1 JENNER & BLOCK LLP

David R. Singer (SBN 204699)

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dsinger@[Link]
3 Julie A. Shepard (SBN 175538)
jshepard@[Link]
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Lauren M. Greene (SBN 271397)
5 lgreene@[Link]
515 South Flower Street, Suite 3300
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Los Angeles, CA 90071-2246
7 Telephone: (213) 239-5100
8 Facsimile: (213) 239-5199

9 Attorneys for Plaintiffs

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11 UNITED STATES DISTRICT COURT
12 CENTRAL DISTRICT OF CALIFORNIA
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WARNER BROS. ENTERTAINMENT Case No. ________________
14 INC.; a Delaware corporation, DC COMICS,
15 a New York general partnership; TURNER
ENTERTAINMENT CO., a Delaware COMPLAINT FOR DIRECT
16 corporation; HANNA-BARBERA COPYRIGHT INFRINGEMENT
PRODUCTIONS, INC., a Delaware AND SECONDARY COPYRIGHT
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corporation; THE CARTOON NETWORK, INFRINGEMENT; DEMAND FOR
18 INC., a Delaware corporation, JURY TRIAL
19 Plaintiffs,
20 v.
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MIDJOURNEY, INC., a Delaware
22 corporation,
23 Defendant.
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COMPLAINT
 1 Plaintiffs Warner Bros. Entertainment Inc., DC Comics, Turner Entertainment Co.,
2 Hanna-Barbera Productions, Inc., and The Cartoon Network, Inc. (collectively “Warner
3 Bros. Discovery”) bring this lawsuit for direct and secondary copyright infringement under
4 the Copyright Act (17 U.S.C. § 101 et seq.) against Midjourney, Inc. (“Midjourney”). This
5 Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338(a), and 17 U.S.C.
6 § 501(b). Warner Bros. Discovery alleges, on personal knowledge as to itself and
7 information and belief as to others, as follows:
8 INTRODUCTION
9 1. Superman, Batman, Wonder Woman, Bugs Bunny, and Scooby-Doo. These
10 are some of the most popular and valuable fictional characters ever created, and they (and
11 many other characters) are owned by Warner Bros. Discovery. That means only Warner
12 Bros. Discovery has the right under U.S. Copyright law to build a business around
13 reproducing, preparing derivative works, distributing, publicly displaying, and performing
14 images and videos featuring its copyrighted characters. These exclusive rights and
15 statutory protections are what incentivize Warner Bros. Discovery (and other movie and
16 television studios) to massively invest in America’s movie and television industries,
17 making them the envy of the world. That is the cornerstone of the U.S. Copyright Act.
18 2. Midjourney thinks it is above the law. It sells a commercial subscription
19 service (the “Service”), powered by artificial intelligence (“AI”) technology, that was
20 developed using illegal copies of Warner Bros. Discovery’s copyrighted works. The
21 Service lets subscribers pick iconic Warner Bros. Discovery copyrighted characters and
22 then reproduces, publicly displays and performs, and makes available for download (i.e.,
23 distributes) infringing images and videos, and unauthorized derivatives, with every
24 imaginable scene featuring those characters. Without any consent or authorization by
25 Warner Bros. Discovery, Midjourney brazenly dispenses Warner Bros. Discovery’s
26 intellectual property as if it were its own.
27 3. Midjourney could easily stop its theft and exploitation of Warner Bros.
28 Discovery’s intellectual property. Midjourney controls what copyrighted content it
1
COMPLAINT
 1 aggregates, selects, copies, and trains on. Midjourney also controls the outputs of its image
2 and video Service, and it has the means to implement protection measures to prevent the
3 ongoing reproduction, public display, public performance, and distribution of Warner Bros.
4 Discovery’s works. Midjourney already possesses the technological means and measures
5 that could prevent its distribution, public display, and public performance of infringing
6 images and videos. But Midjourney has made a calculated and profit-driven decision to
7 offer zero protection for copyright owners even though Midjourney knows about the
8 breathtaking scope of its piracy and copyright infringement.
9 4. Midjourney’s recent conduct shows it has actual knowledge that the Service
10 infringes Warner Bros. Discovery’s copyrighted characters and the ability to stop the
11 infringement. Upon launching video generation, the Service temporarily refused to
12 “animate” (i.e., generate videos from) many of the infringing images of Warner Bros.
13 Discovery’s characters that Midjourney generated. Midjourney could only do this because
14 it recognizes that its Service’s outputs infringe Warner Bros. Discovery’s copyrights.
15 Despite this capability and awareness, within the last couple of weeks, Midjourney
16 deliberately removed these protection measures on video in its Service. And Midjourney
17 heralded this change by formally announcing a so-called “improvement” in Midjourney’s
18 “video moderation” and touted that its subscribers would experience “fewer blocked
19 jobs.” 1 Midjourney also continues to generate countless infringing images. It is hard to
20 imagine copyright infringement that is any more willful than what Midjourney is doing
21 here.
22 5. Other AI image- and video-generating services have instituted copyright
23 protection measures that recognize and protect the rights of content creators like Warner
24 Bros. Discovery. These readily available measures can be implemented in multiple ways:
25 first, by excluding Warner Bros. Discovery’s copyrighted works from the process of
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Caleb, New Video Options and a Home for Moodboards, MIDJOURNEY (Aug. 13, 2025),
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28 [Link]
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COMPLAINT
 1 developing and training the AI software for the Service. Second, by rejecting prompts that
2 request the display or download of Warner Bros. Discovery’s copyrighted characters. And
3 third, by using technology to screen for infringing image outputs—both images and videos.
4 6. Midjourney, however, has prioritized and sought to preserve the hundreds of
5 millions of dollars it earns annually from its Service by doubling down on its theft of
6 copyrighted works. Midjourney chose to not institute any copyright protection measures
7 on the countless infringing images and videos it continues to publicly display, publicly
8 perform, and distribute and to revoke the copyright protection measures it implemented for
9 a short period to limit its generation of infringing video outputs. Midjourney has also
10 recently unveiled part of its piracy playbook: using its unlawful and infringing outputs to
11 substitute and compete with Warner Bros. Discovery’s copyrighted works in yet another
12 manner. Midjourney recently launched “Midjourney TV,” a 24/7 video streaming channel
13 that is publicly accessible via [Link] or Midjourney’s official YouTube page.
14 Midjourney TV is yet another avenue for Midjourney to promote, advertise, and publicly
15 perform the videos that its Service has generated and distributed to other subscribers.
16 7. Despite its knowledge of its infringing outputs of Warner Bros. Discovery’s
17 copyrighted works, Midjourney remains defiant and undeterred. If a Midjourney
18 subscriber submits a simple text prompt requesting an image of Superman in a particular
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COMPLAINT
 1 setting or doing a particular action, Midjourney generates and displays a high quality,
2 downloadable image featuring Warner Bros. Discovery’s copyrighted Superman character:
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15 8. Similarly, if a Midjourney subscriber submits a simple text prompt requesting
16 Batman in a particular setting or doing a particular action, Midjourney generates and
17 displays high quality, downloadable images featuring Batman:
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COMPLAINT
 1 9. Similarly, if a Midjourney subscriber submits a simple text prompt requesting
2 Wonder Woman in a particular setting or doing a particular action, Midjourney generates
3 and displays high quality, downloadable images featuring Wonder Woman:
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15 10. If a Midjourney subscriber submits a simple text prompt requesting Tweety
16 in a particular setting or doing a particular action, Midjourney generates and displays high
17 quality, downloadable images featuring Tweety:
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COMPLAINT
 1 11. If a Midjourney subscriber submits a simple text prompt requesting Scooby-
2 Doo in a particular setting or doing a particular action, Midjourney generates and displays
3 high quality, downloadable images featuring Scooby-Doo:
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15 12. Even in response to generic prompts like “classic comic book superhero
16 battle” that do not mention a Warner Bros. Discovery copyrighted character, Midjourney
17 generates and displays high quality, downloadable images featuring Warner Bros.
18 Discovery’s copyrighted characters such as Superman, Batman, and Flash:
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COMPLAINT
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12 13. Midjourney will then generate a video featuring any of these copyrighted
