We Shall Overcome Foundation v. No Logo Ludlow Music, Inc., Defendant and The Richmond Organization, Inc, Defendant
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
WE SHALL OVERCOME FOUNDATION,
on behalf of itself and all others similarly
CLASS ACTION COMPLAINT
JURY TRIAL DEMANDED
THE RICHMOND ORGANIZATION, INC.
(TRO INC.) and LUDLOW MUSIC, INC.,
Plaintiff, We Shall Overcome Foundation (“WSOF”), on behalf of itself and all others
similarly situated, by its undersigned attorneys, as its Complaint against Defendants, The
Richmond Organization, Inc. (TRO Inc.) (“TRO”) and Ludlow Music, Inc. (“Ludlow”) for: (1)
declaratory judgment pursuant to 28 U.S.C.
damages under 28 U.S.C.
2201; (2) declaratory and injunctive relief and
(3) violations of New York General Business Law
breach of contract; (5) common law money had and received; and (5) rescission for failure of
consideration, hereby alleges as follows:
JURISDICTION AND VENUE
The Court has subject-matter jurisdiction over this action pursuant to 28 U.S.C.
1331 and 28 U.S.C.
1338 with respect to claims seeking declaratory and other relief arising
under the Copyright Act, 17 U.S.C.
101 et seq.; pursuant to the Declaratory Judgment Act, 28
2201 et seq.; and supplemental jurisdiction over the entire case or controversy
pursuant to 28 U.S.C.
The Court has personal jurisdiction over Defendants and venue is proper in this