It appears as though Digitrax decided to strike first after Universal demanded a take down of their content due to unauthorised use... The question is what was considered unauthorised use? Downloads? The Karaoke Vevo channel? The ability to download on other platforms? We won't know until Universal pulls their arsenal and fires back... 
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TENNESSEE KNOXVILLE DIVISION
DIGITRAX ENTERTAINMENT, LLC, Plaintiff,
-against-
UNIVERSAL MUSIC CORPORATION and UNIVERSAL MUSIC PUBLISHING GROUP,
Defendant.
Docket No. _____________________
DECLARATORY JUDGMENT COMPLAINT
Plaintiff DigiTrax Entertainment, LLC (“DigiTrax”), by and through its attorneys, hereby asserts declaratory judgment claims against Defendants Universal Music Corporation and Universal Music Publishing Group (collectively “Universal”), and alleges as follows:
INTRODUCTION
1. DigiTrax brings this Complaint seeking declaratory relief because Universal has threatened it with litigation, claiming copyright infringement of Universal’s copyrighted content used in DigiTrax’s Karaoke Cloud Platform. However, Universal’s threats are in breach of a December 20, 2012 license agreement between DigiTrax and Universal (“License”), which permitted DigiTrax to use Universal’s copyrighted content in DigiTrax’s Karaoke Cloud Platform. Additionally, Universal has unilaterally terminated DigiTrax’s two year license midway in its term in flagrant breach of the License. Universal’s threat of litigation, bad faith denial of the License, and breach of the License are nothing more than an attempt by Universal to extort millions of dollars from DigiTrax. DigiTrax brings this action to obtain a declaration

that its use of Universal songs complies with DigiTrax’s bargained for contractual rights with Universal and the copyright laws of the United States, and to obtain damages for Universal’s bad faith termination of the License.
2. DigiTrax is a premier karaoke company, bringing interactive music, apps and products to the web, mobile and social media. DigiTrax offers a massive catalog of more than 17,000 songs featuring decades of the biggest hits in the music world. DigiTrax is able to offer its massive catalog by negotiating license agreements with multiple rights holders including Sony/ATV Music Publishing and Warner/Chappell Music. DigiTrax is one of the few companies based in the United States delivering fully-licensed digital karaoke for streaming and download.
3. Among its various offerings, in or around June 2012, DigiTrax introduced its Karaoke Cloud Platform/Application (“Karaoke Cloud Platform”). The Karaoke Cloud Platform is an innovative software application that permits users to download or stream songs purely for karaoke from a licensed music catalog stored in the Karaoke Cloud Platform.
4. DigiTrax is a licensee of many rights holders, including music publishers like Sony/ATV Music Publishing and Warner-Chappell Music. Pursuant to these license agreements, DigiTrax pays music publishers and other rights holders an advance and royalties for the right to have its users download or stream copyrighted songs through the Karaoke Cloud Platform, thus authorizing DigiTrax to use copyrighted content through its Karaoke Cloud Platform.
5. Universal is a leading global music publisher with more than 57 offices in 47 countries. Universal is headquartered in Los Angeles, CA, and has grown exponentially through both direct signings and catalogue acquisitions, which include the BMG Music Publishing, Zomba, Polygram, and Rondor catalogues. Universal is also the global leader in the areas of
Production music, Christian/Gospel, and Classical. As one of the largest music publishers in the world administering over one million copyrighted compositions, Universal has some of the most important contemporary songwriters and artists on its global roster and boasts many classic singles as well. (See generally
http://www.umusicpub.com/
). Due to Universal’s dominance in the music publishing industry, the licensing of its catalog is crucial to a karaoke service like DigiTrax and its Karaoke Cloud Platform.
6. On December 20, 2012, DigiTrax and Universal agreed to the License permitting DigiTrax to use Universal’s pre-approved catalog of songs for karaoke as part of DigiTrax’s Karaoke Cloud Platform for a license term of two years. However, Universal has recently denied that it agreed to the terms in the License and instead, it has demanded that DigiTrax remove Universal’s copyrighted content from the Karaoke Cloud Platform and threatened litigation, which Universal claims would subject DigiTrax to “millions” of dollars of liability if DigiTrax in any way resists. Universal’s threats are wholly unwarranted. DigiTrax’s Karaoke Cloud Platform is a legitimate, legal service that DigiTrax was operating in compliance with copyright law and its License with Universal. Despite DigiTrax’s demands, Universal has provided no factual or legal basis for its claims and demands.
