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HALLAM & HOCHBERG. LLP
WILLIAM I. HOCHBERG (SBN 150265)
DANIEL MATUSOV (SBN 286347)
whochberg@hallamhochberg.com
201 Santa Monica Boulevard, Suite 300
Santa Monica, California 90401
Tel: (310)393-4006
Fax: (310)564-7623
Attorneys for Plaintiff Bonnie Schiffman
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA, WESTERNDIVISION
s?
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o
BONNIE SCHIFFMAN, an individual,
Plaintiff,
COT-69 01 ftb-^Wx
vs.
ROD STEWART, an individual; STEWART
ANNOYANCES, LTD., a California
corporation; THE STIEFEL OFFICE,
LIMITED., a California corporation;
ANSCHUTZ ENTERTAINMENT GROUP,
INC., a Colorado corporation dba AEG LIVE;
CAESARS ENTERTAINMENT
CORPORATION, a Delaware corporation; and
DOES 1through55finclusive,
to
Defendants.
COMPLAINT FOR COPYRIGHT
INFRINGEMENT
[DEMANDFOR JURY TRIAL]
Plaintiff BonnieSchiffman alleges:
NATURE OF THE ACTION
1. "Rod's Back" isa tagline referring to a comeback tour by famous singer Rod Stewart and
also to Plaintiffs iconic image of the backof Stewart's head withthe unmistakable bouffant hair
style. Plaintiff created the image and it was licensed non-exclusively for a greatest hits album in
1989. Then in 2013, Stewart and his handlers offered the photographer $1,500 to re-use the image
on abillboard. Plaintiff turned down the offer. Rather than finding anew image. Defendants simply
1
COMPLAINT
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used areplicate image, an unmistakable copy, not only on abillboard, but as the centerpiece of alive
show at Caesars Palace in Las Vegas, aworld tour, and ancillary products. In doing so, Defendants
have not only turned their back onPlaintiff but also onthe law, as their unauthorized use of
Plaintiffs photograph is in violation ofthe Copyright Act of 1976, as amended, 17 U.S.C. 101 et.
seq.
PARTIES
2. Plaintiff Bonnie Schiffman doing business as Bonnie Schiffman Photography ("Schiffman"
or "Plaintiff), aresident ofLos Angeles, California, is an internationally renowned photographer
who has captured defining images ofhundreds of iconic celebrities, such as Steve Jobs, Michael
Jackson, Muhammad Ali, Steven Spielberg, Andy Warhol, Warren Buffet and many others.
3. Defendant Rod Stewart is afamous singer and entertainer who, on information and belief,
resides in Los Angeles, California.
4. Defendant Stewart Annoyances, Ltd., on information and belief, is aCalifornia corporation
with principal place of business located in Los Angeles, California, which serves as defendant
Stewart's principal music business entity.
5. Defendant The Stiefel Office Limited, on information and belief aCalifornia corporation
doing business as Stiefel Entertainment ("Stiefel") with its principal place ofbusiness located in Los
Angeles, California, is a music management firm which handles many facets ofthe business of its
clientelle, including Stewart.
6. Defendant Anschutz Entertainment Group, Inc. ("AEG"), on information and belief, a
Delaware limited liability company with principal place ofbusiness located in Los Angeles,
California, is the world's second largest presenter oflive music and entertainment, and is awholly
owned subsidiary ofAnschutz Entertainment Group, aColorado corporation, which is awholly-
owned subsidiary ofThe Anschutz Corporation, a Kansas corporation which regularly and
systematically conducts business in this district.
7. Defendant Caesars Entertainment Corporation, oninformation and belief, is a Delaware
corporation with principal place ofbusiness located in Las Vegas, Nevada, which operates the
i
COMPLAINT
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Caesars Palace casino, resort and entertainment venues in Las Vegas, Nevada, and which regularly
and systematically conducts business in this district through advertising and promotion activities.
8. The true names and capacities, whether individual, corporate, associate, or otherwise, of all
Defendants sued herein as Does 1through 25, are unknown to Plaintiff, who therefore sue said
Defendants by such fictitious names. Plaintiff will seek leave of the Court to amend this complaint
to state their true names and capacities when the same have been ascertained. Said Defendants are
liable to Plaintiff because they either directly performed all or some of the acts alleged hereinafter or
were acting as the agent, principal, alter ego, employee, representative, or otherwise participated in
the acts alleged.
9. Plaintiff isinformed and believes, and on that basis avers, that at all times mentioned inthis
complaint, each of Defendants was the agent and/or alter ego of each of the other Defendants and, in
doing the times alleged in this complaint, was acting within the course and scope of such agency.
JURISDICTION AND VENUE
10. Federal jurisdiction over Plaintiffs claims is conferred on this Court by 28 U.S.C. 1338, as
this action arises under the Copyright Act of1976 (17 U.S.C. 101 et. seq.).
11. Venue is proper inthis district as Stewart and the Plaintiff reside inthe district and AEG
and Stiefel are headquartered in the district. Defendants also regularly and systematically conduct
business in this district and, therefore, are subject to personal jurisdiction in this district.
SUBSTANCE OF THE ACTION
12. Plaintiff is an internationally known celebrity photographer. She creates portraits and still
hfes for album covers, books, advertising campaigns, magazines and other media around the world.
Plaintiff manages production of all her photo shoots and designs her own sets, backdrops, lighting,
props, positioning and timing. She retains copyrights to many, ifnot all, ofher photographic works,
