文档介绍：UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
TRIPLE UP LIMITED )
Second Floor City )
Independence Avenue ) Case No.: 1:16-cv-159
Victoria, Mahe, Seychelles )
)
Plaintiff, )
) COMPLAINT AND
v. ) JURY DEMAND
)
YOUKU TUDOU INC. )
PO Box 309, Ugland House )
Grand Cayman )
KY1-1104 Cayman Islands )
)
Defendant. )
)
COMPLAINT
Plaintiff, TRIPLE UP LIMITED (“Plaintiff,” or “TUL”), brings plaint in the United States District Court for the District of Columbia against YOUKU TUDOU INC. (“Defendant” or “YOUKU”) and alleges as follows:
NATURE OF THE CASE
Plaintiff owns the exclusive broadcasting rights of three Taiwanese movies in the United States: “沉睡的青春”(“Sleeping Youth”), “對不起,我愛你”(“Sorry, I Love You”), and “松鼠自***事件”(“Squirrel Suicide Incident”) (collectively, “Copyrighted Works”).
Among the bundle of copyright rights afforded Plaintiff, the Copyright Act provides the Plaintiff with the exclusive right “to transmit or municate a performance or display of” the Copyrighted Works “to the public by means of any device or process, whether the members of the public capable of receiving the performance or display
1
receive it in the same place or in separate places and at the same time or at different times.” 17
. § 101; see also § 106.
Defendant claims to be China’s leading pany and its
Youku and Tudou platforms enable users, including those in the United States and in this District, to search, view, and share high-quality video content across multiple devices.
Upon information and belief, Defendant, through one or more of its employees, contractors, and/or agents, uploaded Plaintiff’s Copyrighted Works to its Youku and/or Tudou platforms, then caused and carried out the unauthorized public performance of, reproduced, and/or distributed the Copyrighted Works by publicly streaming them on Defendant’s websites in the United States, including in this District. Upon information and belief, Defendant’s websites streaming or displaying the