13 characters. The below frames from infringing Midjourney-generated videos are just a few
14 examples:
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COMPLAINT
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23 14. Midjourney also copies and uses Warner Bros. Discovery’s copyrighted
24 characters to market and promote its Service, encouraging even more infringement (and
25 falsely implying Warner Bros. Discovery’s endorsement). As a result, subscribers have
26 been drawn to Midjourney’s Service because of its ability to generate images that infringe
27 Warner Bros. Discovery’s copyrighted works.
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COMPLAINT
 1 15. Evidently, Midjourney will not stop stealing Warner Bros. Discovery’s
2 intellectual property until a court orders it to stop. Midjourney’s large-scale infringement
3 is systematic, ongoing, and willful, and Warner Bros. Discovery has been, and continues
4 to be, substantially and irreparably harmed by it. Warner Bros. Discovery brings this action
5 to stop Midjourney’s piracy and to uphold U.S. copyright law and the crucial incentives
6 that reward those who create, not those who take.
7 THE PARTIES
8 16. Plaintiff Warner Bros. Entertainment Inc. (“Warner Bros. Entertainment”) is
9 a corporation duly incorporated under the laws of the State of Delaware with its principal
10 place of business in Burbank, California. Warner Bros. Entertainment owns or controls
11 copyrights or exclusive rights in content that it or its affiliates produce or distribute,
12 including those copyrighted works specified in Exhibit A.
13 17. Plaintiff DC Comics (“DC Comics”) is a New York general partnership with
14 its principal place of business in Burbank, California. DC Comics owns or controls
15 copyrights or exclusive rights in content that it or its affiliates produce or distribute,
16 including those copyrighted works specified in Exhibit A. DC Comics as defined herein
17 includes its predecessor entities.
18 18. Turner Entertainment Co. is a corporation duly organized under the laws of
19 the State of Delaware with its principal place of business in Burbank, California. Turner
20 Entertainment Co. owns or controls copyrights or exclusive rights in content that it or its
21 affiliates produce or distribute, including those copyrighted works specified in Exhibit A.
22 19. Hanna-Barbera Productions, Inc. is a corporation duly organized under the
23 laws of the State of Delaware with its principal place of business in Burbank, California.
24 Hanna-Barbera Productions, Inc. owns or controls copyrights or exclusive rights in content
25 that it or its affiliates produce or distribute, including those copyrighted works specified in
26 Exhibit A.
27 20. The Cartoon Network, Inc. (“The Cartoon Network”) is a corporation duly
28 incorporated under the laws of the State of Delaware with its principal place of business in
9
COMPLAINT
 1 Atlanta, Georgia. The Cartoon Network owns or controls copyrights or exclusive rights in
2 content that it or its affiliates produce or distribute, including those copyrighted works
3 specified in Exhibit A.
4 21. As noted above, Warner Bros. Entertainment Inc., DC Comics, Turner
5 Entertainment Co., Hanna-Barbera Productions, Inc., and The Cartoon Network, are
6 collectively referred to in this Complaint as “Warner Bros. Discovery.” Exhibit A contains
7 a non-exhaustive, representative list of Warner Bros. Discovery’s works, along with their
8 registration numbers, which Midjourney has directly or secondarily infringed and
9 continues to infringe (“Warner Bros. Discovery’s Copyrighted Works”). All of Warner
10 Bros. Discovery’s Copyrighted Works in Exhibit A constitute original works and
11 copyrightable subject matter pursuant to the Copyright Act, 17 U.S.C. § 101, et seq., and
12 they have been duly registered with the U.S. Copyright Office. The copyrights set forth in
13 Exhibit A remain valid and subsisting and have been owned and/or controlled by Warner
14 Bros. Discovery at all times relevant to the allegations in this Complaint. The registered
15 copyrights for Warner Bros. Discovery’s Copyrighted Works encompass the identified
16 characters appearing therein. Moreover, the visual depictions of the characters constitute
17 copyright protected artwork and audiovisual works.
18 22. Defendant Midjourney, Inc. is a corporation duly incorporated in Delaware
19 with its principal place of business in San Francisco, California.
20 JURISDICTION AND VENUE
21 23. This Court has subject matter jurisdiction over this Complaint pursuant to
22 28 U.S.C. §§ 1331, 1338(a), and 17 U.S.C. § 501(b).
23 24. Midjourney is subject to the jurisdiction of this Court. Midjourney is
24 headquartered in San Francisco, California and does continuous, systematic, and routine
25 business in California and in this District.
26 25. Midjourney’s unauthorized exploitation of the Copyrighted Works has caused
27 harm to Warner Bros. Discovery in California and in this District. Midjourney reasonably
28 expected or should have reasonably expected its acts to cause harm in California and in
10
COMPLAINT
 1 this District because Warner Bros. Discovery maintains its headquarters in this District,
2 and it is the location of a significant portion of Warner Bros. Discovery’s production and
3 distribution operations.
4 26. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) because a
5 substantial part of the events giving rise to the claims have occurred in this district.
6 27. Venue is further proper in this District pursuant to 28 U.S.C. § 1400(a)
7 because Midjourney is subject to personal jurisdiction in this District as it purposefully
8 directed its activities toward this District:
9 a. Midjourney knows that Warner Bros. Discovery resides in this District
10 and has intentionally targeted Warner Bros. Discovery’s Copyrighted Works and
11 businesses by developing, training, and commercially offering its image and video service
12 (the “Midjourney Service” or “Service”) that generates, distributes, and publicly displays
13 infringing copies, reproductions, and derivatives of Warner Bros. Discovery’s Copyrighted
14 Works. It is also common knowledge that Warner Bros. Discovery’s world-famous movie
15 studio is located in this District. Moreover, Midjourney uses the infringing copies of
16 Warner Bros. Discovery’s Copyrighted Works generated by its Service to promote its
17 Service and attract subscribers, including subscribers in this District.
18 b. Midjourney competes with Warner Bros. Discovery in this District by
19 distributing infringing copies, reproductions, and derivatives of Warner Bros. Discovery’s
20 Copyrighted Works to subscribers, including subscribers in this District.
21 c. As recently as September 2025, Midjourney has distributed infringing
22 copies, reproductions, and derivatives of Warner Bros. Discovery’s Copyrighted Works to
23 Midjourney’s subscribers in this District. On information and belief, during the entire
24 relevant period, Midjourney has distributed infringing copies, reproductions, and
25 derivatives of Warner Bros. Discovery’s Copyrighted Works to subscribers in this District.
26 d. Midjourney offers and maintains an interactive website in this District
27 and purposefully directs its business activities here. Midjourney charges fees to subscribers
28 in this District and then makes available through downloads, public displays, and/or public
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COMPLAINT
 1 performances infringing copies and derivatives of Warner Bros. Discovery’s Copyrighted
2 Works in this District. Further, to purchase and use Midjourney’s Service, residents of this
3 District must create an account and provide Midjourney with their address. Midjourney
4 accepts payment from residents of this District to use its Service. Once a subscriber’s
5 account is created in this District, Midjourney necessarily knows that a particular user
6 resides in this District and therefore chooses to direct its business activities, and distribution
7 and public display of infringing copies of Warner Bros. Discovery’s Copyrighted Works,
8 into this District.
9 e. Midjourney has specifically targeted this District by hiring at least one
10 employee in Los Angeles, California which is in this District.
11 f. Midjourney further targets “artists” and users involved in “commercial
12 art project[s],” a community that includes many of the human creative professionals that
13 Warner Bros. Discovery has and continue to heavily invest in. In particular, Midjourney
14 CEO David Holz stated in a Forbes interview that Midjourney has “a famous character
15 designer using [its] product.” Holz further opined that the entertainment industry will use
16 systems like Midjourney to “try to cut costs” and that “some people will try to cut artists
17 out.”2 Not only does Warner Bros. Discovery employ numerous creative professionals in
18 this District, but Los Angeles and the surrounding area is a known hub for the global
19 creative community. Midjourney’s Service is built off of decades of hard work by Los
20 Angeles’ creative community, including Warner Bros.
21 28. Midjourney has caused harm that was, and has been, foreseeably suffered in
22 this District during the relevant time period.
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26 Rob Salkowitz, Midjourney Founder David Holz on the Impact of AI on Art,
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27 Imagination and the Creative Economy, FORBES (Sept. 16, 2022),

