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UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
DAVID ICKE and BRIDGE OF LOVE UK, )
)
Plaintiffs,
)
)
vs.
)
)
ROYAL ADAMS, an individual, BRIDGE )
OF LOVE, a registered fictitious name
)
and ROYAL PERSONNEL, INC.,
)
a Missouri corporation,
)
)
Defendants.
)

Case No.: 4-06-cv-00685-ERW

JURY TRIAL DEMANDED

FIRST AMENDED COMPLAINT


COME NOW Plaintiffs David Icke (Icke) and Bridge of Love UK (BOL UK)
(collectively Plaintiffs), pursuant to Fed. R. Civ. P. 15(a), by and through their attorneys, and
for their claims against Defendants Royal Adams (Adams), Bridge of Love (BOL) and
Royal Personnel, Inc. (Royal Personnel) (collectively Defendants), respectfully state to the
Court as follows:
NATURE OF ACTION
1.

Plaintiff Icke is a well known author who resides in the United Kingdom and has

written numerous books that have been printed in the United States and distributed and sold
throughout the United States and United Kingdom. In 1998, Icke and Defendant Royal Adams
(Adams) entered into an oral agreement whereby Adams would arrange for the printing,
distribution and sale of Ickes books in the United States. Pursuant to their agreement, Icke was
to be paid seventy-five percent (75%) of the net profits derived from the sale of his books, with
the remaining twenty-five percent (25%) to be paid to Adams. At all relevant times, Icke retained
the copyrights and all exclusive worldwide ownership rights to his books.

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2.

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Recently, after a review of certain records for the first ten months of 2005, Icke

learned that Adams had not been properly accounting for the revenues derived from Ickes books
and had not been paying Icke his full 75% of net profits, as required by their agreement. Icke
thereafter repeatedly demanded an opportunity to review Adams books and records, and was
repeatedly ignored. Then, in March 2006, Adams ceased making any payments to Icke, claiming
he had exclusive rights to Ickes books.
3.

Accordingly, by letter dated April 10, 2006, Icke terminated the agreement and

directed that Adams, and any entity affiliated with or owned by him, cease and desist from
further exploitation of the books, including the printing and distribution of the books for sale to
the public. Upon information and belief Adams has disregarded Ickes termination of the
agreement, is continuing to sell Ickes books, and is retaining 100% of the profits.
4.

By this action Icke seeks (i) a declaration that the agreement with Adams is

terminated effective April 10, 2006, (ii) an order permanently enjoining Adams from engaging in
activities related to printing, distributing or selling Ickes books, (iii) damages based upon
Adams failure to pay amounts due to Icke, (iv) damages and injunctive relief based upon
Adams infringement upon Ickes copyrighted materials, and (v) an accounting.
PARTIES
5.

Plaintiff David Icke, is an individual residing at 8 Vernon House, 20 Wood Street,

Ryde, Isle of Wight, United Kingdom P033 2JR.


6.

Plaintiff Bridge of Love UK is a corporation with a principal place of business at

185A High Street, Ryde, Isle of Wight, United Kingdom PO33 2PN. BOL UK distributes Ickes
books throughout Europe and through a website owned and operated by BOL UK.

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Upon information and belief, Defendant Adams (Adams) is an individual who

is domiciled in and a citizen of the State of Missouri and who maintains his principal place of
business at 1825 Shiloh Valley Drive, Chesterfield, Missouri 63005.
8.

Upon information and belief, Defendant Bridge of Love (BOL) is a fictitious

name registered to Royal Adams and maintains its principal place of business at 1825 Shiloh
Valley Drive, Chesterfield, Missouri 63005. As such it is a citizen of the State of Missouri.
9.

Upon information and belief Defendant Royal Personnel, Inc. (Royal

Personnel) is a Missouri corporation, which has been Administratively Dissolved by the State of
Missouri, Secretary of State on August 18, 1998, and maintains its principal place of business at
1825 Shiloh Valley Drive, Chesterfield, Missouri 63005. As such it is a citizen of the State of
Missouri.

Defendants Adams, BOL and Royal Personnel are collectively referred to as

Defendants.
JURISDICTION AND VENUE
10.

This is a civil action seeking (i) declaratory relief under the Declaratory Judgment

Act, 28 U.S.C. 2201, (ii) injunctive and monetary relief for infringement and violation of the
copyright laws of the United States, 17 U.S.C. 101, et seq., (iii) accounting, (iv) monetary
relief for breach of contract, unjust enrichment, conversion, breach of an implied covenant of
good faith and tortious interference. The Court has jurisdiction over the subject matter of this
action pursuant to 28 U.S.C. 2201, 2202, 1331, 1332(a) and 1338(a).
11.