7. As described in more detail below, DigiTrax brings this Complaint for a declaratory judgment that DigiTrax is not directly or indirectly infringing the copyrights of Universal, that Universal is bound by the terms of the License, and that Universal’s actions are in bad faith and in breach of the License.
THE PARTIES
8. DigiTrax is a Wyoming limited liability company, with its principal place of business at 6520 Chapman Highway, Suite D, Knoxville, TN 37920. DigiTrax has five
members: Samuel Gary Douglas, a citizen of Tennessee; Frank Scalice, a citizen of New Jersey; Joseph Vangieri, a citizen of Tennessee; Stanley Marcom, a citizen of Tennessee; and Allen Jacobi, a citizen of Florida.
9. Upon information and belief, Universal Music Corporation is a Delaware corporation with its principal place of business at 2100 Colorado Boulevard, Los Angeles, CA 90041. Upon information and belief, Universal Music Publishing Group is a unit or division of Universal Music Corporation. Upon information and belief, Universal owns and/or exclusively administers the catalogs of Songs Of Universal, Inc., Universal-Polygram International Publishing, Inc., Universal-Songs Of Polygram International, Inc., Universal-Polygram International Tunes, Inc., Universal Music-MOB NA LLC, Universal Music-Z Tunes LLC, and Rondor Music International, Inc.
JURISDICTION AND VENUE
10. DigiTrax brings this action under the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202 for a judgment declaring that DigiTrax’s Karaoke Cloud Platform: (i) does not infringe on any copyrights belonging to Universal; (ii) Universal is bound by the terms of the License; (iii) Universal has acted in bad faith; and (iv) Universal has breached the terms of the License.
11. DigiTrax’s copyright claims arise under the Copyright Act, 17 U.S.C. §§ 101 et seq., and this Court has federal question jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
12. In addition to federal question jurisdiction over the copyright claims, there is complete diversity jurisdiction between the parties to support jurisdiction over the state-law contract and bad faith claims, pursuant to 28 U.S.C. § 1332. The amount in controversy exceeds the sum of $100,000, exclusive of costs and interest, and DigiTrax and Universal are citizens of different states. In addition, the contract claims fall within the Court’s supplemental jurisdiction
pursuant to 28 U.S.C. § 1367(a) because the contract claims form part of the same case and controversy as the copyright claims.
13. Venue in this judicial district is conferred under 28 U.S.C. § 1391(b)(2) because this district is the judicial district in which a substantial part of the events or omissions giving rise to the claim occurred.
FACTUAL BACKGROUND
DigiTrax’s Karaoke Cloud Platform
14. Karaoke is a form of interactive entertainment in which amateur singers sing along
with recorded music (usually a music video). Any song can be used for karaoke music, but well- known pop songs are particularly common. Usually the lead vocals for the chosen karaoke song are removed to accommodate the amateur singer singing along to the song. Lyrics for the song are usually displayed on a video screen, along with a moving symbol, changing color, or music video images, to guide the singer.
15. With the increasing digitalization of music and broader use of technology, including personal computers, mobile devices, and mobile phones, much software has been developed and released for the purpose of playing karaoke on personal computers. The benefit is that instead of having to carry around hundreds of CD+Gs (an extension of the compact disc standard that can present low-resolution graphics alongside audio data on a disc when played on a compatible device) or laserdiscs, karaoke enthusiasts can download or stream songs to their computer, and play the songs and lyrics directly from their computer. In addition, karaoke venues can easily provide karaoke music through streaming services or from a computer loaded with a library of karaoke songs.
16. Use of copyrighted songs for karaoke involves various different rights that require

different forms of approval and payments. For example, karaoke enthusiasts or venues must pay money for use of the original music, for use of the song composition, for the ability to perform the song in public, for the ability to match the music to screen visuals (the synchronization license), and for the ability to reprint the lyrics.
17. Partly due to the complicated nature of copyright clearance for songs used for karaoke, rights holders have aggressively fought rampant infringement by karaoke services. (See, e.g.,
https://www.techdirt.com/articles/20120 ... sony-sues-
karaoke-distributor-infringement-gets-sued-right-back-copyright-misuse.shtml;
http://www.seacoastonline.com/articles/ ... -302150410
).