[Link]
28 on-the-impact-of-ai-on-art-imagination-and-the-creative-economy/.
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COMPLAINT
 1 FACTUAL BACKGROUND
2 A. Warner Bros. Discovery Has Created and Owns Some of the Most
3 Popular Movies and Television Shows of All Time.
4 29. Warner Bros. Discovery has a long and storied history of entertaining and
5 inspiring audiences worldwide. Since the 1920s, Warner Bros. Discovery has created,
6 developed, and produced some of the most enduring, valuable, and famous copyrighted
7 entertainment properties in film, television, books, consumer products, theme parks, and
8 other experiences.
9 30. A driving force behind the success of Warner Bros. Discovery entertainment
10 properties are the imaginative and beloved copyrighted characters that appear in those
11 Copyrighted Works. Many of Warner Bros. Discovery’s memorable characters have
12 become pillars of pop culture with a lasting impact on generations of audiences and
13 consumers.
14 31. Warner Bros. Discovery’s characters span across the numerous entertainment
15 properties that they own and exploit, from Superman to Bugs Bunny to Scooby-Doo to
16 Rick and Morty. These original characters are central to the entertainment properties in
17 which they appear. Warner Bros. Discovery’s copyright registrations for those properties
18 encompass those characters.
19 (1) The DC Comics Characters
20 32. The DC Comics works and characters are part of one of the largest collections
21 of entertainment properties that exist in the same shared universe. The origins of the DC
22 Comics works and characters are the superheroes from comic books originally published
23 by DC Comics (including predecessors) starting in 1936. The DC Comics characters and
24 storylines have grown considerably over time and are featured in numerous blockbuster
25 feature films, television series, short films, video games, theme park attractions, and, of
26 course, comic books. Warner Bros. Discovery owns the copyrights to these DC Comics
27 entertainment properties.
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COMPLAINT
 1 33. Warner Bros. Discovery’s DC Comics universes, which include films based
2 on the DC Comics characters, have achieved enormous commercial success. The DC
3 Extended Universe, which encompasses films from 2018 through 2023, grossed over $7.14
4 billion in total at the global box office, with each film earning an average gross of $479
5 million.
6 34. There are numerous superheroes and other characters in the DC Comics
7 works. These characters have expressive conceptual and physical qualities that make them
8 distinctive and immediately recognizable.
9 35. Superman is the quintessential superhero, and one of the most enduring
10 superheroes in popular culture. Superman was first introduced in DC Comics in 1938 and
11 has most recently been featured in the film Superman, which was released domestically on
12 July 11, 2025 and is still in theatres. Superman grossed $125 million domestically in its
13 opening weekend, making it the third-most-successful opening of the year so far.
14 Superman’s alter ego is Clark Kent, who resides in the city of Metropolis. When Clark
15 Kent transforms into Superman to fight crime, he typically dons a blue bodysuit that
16 emphasizes his muscular physique, red trunks, red boots, a yellow belt, and a long red cape.
17 Most importantly, Superman’s suit features his unmistakable logo emblazoned on his
18 chest, which features a red “S” inside a red and yellow shield. Superman has superhuman
19 strength, speed, and reflexes. Throughout the DC Comics universes, Superman has been
20 portrayed both as a live-action and animated superhero, and has appeared across various
21 films, television series, comic books, and video games.
22 36. The superhero Batman is an iconic fictional character who first appeared in
23 the DC Comics anthology series Detective Comics in 1939 and was more recently featured
24 in the 2022 film The Batman, the seventh highest-grossing film of the year. By day,
25 Batman’s alter ego Bruce Wayne is a playboy billionaire, but by night, he fights crime in
26 his distinctive Batsuit, which features a bat-inspired mask, yellow utility belt, and Batman
27 emblem on the chest. Throughout the DC Comics universes, Batman has been portrayed
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COMPLAINT
 1 both as a live-action and animated superhero, and has appeared across various films,
2 television series, comic books, and video games.
3 37. The supervillain The Joker is Batman’s archenemy. The Joker typically wears
4 a purple suit and has stark white skin, green hair, and a wide, dramatic smile often with
5 bright red lips. The Joker was introduced by DC Comics in 1940 and was recently featured
6 in the 2024 film Joker: Folie à Deux. Throughout the DC Comics universes, the Joker has
7 been portrayed both as a live-action and animated character.
8 38. Flash is a distinctive and popular superhero character known for his
9 superhuman speed, which he can also use to generate lightning. Flash wears a red suit and
10 mask with gold lightning bolt-shaped ear and a lightning bolt emblem on the chest. Flash
11 first appeared in a comic book published by DC Comics in 1940 and more recently in the
12 2023 film The Flash. Throughout the DC Comics universes, Flash has been portrayed both
13 as a live-action and animated character.
14 39. Wonder Woman is another central superhero in the DC Comics works who
15 debuted in 1941. She is an Amazonian warrior from the fictional Themyscira who wears
16 a distinctive blue and red outfit with a tiara, bracelets, and her Lasso of Truth. Wonder
17 Woman has starred in numerous television and film projects over the decades including the
18 1970s television show Wonder Woman and more recently in the 2020 film, Wonder Woman
19 1984. Throughout the DC Comics universes, Wonder Woman has been portrayed both as
20 a live-action and animated character.
21 40. Warner Bros. Discovery’s Teens Titans Go! is a comedic animated series that
22 first broadcast in 2013 that follows teenage versions of superheroes from the DC Comics
23 universe. The team includes Robin. Teen Titans Go! and the characters therein, have a
24 distinctive animation style, outfits, and visual appearance.
25 41. Warner Bros. Discovery’s copyright registrations for the DC Comics works
26 encompass the central characters therein.
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COMPLAINT
 1 (2) Looney Tunes Characters
2 42. The animated franchise Looney Tunes was first released as a series of
3 animated theatrical short films beginning in 1930. The franchise has spawned numerous
4 television series that are still broadcast today. The franchise also includes televisions
5 specials, films, comic books, theme park attractions, and video games.
6 43. Many of the Looney Tunes characters are ubiquitous household names, and
7 these characters have expressive conceptual and physical qualities that make them
8 distinctive and immediately recognizable. Bugs Bunny, for example, is a playfully
9 irreverent anthropomorphic gray and white rabbit, who has a star on the Hollywood Walk
10 of Fame. Bugs Bunny has an overbite that showcases his two long front teeth, oversized
11 feet with white fur, and is often depicted eating a carrot.
12 44. Other major Looney Tunes characters include Daffy Duck, a black duck with
13 an orange beak and orange feet, and a white ring around his neck; Sylvester the Cat, an
14 anthropomorphic tuxedo cat with a bulbous red nose and hairy white cheeks; and Tweety,
15 a yellow canary bird with baby blue eyes, long eyelashes, chubby cheeks, and oversized
16 orange feet. Sylvester the Cat is often portrayed chasing Tweety.
17 45. Warner Bros. Discovery’s copyright registrations for the entertainment
18 properties in the Looney Tunes franchise encompass the central characters therein. Warner
19 Bros. Discovery owns the copyrights to the Looney Tunes properties.
20 (3) Tom and Jerry
21 46. Tom and Jerry is a classic animated short film franchise originally created in
22 1940. Since then, numerous spinoffs have been released in the form of television shows,
23 feature films, comic books, comic strips, video games, and a staged musical. Seven Tom
24 and Jerry short films have won the Academy Award for Best Animated Short Film. In
25 2021, Tom and Jerry was released as a hybrid live-action and animated film in theatres and
26 via HBO Max.
27 47. The characters in Tom and Jerry have expressive conceptual and physical
28 qualities that make them distinctive and immediately recognizable. Tom is a gray,
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COMPLAINT
 1 anthropomorphic tuxedo cat, and Jerry is a small brown anthropomorphic mouse. Tom
2 and Jerry’s creators characterized the duo as “the best of enemies,” in a nod to their
3 antagonistic yet caring relationship. Tom is often depicted chasing Jerry and ultimately
4 failing to capture him.
5 48. Warner Bros. Discovery’s copyright registrations for Tom and Jerry
6 encompass the central characters therein. Warner Bros. Discovery owns the copyrights to
7 the Tom and Jerry properties.
8 (4) Scooby-Doo
9 49. Scooby-Doo is a media franchise that features four teenagers and their Great
10 Dane, Scooby-Doo, who solve mysteries, encounter spooky villains, and get caught up in
11 antics as they travel around in their distinctive van, the Mystery Machine. Scooby-Doo
12 was first broadcast as an animated television series in 1969, and the franchise has been
13 refreshed in various television series, including as recently as 2021. A live-action series is
14 currently in development for release on Netflix. The Scooby-Doo characters have also
15 been featured in films, comic books, theme park attractions, and tabletop games.
16 50. The characters in the Scooby-Doo media franchise have expressive conceptual
17 and physical qualities that make them distinctive and immediately recognizable.
18 51. Scooby-Doo is an animated Great Dane who is brown with black spots on his
19 back and shoulders. Scooby-Doo wears a teal collar with a gold-trimmed teal tag that bears
20 his initials, “SD.” He has a large, black, triangular nose, thick eyebrows, rounded upright
21 ears, and small spots on his cheeks.
22 52. Warner Bros. Discovery’s copyright registrations for Scooby-Doo encompass
23 the central characters therein. Warner Bros. Discovery owns the copyrights to the Scooby-
24 Doo properties.
25 (5) The Cartoon Network Characters
26 53. The Cartoon Network is a cable television network that broadcasts animated
27 television series ranging from action to comedy for both children and adults. The Cartoon
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COMPLAINT
 1 Network owns the copyrights to many popular American cartoons including The Powerpuff
2 Girls and Rick and Morty.
3 54. The Powerpuff Girls is an animated television series that features three
4 kindergarten-aged girls, Blossom, Bubbles, and Buttercup, who fight crime in the fictional
5 city of Townsville. The franchise originated in 1992 with the introduction of the three
6 characters in a cartoon short and became a full television series in 1998. The series
7 received a reboot in 2016. The franchise also includes television specials, films, anime
8 adaptations, comic books, video games, and consumer products.
9 55. The Powerpuff Girls have expressive conceptual and physical qualities that
10 make them distinctive and immediately recognizable. The Powerpuff Girls are small,
11 animated girls with oversized heads, distinctive large circular eyes that cover the majority
12 of their faces, and small, rounded features. They have small, simple mouths, and no noses
13 or necks. The Powerpuff Girls have superpowers including the ability to fly.
14 56. All three characters wear a color blocked dress with a black stripe, white
15 stockings, and black Mary Jane shoes, and have eyes the same color as their
16 outfits. Blossom has orange hair and wears pink. Bubbles is blond and wears blue.
17 Buttercup has black hair and wears green.
18 57. The Cartoon Network’s copyright registrations for The Powerpuff Girls
19 encompass the central characters therein. The Cartoon Network owns the copyrights to
20 The Powerpuff Girls properties.
21 58. Rick and Morty is an adult animated television series released under Cartoon
22 Network’s “Adult Swim” brand. Rick and Morty features two titular characters: mad
23 scientist Rick Sanchez, and his gullible and anxious grandson Morty Smith. Rick and
24 Morty was initially released in 2013 and has consistently received high viewer ratings and
25 critical acclaim. The series has been nominated for many awards, and has won multiple
26 Emmy and Annie Awards, among others. Rick and Morty characters have been featured
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COMPLAINT
 1 in short spinoff series and comic books and have made cameo appearances in other films
2 and television series, including The Simpsons.
3 59. The characters in Rick and Morty have expressive conceptual and physical
4 qualities that make them distinctive and immediately recognizable. Rick Sanchez is an
5 animated eccentric mad scientist with spiky, baby-blue hair, and a unibrow of the same
6 color. He has grayish skin and large eyes, and typically wears a blue shirt and a long, white
7 lab coat. He also wears brown trousers over his pencil-thin legs. Morty Smith is an
8 animated 14-year-old boy with brown hair and bulbous eyes. He typically wears a plain
9 yellow t-shirt and blue trousers. The duo is often pictured traveling in their Space Cruiser
10 or traveling through the universe using glowing, bright green portals.
11 60. The Cartoon Network’s copyright registrations for Rick and Morty encompass
12 the central characters therein. The Cartoon Network owns the copyrights to the Rick and
13 Morty properties.
14 B. Midjourney Infringes Warner Bros. Discovery’s Intellectual Property.
15 (1) The Midjourney Service
16 61. Midjourney was founded in 2021 by David Holz, its Chief Executive Officer.
17 Midjourney develops, operates, and sells its generative AI Service, which includes image
18 and video generation capabilities. Midjourney is a successful enterprise that surpassed
19 $200 million in revenue in 2023, and reportedly made $300 million in revenue in 2024,
20 despite the company’s relatively short existence. Midjourney had nearly 21 million users
21 as of September 2024. 3
22 62. Unbeknownst to Warner Bros. Discovery, Midjourney first launched its
23 Service in February 2022 as a “bot” accessible within the Discord communication platform.
24
25 See Kyle Wiggers, Midjourney Says It’s ‘Getting Into Hardware’, TECHCRUNCH (Aug.
3

