Lisa Loucks-Christenson Publishing

Demand Letter for Copyright Infringement and Breach of Contract

Lisa Loucks-Christenson
P.O. Box 9177
Rochester, MN 55903
Phone: (866) 562-5125
Email: Lisa@LisaLC.com

January 14, 2025

Legal Department

Penguin Random House
1745 Broadway
New York, NY 10019

Subject: Demand Letter for Copyright Infringement and Breach of Contract

Dear Sir/Madam,

I am writing to formally notify you of multiple instances of copyright infringement and breach of contract regarding the unauthorized use of my copyrighted images in the book Pets at My House: Turtles by Jennifer Blizin Gillis, originally published by Heinemann-Raintree, an imprint of Penguin Random House.

Identification of Copyrighted Work:
12 images, including the cover image, licensed for one-time usage in 2004 for the aforementioned book.Description of Infringing Material:

Unauthorized reproduction in multiple editions
Use in softcover and library bindings (only one-time usage was granted)
Failure to provide proper credit in the initial and only licensed usage of the images, with subsequent unauthorized books using images not fully paid for
Unauthorized size alterations
Multiple uses of model-released images licensed for one-time use
Unauthorized electronic use
Unauthorized use in multiple languages (English and Spanish confirmed)

These actions constitute copyright infringement under 17 U.S.C. Section 101 et seq. and breach of our original licensing agreement.

Demand for Compensation:
I hereby demand payment in the amount of $280,000.00 USD by January 28, 2025, as compensation for the unauthorized uses detailed above. This amount covers:

Unpaid usage of 12 original images
Multiple unauthorized editions
Compensation for three models featured in the images
Usage in sizes not compensated for
Editions published with and without proper credit

This fee represents your sole opportunity to resolve the discovered unauthorized uses. If you are aware of any other uses of my images in other books, you must disclose this information immediately.

Legal Consequences:

Failure to comply with this demand by the specified date will result in the pursuit of legal action for copyright infringement. As per our original agreement, any legal proceedings will be conducted in Olmsted District Court, Minnesota for the invoice fees. Federal court will be used for copyright infringement allegations.

Additional Demands:

Immediate removal of all my images from any and all of your databases.
Full disclosure of any other unauthorized uses of my images in your publications.

Please note that I will be conducting a thorough investigation of all books to which I have supplied images for your publishing house. Furthermore, I will be notifying all photographers who contributed to the book in question about potential unauthorized use of their work.

Given the extent of this infringement, this matter may be referred to the Department of Justice for further investigation.

I look forward to your prompt response and resolution of this matter.

Sincerely,

Lisa Loucks-Christenson

Demand Letter for Copyright Infringement and Breach of Contract

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