COMPLAINT
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including the work at issue here. Plaintiff and her work have attained worldwide fame, popularity
and recognition.
13. In 1981, Plaintiff created a photograph of Rod Stewart ("Schiffman Image") featuring the
back of Rod Stewart's head and shoulders, with his signature bouffant hair style for which he was
known for several decades ofhis career. Below is atrue and correct copy ofthe Schiffman Image
14. The Schiffman Image appeared on the cover of Rod Stewart's greatest hits anthology
album entitled "Storyteller", first released by Warner Bros. Records in 1989, subject toa non
exclusive license from Plaintiff. The Schiffman Image, as it appears onthe Storyteller album cover,
is cropped so that only the left side appears. Below is a true and correct copy of the Schiffman
Image embodied on the Storyteller album:
ROD
STEWART
Moryu'Kcr
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15. The Schtffman Image is protected by United States Copyright Law and registered with the
Umted States Copyngh, Office. P.amtiff is the sole owner of the copyright and the reg.stration
16. In late 2010, Amo.d Stiefel. principal of defendant The Stiefel Office, Ltd contacted
Sch.ffman by telephone and left avotce mail stating tna, he and Rod Stewart wou.d ke to use the
Schtffman Image on abtllboard for acampaign called "Rod's Back", adoub.e entendre s.gnify.ng
both the artist's comeback and the upper posterior image featured in the Schtffman Image.
17. Through an intermedtary, Stiefel conveyed , Schtffman tha, he wou.d pa, alicenstng fee
of$1,500 for the billboard usage of the Schtffman Image. Schiffman mdtcated tha, the fee was too
low. Sttefe, sa,d he would no, offer any htgher fee and tha, ,hey wou.d obtam another photograph
somewhere else.
.8. In or about February of 20,3, Plaintiff learned that Defendant, were using areplicate of
the Schtffman Image ("Repl.cate Image") as the centerpiece ofa"residency" show a, Caesars
Palace ,n Las Vegas, Nevada. The Repltcate Image appears a, live performances and on phystcal
signage, print advertising, tickets and online marketing in th,s District and elsewhere.
19. True and correct coptes ofthe Replicate Image are reproduced hereinbe.ow:
COMPLAINT
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20. On or about March 6, 2014, Plaintiffs counsel sent acease and desist letter to Defendants
requesting that they account for all of their usages and pay afair license fee therefor.
21. On information and belief, Defendants, their agents, and employees had access to
Plaintiffs work at issue by virtue of its appearance on the Storyteller album cover, since at least
1985.
22. Defendants have created and published the Replicate Image, knowingly and intentionally
using the famous and distinctive picture featured in the Schiffman Image. As such, Defendants have
created an unauthorized derivative work of Plaintiffscopyrighted photograph.
23. Defendants, through their agents and employees, have misappropriated the most
recognizable elements of the Schiffman Image, if not the exact image itself, and utilized it as a
commercial vehicle to promote Rod Stewart and ancillary products.
24. Defendants have willfully infringed upon Plaintiffs copyright of the Schiffman Image with
the intent to commercially exploit the artistic work to which they have no legal or proprietary rights.
COMPLAINT
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25. On information and belief. Defendants have been marketing, publishing, and distributing
the infringing work without permission or license from Plaintiff, in violation of federal law, in other
widely distributed print and billboard campaigns.
26. Ifsuch use on the part of Defendants continues, Plaintiff will suffer irreparable harm of a
continuing nature for which there is no plain, speedy or adequate remedy at law.
27. By reason ofthe willful infringement ofcopyright by Defendants, Plaintiff has sustained
injury, loss and damage to her ownership rights and Defendants have unlawfully, unfairly and
wrongfully derived and will continue to derive income from these infringing acts. Defendants are
being unjustly enriched by their infringement.
CLAIM FOR RELIEF
(Copyright Infringement Against All Defendants)
28. Plaintiff repeats and re-alleges each and every foregoing and subsequent allegation
contained inthe Complaint, and further alleges as follows.
29. Plaintiff is the original author and creator of the photograph currently being used and
exploited by Defendants.
30. Plaintiff possesses and is the rightful holder ofthe copyright, its registration and the
interest in, to and under the Schiffman Image being used and exploited by Defendants.
31. Defendants have infringed and are infringing Plaintiffs copyright in, to and under the
Schiffman Image by creating aderivative, unauthorized work from it and using said derivative work
for marketing, advertising, promoting, publicly distributing and benefiting from Plaintiffs
copyrighted photograph without her consent or authorization.
32. As adirect and proximate result ofDefendants' copyright infringement, Plaintiff has
sustained and will continue to sustain financial loss, harm to her artistic reputation, loss of good will,
loss of profits, loss of business opportunities and loss of control over the marketing and use of her
copyrighted photograph. Defendants have been unjustly enriched by its infringement.
7
COMPLAINT
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33. Defendants' infringing acts have been performed with knowledge of Plaintiffscopyrights
and such acts were performed intentionally and willfully.