28, 2024), [Link]

26 hardware/; Naveen Kumar, Midjourney Statistics 2025: Users & Revenue Data,
27 DEMANDSAGE (Dec. 31, 2024), [Link]
Oskar Mortensen, How Many People Work at Midjourney? Statistics & Facts (2025),
28 [Link] (Dec. 2, 2024), [Link]
19
COMPLAINT
 1 Since then, Midjourney has released various versions of its Service. Midjourney began to
2 offer its Service to consumers via its own website, [Link], in or around October
3 2023. Originally, the website was open only to Midjourney customers who had used
4 Midjourney’s Service via the Discord platform. On or around August 23, 2024,
5 Midjourney began offering its Service to all subscribers. On or around April 3, 2025,
6 Midjourney launched version 7 (“V7”) of its image Service. Midjourney’s Service is a
7 commercial service. Currently, subscribers can access the Service by signing up for a
8 subscription on Midjourney’s website.4
9 63. On or around June 18, 2025, Midjourney launched version 1 (“V1”) of its
10 video Service. Midjourney’s video Service features image-to-video capabilities. Like the
11 image Service, Midjourney’s video Service is a commercial service available only to
12 Midjourney subscribers.
13 64. As discussed in more detail below, Midjourney’s Service can generate high
14 quality and high-resolution images and can also generate videos from the images it
15 generates. If a subscriber requests a video based on an image (or, in Midjourney parlance,
16 asks to “animate” an image), the Service adds realistic motion to the image and generates
17 a five second video output.
18 ///
19 ///
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22 ///
23 ///
24 ///
25 ///
26
27
See Comparing Midjourney Plans, MIDJOURNEY,
4