This Court has personal jurisdiction over each of the Defendants because

Defendants do business and maintain an office in this State and in this District.
12.

Venue is properly in this District pursuant to 28 U.S.C. 1391(b) and (c) as well

as 1400(a).

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ALLEGATIONS COMMON TO ALL COUNTS


Background: The Works
13.

Icke is the author of numerous published books and is the exclusive worldwide

copyright owner and/or owner of all of the exclusive rights related to such books. The following
books authored by Icke were printed and/or distributed in the United States and are at issue in
this action: Alice In Wonderland And The World Trade Center Disaster; And The Truth Shall
Set You Free; And The Truth Shall Set You Free 21st Century Edition; The Biggest Secret;
Children Of The Matrix; Tales From The Time Loop; I Am Me I Am Free; Infinite Love Is The
Only Truth Etc. (collectively referred to hereinafter as the Works).
14.

Certificates of Copyright Registration have been applied for and/or received from

the Register of Copyrights for the respective Works. Under Section 106 of the Copyright Act,
Plaintiff has the exclusive right to do and to authorize any of the following: (1) to reproduce the
[Works] in copies or phonorecords; (2) to prepare derivative works based upon the [Works];
(3) to distribute copies or phonorecords of the [Works] to the public; (4) to perform the
[Works] publicly and (5)to display the [Works] publicly. The Works are the subject of
Certificates of Copyright Registration issued by the Register of Copyrights on the dates indicated
herein and bearing the following registration numbers:
Name:

Registration Number

Date of Issuance

And the Truth Shall Set You Free

TX 6-327-286

May 1, 2006

I Am Me, I Am Free

TX 6-327-220

May 1, 2006

The Biggest Secret

TX 6-327-282

May 1, 2006

Children Of The Matrix

TX 6-327-281

May 1, 2006

Alice In Wonderland And The


World Trade Center Disaster

TX 6-327-287

May 1, 2006

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Tales From The Time Loop

TX 6-327-284

May 1, 2006

And The Truth Shall Set You Free


(21st Century Edition)

TX 6-327-285

May 1, 2006

Infinite Love Is The Only Truth


Everything Else Is Illusion

TX 6-327-283

May 1, 2006

Copies of the registrations for the Works are annexed hereto as Exhibit A.
15.

In all respects, the laws of the United States and all other laws governing

copyright have been complied with as respects the Works, and Icke has secured the rights and
privileges under the copyrights of the Works.
The Agreement
16.

Upon information and belief, Adams is engaged in the business of representing

authors in securing printing and distribution services for their books. In 1998, Icke met Adams
at a conference where Icke had been discussing topics and issues addressed in some of his
Works. At that time, Icke had not published any of the Works in the United States. Adams
approached Icke and identified himself as someone who could assist Icke with the printing and
distribution of the Works within the United States.
17.

Later that year, Icke and Adams entered into an oral agreement whereby Adams

was to arrange printing and distribution services for Ickes Works (the Agreement) in the
United States. Pursuant to the Agreement, Icke was to be paid seventy-five percent (75%) of the
net profits derived from the sale of the Works, with the remaining twenty-five percent (25%) to
be paid to Adams. Consistent with the terms of the Agreement, Adams subsequently arranged
for Patterson Printing (Patterson) to print copies of the Works and Bookworld Companies
(Bookworld) to distribute the Works on Ickes behalf.

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18.

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After consummating the Agreement, Icke and BOL UK undertook all activities

necessary to bring a new book to print. Specifically, Icke and BOL UK performed and paid for
all writing, researching, editing, proofreading, artwork creation, book design and indexing of
Ickes books and delivered direct to the printer a disc containing the final version of the books in
a format ready for printing. Adams had no input whatsoever with respect to this process and his
sole responsibility was to arrange for the printing of the books using the materials created,
provided and paid for by Icke and BOL UK and to arrange for the distribution of the books in the
United States.
19.

Moreover, in 1998 Icke paid for the initial printing of his Works by allowing

Adams to retain Ickes 75% share of profits until such costs were recouped by Adams. At all
times thereafter, the printing costs for all books have been paid out of the revenue generated
from the sale of the Works.
20.