18. In an effort to offer an alternative that provides a legal, non-infringing path to using songs for karaoke, DigiTrax developed its Karaoke Cloud Platform. As a cross between iTunes and Hulu specific for karaoke, DigiTrax has engaged multiple rights holders, including Sony/ATV Music Publishing and Warner/Chappell Music, for licenses permitting users of the Karaoke Cloud Platform to download or stream songs for karaoke.
19. The Karaoke Cloud Platform has aggregated various catalogs from around the world and has over 17,000 karaoke songs. Importantly, the Karaoke Cloud Platform is a major deterrent for online piracy. DigiTrax makes it easy and affordable for karaoke enthusiasts and venues to legally enjoy karaoke using copyrighted songs.
The Universal License
20. On or around September 4, 2012, Mr. Vangieri, CEO of DigiTrax, sent an e-mail to Jerrold Grannis, Associate Director of Music Clearance at Universal, explaining the Karaoke Cloud Platform in an effort to engage Universal in licensing discussions.
21. On or around October 4, 2012, Mr. Grannis sent an e-mail to DigiTrax asking that it

send a formal licensing proposal. Negotiations ensued.
22. On or around November 17, 2012, Mr. Grannis sent a licensing proposal to Allen
Jacobi, counsel for DigiTrax. This proposal is attached hereto as Exhibit 1. On or around November 20, 2012, Mr. Jacobi and Mr. Grannis exchanged further correspondence regarding terms for a license. The November 20, 2012 correspondence is attached hereto as Exhibit 2.
23. On or around December 20, 2012, Mr. Grannis sent an e-mail to Mr. Jacobi “address[ing] all open items of discussion” with regard to the License. In this e-mail, Mr. Grannis stipulated to a number of terms, including a two year period for the License. Mr. Grannis’ December 20, 2012 e-mail is attached hereto as Exhibit 2. The discussions between Mr. Grannis and Mr. Jacobi between November 20, 2012 and December 20, 2012 constitute the general terms of the License between DigiTrax and Universal.
24. In addition, Mr. Grannis provided Mr. Jacobi with the necessary information for DigiTrax to begin making payments to Universal for its use of Universal songs. Importantly, Mr. Grannis explicitly stated that Universal would “get a draft longform [license] underway . . . [and] [a]s a sign of good faith, Digitrax is free to use Universal compositions in the KaraokeCloud service as of today while both sides work to execute longform, provided of course that Digitrax returns same good faith with regards to all points outlined herein, including without limitation, timely remittance of any funds due” (emphasis added).
25. Pursuant to the License, Universal agreed to permit DigiTrax to use Universal songs in the Karaoke Cloud Platform in exchange for DigiTrax paying Universal a $20,000 advance (the contract term is for two years) and royalties.
26. The full list of Universal copyrights at issue as of the date of this Complaint is attached hereto as Exhibit 3.
Universal and DigiTrax Maintain A Course of Dealing Consistent With the License
27. On or around February 20, 2013, DigiTrax paid Universal a $20,000 advance in accordance with terms of the License. Correspondence reflecting Universal’s acceptance of
DigiTrax’s $20,000 advance pursuant to the License is attached as Exhibit 4.
28. BetweenapproximatelyFebruary2013andJanuary2014,DigiTraxusedthousands
of songs approved by Universal for karaoke in the Karaoke Cloud Platform. During that time, Mr. Grannis regularly communicated with Toni Roberts, Director of Production and Licensing at DigiTrax and other DigiTrax representatives. Mr. Grannis’ communications consisted of, among other things, a master list of songs approved for karaoke, bi-monthly confirmations of new songs that were newly approved for inclusion in the License, and answers to questions regarding approval requirements for certain songs. The few occasions when DigiTrax used sound recordings or means of distribution to which Universal objected, DigiTrax promptly complied with Universal’s requests to “pull” such recordings. At all times during 2013, Universal monitored, was aware of, and approved DigiTrax uses of the Universal catalog. A sample of communications between Mr. Grannis and Ms. Roberts reflecting a course of dealing in accordance with terms of the License is attached hereto as Exhibit 5.