28 [Link]
20
COMPLAINT
 1 65. Midjourney encourages its subscribers to create videos by prominently
2 offering to “animate” images when a subscriber hovers their mouse over an image. The
3 Midjourney Service has “high motion” and “low motion” video settings, and it can extend
4 a video it generated by up to four seconds, up to four times per video, as shown below:
5
6
7
8
9
10
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12
13
14
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18
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28
21
COMPLAINT
 1 66. Midjourney offers four different subscription levels for its Service, as shown
2 below:
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 67. Midjourney’s four levels of paid subscriptions range from $10 per month to
25 $120 per month. Subscribers can receive a discount of approximately 20% on monthly
26 pricing by paying for an annual subscription. Image and video generation requires
27 processing time on Graphics Processing Units (“GPUs”), and Midjourney’s different
28 subscription levels come with different amounts of “Fast” GPU time. According to
22
COMPLAINT
 1 Midjourney, it takes approximately one minute of GPU time to generate images and
2 approximately eight minutes of GPU time to generate videos.
3 68. What Midjourney calls its “Basic Plan” costs $10 per month and comes with
4 3.3 hours of Fast GPU Time per month. This allows Basic Plan subscribers to receive
5 roughly 200 images per month. The more expensive the plan, the more Fast GPU Time
6 the subscriber is allocated, and the more images and videos that subscriber can receive. All
7 subscribers can purchase additional Fast GPU Time for $4 per hour.
8 69. Additionally, subscribers with a “Standard Plan,” “Pro Plan,” or “Mega Plan”
9 receive unlimited “Relax” GPU Time. An image or video generated using Relax GPU
10 Time, which Midjourney refers to as “Relax Mode,” does not cost the subscriber any Fast
11 GPU Time; however, the generation is placed into a queue based on how much the
12 subscriber has used the system. Wait times in Relax Mode can range up to ten minutes per
13 job.
14 70. Copies of the images and videos generated by Midjourney for its subscribers
15 are also publicly displayed and performed on the “Explore” page on Midjourney’s website.
16 Midjourney’s Explore page is a prominent feature of its website where Midjourney
17 promotes and advertises the images and videos that its Service has generated and
18 distributed to other subscribers. The Explore page is a means for Midjourney to promote
19 its Service, attract subscribers to the Service, and encourage subscribers to use the Service,
20 thereby generating more money for Midjourney.
21 71. Copies of the videos generated by Midjourney for its subscribers are also
22 publicly displayed and performed on “Midjourney TV,” a 24/7 video stream that was
23 launched in late July 2025, and that is publicly accessible via [Link] or
24 Midjourney’s official YouTube page. Midjourney TV is yet another avenue for
25 Midjourney to promote and advertise the videos that its Service has generated and
26 distributed to other subscribers. Midjourney has announced that it is considering adding
27 search and personalization features to Midjourney TV, and that it may expand Midjourney
28 TV to have more “channels,” indicating its intent to expand into the traditional television
23
COMPLAINT
 1 or streaming markets. Midjourney TV is a means for Midjourney to promote its Service,
2 attract subscribers to the Service, and encourage subscribers to use the Service, thereby
3 generating more money for Midjourney.
4 (2) Midjourney Reproduces, Generates, Publicly Displays, Publicly
5 Performs, and Distributes Reproductions and Derivative Works of
6 Warner Bros. Discovery’s Copyrighted Works.
7 72. Through its own affirmative conduct, including the selection of which
8 copyrighted works will be stored by and made available through the Service, Midjourney
9 directly reproduces, publicly displays, and distributes infringing reproductions and
10 unauthorized derivative works of Warner Bros. Discovery’s content.
11 73. The examples below confirm that Midjourney directly produces outputs that
12 infringe on Warner Bros. Discovery’s copyrighted characters.
13 ///
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28
24
COMPLAINT
 1 74. Midjourney consistently and accurately reproduces, publicly displays, and
2 distributes infringing copies and unauthorized derivatives of characters from Warner Bros.
3 Discovery’s DC Comics to its subscribers. In response to the simple request (often referred
4 to as a “prompt”) asking to see “Superman, classic cartoon character, DC comics,”
5 Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted Works that is
6 stored by the Service and then reproduced, publicly displayed, and made available for
7 download an image output that copies Warner Bros. Discovery’s Superman, as shown
8 below:
9
10 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 ///
26 ///
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28 ///
25
COMPLAINT
 1 75. In response to a prompt asking to see “Superman flying over Metropolis with
2 his arms outstretched, animated 2d cartoon,” Midjourney accessed the data about Warner
3 Bros. Discovery’s Copyrighted Works that is stored by the Service and then reproduced,
4 publicly displayed, and made available for download an image output that copies Warner
5 Bros. Discovery’s Superman, as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20 ///
21 ///
22 ///
23 ///
24 ///
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28
26
COMPLAINT
 1 76. In response to a prompt asking to see “Batman, 1960s DC comic strip
2 character,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Batman, as
5 shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23 ///
24 ///
25 ///
26 ///
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28
27
COMPLAINT
 1 77. In response to a prompt asking to see “Batman, 1960s DC comic strip
2 character,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Batman, as
5 shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20 ///
21 ///
22 ///
23 ///
24 ///
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28
28
COMPLAINT
 1 78. In response to a prompt asking to see “Batman, comic book character from
2 DC Comics,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Batman, as
5 shown below:
6
Midjourney Output Warner Bros. Discovery’s Copyrighted
7 Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23 ///
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28
29
COMPLAINT
 1 79. In response to a prompt asking to see “Batman, screencap from The Dark
2 Knight,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Batman, as
5 shown below:
6
Midjourney Output Warner Bros. Discovery’s Copyrighted
7 Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 ///
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26 ///
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28
30
COMPLAINT
 1 80. In response to a prompt asking to see “The Joker, DC comic book character,”
2 Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted Works that is
3 stored by the Service and then reproduced, publicly displayed, and made available for
4 download an image output that copies Warner Bros. Discovery’s The Joker, as shown
5 below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23 ///
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28
31
COMPLAINT
 1 81. In response to a prompt asking to see “The Joker, 1970s animated cartoon
2 character,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s The Joker,
5 as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20 ///
21 ///
22 ///
23 ///
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32
COMPLAINT
 1 82. In response to a prompt asking to see “The Flash, animated DC superhero,”
2 Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted Works that is
3 stored by the Service and then reproduced, publicly displayed, and made available for
4 download an image output that copies Warner Bros. Discovery’s Flash, as shown below:
5
6 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
7
8
9
10
11
12
13
14
15
16
17
18
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33
COMPLAINT
 1 83. In response to a prompt asking to see “Wonder Woman casts the Lasso of
2 Truth toward a villain, cartoon,” Midjourney accessed the data about Warner Bros.
3 Discovery’s Copyrighted Works that is stored by the Service and then reproduced, publicly
4 displayed, and made available for download an image output that copies Warner Bros.
5 Discovery’s Wonder Woman, as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
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18
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21
22
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27 ///
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34
COMPLAINT
 1 84. In response to a prompt asking to see “Robin from Teen Titans Go! running
2 toward the camera, action style, animated TV series, 2010s style,” Midjourney accessed
3 the data about Warner Bros. Discovery’s Copyrighted Works that is stored by the Service
4 and then reproduced, publicly displayed, and made available for download an image output
5 that copies Warner Bros. Discovery’s Teen Titans Go! character Robin, as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
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21
22
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24 ///
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35
COMPLAINT
 1 85. Midjourney consistently and accurately reproduces, publicly displays, and
2 distributes copies and derivatives of characters from Warner Bros. Discovery’s Looney
3 Tunes properties to its subscribers. In response to a prompt asking to see “Bugs Bunny,
4 Looney Tunes cartoon character,” Midjourney accessed the data about Warner Bros.
5 Discovery’s Copyrighted Works that is stored by the Service and then reproduced, publicly
6 displayed, and made available for download an image output that copies Warner Bros.
7 Discovery’s Bugs Bunny, as shown below:
8
9 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
10
11
12
13
14
15
16
17
18
19
20
21
22 ///
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36
COMPLAINT
 1 86. In response to a prompt asking to see “Bugs Bunny, hand drawn animated
2 character,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Bugs Bunny,
5 as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
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12
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15
16
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37
COMPLAINT
 1 87. In response to a prompt asking to see “Daffy Duck, classic 2d animated
2 character,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Daffy Duck,
5 as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
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12
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16
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22 ///
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38
COMPLAINT
 1 88. In response to a prompt asking to see “Tweety, famous cartoon character, cel
2 art,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted Works
3 that is stored by the Service and then reproduced, publicly displayed, and made available
4 for download an image output that copies Warner Bros. Discovery’s Tweety character, as
5 shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
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12
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39
COMPLAINT
 1 89. Midjourney consistently and accurately reproduces, publicly displays, and
2 distributes copies and derivatives of characters from Warner Bros. Discovery’s other
3 animated properties to its subscribers. In response to a prompt asking to see “Tom Cat
4 chasing Jerry Mouse, classic cartoon characters,” Midjourney accessed the data about
5 Warner Bros. Discovery’s Copyrighted Works that is stored by the Service and then
6 reproduced, publicly displayed, and made available for download an image output that
7 copies Warner Bros. Discovery’s Tom and Jerry characters, as shown below:
8
9 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
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11
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15
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17
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22 ///
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40
COMPLAINT
 1 90. In response to a prompt asking to see “Tom Cat chasing Jerry Mouse around
2 a living room,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Tom and
5 Jerry characters, as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
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11
12
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41
COMPLAINT
 1 91. In response to a prompt asking to see “Scooby-Doo animated character
2 standing in a spooky room in an old house,” Midjourney accessed the data about Warner
3 Bros. Discovery’s Copyrighted Works that is stored by the Service and then reproduced,
4 publicly displayed, and made available for download an image output that copies Warner
5 Bros. Discovery’s Scooby-Doo character, as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
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42
COMPLAINT
 1 92. Midjourney consistently and accurately reproduces, publicly displays, and
2 distributes copies and derivatives of characters from Warner Bros. Discovery’s Cartoon
3 Network properties to its subscribers. In response to a prompt asking to see “Bubbles,
4 Blossom, and Buttercup cartoon characters from Powerpuff Girls flying through the sky,
5 2000s style, 2d screencap,” Midjourney accessed the data about Warner Bros. Discovery’s
6 Copyrighted Works that is stored by the Service and then reproduced, publicly displayed,
7 and made available for download an image output that copies Warner Bros. Discovery’s
8 characters from The Powerpuff Girls, as shown below:
9
10 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
11
12
13
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15
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17
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19
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21
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43
COMPLAINT
 1 93. In response to a prompt asking to see “Rick and Morty, animated TV show,
2 screencap,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Rick
5 Sanchez and Morty Smith characters, as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20 ///
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44
COMPLAINT
 1 94. In response to a prompt asking to see “Rick and Morty, animated TV show,
2 screencap,” Midjourney accessed the data about Warner Bros. Discovery’s Copyrighted
3 Works that is stored by the Service and then reproduced, publicly displayed, and made
4 available for download an image output that copies Warner Bros. Discovery’s Rick
5 Sanchez and Morty Smith characters, as shown below:
6
7 Midjourney Output Warner Bros. Discovery’s Copyrighted
Character(s)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22 95. As detailed in the introduction section above, Midjourney generates and
23 displays high quality, downloadable images featuring Warner Bros. Discovery’s
24 copyrighted characters, even when the prompt does not include a Warner Bros. Discovery
25 character by name.
26 96. Additionally, Midjourney consistently and accurately reproduces, publicly
27 displays, publicly performs, and distributes copies and derivatives of characters from
28 Warner Bros. Discovery’s Copyrighted Works by generating videos featuring Warner
45
COMPLAINT
 1 Bros. Discovery characters, as illustrated by the screenshots below, which were generated
2 by the Midjourney Service:
3
4
5
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46
COMPLAINT
 1
2
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47
COMPLAINT
 1
2
3
4
5
6
7
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48
COMPLAINT
 1
2
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49
COMPLAINT
 1
2
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50
COMPLAINT
 1
2
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51
COMPLAINT
 1
2
3
4
5
6
7
8
9
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12
13 97. As shown above, the outputs created by Midjourney are reproductions and
14 derivative works of Warner Bros. Discovery’s valuable copyrighted characters. The
15 outputs often contain extensive nuance and detail, background elements, costumes, and
16 accessories beyond what was specified in the prompt. As explained below, Midjourney is
17 able to reproduce, publicly display, publicly perform, and distribute these copies because
18 Midjourney selected and copied Warner Bros. Discovery’s Copyrighted Works as part of
19 the training process for its Service.
20 (3) Midjourney Was Trained to Output Infringing Content.
21 98. Midjourney’s ability to consistently generate infringing copies and
22 unauthorized derivatives of Warner Bros. Discovery’s Copyrighted Works demonstrates
23 that Midjourney, without Warner Bros. Discovery’s knowledge or permission, aggregated
24 and copied Warner Bros. Discovery’s Copyrighted Works to train and develop its Service.
25 It also shows that Midjourney’s Service, through software programming and computer
26 storage devices, embodies “copies” of those works, as that term is defined in Section 101
27 of the Copyright Act, in the AI software that powers the Service. On information and
28 belief, and unbeknownst to Warner Bros. Discovery, Midjourney developed and trained its
52
COMPLAINT
 1 Service on copyrighted works, including Warner Bros. Discovery’s Copyrighted Works to
2 help ensure that it is able to reproduce, publicly display, and distribute faithful, high-quality
3 copies and derivative works of the works it trained on, including Warner Bros. Discovery’s
4 Copyrighted Works. On information and belief, Midjourney trains on video of Warner
5 Bros. Discovery’s Copyrighted Works to replicate, among other things, the expressive
6 motion of its copyrighted characters.
7 99. Based on the facts and circumstantial evidence alleged in this Complaint and
8 common knowledge about the process for creating a generative AI service like Midjourney,
9 Warner Bros. Discovery is informed and believes that Midjourney engaged in the following
10 conduct to train its Service:
11 a. First, Midjourney gathered the underlying works to be used to train the
12 Service. To do so, Midjourney downloaded from the internet, and other sources, content
13 using tools variously described as bots, scrapers, streamrippers, video downloaders, and
14 web crawlers. David Holz admitted that to collect the training data, Midjourney “pulls off
15 all the data it can, all the text it can, all the images it can.”5 Mr. Holz elaborated saying
16 that Midjourney, “grabs everything they can, they dump it in a huge file, and they kind of
17 set it on fire to train some huge thing.” Admitting even more, in a September 2022
18 interview, Mr. Holz confirmed that Midjourney never sought any copyright content
19 holders’ consent to copy and exploit their works.6 The data gathered and copied by
20 Midjourney to use in training its Service includes Warner Bros. Discovery’s Copyrighted
21 Works.
22
23 James Vincent, ‘An Engine for the Imagination’: The Rise of AI Image Generators, An
5