BOL UK is responsible for the distribution and sale of the Works throughout

Europe and through a website owned and operated by BOL UK. Given that printing costs are
less expensive in the United States than in the United Kingdom, all printing for Ickes books was
done in the United States by Patterson. The expense of securing an inventory in the United
Kingdom for distribution by BOL UK (including costs or purchasing and shipping the inventory)
was incurred solely by me, and did not involve the Defendants in any way.
21.

Website orders for the Works were placed by BOL UK directly with Bookworld,

the distributor of the Works. Bookworld filled website orders directly and invoiced BOL UK for
20% of the cover price of the books with shipping paid by the customer. When the full cost of
the book plus shipping was received by BOL UK from the customer, BOL UK remitted all

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invoiced amounts to Bookworld. The distribution of Works via internet sales did not involve the
Defendants in any way.
22.

Upon information and belief, at some point after Icke and Adams entered into the

Agreement, Adams registered Defendant BOL as a fictitious name without the permission or
consent from Icke and has been engaging in the printing, distribution and sale of the Works
through these entities without Ickes consent.
23.

Upon information and belief, BOL is a fictitious name registered to Adams, and

Adams is the alter ego and sole proprietor of BOL.


24.

Upon information and belief, Adams is the sole shareholder and owner of Royal

Personnel.
25.

The Agreement did not transfer any right, title or interest in or to any of the

Works to Adams or any of the Defendants, but merely permitted Adams to act as an agent to
arrange for the printing and distribution of the Works.
26.

Section 204 of the Copyright Act provides that [a] transfer of copyright

ownership, other than by operation of law, is not valid unless an instrument of conveyance, or a
note or memorandum of the transfer, is in writing and signed by the owner of the rights
conveyed. Icke has not executed any document effecting transfer of rights to Adams or any
entity affiliated with him, including Defendants.
27.

At all relevant times, it was the intent and understanding of Icke and Adams that

all rights relating to the Works would be owned by Icke, and that Defendants, or any entity
affiliated with or owned by Adams, would have no ownership rights to the Works.

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Adams Breaches The Agreement


28.

In mid-2005, Icke requested that Defendants supply to him for review the books

and records related to the printing and distribution of the Works, and the revenues derived there
from, throughout the term of the Agreement. Based upon a limited review by Ickes accountant
of certain books and records for the first ten months of 2005, Icke learned that Adams had not
been remitting to Icke the full 75% of net profits to which he was entitled. When Icke requested
an opportunity to review all of the books and records related to the printing and distribution of
the Works from the inception of the Agreement, Adams refused to provide Icke with access to
the books and records for the years through and including 2004. Moreover, upon information
and belief, Adams contacted the printer and distributor of Ickes Works and instructed them not
to provide Icke with the requested information.
29.

Then, on or about March 15, 2006, Adams advised Icke that he will no longer

remit to Icke any monies derived from the sale of the Works. Furthermore, Adams claimed that
he was the exclusive publisher of the Works and can continue to print and distribute the Works
as well as copy and print any new books authored by Icke. Since that time, Adams has
improperly withheld the entire 75% share due Icke, claiming that he (and/or BOL or Royal
Personnel) have exclusive rights in and to Ickes Works.
The Notice of Termination
30.

By letter dated April 10, 2006, Icke terminated the Agreement (the Notice of

Termination), effective immediately. In the Notice of Termination, Icke demanded that, by


April 18, 2006, Adams, and any entity affiliated with or owned by him: (1) cease all activities
related to the printing, distributing and sale of Ickes Works, or any other products containing or
incorporating the Works, and confirm such cessation in writing to Ickes counsel; (2)

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immediately provide Ickes counsel with copies of all books and records related to the printing,
distribution and sales of the Works in the United States from 1998 to the present; (3) remit to
Ickes counsel a check, payable to David Icke, in the amount equal to 75% of net profits derived
from the Works since March 2006; and (4) deliver to Ickes counsel all remaining inventory of
the Works.
31.

Defendants did not respond to the Notice of Termination until April 24, 2006,

when Defendants attorney, Robert Cox, Esq., contacted Ickes counsel and reiterated that
Defendants intend to continue selling the Works, notwithstanding the Notice of Termination and
Ickes clear right to determine who may print, distribute and sell his Works. Upon information
and belief, Defendants are continuing to distribute and sell the Works without Ickes
authorization or consent.
32.