34. Plaintiff has been damaged by Defendants' acts in an amount yet unascertained but to be
proven at the time of trial.
WHEREFORE, Plaintiff demands judgment against Defendants as follows:
1. Injunctive relief preliminarily and permanently enjoining Defendants, their
subsidiaries, directors, officers, employees, agents, and all other persons or
entities acting, by contract or agreement, in concert with it, or on behalf of it,
directly or indirectly, from offering, providing, advertising, printing, distributing,
selling or in any way making available to the public any photograph created by
Plaintiff or any derivative work thereof;
2. Injunctive relief compelling Defendants to return all originals, copies and
negatives of Plaintiffsphotograph and of any derivative work thereof to Plaintiff,
and to destroy any and all digital or computer images Defendants have of
Plaintiffs photograph in their possession, custody or control;
3. Awarding to Plaintiff as against Defendants, compensatory damages in asum of not less
than $2,500,000;
4. Awarding to Plaintiff as against Defendants, punitive damages in asum of not less than
$2,500,000;
5. Awarding to Plaintiff as against Defendants, actual damages and any profits
attributable to the infringement of Plaintiffscopyright by Defendants;
6. Awarding to Plaintiff as against Defendants statutory damages based upon
Defendants' acts of infringement pursuant to the Copyright Act of 1976, as
amended, 17 U.S.C. 101, et seq.;
7. Awarding to Plaintiff as against Defendants, costs and reasonable attorney's fees incurred
by virtue of this action; and
8
COMPLAINT
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8. Granting Plaintiff such other and further relief as this Court may deemjust and proper.
DATED: September 4,2014 HALLAM &HOCHBERG, LLP
By:
iRC" WILLIAM I. fflOCHBER
Attorneys forYlaintiff
COMPLAINT
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Pursuant to Fed.R.Civ.P. 38, Plaintiff hereby demands atrial by jury on all claims so triable, other
than their request for injunctive relief.
DATED: September 4, 2014
HALLAM & HOCHBERG, LLP
'WILLIAM I.
10
COMPLAINT
[OCHBEI
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OFCALIFORNIA
CIVIL COVER SHEET
F. (a) PLAINTIFFS ( Check box if you are representing yourself ("J
BONNIESCHIFFMAN, an individual
(b) Countyof Residenceof First Listed Plaintiff LOS ANGELES
(EXCEPTINU.S. PLAINTIFFCASES)
(c) Attorneys {Firm Name, Address and Telephone Number) If you are
representing yourself, provide the same information.
HALLAM &HOCHBERG, LLP
201 SANTAMONICABLVD., SUITE300
SANTA MONICA, CA90401 (310)393-1388
DEFENDANTS (Check box if you are representing yourself [~J
ROD STEWART, an individual; STEWART ANNOYANCES, LTD., a California
corporation;THE STIEFEL OFFICE LTD., a California corporation; ET AL
Countyof Residence of First Listed Defendant LOS ANGELES
(IN U.S. PLAINTIFF CASES ONLY)
Attorneys (Firm Name, Address and Telephone Number) If you are
representing yourself, provide the same information.
II. BASIS OF JURISDICTION (Place an Xin onebox only.)
| 11. U.S. Government
Plaintiff
]3.Federal Question (U.S.
Government Not a Party)
III. CITIZENSHIP OF PRINCIPAL PARTIES-For Diversity Cases Only
(Place an Xinone boxfor plaintiff andone fordefendant)
Citizen of This State Q 1 m Incorporated or Principal Place RF ^F
"-1 L-s of Businessinthis State "-1 u
Citizen ofAnother State 2 fj 2 Incorporated and Principal Place 5 fj 5
of Business in Another State
Citizen or Subject of a _ , .,
Foreign Country 3 3 Foreign Nation [J 6 6
| | 2. US. Government
Defendant
[~~|4. Diversity (Indicate Citizenship
ofPartiesinltemlll)
IV. ORIGIN (Placean Xin one box only.)
2. Removed from i
State Court L_I
1. Original ,, 2. Removed from ,, 3. Remanded from r-i 4. Reinstated or r-, 5. Transferred from Another ,
II RpononeH II District (SDecifv) I I
Proceeding Appellate Court Reopened District (Specify)
6. Multi-
District
Litigation
V. REQUESTED IN COMPLAINT: JURY DEMAND: [x] Yes fj No (Check "Yes" only ifdemanded in complaint.)
CLASS ACTION under F.R.CV.P. 23: Qyes [x]No [X] MONEY DEMANDED IN COMPLAINT: $2,500,000
VI. CAUSE OF ACTION (Cite the VS. Civil Statute under which you are filing and write abrief statement of cause. Do not cite jurisdictional statutes unless diversity)
COPYRIGHT INFRINGEMENT INVOLVING UNAUTHORIZED USE OF PLAINTIFF'S PHOTOGRAPH IN MARKETING AND PUBLICITY FOR DEFENDANTS
VII. NATURE OF SUIT (Place an Xinone box only).
OTHER STATUTES
375 False Claims Act
400 State
Reapportionment
410 Antitrust
Q 430 Banks and Banking
450 Commerce/ICC
Rates/Etc.
460 Deportation
470 Racketeer Influ
enced &Corrupt Org.
Q 480 Consumer Credit
490Cable/Sat TV
850 Securities/Com
modities/Exchange
890 Other Statutory
Actions
891 Agricultural Acts
893 Environmental
Matters
895 Freedom of Info.
Act
896 Arbitration
899 Admin. Procedures
f_] Act/Reviewof Appeal of
Agency Decision
950 Constitutionality of
State Statutes
FOR OFFICE USE ONLY:
CONTRACT
fl 110 Insurance
120Marine
130Miller Act
140 Negotiable
Instrument
150 Recovery of
r~| Overpayments
Enforcement of
Judgment
151 Medicare Act
152 Recovery of
Defaulted Student
Loan (Excl. Vet.)
153 Recovery of
|~| Overpaymentof
Vet. Benefits
r-i 160 Stockholders'
L-1 Suits
r~I 190 Other
Contract
195 Contract
Product Liability
196Franchise
REAL PROPERTY
210Land
Condemnation
fj 220Foreclosure
230 Rent Lease &
D
Ejectment
REAL PROPERTY CONT.
240Torts to Land
Q 245 Tort Product
Liability
[J 290 All Other Real
Property
TORTS
PERSONAL INJURY
310Airplane
315 Airplane
Product Liability
320 Assault, Libel &
Slander
330 Fed. Employers'
Liability
340Marine
345 Marine Product
Liability
350Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal

