Marc J.

Randazza, SBN 269535

1 Randazza Legal Group
3969 Fourth Avenue, Suite 204
2 San Diego, CA 92103
888-667-1113
3 305-437-7662 (fax)
4 MJR@randazza.com
5 Counsel for Plaintiff,
LIBERTY MEDIA HOLDINGS, LLC
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7 UNITED STATES DISTRICT COURT

8 SOUTHERN DISTRICT OF CALIFONRIA, SAN DIEGO DIVISION

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9 LIBERTY MEDIA HOLDINGS, LLC d/b/a ) Case No. 10-CV-1810-JLS-WMC
CORBIN FISHER )
10 ) SECOND AMENDED COMPLAINT
Plaintiff, )
11 ) (1) COPYRIGHT INFRINGEMENT
vs. )
12 ) INJUNCTIVE RELIEF SOUGHT
13 PORNILOVE.NET, COREY DEBARROS, )
and JOHN DOES 3-1000 )
14 )
Defendants )
15 )

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The Plaintiff is a well-known adult entertainment company that produces high-quality
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erotic content under the name "Corbin Fisher." The defendants misappropriated the Plaintiff's
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intellectual property by illegally copying and distributing the Plaintiff’s copyrighted films and
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photographs. The Plaintiff has suffered damages as a result of the Defendants' misappropriation
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and misuse of its intellectual property, and the Plaintiff brings this action seeking monetary
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damages and injunctive relief under the Copyright Act.
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INTRODUCTION
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1. The Plaintiff, Liberty Media Holdings, LLC (“Liberty” or “Plaintiff”) and its
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partner company produce high quality photographs, which are published and licensed to third
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party publishers for a premium fee.
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2. The Defendants misappropriated dozens of the Plaintiff’s films, the full number of
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which will only be able to be ascertained after discovery.
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3. The Defendants’ actions are a clear violation of the Plaintiff’s copyrights as
protected by Title 17 of the U.S. Code.
 1 4. The Defendants’ actions were willful in nature, entitling the Plaintiff to enhanced
2 damages. The Plaintiff seeks statutory damages, actual damages, an award of its attorney’s fees
3 and costs, as well as injunctive relief to ensure that Defendants engage in no future activity of a
4 similar nature.
5 THE PARTIES
6 THE PLAINTIFF, LIBERTY MEDIA HOLDINGS, LLC
7 5. Liberty is a California corporation with a mailing address of 302 Washington
8 Street, Suite 321, San Diego, CA 92103.
9 6. Liberty is a movie company that produces, directs, and markets original erotic
10 films, all of which are protected by copyright, and the copyrights thereto are registered on the
11 day the films are released or within 90 days of release.
12 DEFENDANT COREY DEBARROS
13 7. Liberty is informed and believes, and on that basis alleges that Corey Debarros
14 (Debarros) is an individual who resides in Florida.
15 8. On information and belief, Debarros owned, operated, and controlled the
16 Pornilove.net website, Pornilove blog sites, and Pornilove Yahoo! Group, and was responsible
17 for the illegal distribution of the Plaintiff’s copyrighted works.
18 DEFENDANT PORNILOVE.NET
19 9. Liberty is informed and believes, and on that basis alleges that Pornilove.net was
20 an unincorporated entity owned and controlled by Debarros and that the two are merely alter-
21 egos of one another. In addition to the Pornilove.net website, Debarros operated numerous
22 Pornilove blog sites and Yahoo! groups, each aimed at illegally publishing and distributing
23 Plaintiff’s copyrighted works.
24 DEFENDANTS JOHN DOES 3-1000
25 10. John Does 3-1000 are individuals who acted in concert with Debarros and
26 Pornilove.net to commit the acts complained of herein, and in particular, they downloaded and
27 thus copied the Plaintiff’s copyrighted works.
28 /
/

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SECOND AMENDED COMPLAINT
 1 JURISDICTION AND VENUE
2 11. This Court has subject matter jurisdiction pursuant to the Copyright Act (17
3 U.S.C. §§ 101 et. seq.), and 28 U.S.C. §§ 1331, 1338(a), 2201, and 2202, and this Court has
4 supplemental jurisdiction over the state law claims as they arise from the same common nucleus
5 of operable facts as the federal claims.
6 12. Defendants have caused injury to the Plaintiff’s intellectual property in this state
7 by purposely aiming their tortious and illegal conduct toward a corporation based in this state,
8 and in this particular judicial district. Defendants did so with the full knowledge that the
9 Plaintiff was located here, and specifically targeted their illegal behavior toward this forum and
10 caused damage in this forum through the commission of willful acts.
11 13. Venue is proper in this Court pursuant to 28 U.S.C. § 1391, as a substantial part of
12 the events or omissions giving rise to the claims pleaded herein occurred in this district, and thus,
13 this venue is the most appropriate forum in which this case should be heard.
14 FACTS COMMON TO ALL CLAIMS
15 THE PLAINTIFF’S PROPERTY
16 14. Corbin Fisher is one of the most well-known names in the adult entertainment
17 business featuring gay content. It is inconceivable that the defendant, who made a business of
18 stealing gay adult films, was not aware of the Plaintiff and its intellectual property rights. In fact,
19 the Defendants labeled the films with the Plaintiff’s trademarks and categorized them under the
20 Plaintiff’s trademarks, and used still photographs from the Plaintiff’s website to draw attention to
21 the links where the Defendants distributed the Plaintiff’s films.
22 15. The Plaintiff is the Author of multiple original works of expression, all of which
23 were created by the Plaintiff and then duly registered with the United States Copyright Office.
24 16. The effective date of registration of these works was prior to the infringement
25 committed by the Defendants.
26 17. The Plaintiff gave no Defendant permission to republish or copy its copyrighted
27 works, neither explicitly nor implicitly.
28 18. The commercial value of the relevant Copyrights has been diminished by the
Defendants’ actions.

