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Description: Tulsa, Oklahoma intellectual property lawyer represented Plaintiff, who sued Defendant on a copyright infringement theory.

Plaintiff is a wildlife illustrator who created and owns copyrights to numerous works of art. Dkt. No. 2 at 2-4, Dkt No. 2-1. Plaintiff alleges that Defendants Jane Doe and Does 1-10 (“Doe Defendants”) have unlawfully reproduced, adapted, displayed, and used some of his works of art to create derivative works. Dkt. No. 2 at 7; Dkt No. 2-1. Specifically, Plaintiff identifies the following: (1) Airborne Bass, U.S. Copyright Registration No. VA-1-957-011; (2) Action Series: Bass Spinner; Brown Trout; Northern Pike, Crappie, Stripped Bass; Musky; Rainbow Trout, U.S. Copyright Registration No. VAu-348-036; (3) 2000 Unpublished Apparel Series: Side Fish Collage; Steelhead Reel Rocks, U.S. Copyright Registration No. VAu-486-561; (4) 2000 Published Apparel Series: Lures, U.S. Copyright Registration No. VA 1-032-512; (5) Bass Spinner and Log, U.S. Copyright Registration No. VA 2-302-584; (6) Crappie and Root, U.S. Copyright Registration No. VA 2-303-553; (7) Smallmouth Bass and Topwater Bait, U.S. Copyright Registration No. VA 2-160-537; (8) Walleye Spinner Rig, U.S. Copyright Registration No. VA 2151-863; (9) Legends Series Artwork: Bass, U.S. Copyright Registration No. VA-1-153-915; (10) Crappie Dock Painting, U.S. Copyright Registration No. VA-1-957-012; (11) Northern & Bucktail, U.S. Copyright Registration No. VAu-214-078; (12) JQ Fish Art: Walleye Green Lure; 2 Bass Group, U.S. Copyright Registration No. VA-1-021-822; (13) Fooled Again Bass, U.S. Copyright Registration No. VA-519-738; (14) Tangled Cover Crappie, U.S. Copyright Registration No. VA-500-654; (15) Sunbay Bluegill, U.S. Copyright Registration No. VA-2-087-516; (16) Harvest Moon Walleye 3, U.S. Copyright Registration No. VA-2-084-056; (17) Breakline Hunter Musky, U.S. Copyright Registration No. VA-2-083-993; (18) Crappie and Leaves, Pending Registration; and (19) Salmon Stream Print, Pending Registration (collectively “Subject Works”). Dkt. No. 2 at 3-4.

Plaintiff claims that the Doe Defendants are selling infringing materials in the form of digital files on the online marketplace www.etsy.com. Dkt. No. 3 at 6.


In this case, Jane Doe submitted counternotices to Etsy on June 27, 2022, indicating her good faith belief that the notice of infringement was based on a mistake or misidentification of the infringing material. Dkt. No. 2-3. The member information included on the counternotices included the name Jonnita Rogers, a contact email of kristine@sweetandsourgoodies.com, and a physical address in Bartlesville, Oklahoma.[1] Id. at 1, 3, 5. Plaintiff's counsel performed an internet search and was unable to find information linking a Jonnita Rogers to the domain sweetandsourgoodies.com or to the sweetandsourgoodies storefront. Dkt. No. 3-2 at 5. He also discovered that the domain sweetandsourgoodies.com is not currently active. Id.; Dkt. No. 3-4. A search of the email address led counsel to a separate online marketplace-Flickr.com-where the email address was linked to the user profile of a Kristine Domingo Hoffman. Dkt. No. 3-2 at 5. Dolls listed for sale on this user's Flickr page bear a striking resemblance to dolls sold at the sweetandsourgoodies storefront. Dkt. No. 3-7 at 2-3; Dkt. No. 5-8. Based on this information, counsel asserts that Jane Doe either provided entirely inaccurate information in the counternotice to avoid detection, or “has otherwise created legitimate suspicion regarding the true ownership” of the sweetandsourgoodies storefront. Dkt. No. 3-2 at 6.

Outcome: This Temporary Restraining Order shall remain in full force and effect for fourteen (14) days unless otherwise dissolved by this Court or extended for good cause. A hearing is set for July 28, 2022 at 2:00 p.m. to hear evidence and argument as to whether this Temporary Restraining Order should be converted into a preliminary injunction under the applicable law.

Plaintiff's Experts:

Defendant's Experts:

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