Case 3:16-cv-02130-HZ

Document 1

Filed 11/07/16

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Andrew D. Glascock, OSB No. 992676

Email: aglascock@hfg-law.com
Alison M. Brown, OSB No. 113376
Email: abrown@hfg-law.com
Hiefield Foster & Glascock LLP
Attorneys at Law
6915 SW Macadam Ave, Ste 300
Portland, OR 97219
Telephone: (503) 501-5430
Fax: (503) 501-5626
Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
OREGON BREWING COMPANY, an
Oregon corporation,

Case No.:
COMPLAINT
(Copyright Infringement)

Plaintiff,
vs.

DEMAND FOR JURY TRIAL

BENJAMIN R. BLAIR, an individual,
Defendant.
NATURE OF THE ACTION
1.

This is an action for copyright infringement arising under the copyright laws of

the United States, 17 U.S.C. 101, et seq.

2.

Oregon Brewing Company (OBC) brings this action to prevent further

irrevocable harm such as that which it has suffered due to the Defendants infringement of its
copyrighted work, and to recover appropriate damages against the Defendant under the laws of
the United States.
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PARTIES, JURISDICTION AND VENUE

3.

Plaintiff OBC is a corporation with its principal place of business in Newport,

Oregon.
4.

On information and belief, Defendant Benjamin Blair (Blair) is an individual

who resides in Portland, Oregon and does business in Oregon and is subject to the jurisdiction of
this Court.
5.

This Court has jurisdiction pursuant to 28 U.S.C. 1331 and 1338. Venue is

proper under 28 U.S.C. 1391 and 1400(a).

FACTS COMMON TO ALL COUNTS
6.

Plaintiff OBC was at all times material an Oregon corporation doing business and

having offices located in Lincoln County Oregon. OBC is the producer, seller and marketer of
alcoholic beverages and related marketing materials which it sells throughout the United States
through a series of distributors.
7.

Prior to being employed by OBC, Benjamin Blair was a freelance photographer

and director. Blair was employed as a W-2 employee by OBC, as its photographer and
videographer from approximately April 28, 2014 to March 15, 2016.
8.

As part of his position as photographer and videographer, Blair took photographs

and created short films for plaintiff OBC.

9.

On August 2, 8, 11, and 12, 2016, the photographs and short films created by

Blair during his employment with OBC were submitted to the Registrar of Copyrights for a
Certification of Registration.
10.

OBC currently is, and at all material times was, the sole proprietor of all right,

title, and interest in and to the copyright of the photographs and short films.

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OBC has complied with all formalities under the copyright laws of the United

States, 17 U.S.C. 101, et seq.

12.

Upon Blairs employment with OBC he signed an intellectual property agreement

whereby Blair agreed that all works created by him during his employment with OBC were the
property of OBC.
13.

Blair executed this intellectual property agreement with OBC on April 28, 2014.

(Exhibit 1.)
14.

OBC never granted Blair the authority to use the photographs or short films he

created as part of his employment with OBC for his own personal benefit or for any purpose
other than in his employment with OBC.
15.

In violation of the law, photographs and short films licenses, OBCs intellectual

property agreement, and copyrights to use and copy OBCs photographs and short films
produced by Blair while employed with OBC were illegitimately copied and used by Blair on his
personal professional website, www.benblairdonethat.com, without notice, permission, or
compensation to OBC.
16.

OBC learned of the unauthorized use of OBCs photographs and short films on or

17.

On March 23, 2016, OBC informed Blair of his wrongful use of OBCs

about.

photographs and short films and demanded that Blair cease and desist use of those photographs
and short films for his personal use.
18.

To date Blair has failed to remove the OBC photographs and short films from his

personal professional/commercial website.

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Blairs conduct has involved the use of OBCs copyright protected photographs

and short films for his own personal professional purposes without the consent of OBC and
without compensation to OBC, and constitutes actionable infringement under 17 U.S.C. 501.
20.

All individual acts of infringement by Blair, counted below, have caused

substantial injury to OBC.

21.

Blair has been put on notice many times informing him that he was engaging in

wrongful acts of infringement that were necessarily causing injury to OBC.

22.

OBC concludes, that in consideration of the above facts, the injuries resulting to

OBC from the infringing activities of Blair have been knowingly committed with a willful and
malicious disregard of OBCs rights during the many months after OBCs notice of infringement
and upon information and belief, before the notice as well.
23.

As a result of Blairs conduct, OBC has been forced to expend large amounts of

time and expense, and retain attorneys to which it is obligated to pay a reasonable fee.
COUNT ONE: COPYRIGHT INFRINGEMENT
24.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
25.