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SECOND AMENDED COMPLAINT
 1 THE DEFENDANTS’ WRONGFUL ACTS
2 19. Debarros and Pornilove uploaded the Plaintiff’s copyrighted films to various
3 websites, thus copying them in the process, and made them available for further distribution, and
4 actually did distribute them for profit, over the Internet.
5 20. The films at issue all clearly display the Plaintiff’s registered trademarks in a
6 video watermark, thus making it clear to all viewers that these films belong to the Plaintiff.
7 21. Debarros and Pornilove used and published the Plaintiff’s films for profit and
8 without the Plaintiff’s permission.
9 22. Debarros and Pornilove used and published The Intellectual Property without any
10 regard as to the rights of the owner of The Intellectual Property.
11 23. Debarros and Pornilove profited from this publication, or sought to do so.
12 24. John Does 3-1000 illegally downloaded the Plaintiff’s copyrighted works, and in
13 doing so, created a digital copy of the Plaintiff’s copyrighted works in violation of the Plaintiff’s
14 rights under the Copyright Act.
15 25. Defendants knowingly and willfully infringed upon the Plaintiff’s copyrights.
16 26. Neither Plaintiff nor any other person granted Defendants the right to
17 manufacture, copy, and/or distribute the Plaintiff’s intellectual property, nor to exploit The
18 Intellectual Property for the Defendants’ own use, profit, or enjoyment.
19 27. The Defendants have never sought nor acquired permission to use any of The
20 Intellectual Property, yet they still commercially distributed The Intellectual Property for their
21 own profit or duplicated and copied the Intellectual Property for their own use.
22 FIRST CLAIM FOR RELIEF
23 (Copyright Infringement 17 U.S.C. § 501)
24 28. Plaintiff re-alleges and incorporates by reference as if verbatim, each and every
25 paragraph preceding.
26 29. At all times relevant hereto, the Plaintiff has been the owner and producer of the
27 dozens of infringed upon films, which were reproduced, distributed, and publicly displayed by
28 the Defendants.

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SECOND AMENDED COMPLAINT
 1 30. The Plaintiff holds copyright registration certificates from the United States
2 Copyright Office that cover the infringed upon works.
3 31. Without authorization, the Defendants reproduced and distributed the Plaintiff’s
4 copyrighted and registered works.
5 32. The Defendants’ conduct was willful within the meaning given to that term by the
6 Copyright Act.
7 33. As a result of their wrongful conduct, the Defendants are liable to the Plaintiff for
8 copyright infringement under 17 U.S.C. § 501.
9 34. Plaintiff is entitled to recover statutory damages under 17 U.S.C. § 504(c).
10 35. In addition, because the Defendants’ infringing acts were willful, the award of
11 statutory damages should be enhanced in accordance with 17 U.S.C. § 504(c)(2).
12 36. Plaintiff is entitled to recover its attorneys’ fees and costs of suit pursuant to 17
13 U.S.C. § 505.
14 WHEREFORE; PLAINTIFF PRAYS
15 1. That the Court issue a Permanent Injunction prohibiting the Defendants from
16 future misconduct of the type complained of in the Action.
17 2. That all Defendants be found jointly and severally liable for all acts complained
18 of.
19 3. For statutory and/or exemplary and/or exemplary damages in an amount of no less
20 than $750 per infringed-upon copyrighted work and no more than $150,000 per infringed-upon
21 copyrighted work.
22 4. That Defendants pay to the Plaintiff its reasonable attorneys’ fees pursuant to 17
23 U.S.C. § 505 and/or 15 U.S.C. § 1117(a).
24 5. That Defendants pay the Plaintiff the costs of this action; and,
25 6. For any additional and further relief which this Court deems to be just and proper.
26 /
27 /
28 /
/

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SECOND AMENDED COMPLAINT
 1
Dated: March 16, 2010 Respectfully Submitted,
2
s/ Marc Randazza
3 Marc J. Randazza, SBN 269535
4 Randazza Legal Group
3969 Fourth Avenue, Suite 204
5 San Diego, CA 92103
888-667-1113
6 305-437-7662 (fax)
7 MJR@randazza.com

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SECOND AMENDED COMPLAINT
 Certificate of Service
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I hereby certify that the foregoing document was filed using this Court’s CM/ECF system on
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March 16, 2011. A copy, along with the Court’s Order Granting Plaintiff’s Motion to Substitute
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Party was also served on Defendants Corey Debarros and Pornilove.net via UPS at 1034 NE
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128th St, Apt. B, North Miami, Florida 33161, and via email at coredebarros@gmail.com and
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coreydnyc@gmail.com.
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s/ Marc Randazza
8 Marc J. Randazza, SBN 269535
Randazza Legal Group
9 3969 Fourth Avenue, Suite 204
10 San Diego, CA 92103
888-667-1113
11 305-437-7662 (fax)
MJR@randazza.com
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SECOND AMENDED COMPLAINT