29. In accordance with the License, DigiTrax also provided Universal with quarterly, detailed accounting reports relating to the exploitation of the Universal compositions pursuant to the License. All accounting reports detailed every partner from whom revenue was derived. Correspondence reflecting accounting reports sent by DigiTrax to Universal are attached hereto as Exhibit 6.
30. Throughout 2013, in reliance on the License and on Universal’s regular updating and confirmation of new compositions which were available for exploitation under the License,

DigiTrax invested hundreds of thousands of dollars in producing sound recordings embodying the new Universal compositions for use under the full term of the License.
31. Throughout 2013, Mr. Jacobi and others at DigiTrax repeatedly inquired of Mr. Grannis and others at Universal about the status of a draft of the longform license agreement that would more formally memorialize the relationship and existing License between DigiTrax and Universal. However, DigiTrax was merely told that Universal was “[w]orking to get the draft [of the longform license] out” and that Universal “apologize[d] profusely for . . . the delay in getting it issued.” As a result of Universal’s delay, a draft longform license that more formally memorialized the License was never sent to DigiTrax for execution.
Universal Suddenly Accuses DigiTrax of Copyright Infringement
32. On or around February 21, 2014, Kent Klavens, Senior Vice-President of Business and Legal Affairs at Universal, sent an e-mail to Mr. Jacobi stating that “no licensing agreement [had] been concluded with your client Digitrax” and that DigiTrax was “exploiting various recordings, apps and products that have never even been discussed as part of the license that was being negotiated [between DigiTrax and Universal].” Mr. Klavens’ e-mail served as “formal notice that [DigiTrax] must immediately discontinue any use whatsoever of any musical compositions owned or administered by any of [Universal’s] music publishing entities throughout the world.” Mr. Klavens concluded by directing Mr. Jacobi to “contact [him] without delay to discuss settlement of [Universal’s] substantial copyright infringement claim against DigiTrax and their licensees” or else Universal would “not hesitate to retain litigation counsel to enforce [its] rights.” Mr. Klavens’ February 21, 2014 e-mail is attached hereto as Exhibit 7.
33. On or around February 25, 2014, Mr. Klavens sent another e-mail to Mr. Jacobi implying that DigiTrax was not licensed to use Universal songs in the Karaoke Cloud Platform,

and threatening that DigiTrax would have to either “resolve this on a reasonable basis, or [Universal] will once again retain Paul Stacey (as we have for other cases) to pursue our claim far more aggressively and, for your clients, far more financially painfully.” Mr. Klavens’ February 25, 2014 e-mail is attached hereto as Exhibit 7.
34. In response to Universal’s demand and wrongful termination of DigiTrax’s right under the License, DigiTrax promptly suspended the inclusion of all the many thousands of Universal compositions available on DigiTrax’s Karaoke Cloud Platform. Despite DigiTrax’s demand, Universal has provided no factual basis for its various claims that: (i) it had not licensed the Universal catalog of songs under the License; (ii) DigiTrax had violated the “contemplated” license which the parties had operated under for over one year; and (iii) Universal was entitled to “millions” for its claims. Universal has also failed to provide any basis whatsoever for its unilateral and bad faith termination of the License almost a year prior to the end of its two year term.
COUNT I – DECLARATORY JUDGMENT (NO COPYRIGHT INFRINGEMENT)
35. DigiTraxincorporatesbyreferenceallallegationscontainedinparagraphs1through 34 of this Complaint, as though fully set forth herein.
36. AnactualcontroversyexistsbetweenDigiTraxandUniversal,andDigiTraxis reasonably apprehensive that, if it continued to operate its Karaoke Cloud Platform with Universal songs, Universal would commence a copyright infringement action against it. DigiTrax has the right to include Universal songs on its Karaoke Cloud Platform pursuant to terms of the License and Universal’s course of dealing. As a result, including Universal’s songs in the Karaoke Cloud Platform does not directly or indirectly infringe any Universal copyrights. Such an action by Universal would have the potential to damage DigiTrax and its customers who
are entitled to rightfully and fairly use the Karaoke Cloud Platform with Universal songs. This controversy is of sufficient immediacy and reality to warrant the issuance of a declaratory judgment as to non-infringement.
37. A declaratory judgment on non-infringement would serve a useful purpose in clarifying or settling the legal issues between DigiTrax and Universal.