Defendant has infringed OBCs copyrights in the photograph titled Pendleton

Pilsner at Pendleton, copyright case no. 1-3872836781, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWO: COPYRIGHT INFRINGEMENT
26.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled Hazelnut

Harvest, copyright case no. 1-3782537325, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THREE: COPYRIGHT INFRINGEMENT
28.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
29.

Defendant has infringed OBCs copyrights in the photograph titled Barrel

Making, copyright case no. 1-3872742135, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT FOUR: COPYRIGHT INFRINGEMENT
30.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
31.

Defendant has infringed OBCs copyrights in the photograph titled Corn

Picking, copyright case no. 1-3872816558, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT FIVE: COPYRIGHT INFRINGEMENT
32.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
33.

Defendant has infringed OBCs copyrights in the photograph titled Red

Cocktail-0010, copyright case no.1-3889940031, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT SIX: COPYRIGHT INFRINGEMENT
34.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled Wasted Sea

Star Tidepool, copyright case no. 1-3889940135, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT SEVEN: COPYRIGHT INFRINGEMENT
36.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
37.

Defendant has infringed OBCs copyrights in the photograph titled Tomorrows,

copyright case no. 1-3890011298, for his own professional benefit, actions which constitute
copyright infringement as defined by 17 U.S.C. 501.
COUNT EIGHT: COPYRIGHT INFRINGEMENT
38.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
39.

Defendant has infringed OBCs copyrights in the photograph titled Yaquina

Bridge, copyright case no. 1-389971441, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT NINE: COPYRIGHT INFRINGEMENT
40.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
41.

Defendant has infringed OBCs copyrights in the photograph titled Hellboy

Bottle Release, copyright case no. 1-3899714685, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TEN: COPYRIGHT INFRINGEMENT
42.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled PDX Carpet

Bottles, copyright case no. 1-3899736591, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT ELEVEN: COPYRIGHT INFRINGEMENT
44.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
45.

Defendant has infringed OBCs copyrights in the photograph titled John Maier

Bicycle Ride, copyright case no. 1-3899749491, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWELVE: COPYRIGHT INFRINGEMENT
46.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
47.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0089, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTEEN: COPYRIGHT INFRINGEMENT
48.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
49.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0126, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT FOURTEEN: COPYRIGHT INFRINGEMENT
50.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0202, copyright case no. 1-3902514541, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT FIFTEEN: COPYRIGHT INFRINGEMENT
52.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
53.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0218, copyright case no. 1-3902514541, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT SIXTEEN: COPYRIGHT INFRINGEMENT
54.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
55.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0368, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT SEVENTEEN: COPYRIGHT INFRINGEMENT
56.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
57.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0439, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT EIGHTEEN: COPYRIGHT INFRINGEMENT
58.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0467, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT NINETEEN: COPYRIGHT INFRINGEMENT
60.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
61.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0481, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY: COPYRIGHT INFRINGEMENT
62.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
63.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0536, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-ONE: COPYRIGHT INFRINGEMENT
64.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
65.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0608, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-TWO: COPYRIGHT INFRINGEMENT
66.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0791, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-THREE: COPYRIGHT INFRINGEMENT
68.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
69.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 0915, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-FOUR: COPYRIGHT INFRINGEMENT
70.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
71.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9400, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-FIVE: COPYRIGHT INFRINGEMENT
72.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
73.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9520, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-SIX: COPYRIGHT INFRINGEMENT
74.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9538, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-SEVEN: COPYRIGHT INFRINGEMENT
76.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
77.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9550, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-EIGHT: COPYRIGHT INFRINGEMENT
78.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
79.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9563, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT TWENTY-NINE: COPYRIGHT INFRINGEMENT
80.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
81.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9597, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY: COPYRIGHT INFRINGEMENT
82.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9607, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-ONE: COPYRIGHT INFRINGEMENT
84.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
85.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9682, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-TWO: COPYRIGHT INFRINGEMENT
86.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
87.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9754, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-THREE: COPYRIGHT INFRINGEMENT
88.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
89.

Defendant has infringed OBCs copyrights in the photograph titled Frogs &

Dogs Image 9760, copyright case no. 1-3902514241, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-FOUR: COPYRIGHT INFRINGEMENT
90.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the short film titled Rogue

Revolution, copyright case no. 1-3872650411, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-FIVE: COPYRIGHT INFRINGEMENT
92.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
93.

