully submitted,

COWAN, LIEBOWITZ & LATMAN, P.C.

By: s/ Kieran G. Doyle _ Kieran G. Doyle

114 West 47th Street New York, New York 10036 (212) 790-9200

20-cv-3366


AO 121 ( 6/ ) TO:

REPORT ON THEFILING OR DETERMINATION OF AN

ACTION OR APPEALREGARDING A COPYRIGHT

In compliance with the provisions of 17 U.S.C. 508, you are hereby advised that a court action or appeal has been filedon the following copyright(s):

COURT NAME AND LOCATIONG ACTION G APPEAL

DOCKET NO. DATE FILED

PLAINTIFF DEFENDANT

COPYRIGHTREGISTRATION NO. TITLE OF WORK AUTHOR OR WORK

1

2

3

4

5

In the above-entitled case, the following copyright(s) have been included:DATE INCLUDED INCLUDED BY

G Amendment G Answer G Cross Bill G Other PleadingCOPYRIGHT

REGISTRATION NO. TITLE OF WORK AUTHOR OF WORK

1

2

3 .

In the above-entitled case, a final decision was rendered on the date entered below. A copy of the order or judgmenttogether with the written opinion, if any, of the court is attached.

COPY ATTACHED WRITTEN OPINION ATTACHED DATE RENDERED

G Order G Judgment G Yes G No

CLERK (BY) DEPUTY CLERK DATE

1) Upon initiation of action, 2) Upon filing of document adding copyright(s), 3) Upon termination of action,mail copy to Register of Copyrights mail copy to Register of Copyrights mail copy to Register of Copyrights

DISTRIBUTION:4) In the event of an appeal, forward copy to Appellate Court 5) Case File Copy

✔ USDC-Southern District of New York

20-cv-3366 4/30/2020

Watch Tower Bible and Tract Society of Pennsylvania The Truth and Transparency Foundation, Ryan C.McKnight and Ethan G. Dodge

PA0002121393 “Be a Courageous … Pioneer” Watch Tower Bible and Tract Soc.

PA0002121074 Talk 33 - Video 1 - Learn Courage From Creation... Watch Tower Bible and Tract Soc.

PA0002121104 Talk 40 - Video 1 - How Our Brothers Are Showing... Watch Tower Bible and Tract Soc.

PA0002121120 Talk 44 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.

PA0002121121 Talk 45 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.

See Attached Schedule for Complete List


COPYRIGHT REGISTRATION NO.

TITLE OF WORK AUTHOR OR WORK

PA0002121124 Talk 46-Video 1 - Future Events That Will Require Courage (Symposium) - The Proclamation of the Hailstone Message

Watch Tower Bible and Tract Society of Pennsylvania

PA0002121125 Talk 47 - Video 1 - Future Events That Will Require Courage (Symposium) - The Attack by Gog of Magog


PA0002121607 Talk 48-Video 1 - Future Events That Will Require Courage (Symposium) - Armageddon


PA0002121129 Talk 49 - Video 1 - Future Events That Will Require Courage (Symposium) - The Great Reconstruction


PA0002121132 Talk 50 - Video 1 - Future Events That Will Require Courage (Symposium) - The Final Test


PA0002191509 2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1


PA0002191514 Talk 01 Video 1 - Chairman’s Address: ‘Love Never Fails - Why?


PA0002191517 Talk 01 Video 2 - Chairman’s Address: ‘Love Never Fails’ - Why?


PA0002191478 Talk 02 Video 1 - Symposium: Beware of Trusting in What Fails! - Wealth (Matthew 6:24)


PA0002191475 Talk 03 Video 1 - Symposium: Beware of Trusting in What Fails! - Status and Fame (Ecclesiastes 2:16; Romans 12:16)


PA0002191487 Talk 04 Video 1 - Symposium: Beware of Trusting in What Fails! - Human Wisdom (Romans 12:1, 2)



PA0002191489 Talk 05 Video 1 - Symposium: Beware of Trusting in What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter 3:3, 4)


PA0002191501 Talk 06 Video 1 - DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1; 47:12)


PA0002191510 2019 ‘Love Never Fails’! Convention—Music-Video Presentation 2Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32)


PA0002191450 Talk 08 Video 1 - Symposium: Love Never Fails Despite … A Loveless Upbringing (Psalm 27:10)


PA0002191453 Talk 09 Video 1 - Symposium: Love Never Fails Despite … A Difficult Work Environment (1 Peter 2:18-20)


PA0002191458 Talk 10 Video 2 - Symposium: Love Never Fails Despite … An Ungodly School Environment (1 Timothy 4:12)


PA0002191459 Talk 11 Video 1 - Symposium: Love Never Fails Despite … Chronic Health Problems (2 Corinthians 12:9, 10)


PA0002191460 Talk 12 Video 1 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12, 13)


PA0002191461 Talk 12 Video 2 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12, 13)