Injury
r1 362 Personal Injury-
l1 Med Malpratice
365 Personal Injury-
Product Liability
367 Health Care/
r~\ Pharmaceutical
Personal Injury
Product Liability
._. 368 Asbestos
LI Personal Injury
Product Liability
Case Number
IMMIGRATION
462 Naturalization
Application
465 Other
Immigration Actions
TORTS
PERSONAL PROPERTY
370OtherFraud
|~1 371 Truth in Lending
380 Other Personal

Property Damage
385 Property Damage
Product Liability
BANKRUPTCY
1I 422 Appeal 28
USC 158
423 Withdrawal 28
USC 157

CIVIL RIGHTS
440OtherCivil Rights
441 Voting
|~1 442 Employment
1I 443 Housing/
!' Accommodations
445 American with
Disabilities-
Employment
446 American with
Disabilities-Other
448Education
PRISONER PETITIONS
Habaas Corpus:
fj] 463Alien Detainee
11 510 Motions to Vacate
' Sentence
530General
535DeathPenalty
Other:
540Mandamus/Other
550Civil Rights
11 555 Prison Condition
560 Civil Detainee
Ll Conditions of
Confinement
FORFEITURE/PENALTY
._. 625 Drug Related
l_l Seizure ofProperty 21
USC 881
690Other
LABOR
710 Fair Labor Standards
Act
(-] 720Labor/Mgmt.
L-' Relations
740Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor
Litigation
791 Employee Ret. Inc.
PROPERTY RIGHTS
fx] 820Copyrights
830Patent
840Trademark
SOCIAL SECURITY
861 HIA (1395(f)
862Black Lung (923)
863DIWC/DIWW (405 (g))
864SSID Title XVI
865 RSI (405 (g))
FEDERAL TAX SUITS
r-i 870 Taxes (U.S. Plaintiff or
ll Defendant)
871 IRS-Third Party 26 USC
7609