38. A judgment declaring that DigiTrax is not infringing on copyrights owned by Universal would finalize the controversy between the parties and offer them relief from uncertainty.
COUNT II – DECLARATORY JUDGMENT (EXISTENCE OF AN ENFORCEABLE LICENSE)
39. DigiTraxincorporatesbyreferenceallallegationscontainedinparagraphs1through 38 of this Complaint, as though fully set forth herein.
40. AnactualcontroversyexistsbetweenDigiTraxandUniversal,andDigiTraxis reasonably apprehensive that if it continued to operate its Karaoke Cloud Platform with Universal songs, Universal would commence a copyright infringement action against it. DigiTrax has the right to include Universal songs as part of its Karaoke Cloud Platform pursuant to terms of the License and Universal’s course of dealing. DigiTrax and Universal negotiated terms of the License, both parties accepted terms on or around December 20, 2012, Universal specifically represented to DigiTrax that it had the right to use Universal songs pursuant to the License, DigiTrax paid a $20,000 advance to Universal pursuant to the License, Universal regularly communicated with DigiTrax personnel and provided DigiTrax with systematic updates on songs available under the License, and DigiTrax prepared royalty reports to Universal pursuant to the License. As a result, an enforceable license of copyrights owned by Universal to DigiTrax for use in the Karaoke Cloud Platform exists. Universal’s failure to recognize the
License would have the potential to damage DigiTrax and its customers who are entitled to rightfully and fairly use the Karaoke Cloud Platform with Universal songs. This controversy is of sufficient immediacy and reality to warrant the issuance of a declaratory judgment as to non- infringement.
41. A declaratory judgment on non-infringement would serve a useful purpose in clarifying or settling the legal issues between DigiTrax and Universal.
42. A judgment declaring that DigiTrax is not infringing on copyrights owned by Universal would finalize the controversy between the parties and offer them relief from uncertainty.
COUNT III – BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
43. DigiTraxincorporatesbyreferenceallallegationscontainedinparagraphs1through 42 of this Complaint, as though fully set forth herein.
44. Universal has breached its implied duty of good faith and fair dealing implicit in all commercial agreements by, among other things:
a. contrary to the License, unilaterally refusing to recognize the License, which the parties abided by from approximately January 2013 through February 2014;
b. contrary to the License, baselessly accusing DigiTrax of copyright infringement – despite Universal agreeing to the License and explicitly permitting DigiTrax to use Universal songs in the Karaoke Cloud Platform throughout 2013 – and demanding millions of dollars in damages from DigiTrax;
c. discounting a good faith effort to engage in discussions, Universal stated that it would provide DigiTrax with a report detailing its bases for alleging copyright infringement, but Universal has yet to provide any such report to DigiTrax, and has
entirely failed to substantiate any of its allegations to date;
d. contrary to the License, asserting allegations of copyright infringement against DigiTrax despite Universal accepting DigiTrax’s $20,000 advance, paid on or around February 20, 2013 pursuant to the License;
e. contrary to the License and its representations, failing to draft a longform license to more formally memorialize the License and DigiTrax and Universal’s course of dealing; f. accepting DigiTrax’s royalty reports throughout 2013 pursuant to the License, but then baselessly accusing DigiTrax of copyright infringement and demanding millions of dollars in damages;
g. contrary to the License, unilaterally prohibiting DigiTrax from using Universal songs in the Karaoke Cloud Platform despite granting those rights to DigiTrax through negotiations for and acceptance of the License; and
h. encouraging and allowing DigiTrax to make substantial investments in reliance on the License including, but not limited to, investing in sound recordings embodying Universal compositions for use under the full term of the License and acquiring catalogs of sound recordings for exploitation under the License, but then unilaterally terminating the License almost one year before the end of the agreed to terms and demanding “millions” if DigiTrax resisted.
45. AsaresultofUniversal’sbreachofitsimplieddutyofgoodfaithandfairdealing,
DigiTrax has suffered monetary damages.
46. AsaresultofUniversal’songoingbreachofitsimplieddutyofgoodfaithandfair
dealing, DigiTrax has suffered, continues to suffer and will in the future suffer monetary damages.
COUNT IV – BREACH OF CONTRACT
47. DigiTraxincorporatesbyreferenceallallegationscontainedinparagraphs1through 46 of this Complaint, as though fully set forth herein.