PA0002191455 Talk 13 Video 1 - Symposium: Love Never Fails Despite … Family Opposition (Matthew 5:44)


PA0002191432 Talk 14 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)


PA0002191434 Talk 15 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Earth (Psalm 37:29; 115:16)


PA0002191437 Talk 16 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)


PA0002191444 Talk 17 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)


PA0002191446 Talk 18 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes 3:11)


PA0002191504 Talk 19 Video 1 - ‘Those Whom Jehovah Loves He Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)


PA0002191471 Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14)




PA0002191157 Talk 21 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Those Taking the Lead (1 Thessalonians 5:12, 13)



PA0002191160 Suppl. Reg. PA0002216893

Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32)


PA0002191146 Talk 24 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Full-Time Ministers (1 Thessalonians 1:3)


PA0002191155 Talk 25 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Foreign Residents (Leviticus 19:34; Romans 15:7)


PA0002191149 ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers Meeting


PA0002191683 Talk 26 Video 1 - A0002191683: Display Unfailing Love in the Ministry - Show Your Love for God (1 John 5:3)


PA0002191148 Talk 27 Video 1 - Symposium: Display Unfailing Love in the Ministry – ‘Love Your Neighbor as Yourself’ (Matthew 22:39)


PA0002191684 Talk 28 Video 1 - Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s Word (Psalm 119:97; Matthew 13:52)


PA0002193286 2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4 (v2)



PA0002191713 Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In … Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians 9:22), Oceania (Psalm 35:18), South America (Acts 1:8)


PA0002191714 Talk 31 Video 1 - Display Unfailing Love in Your Family - Love Your Wife (Ephesians 5:28, 29)


PA0002191715 Talk 32 Video 1 - Display Unfailing Love in Your Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)


PA0002191717 Talk 33 Video 1 - Display Unfailing Love in Your Family - Love Your Children (Titus 2:4)


PA0002191144 The Story of Josiah: Love Jehovah; Hate What Is Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)


PA0002191678 Talk 35 Video 1 - Teach Your Children How to Show Love (2 Timothy 3:14, 15)








PA0002192010 Talk 36 Video 1 - Symposium: Remember How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)


PA0002192009 Talk 36 Video 2 - Symposium: Remember How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)



PA0002191147 Talk 37 Video 1 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)


PA0002191150 Talk 37 Video 2 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)


PA0002191151 Talk 38 Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)


PA0002191152 Talk 38 Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)


PA0002191156 Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1 Corinthians 13:5)


PA0002191153 Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1 Corinthians 13:5)


PA0002191154 Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)



PA0002191719 Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)


PA0002191722 Talk 41 Video 1 - Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)


PA0002191723 Talk 41 Video 2 - Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)


PA0002191724 Talk 42 Video 1 - Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)


PA0002191727 Talk 42 Video 2 - Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)


PA0002191729 Talk 43 Video 1 - Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)


PA0002191159 Talk 43 Video 2 - Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)


PA0002191418 Talk 44 Video 1 - Public Bible Discourse: True Love in a Hate-Filled World - Where? (John 13:34, 35)



PA0002191141 Talk 44 Video 2 - Public Bible Discourse: True Love in a Hate-Filled World - Where? (John 13:34, 35)


PA0002191682 The Story of Josiah: Love Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)


PA0002191138 Talk 47 Video 1 - ‘Carefully Consider Jehovah’s Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)


PA0002191706 Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8))





AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

CLERK OF COURT

Date:Signature of Clerk or Deputy Clerk

Southern District of New York

WATCH TOWER BIBLE AND TRACT SOCIETY OFPENNSYLVANIA

20-cv-3366

THE TRUTH AND TRANSPARENCYFOUNDATION, RYAN C. McKNIGHT,

and ETHAN G. DODGE

The Truth and Transparency Foundation109 Cascade Meadow CourtHenderson, Nevada 89011

Kieran G. DoyleThomas KjelbergCowan, Liebowitz & Latman, P.C.114 West 47th Street21st FloorNew York, NY 10036


AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individual’s last known address; or

I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

I returned the summons unexecuted because ; or

Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

20-cv-3366

0.00




__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)






CLERK OF COURT




20-cv-3366


and ETHAN G. DODGE

Ryan C. McKnight109 Cascade Meadow CourtHenderson, Nevada 89011




Civil Action No.





on (date) ; or






on (date) ; or


Other (specify):

.





Server’s address


20-cv-3366

0.00




__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)






CLERK OF COURT




20-cv-3366


and ETHAN G. DODGE

Ethan G. Dodge12597 Cresthaven DriveGroveland, CA 95321-9316




Civil Action No.





on (date) ; or






on (date) ; or


Other (specify):

.





Server’s address


20-cv-3366

0.00


Documents

WATCH TOWER BIBLE AND TRACT SOCIETY OF · rutube.ru. and available to users worldwide. 17. Watch Tower submitted to Rutube notices of claimed infringement, objecting to the unauthorized