24 Interview with Midjourney Founder David Holz, THE VERGE (Aug. 2, 2022),
[Link]
25 multiverse-interview-david-holz.
26 6 Rob Salkowitz, Midjourney Founder David Holz on the Impact of AI on Art,
27 Imagination and the Creative Economy, FORBES (Sept. 16, 2022),
[Link]
28 on-the-impact-of-ai-on-art-imagination-and-the-creative-economy/.
53
COMPLAINT
 1 b. Second, to prepare the data for ingestion, Midjourney “cleaned” the
2 copies of the underlying works that were collected in the previous step through a filtering
3 process and reformatted (e.g., converted them to a common technical format) the copies
4 that were not filtered out in the cleaning process to train its Service. This step necessarily
5 included creating more copies of the materials obtained in the gathering phase, such as a
6 new copy of each reformatted item (including Warner Bros. Discovery’s Copyrighted
7 Works).
8 c. Third, Midjourney then used the collected and cleaned data and
9 Copyrighted Works to “train” its Service. Although the specifics of this training phase
10 have not been disclosed by Midjourney, and will be the subject of discovery in this action,
11 Midjourney’s ability to repeatedly use the data stored in its software system to reproduce,
12 publicly display, publicly perform, and distribute further copies of Warner Bros.
13 Discovery’s Copyrighted Works for its subscribers demonstrates that Midjourney’s
14 training of its generative AI model involved the fixation of copies of Warner Bros.
15 Discovery’s Copyrighted Works in a tangible medium from which the work can be
16 perceived, reproduced, or otherwise communicated with the aid of a machine or device.
17 On information and belief, and based on Midjourney’s terms of use, Midjourney also trains
18 on the outputs it has generated for its subscribers. Midjourney’s process of training and
19 making multiple copies of Warner Bros. Discovery’s Copyrighted Works was done without
20 Warner Bros. Discovery’s approval or authorization.
21 100. In other words, Midjourney used software, servers, and other technology to
22 store and fix data associated with Warner Bros. Discovery’s Copyrighted Works in such a
23 manner that those works are thereby embodied in the model, from which Midjourney is
24 then able to generate, reproduce, publicly display, and distribute unlimited “copies” and
25 “derivative works” of Warner Bros. Discovery’s works as defined by the Copyright Act.
26 101. Moreover, Midjourney repeats this process each time it trains and creates a
27 substantially new version of its Service. With each major reiteration of its Service,
28 Midjourney created a new model trained anew on Warner Bros. Discovery’s Copyrighted
54
COMPLAINT
 1 Works without Warner Bros. Discovery’s knowledge. For example, according to
2 Midjourney’s CEO, version 6 of Midjourney’s image Service was actually the “third model
3 trained from scratch.” On information and belief, Midjourney will also repeat the training
4 process each time it creates a substantially new version of its video Service.
5 102. Midjourney had to copy Warner Bros. Discovery’s Copyrighted Works in
6 order for it to be able to subsequently disseminate reproductions and derivatives of Warner
7 Bros. Discovery’s Copyrighted Works as outputs. Midjourney’s unauthorized copying of
8 Warner Bros. Discovery’s Copyrighted Works to train its Service infringes Warner Bros.
9 Discovery’s copyrights in its Copyrighted Works.
10 (4) Midjourney’s Public Display and Distribution of Warner Bros.
11 Discovery’s Copyrighted Works Is Pervasive and a Clear Draw for
12 Its Subscribers.
13 103. Once the training process is complete, due to Midjourney’s massive copying
14 of Warner Bros. Discovery’s Copyrighted Works, and as a direct and intentional result of
15 Midjourney’s development and training, Midjourney’s Service generates reproductions
16 and derivatives of Warner Bros. Discovery’s Copyrighted Works. Through its Service
17 Midjourney is able to further reproduce, publicly display, publicly perform, and distribute
18 image and video outputs that are identical or virtually identical to Warner Bros.
19 Discovery’s Copyrighted Works in response to simple prompts from subscribers.
20 104. As repeatedly shown above, the outputs created by Midjourney are copies and
21 derivative works of Warner Bros. Discovery’s valuable copyrighted characters. When a
22 subscriber enters a prompt for an image of Batman, Tom and Jerry, Flash or any of Warner
23 Bros. Discovery’s countless copyrighted characters, Midjourney creates yet another copy
24 of that character which it publicly displays, publicly performs, and/or distributes via
25 download. These so-called outputs—which can appear in all sorts of different settings and
26 engaged in any manner of actions—are copies and/or derivatives of Warner Bros.
27 Discovery’s copyrighted characters. Midjourney thus can generate an endless supply of
28
55
COMPLAINT
 1 unlawful copies and derivative works that it can publicly display and distribute to
2 subscribers on demand.
3 105. Midjourney’s subscribers are undoubtedly drawn to the Service due to its
4 ability to infringe Warner Bros. Discovery’s Copyrighted Works. Midjourney’s Discord
5 server contains troves of images generated by the Service that consist of copies and
6 derivatives of Warner Bros. Discovery’s copyrighted characters. For example, a subscriber
7 requested an image featuring Warner Bros. Discovery’s Rick and Morty characters, and
8 the Midjourney Service created and distributed the infringing image below. 7
9
10
11
12
13
14
15
16
17
18
19
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26
27
[Link]
7

28 140539565.
56
COMPLAINT
 1 106. A subscriber requested an image featuring Batman and R2-D2, and the
2 Midjourney Service created and distributed the infringing image below. 8
3
4
5
6
7
8
9
10
11
12
13
107. A subscriber requested an image featuring Shaggy and Scooby Doo, and the
14
Midjourney Service created and distributed the infringing image below. 9
15
16
17
18
19
20
21
22
23
24
25
26
8
[Link]
363752478.
27
[Link]
9

28 339622511.
57
COMPLAINT
 1 108. A subscriber requested an image featuring Bugs Bunny, and the Midjourney
2 Service created and distributed the infringing image below. 10
3
4
5
6
7
8
9
10
11
12
13 ///
14 ///
15 ///
16 ///
17 ///
18 ///
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26
27
[Link]
10

28 957525052.
58
COMPLAINT
 1 109. Midjourney’s official Reddit page, also known as a subreddit, contains
2 numerous infringing copies and derivatives of Warner Bros. Discovery’s copyrighted
3 characters generated by its Service. For example, a Reddit user posted an image of
4 “Upcoming Batman movie inspired by the ‘New Look’ era” to the r/Midjourney Subreddit,
5 and received 177 “upvotes” and 13 comments. 11
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23 ///
24 ///
25
26 u/Larry-fine-wine, REDDIT (r/midjourney), Upcoming Batman movie inspired by the
11

27 ‘New Look’ era,

[Link]
28 pired_by_the_new_look_era/.
59
COMPLAINT
 1 110. Another Reddit user posted an image of “Superman’s bored” to the
2 r/Midjourney Subreddit, and received 10 “upvotes”.12
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26
27
u/esmagik, REDDIT (r/midjourney), Superman’s bored,
12

28 [Link]
60
COMPLAINT
 1 111. A Reddit user posted an image of “Batman” to the r/Midjourney Subreddit,
2 and received 5 “upvotes” and one comment. 13
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21 ///
22 ///
23 ///
24 ///
25 ///
26
27
u/bryanpotter, REDDIT (r/midjourney), Batman,
13

28 [Link]
61
COMPLAINT
 1 112. A Reddit user posted an image of “Superman is toast” to the r/Midjourney
2 Subreddit, and received one comment. 14
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17 113. Notably, that the examples above are on Midjourney’s own Discord server

18 and its Midjourney Subreddit shows that Midjourney had actual knowledge of its Service’s
19 infringement of the characters discussed above.
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26
27
u/garbonzo00, REDDIT (r/midjourney), Superman is toast,
14

28 [Link]
62
COMPLAINT
 1 114. There are also many posts on Instagram that feature infringing copies and
2 derivatives of Warner Bros. Discovery’s copyrighted characters generated by
3 Midjourney’s Service. For example, an Instagram user posted a video of Superman
4 swimming.15
5
6
7
8
9
10
11
12
13
14
15 115. Another user posted a video of the Warner Bros. Discovery’s the Joker

16 playing violin. 16

17
18
19
20
21
22
23
24
25
26
15
@earthdwelling, INSTAGRAM, Superman in the water (Aug. 3, 2025),
[Link]
27
@thejokerds, INSTAGRAM (July 1, 2025), [Link]
16

28 yNvNb/.
63
COMPLAINT
 1 116. One user of the social media app TikTok posted a video of Warner Bros.
2 Discovery’s Superman flying.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28
64
COMPLAINT
 1 117. A subscriber posted to the website PromptBase, displaying a number of
2 infringing images of Warner Bros. Discovery’s superheroes, including Batman, Superman,
3 Flash and Aquaman, which were generated by Midjourney’s Service. 17
4
5
6
7
8
9
10
11
12
13
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15
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24
25 ///
26
27
@alchemydesign, Bruce Timm Animation Charadesigned, PROMPTBASE,
17

28 [Link]
65
COMPLAINT
 1 118. Another subscriber posted to PromptBase, displaying infringing images of
2 Warner Bros. Discovery’s Copyrighted Works, including Flash, Supergirl, Raven, Harley
3 Quinn, and Aquaman, which had been generated by Midjourney’s Service. 18
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22 119. Midjourney has faced widespread criticism for copying, publicly displaying,
23 and distributing images of copyrighted works, including images of Warner Bros.
24 Discovery’s Copyrighted Works. AI researcher Gary Marcus and film artist Reid Southen
25
26
27
@alchemydesign, Alex Ross Iconic Covers Dc Comics, PROMPTBASE,
18

28 [Link]
66
COMPLAINT
 1 published a research article detailing how Midjourney generates copyrighted works. 19 In
2 that research article, Dr. Marcus and Mr. Southen detailed Midjourney’s ability to generate
3 images that were essentially stills from Warner Bros. Discovery’s popular films Batman v.
4 Superman and The Dark Knight, as shown below:
5
6
7
8
9
j

10
11
12
13
14
15
16
17
18
19
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26
27 Gary Marcus and Reid Southen, Generative AI Has A Visual Plagiarism Problem
19

Experiments With Midjourney And DALL-E 3 Show A Copyright Minefield, IEEE

28 SPECTRUM (Jan. 6, 2024), [Link]
67
COMPLAINT
 1
2
3
4
5
6
7
8
9
10
11
12 120. The New York Times ran an article discussing the research article by Dr.
13 Marcus and Mr. Southen, and revealed that The Times had approached Midjourney about
14 the article but “Midjourney did not respond to requests for comment.” 20 Business Insider
15 also ran an article discussing the research article and noted that it had reached out to
16 Midjourney.21 The New York Times and Business Insider articles indicate that Midjourney
17 had actual knowledge of the copyright infringement of Warner Bros. Discovery’s
18 characters detailed in the research article.
19 121. While Midjourney refused to comment to The New York Times or Business
20 Insider, it reportedly punished Mr. Southen for criticizing Midjourney’s infringing Service.
21 After Mr. Southen posted about Midjourney’s infringement of Batman and Joker on X,
22
23 Stuart A. Thomson, We Asked A.I. to Create the Joker. It Generated a Copyrighted
20