As a result of Defendants unauthorized use of Ickes Works, Plaintiffs have been

and continue to be irreparably harmed in that Ickes income has been severely compromised and
rendered him unable to continue to finance research on additional books which he wishes to
author. Additionally, the Defendants improper wresting of control of the Works from Icke has
caused him irreparable harm in that he cannot control the printing, distribution and sale of the
Works to the general public.
33.

Furthermore, by letters dated April 24, 2006, Icke notified Patterson and

Bookworld of the termination of the Agreement and demanded that all printing and distribution
of the Works immediately cease. Bookworld continues to sell Ickes Works on its company
website despite Ickes direction that they cease from doing so. Similarly, in an April 26, 2006
letter to Ickes counsel, Patterson stated that it recognized Adams as the owner of the Works and
refused to return computer discs and other materials relating to the Works to Icke. By continuing

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to print and distribute the Works, notwithstanding the Notice of Termination, and by failing to
return all materials relating to the Works to Icke and to remit monies owed to Icke resulting from
the sale of the Works, Bookworld and Patterson have also irreparably harmed Plaintiffs in that
Icke cannot control the printing, distribution and sale of the Works to the general public.
FIRST CAUSE OF ACTION
(Declaratory Judgment)
34.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 33 above, as if fully set forth herein.


35.

Icke is the exclusive worldwide owner of all right, title and interest in and to the

36.

Pursuant to the Agreement, Adams had the right to print and distribute the Works

Works.

in the United States for an indefinite term.


37.

The Agreement, and any relationship between Icke and Adams (or any entity

affiliated with or owned by Adams) was terminable at will.


38.

As set forth herein above, during the term of the Agreement, Defendants engaged

in activities in breach of the Agreement.


39.

Pursuant to the Notice of Termination, the Agreement was terminated effective

April 10, 2006.


40.

Upon information and belief, at all times since the Notice of Termination,

Defendants have continued to engage in the printing, distribution and sale of the Works without
Plaintiffs authorization or consent.
41.

By continuing to engage in the printing and distribution of the Works subsequent

to the Notice of Termination, Defendants have taken the position that the Agreement has not

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been terminated and that Defendants, or some entity affiliated with or owned by Adams, are
entitled to continue to act as the exclusive publisher of the Works.
42.

As such, for purposes of 28 U.S.C. 2201, 2202, there is an actual and

justiciable controversy between Icke and the Defendants with respect to the termination of the
Agreement and as Defendants right to exploit the Works.
43.

For the reasons set forth herein, this Court should declare and adjudge that: (i) the

Agreement has been terminated, effective April 10, 2006, (ii) Plaintiff is the owner of all right,
title and interest in and to the Works, and (iii) Defendants, or any other entity affiliated or owned
by Adams, have no rights in and to the Works and cannot engage in any printing, distribution or
sales activities related to the Works.
SECOND CAUSE OF ACTION
(Copyright Infringement)
44.

Icke incorporates by reference each and every allegation contained in paragraphs

1 through 43 above, as if fully set forth herein.


45.

Under Sections 106, 114, 115 and 201(a) of the Copyright Act, Icke has the

exclusive right, among other things, to authorize reproduction of the Works, the preparation of
derivative works based upon the Works, and the distribution and sale of the Works to the public.
46.

Defendants unauthorized reproduction, distribution, and sale of the Works

subsequent to the Notice of Termination constitutes infringement of Ickes exclusive rights under
Section 106 of the Copyright Act.
47.

At all times since the Notice of Termination, Defendants have willfully and with

full knowledge of Ickes copyrights made infringing reproductions of the Works, and offered the
reproductions for sale to the general public.

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48.

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As a result of Defendants unauthorized use of Ickes Works, Icke has been and

continues to be irreparably harmed.


49.

As a direct and proximate result of the foregoing acts of infringement by the

Defendants, Icke is entitled to actual damages and profits under Section 504 of the Copyright Act
in an amount to be determined at trial.
50.

As a direct and proximate result of the foregoing acts of infringement by the

Defendants, Icke is entitled to statutory damages under Section 504 of the Copyright Act in an
amount to be determined at trial.
51.

As a direct and proximate result of the foregoing acts of infringement by

Defendants, Icke is entitled to attorneys fees and the costs of this action under Section 505 of
the Copyright Act.
52.

As a direct and proximate result of the foregoing acts of infringement by

Defendants, Icke is entitled to the immediate return of all computer discs and other materials
relating to the Works in the possession of Defendants and/or their agents Patterson and
Bookworld.
THIRD CAUSE OF ACTION
(Breach of Contract)
53.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 52 above, as if fully set forth herein.