0714-6901
CV-71 (11/13)
CIVIL COVER SHEET
Pag1 of 3
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
V,"^ENlJE: ^^ anSW!rS t0 the qUeStinS b6l0WWi" determine the dlViSi0n fthe CUrt t0 which this case wi" most likelV be Initially assigned. This initial assignment
is subject to change, ,n accordance with the Court's General Orders, upon review by the Court of your Complaint or Notice of Removal.
Question A: Was this case removed from
state court?
Yes fx] No
If"no,"go to QuestionB. If"yes," checkthe
boxto the right that applies, enter the
corresponding divisionin response to
Question D, below, and skipto Section IX.
STATE CASE WAS PENDING INTHE COUNTYOF:
INITIAL DIVISIONINCACD IS:
Question B: Is the United States, or one of
its agencies or employees, a party to this
action?
n yes [x] No
If"no,goto QuestionC. If"yes," checkthe
boxto the right that applies, enter the
corresponding division in response to
Question D,below, and skipto Section IX.
|~1 Los Angeles
Ventura, Santa Barbara, orSan Luis Obispo
fj Orange
Riverside or SanBernardino
If the United States, orone ofits agencies oremployees, is aparty, is it:
Western
Western
Southern
Eastern
A PLAINTIFF?
Thencheckthe boxbelowforthe countyin
which the majorityof DEFENDANTS reside.
A DEFENDANT?
Then checktheboxbelowforthe county in
whichthe majorityof PLAINTIFFS reside.
INITIAL
DIVISION IN
CACD IS:
f~| Los Angeles