24 Image, THE NEW YORK TIMES, (Jan. 25, 2024),

[Link]
25 [Link].
26 21 Lakshmi Varanasi, Generative AI Models Can Now Create Replicas of Trademarked
27 Characters With Prompts As Simple As ‘Videogame Italian’, BUSINESS INSIDER, (Jan. 7,
2024), [Link]
28 images-study-text-phrase-prompts-2024-1.
68
COMPLAINT
 1 Midjourney retaliated by “revoking Mr. Southen’s Midjourney privileges and wiping his
2 history.”22
3 122. Midjourney’s response to criticism from Dr. Marcus and Mr. Southen further
4 establishes that it had actual knowledge that the Service infringed Warner Bros.
5 Discovery’s Batman and Joker characters and did nothing to prevent further infringement.
6 123. Further evidencing Midjourney’s knowledge that its Service infringed Warner
7 Bros. Discovery’s copyrighted characters, Midjourney updated its Terms of Service to
8 prohibit redteaming, the practice of testing an AI system for vulnerabilities such as the
9 ability to infringe copyrights or generate outputs that may have ethical problems.23
10 Midjourney then tried to cover its tracks by deleting discussion of this change from its
11 Reddit channel.
12 124. As further evidence that subscribers are drawn to Midjourney’s Service
13 because it distributes infringing copies of Warner Bros. Discovery’s copyrighted
14 characters, there are marketplaces and forums where subscribers exchange tips about how
15 to use the Service to download a variety of images featuring Warner Bros. Discovery’s
16 copyrighted characters. These marketplaces and forums, as well as the articles, social
17 media, and other postings discussed above, demonstrate as strong consumer desire to use
18 Midjourney’s commercial Service as a source for reproductions of characters from Warner
19 Bros. Discovery’s Copyrighted Works.
20 (5) Midjourney Chooses to Not Take Reasonable Measures to Prevent
21 Further Copyright Infringement.
22 125. Midjourney could stop, or at least minimize, its ongoing copyright
23 infringement. Specifically, in addition to discontinuing its large-scale infringement of the
24
25 Gary Marcus, An Artist Fights Back, and Midjourney Has Embarrassed Themselves,
22

26 MARCUS ON AI, (Dec. 23, 2023), [Link]

back-and-midjourney.
27 23
See Gary Marcus (@GaryMarcus), X (Dec. 25, 2023, at 6:16 PM),
28 [Link]
69
COMPLAINT
 1 Copyrighted Works to train its models, Midjourney could readily implement copyright
2 protection measures to prevent or limit infringing outputs.
3 126. Midjourney controls the outputs of its image and video Service, and it has the
4 means to implement protection measures to prevent the ongoing reproduction, public
5 display, public performance, and distribution of Warner Bros. Discovery’s works.
6 Midjourney has demonstrated its ability to implement technological measures designed to
7 prevent its distribution, public display, and public performance of certain images and
8 videos. But Midjourney has chosen not to use them. For example, Midjourney has limited
9 its technological protection measures for images to violence and nudity and offered no
10 protections for copyright owners, even though Midjourney knows that it is infringing a
11 multitude of copyrights, including those owned by Warner Bros. Discovery.
12 127. For example, if a Midjourney subscriber submits a prompt asking for images
13 with violence or nudity, Midjourney’s protection measures cause a response that says
14 “Sorry! The AI Moderator is unsure about this prompt. It might not meet our community
15 guidelines or our AI moderation might have gotten confused. Please try a different one.”
16 An example of this is shown below:
17
18
19
20
21
22
23
24 128. The error messages explain Midjourney’s “Community Standards,” which list
25 four categories of prompts that Midjourney does not allow: (1) “Content that disrespects,
26 harms, or misleads about public figures or events,” (2) “Hate speech, explicit or real-world
27 violence,” (3) “Nudity or overtly sexualized images,” and (4) “Imagery that might be
28 considered culturally insensitive.”
70
COMPLAINT
 1 129. Midjourney’s Terms of Service further describe its prohibitions on “adult
2 content,” “gore,” and “images for political campaigns,” and ask subscribers to “avoid
3 making visually shocking or disturbing content.” The Terms of Service then explain that
4 Midjourney “will block some text inputs automatically.”
5 130. Midjourney’s knowledge of its ongoing infringement is apparent from
6 Midjourney’s actions with respect to its video Service. As noted above, Midjourney
7 initially deployed technology protection measures that to some degree prevented its
8 distribution, public display, and public performance of infringing videos by refusing to
9 “animate” infringing images that Midjourney generated, including images of Warner Bros.
10 Discovery’s Copyrighted Works. On information and belief, these partial protections
11 briefly existed on its video Service in response to a recent lawsuit filed against Midjourney
12 by major movie studios and entertainment companies, Disney and Universal, alleging that
13 the Service infringes their copyrights. Midjourney effectively conceded wrongdoing by
14 instituting these measures, apparently to reduce its legal exposure.
15 131. But, inexplicably, Midjourney has recently reversed course and removed even
16 those imperfect protections against its copyright infringement. Midjourney’s actions
17 validate Warner Bros. Discovery’s concerns that Midjourney can and will remove
18 copyright protection measures on a whim. Midjourney refuses to stop its infringement
19 while many of Midjourney’s competitors have implemented technological measures to
20 prevent the generation of infringing outputs.
21 132. Midjourney’s now abandoned attempts to institute some copyright protection
22 measures that limit the Service from generating videos that feature Warner Bros.
23 Discovery’s characters evidence Midjourney’s actual knowledge of the Service’s
24 infringement of Warner Bros. Discovery’s characters. In other words, Midjourney could
25 not have implemented these measures to block videos featuring specific copyrighted
26 Warner Bros. Discovery’s characters unless it had actual knowledge that the Service
27 infringed those characters.
28
71
COMPLAINT
 1 133. Midjourney’s Explore page displays images and videos generated by the
2 Service to promote the Service and attract subscribers, including outputs that infringe
3 Warner Bros. Discovery’s Copyrighted Works. Those outputs are sometimes searchable
4 by name, as shown below:
5
6
7
8
9
10
11
12
13
14
15
16 134. As evidenced from the above examples, the Explore page continues to feature,
17 publicly display, and distribute countless images that infringe Warner Bros. Discovery’s
18 Copyrighted Works. However, similar to actions Midjourney has taken in the past to try
19 to conceal its infringement, including by terminating the account of a user investigating the
20 Service’s infringing capabilities,24 Midjourney implemented some suspicious and spotty
21 technical changes to its Explore page to make it harder to locate examples of its repeat
22 copyright infringement after Disney and Universal sued Midjourney for copyright
23 infringement.
24 135. Previously, if a subscriber searched for “Batman,” the Explore page would
25 publicly display a trove of infringing copies of Warner Bros. Discovery’s copyrighted
26
27 Gary Marcus and Reid Southen, Generative AI Has A Visual Plagiarism Problem
24