54.

From 1998 through April 10, 2006, Icke performed all obligations pursuant to the

Agreement.
55.

Defendants breached the Agreement by, among other things: (i) from 1998 to the

present, failing to remit to Plaintiff his full 75% of the net profits derived from the sale of Ickes

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Works, and (ii) as of March 2006, failing and refusing to make any payments to Icke pursuant to
the Agreement.
56.

Defendants refusal to remit to Icke the appropriate share of net profits derived

from the sale of the Works is not authorized by the Agreement.


57.

As a result of Defendants breach of the Agreement, Icke has been and continues

to be harmed and is entitled to monetary damages in an amount to be determined at trial.


FOURTH CAUSE OF ACTION
(Unjust Enrichment)
58.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 57 above, as if fully set forth herein.


59.

Throughout the term of the Agreement, Defendants received, retained and

benefited from the monies collected by Defendants from the sale of the Works and failed to remit
to Plaintiff the full 75% of net profits to which Icke was entitled.
60.

At all times since March 2006, Defendants have failed and refused to pay Icke the

75% of net profits due to Plaintiff, or any portion thereof.


61.

By failing to pay Icke the full 75% of net profits to which he was entitled, and by

refusing to pay any amounts due to Icke since March 2006, Defendants have been unjustly
enriched in an amount to be determined at trial.
FIFTH CAUSE OF ACTION
(Conversion)
62.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 61 above, as if fully set forth herein.


63.

At all relevant times, Icke remained the sole owner of all rights in and to the

Works and was entitled to 75% of all net profits derived from the sale of the Works.

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The 75% share of net profits due Icke pursuant to the terms of the Agreement are

specific, identifiable funds.


65.

By (i) failing to pay Icke pursuant to the terms of the Agreement his full 75%

share of the net profits, and (ii) as of March 2006, failing and refusing to pay to Icke any monies
due pursuant to the Agreement, Defendants have converted Ickes 75% share of the net profits to
their own use.
66.

Defendants refusal to remit to Icke all amounts due to him is willful and

malicious, without any legal basis and done with the intent to harm Icke.
67.

As a result of Defendants conversion, Icke has been damaged in an amount to be

determined at trial.
SIXTH CAUSE OF ACTION
(Breach of the Covenant of Good Faith and Fair Dealing)
68.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 67 above, as if fully set forth herein.


69.

Implied in the Agreement was a covenant of good faith and fair dealing, whereby

Adams was to provide publishing services for the benefit of Icke and was not to exploit Ickes
Works in any unauthorized manner or without compensation to Icke.
70.

Throughout the term of the Agreement, Defendants breached the covenant of

good faith and fair dealing by failing to remit to Icke the full 75% share of net profits to which he
was entitled.
71.

Since March 2006, Defendants breached the covenant of good faith and fair

dealing by exploiting Ickes Works through the painting and distribution of the Works, while
refusing to pay to Icke any potion of his 75% share of the net profits.

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As a result of Ickes breaches of the covenant of good faith and fair dealing, Icke

has been damaged in an amount to be determined at trial.


AS AND FOR A SEVENTH CAUSE OF ACTION
(Accounting)
73.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 72 above, as if fully set forth herein.


74.

Despite repeated requests by Icke for an accounting of all revenues received by

Defendants pursuant to the Agreement which were derived from the printing and distribution of
Ickes Works, Defendants have failed to provide Icke with such information.
75.

Accordingly, Icke is entitled to an Order requiring Defendants to deliver to Icke

all books and records of Defendants related to the Agreement and/or the printing and distribution
of the Works.
AS AND FOR AN EIGHT CAUSE OF ACTION
(Permanent Injunction)
76.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 75 above, as if fully set forth herein.


77.

By the Notice of Termination, Icke terminated the Agreement in its entirety,

including Adams rights to print and distribute the Works and to receive revenues and net profits
derived from these services.
78.

Notwithstanding the Notice of Termination, Defendants continue to engage in the

printing and distribution of the Works without Ickes consent and to receive revenues and net
profits derived from these services.

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Accordingly, Icke is entitled to an order permanently enjoining Defendants from

(i) engaging in any activities related to the Works, receiving any revenues and net profits with
respect to the Works, and (iii) exploiting the Works in any manner.
AS AND FOR A NINTH CAUSE OF ACTION
(Tortious Interference with Economic
Advantage and/or Business Relations)
80.