48. Between November 17, 2012 and December 20, 2012, DigiTrax and Universal negotiated terms of the License permitting DigiTrax to use Universal’s pre-approved catalog of songs for karaoke as part of DigiTrax’s Karaoke Cloud Platform for a license term of two years.
49. On or around December 20, 2012, DigiTrax and Universal reached agreement on terms of the License. In e-mail correspondence sent on December 20, 2012, Mr. Grannis of Universal explicitly stated that “[a]s a sign of good faith, Digitrax is free to use Universal compositions in the KaraokeCloud service as of today while both sides work to execute longform, provided of course that Digitrax returns same good faith with regards to all points outlined herein, including without limitation, timely remittance of any funds due” (emphasis added).
50. Pursuant to terms of the License, DigiTrax paid Universal a $20,000 advance and Mr. Grannis regularly communicated with DigiTrax representatives, including Ms. Roberts, regarding, among other things, a master list of songs approved for karaoke, bi-monthly confirmations of new songs that were newly approved for inclusion in the License, and answers to questions regarding approval requirements for certain songs. Also pursuant to the terms of the License, DigiTrax began including Universal compositions in the Karaoke Cloud Platform and sending quarterly accounting reports to Universal. DigiTrax and Universal maintained a course of dealing under the License between approximately January 2013 through February 2014.
51. The few occasions when DigiTrax used sound recordings or means of distribution to which Universal objected, DigiTrax promptly complied with Universal’s requests to “pull” such
recordings. At all times during 2013, Universal monitored, was aware of, and approved DigiTrax uses of the Universal catalog.
52. In breach of the License, on or around February 21, 2014, Universal sent “formal notice that [DigiTrax] must immediately discontinue any use whatsoever of any musical compositions owned or administered by any of [Universal’s] music publishing entities throughout the world,” or risk having to pay “millions” if DigiTrax resisted and continued to exercise its rights under the License. Universal’s unilateral breach of the License was almost one year before the end of the License’s two year term.
53. In response to Universal’s demand and wrongful termination of DigiTrax’s rights under the License, DigiTrax promptly suspended the inclusion of all the many thousands of Universal compositions available on DigiTrax’s Karaoke Cloud Platform. Despite DigiTrax’s demand, Universal has provided no factual basis for its various claims that: (i) it had not licensed the Universal catalog of songs under the License; (ii) DigiTrax had violated the “contemplated” license which the parties had operated under for over one year; and (iii) Universal was entitled to “millions” for its claims. Universal has also failed to provide any basis whatsoever for its unilateral and bad faith termination of the License almost a year prior to the end of its two year term.
54. As a result of Universal’s breach of the License, DigiTrax has suffered monetary damages.
55. As a result of Universal’s ongoing breach of the License, DigiTrax has suffered, continues to suffer and will in the future suffer monetary damages.
PRAYER FOR RELIEF
WHEREFORE, DigiTrax requests the following relief:
A. A judgment declaring that DigiTrax has not, willfully or otherwise, directly or indirectly infringed any copyright owned by Universal;
B. A judgment declaring that a license exists between DigiTrax and Universal granting DigiTrax the right to use Universal songs in the Karaoke Cloud Platform;
C. A judgment that Universal breached the implied covenant of good faith and fair dealing and damages of $1,000,000;
Dated:
March 12, 2014
Respectfully submitted,
/s/ John A. Lucas _
John A. Lucas (011198)
W. Edward Shipe (023887)
WAGNER, MYERS & SANGER, P.C. 1801 First Tennessee Plaza
800 S. Gay Street
Knoxville, TN 37901
T: (865) 525-4600
F: (865) 524-5731
jlucas@wmspc.com
eshipe@wmspc.com
Paul V. LiCalsi (pro hac vice pending)
Shane St. Hill (pro hac vice pending)
ROBINS, KAPLAN, MILLER & CIRESI L.L.P. 601 Lexington Avenue, Suite 3400
New York, New York 10022
T: (212) 980-7400
F: (212) 980-7499
pvlicalsi@rkmc.com
ssthill@rkmc.com
Attorneys for Plaintiff DigiTrax Entertainment, LLC
D. E.
A judgment that Universal breached the License and damages of $1,000,000; and An award of such other and further relief that this Court deems proper.

Statistics: Posted by Bradsinger — Sun Mar 30, 2014 10:17 am