Ventura, Santa Barbara, or San Luis

Obispo
Orange
Riverside or SanBernardino
Other
|~1 Los Angeles

Ventura, Santa Barbara, or San Luis

Obispo
Orange
Riverside or SanBernardino
Other
Western
Western
Southern
Eastern
Western
Question C: Location of
plaintiffs, defendants, and claims?
(Make onlyone selection per row)
A.
Los Angeles
County
Ventura, Santa Barbara, or
San LuisObispo Counties
C.
Orange County
D.
Riverside or San
Bernardino Counties
Outside the Central
District of California
F.
Other
Indicate the location in which a
majority of plaintiffs reside:
Indicate the location in which a
majority of defendants reside:
Indicate the location In which a
malority of claims arose:

CI. Iseitherofthefollowing true? Ifso,check the onethat applies:
Q 2or more answers in Column C
I | only 1answer in Column Candnoanswers in Column D
Yourcase willinitiallybe assigned to the
SOUTHERN DIVISION.
Enter "Southern" in response to Question D, below.
If none applies, answer question C2 totheright, m^



D

C.2. iseitherofthefollowing true? Ifso,check theonethat applies:
| | 2ormore answers inColumn D
I I only 1answer in Column Dand noanswers in Column C
Yourcase willinitiallybe assigned to the
EASTERN DIVISION.
Enter "Eastern" in response to Question D, below.
Ifnone applies, go to the box below.
I
Yourcase willinitially be assigned to the
WESTERN DIVISION.
Enter "Western" in response to Question Dbelow.
Question 0: Initial Division?
INITIAL DIVISION IN CACD
Enterthe initial division determined by QuestionA, B, orC above:
WESTERN DIVISION
D
D
CV-71 (11/13)
CIVIL COVER SHEET
Page 2 of 3
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
IX(a). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed? [gj NO fj YES
Ifyes, listcase number(s):
IX(b). RELATED CASES: Have any cases been previously filed in this court that are related to the present case? fxj NO QYES
Ifyes, listcase number(s):
Civil cases are deemed related if apreviously filed case and the present case:
(Checkall boxes that apply) ii . . . ,
[_J A. Arise from the same orclosely related transactions, happenings, or events; or
B. Call for determination of the same or substantially related or similar questions of lawand fact; or
C. For other reasons would entail substantial duplication of labor if heard by different judges; or
D. Involve the same patent, trademark or copyright^dpne/the factors identified above in a, bor calso is present.
X. SIGNATURE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT): ^* 6 * i/v^ *1 DATE: September 3, 2014
butisusedbythec,erkofthecourtfo^
Key toStatistical codes relating to Social Security Cases:
Nature ofSuit Code Abbreviation Substantive Statement ofCause ofAction
861 HIA A" iCl!l,imSi f?r h!allh insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act as amond^ Afcr,
^utcT^F^b"^1315' ^ "^'"^fad"tk* *' for certiflcati" - proS^serv^rffi^S,^
862 BL AJl3<jla,ms for "Black Lun9"benefrts under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. (30 U.S.C.
863 DIWC iVl'chim. flu?frXI5f-S^ WrkerS f? di?blity in?urance benefits u"der Title 2of the Social Security Art, as amended- plus
all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405 (g)) rea'plus
863 DIWW amencled.IfUS.c'Sg^WidWerS lnSUranCe b*nefltS baSed n diSabHity Under e 2of the Social Securrtv A-
864 SSID amendedf0r SUpplemental secwit*income Payments based upon disability filed under Title 16 of the Social Security Act, as
SCuasxS405rS))ement ('d aQe) and SUrViV0rs benefits under T,tle 2of tne Social Securtty Act, as amended.
865 RSi
CV-71 (11/13) C|V|L COVER SHEET
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