Plaintiffs incorporate by reference each and every allegation contained in

paragraphs 1 through 79 above, as if fully set forth herein.


81.

Adams has, without justification, intentionally and maliciously interfered to

Plaintiffs detriment with Plaintiffs business and business relations with its customers by
instructing Bookworld not to fulfill orders for books placed by Bridge of Love UK and Bridge of
Love UKs website.
82.

These acts were committed without justification and with the intent to injure

Plaintiffs business.
83.

As a result of the Adams actions, Plaintiffs have suffered and seek compensatory

and punitive damages in an amount to be determined at trial.


AS AND FOR A TENTH CAUSE OF ACTION
(Tortious Interference with Contract)
84.

Plaintiff incorporate by reference each and every allegation contained in

paragraphs 1 through 83 above, as if fully set forth herein.


85.

With knowledge of the Plaintiffs agreement with Bookworld regarding

fulfillment of orders placed through Bridge of Love UK, Adams, without justification,
maliciously and intentionally interfered with that agreement when he instructed Bookworld to
not fulfill any orders for books placed by or through Bridge of Love UK or Bridge of Love UKs

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website. These acts were committed with intent to injure Plaintiffs business and have injured
Plaintiffs business.
86.

As a result of Adams actions, Plaintiffs have suffered and seek compensatory and

punitive damages in an amount to be determined at trial.


WHEREFORE, Plaintiffs respectfully request that the Court enter an order:

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A.

On the First Cause of Action: declaring and adjudging that (i) the Agreement
between David Icke and Adams has been terminated effective April 10, 2006,
(ii) that Icke is the owner of all right, title and interest in and to the Works, and
(iii) that Defendants, or any other entity affiliated or owned by Adams, have no
right or interest in and to the Works;

B.

On the Second Cause of Action: (i) awarding actual damages suffered by


Plaintiffs as a result of Defendants copyright infringement as well as all profits
received from the use, distribution or sale of infringing copies of the Works;
(ii) awarding statutory damages for willful infringement in an amount of $150,000
per work infringed; (iii) granting a permanent injunction enjoining Defendants, or
any other entity affiliated with or owned by Adams, from using the Works;
(iv) directing Defendants and their agents Patterson and Bookworld to deliver
immediately to Plaintiffs all computer discs and materials in their possession,
custody or control relating to the Works; and (v) awarding costs and
disbursements of this action, including reasonable attorneys fees; and

C.

On the Third Cause of Action: (i) awarding actual damages suffered by Icke as a
result of Defendants breaches of the Agreement; and

D.

On the Fourth, Fifth and Sixth Causes of Action: (i) awarding actual damages
suffered by Icke as a result of Defendants failure to properly remit Ickes
seventy-five percent share of net profits for March 2006 and improper
withholding of monies due to Icke since the inception of the Agreement; and

E.

On the Seventh Cause of Action: ordering Defendants to deliver to Plaintiffs all


books and records of Defendants pertaining to the Agreement and/or the printing
and distribution of the Works;

F.

On the Eighth Cause of Action: permanently enjoining Defendants from


(i) engaging in any printing or distribution services related to the Works,
(ii) exploiting the Works in any way, and (iii) receiving any revenues related to
the Works.

G.

On the Ninth Cause of Action: awarding compensatory and punitive damages to


the Plaintiffs as a result of the Defendants tortious interference with Plaintiffs
business relations with Bookworld; and

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H.

On the Tenth Cause of Action: awarding compensatory and punitive damages to


Plaintiffs as a result of the Defendants tortious interference with Plaintiffs
contract with Bookworld; and

I.

Awarding Plaintiffs attorneys fees and costs; and

J.

Awarding such other and further relief as this Court deems just and proper.

Dated: May 22, 2006

Respectfully submitted,

/s/ Mary Ann L. Wymore


Mary Ann L. Wymore, E.D. Reg. # 28939
mlw@greensfelder.com
Erika M. Anderson, E.D. Reg. # 506103
ema@greensfelder.com
GREENSFELDER, HEMKER & GALE, P.C.
10 South Broadway, Suite 2000
St. Louis, Missouri 63102
Tel: (314) 241-9090
Fax: (314) 345-5466
Shari M. Savitt (upon pro hace vice application)
John J. Burke, Jr. (upon pro hace vice application)
THELEN REID & PRIEST LLP
875 Third Avenue
New York, New York 10022
Tel: (212) 603-2000
Fax: (212) 603-2001
Attorneys for the Plaintiffs
David Icke and Bridge of Love UK

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