IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
DONALD J. TRUMP FOR PRESIDENT, INC.,
DONALD TRUMP, SR., DONALD TRUMP,
JR., MICHAEL PENCE, and DOES 1-10,
Civil Action No. 1:16-cv-9818
Plaintiff David Kittos (hereinafter “Plaintiff” or “Kittos”), by and through his counsel of
record Blaise & Nitschke, P.C., alleges for his Complaint against the Defendants, Donald J.
Trump for President, Inc., Donald Trump Sr., Donald Trump Jr., Michael Pence, and Does 1-10
(hereinafter, each a “Defendant” and collectively, the “Defendants”) as follows:
Nature of the Action
This is a civil action against the Defendants for wrongful acts of
copyright infringement (U.S. Copyright Act, 17 U.S.C. § 101 et seq.).
Plaintiff is an individual who resides, and at all times relevant to this
Complaint did reside, in the United Kingdom.
On information and belief, Defendant Donald J. Trump for President, Inc.
(“Trump for President, Inc.”) is a Virginia corporation maintaining its principal place of business
at 725 Fifth Avenue, New York, NY 10022. On information and belief as informed by online
records furnished by the State Corporation Commission of the Commonwealth of Virginia,