Defendant has infringed OBCs copyrights in the short film titled Crafts and

Drafts Video - Final, copyright case no. 1-2872741791, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-SIX: COPYRIGHT INFRINGEMENT
94.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
95.

Defendant has infringed OBCs copyrights in the short film titled Beard Beer

master cut - Final, copyright case no. 1-3872836875, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-SEVEN: COPYRIGHT INFRINGEMENT
96.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
97.

Defendant has infringed OBCs copyrights in the short film titled Rogue Nation

Tour Highlights, copyright case no. 1-3890011391, for his own professional benefit, actions
which constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-EIGHT: COPYRIGHT INFRINGEMENT
98.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
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Defendant has infringed OBCs copyrights in the short film titled Unipiper Final

Master, copyright case no. 1-3890011434, for his own professional benefit, actions which
constitute copyright infringement as defined by 17 U.S.C. 501.
COUNT THIRTY-NINE: COPYRIGHT INFRINGEMENT
100.

Paragraphs 1 through 23 are adopted and incorporated by reference as if fully set

out herein.
101.

Defendant has infringed OBCs copyrights in the short film titled Yard House

Spruce Tip IPA 19th Anniversary Release, copyright case no. 1-3890011997, for his own
professional benefit, actions which constitute copyright infringement as defined by 17 U.S.C.
501.
102.

Defendant has copied, reproduced, distributed, adapted, and/or publicly displayed

OBCs copyrighted photographs and short films without the consent or authority of OBC,
thereby directly infringing OBCs copyrights.
103.

Defendants conduct constitutes infringement of OBCs copyrights and exclusive

rights under copyright in violation of 17 U.S.C. 106 and 501 et seq.

104.

The infringement of OBCs rights in and to each of the digital images and short

films constitutes a separate and distinct act of infringement.

105.

The acts of infringement by defendant have been willful, intentional, and

purposeful, in reckless disregard of and with indifference to the rights of OBC.

106.

As a direct and proximate result of its unlawful conduct, defendant is liable for

OBC for copyright infringement. OBC has suffered and will continue to suffer substantial
losses, including, but not limited to, damages to its business reputation and goodwill. OBC is
entitled to recover damages, which include its losses and all profits defendant has made as a
result of his wrongful conduct pursuant to 17 U.S.C. 504(b).
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Alternative to actual damages plus defendants profits, OBC is entitled to the

maximum statutory damages, pursuant to 17 U.S.C. 504(c), in the amount of $150,000.00 for
each infringed image, or other such amounts as may be proper pursuant to 17 U.S.C. 504(c).
108.

Defendants conduct has caused and, unless enjoined and restrained by this court,

will continue to cause irreparable injury to OBC for which OBC has no adequate remedy at law.
Pursuant to 17 U.S.C. 502, OBC is entitled to injunctive relief prohibiting further infringement
of OBCs copyrights.
109.

Plaintiff is entitled to the recovery of full costs and reasonable attorneys fees in

an amount to be determined by the court pursuant to 17 U.S.C. 505 and any other rule or
statute.
PRAYER FOR RELIEF
WHEREFORE, OBC respectfully requests this Honorable Court enter such order and
judgments as are necessary to provide the following relief:
A.

Enter a Judgment against Defendant on Counts one through thirty-nine of the

Complaint;

B.

Enter a permanent injunction enjoining Defendant from infringing OBCs

copyrighted photographs and short films under 17 U.S.C. 502;

C.

Require the destruction of all infringing copies of OBCs copyrighted

photographs and short films in the possession, custody or control of Defendant,
including any agents, employees or attorneys, and its removal from defendants
website or social media accounts under 17 U.S.C. 503;

D.

That the Court order Defendant to pay OBC damages and Defendants profits
pursuant to 17 U.S.C. 504(b), or, alternatively, enhanced statutory damages

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pursuant to 17 U.S.C. 504(c) and 17 U.S.C. 504(c)(2), for Defendants willful

infringement of OBCs copyrights;
E.

That the Court order Defendant to pay to OBC both the costs of this suit and the
reasonable attorneys fees incurred by OBC in investigating and prosecuting this
action; and

F.

That the Court grant OBC such other and additional relief as is just and proper.
JURY DEMAND

Plaintiff demands a trial by a 12-person jury.

Dated this 7th day of November, 2016.
HIEFIELD FOSTER & GLASCOCK, LLP
s/ Andrew D. Glascock
By ______________________________________
Andrew D. Glascock, OSB No. 992676
Email: aglascock@hfg-law.com
Alison M. Brown, OSB No. 113376
Email: abrown@hfg-law.com
Trial Attorney
Of Attorneys for Plaintiff

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