Experiments With Midjourney And DALL-E 3 Show A Copyright Minefield, IEEE

28 SPECTRUM (Jan. 6, 2024), [Link]
72
COMPLAINT
 1 Batman character that the Service had previously generated and distributed to subscribers.
2 After Disney and Universal filed their copyright infringement lawsuit, if a subscriber
3 searches the Explore page for “Batman,” the Explore page now displays a message that
4 says, “nothing to see right now.” But that is not accurate because when a subscriber
5 searches the Explore page for “Batma,” Midjourney displays infringing images of Warner
6 Bros. Discovery’s Batman character that Midjourney has generated and distributed to its
7 subscribers.
8
9
10
11
12
13
14
15
16
17
18
19
20 136. On information and belief, Midjourney curates and presents Explore page
21 search results that publicly display and make available for download images that infringe
22 Warner Bros. Discovery’s copyrighted characters. Midjourney’s publication and curation
23 of infringing images on the Explore page show that Midjourney knows that its platform
24 actually infringes Warner Bros. Discovery’s Copyrighted Works, and that the Explore page
25 is intended to advertise Midjourney’s ability to infringe the Copyrighted Works.
26
27
28
73
COMPLAINT
 1 137. For example, on its Explore page, Midjourney also publicly displays
2 infringing images of Warner Bros. Discovery’s Superman character that Midjourney has
3 generated and distributed to its subscribers:
4
5
6
7
8
9
10
11
12
13
14
15 138. Midjourney also publicly displays infringing images of Warner Bros.
16 Discovery’s Wonder Woman character that Midjourney has generated and distributed to
17 its subscribers:
18
19
20
21
22
23
24
25
26
27
28
74
COMPLAINT
 1 139. Midjourney also publicly displays infringing images of Warner Bros.
2 Discovery’s Scooby-Doo character that Midjourney has generated and distributed to its
3 subscribers:
4
5
6
7
8
9
10
11
12
13
14
15 140. Midjourney also publicly displays infringing images of Warner Bros.
16 Discovery’s Rick and Morty characters that Midjourney has generated and distributed to
17 its subscribers:
18
19
20
21
22
23
24
25
26
27
28
75
COMPLAINT
 1 141. By maintaining and publicly displaying infringing copies of Warner Bros.
2 Discovery’s Copyrighted Works on its Explore page, Midjourney is advertising its ability
3 to reliably reproduce Warner Bros. Discovery’s Copyrighted Works for its subscribers.
4 Midjourney’s Explore gallery also demonstrates that Midjourney subscribers use
5 Midjourney to view and/or download copies of Warner Bros. Discovery’s Copyrighted
6 Works.
7 142. Midjourney’s Explore page manifests its express intention and desire to attract
8 Midjourney subscribers (and increase its revenues) by exploiting the availability of
9 infringing Warner Bros. Discovery content and its ability to reliably reproduce Warner
10 Bros. Discovery’s Copyrighted Works for its subscribers. And Midjourney further
11 facilitates and encourages infringement by publicly displaying the prompts used to generate
12 the images Midjourney displays on the Explore page, which encourages Midjourney
13 subscribers to obtain similar results to those they find in the gallery. Midjourney also
14 allows subscribers to drag generations displayed on the Explore page into the prompt bar
15 to generate similar results as those featured on the Explore page.
16 143. The technical and copyright protection measures discussed above demonstrate
17 that Midjourney controls, and has the ability to control, generative outputs through readily
18 available technical protection measures. Midjourney’s infringement of Warner Bros.
19 Discovery’s Copyrighted Works is manifestly willful. Despite having the ability to do so,
20 Midjourney has affirmatively chosen not to use copyright protection measures to limit the
21 infringement of Warner Bros. Discovery’s Copyrighted Works by its Service. Indeed,
22 despite temporarily adding some protection measures to the video Service, Midjourney has
23 since removed those measures, and has not implemented such measures on its image
24 Service, allowing its infringement to continue unabated by generating both infringing
25 images and videos.
26 144. In contrast, other AI services have demonstrated that reasonable, readily
27 available copyright protection measures can prevent or limit infringing generative AI
28 outputs, including by training only on licensed copyrighted works, screening image outputs
76
COMPLAINT
 1 for infringing material before the image is displayed to the subscriber, and by refusing to
2 allow generations based on prompts likely to elicit infringing content.
3 145. Midjourney also makes clear in its Terms of Service that it has the ability to
4 police and control the content its Service makes available, stating that it can terminate
5 “access to and use of” the Service “for any user who engages in repeated acts of [copyright]
6 infringement.”25 However, given the extraordinary volume of outputs that infringe Warner
7 Bros. Discovery’s Copyrighted Works, and that this provision was added in response to
8 allegations regarding that infringement, it is clear that this provision is Midjourney’s way
9 to retaliate against accounts that redteam its Service and to chill those efforts to expose
10 infringement, rather than a good faith attempt to prevent or limit infringement.
11 146. If Midjourney is not enjoined, it intends to continue to develop and scale its
12 Service, thereby enhancing its ability to infringe Warner Bros. Discovery’s Copyrighted
13 Works. Indeed, in addition to recently launching Midjourney TV and its YouTube channel,
14 this week, Midjourney’s CEO announced that Midjourney plans to continue deploying new
15 versions of its Service.
16 147. Midjourney’s unlawful conduct has caused, and will continue to cause,
17 substantial and irreparable harm to Warner Bros. Discovery, if it is not enjoined.
18 148. Warner Bros. Discovery exercises its exclusive rights to exploit and license
19 (or not to license) its characters and intellectual property, including images and video clips
20 of its Copyrighted Works, to develop and grow selected markets for its Copyrighted Works.
21 Midjourney’s conduct usurps Warner Bros. Discovery’s control over the exercise of its
22 exclusive rights in its Copyrighted Works, interfering with Warner Bros. Discovery’s
23 exploitation and licensing strategies.
24 ///
25 ///
26
27
See Terms of Service, MIDJOURNEY (June 23, 2025), available at
25

28 [Link]
77
COMPLAINT
 1 149. Midjourney illegally and unfairly diverts consumers away from Warner Bros.
2 Discovery’s business which includes selling posters, wall art, prints, coloring books, and
3 other products that contain images of the Warner Bros. Discovery’s Copyrighted Works
4 and the copyrighted characters therein.
5 150. Midjourney also illegally and unfairly competes with companies that license
6 Warner Bros. Discovery’s Copyrighted Works for the purpose of creating authorized
7 derivatives, and undercuts those existing and potential licensing markets. Such companies
8 negotiate licenses with Warner Bros. Discovery and abide by contractual restrictions in
9 those agreements. Midjourney need not honor such contractual restrictions because it
10 circumvents the licensing process altogether.
11 151. Midjourney is also contributing to consumer confusion regarding what is
12 lawful and what is not lawful by misleading its subscribers to believe that Midjourney’s
13 massive copying and the countless infringing images and videos generated by its Service
14 are somehow authorized by Warner Bros. Discovery.
15 152. Warner Bros. Discovery has no adequate remedy at law for the substantial and
16 irreparable harm that Midjourney has caused and continues to cause. Midjourney must be
17 held accountable for its vast, intentional, and unrelenting copyright infringement and
18 enjoined from further infringing activities.
19 FIRST CLAIM FOR RELIEF
20 (Direct Copyright Infringement)
21 153. Warner Bros. Discovery incorporates herein by reference each and every
22 averment contained in paragraphs 1 to 152 inclusive.
23 154. Warner Bros. Discovery owns the Copyrighted Works at issue, including
24 those in the non-exhaustive, representative lists attached as Exhibit A, and has the exclusive
25 right, among others, to reproduce, publicly display, publicly perform, distribute, and make
26 derivative works under Section 106 of the Copyright Act.
27
28
78
COMPLAINT
 1 155. Warner Bros. Discovery never authorized Midjourney to reproduce, publicly
2 display, publicly perform, distribute, make derivatives of, or otherwise exploit its
3 Copyrighted Works.
4 156. Midjourney has directly infringed Warner Bros. Discovery’s Copyrighted
5 Works by unlawfully reproducing, publicly displaying, publicly performing, distributing,
6 and making derivative works based on Warner Bros. Discovery’s Copyrighted Works, both
7 in developing and training its Service, and in the outputs Midjourney generates for its
8 subscribers.
9 157. Each act of infringement by Midjourney constitutes a separate and distinct act
10 of infringement.
11 158. Midjourney’s acts of infringement are willful, in disregard of and with
12 indifference to Warner Bros. Discovery’s rights.
13 159. Midjourney is purposefully exploiting Warner Bros. Discovery’s valuable
14 intellectual property to attract subscribers, and profiting by providing subscribers with
15 countless copies and derivatives of Warner Bros. Discovery’s Copyrighted Works.
16 160. As a direct and proximate result of Midjourney’s infringement, Warner Bros.
17 Discovery is entitled to damages and Midjourney’s profits in an amount according to proof.
18 161. Alternatively, and at its election, Warner Bros. Discovery is entitled to
19 statutory damages, up to $150,000 per infringed work by virtue of Midjourney’s willful
20 infringement, or for such other amounts as may be proper under 17 U.S.C. § 504.
21 162. Warner Bros. Discovery is further entitled to recover its attorneys’ fees and
22 full costs pursuant to 17 U.S.C. § 505.
23 163. As a direct and proximate result of the foregoing acts and conduct, Warner
24 Bros. Discovery has sustained and will continue to sustain substantial and irreparable
25 injury, for which there is no adequate remedy at law. Unless enjoined and restrained by
26 this Court, Midjourney will continue to infringe Warner Bros. Discovery’s rights in its
27 Copyrighted Works. Warner Bros. Discovery is entitled to injunctive relief under 17
28 U.S.C. § 502.
79
COMPLAINT
 1 SECOND CLAIM FOR RELIEF
2 (Secondary Copyright Infringement)
3 164. Warner Bros. Discovery incorporates herein by reference each and every
4 averment contained in paragraphs 1 to 163 inclusive.
5 165. Warner Bros. Discovery alleges that Midjourney is the direct copyright
6 infringer of the Copyrighted Works at issue in this litigation. However, in the event that
7 Midjourney argues that it is not the direct infringer of Warner Bros. Discovery’s
8 Copyrighted Works, and that its own subscribers are somehow the direct infringers of the
9 Copyrighted Works, then Warner Bros. Discovery pleads, in the alternative, that
10 Midjourney is nevertheless liable for secondary copyright infringement.
11 166. Warner Bros. Discovery owns the Copyrighted Works at issue, including
12 those in the non-exhaustive, representative lists attached as Exhibit A, and has the exclusive
13 right, among others, to reproduce, publicly display, publicly perform, distribute, and make
14 derivative works under Section 106 of the Copyright Act.
15 167. As alleged above, the unauthorized reproduction, public display, public
16 performance, distribution, and creation of derivatives of Warner Bros. Discovery’s
17 Copyrighted Works through Midjourney’s output infringes Warner Bros. Discovery’s
18 exclusive copyrights under Section 106 of the Copyright Act.
19 168. If Midjourney contends that its own subscribers are the volitional actors
20 responsible for making the copies of Warner Bros. Discovery’s Copyrighted Works
21 identified in this Complaint, such copying was done (and is being done) without Warner
22 Bros. Discovery’s authorization or consent and constitutes copyright infringement under
23 the Copyright Act.
24 169. Midjourney is vicariously liable for these acts of direct copyright infringement
25 (assuming they are adjudicated to be direct infringement by Midjourney’s subscribers).
26 170. Midjourney has the right and ability to supervise and/or control these acts of
27 direct copyright infringement.
28
80
COMPLAINT
 1 171. First, Midjourney has the ability to control the copyright infringement at issue
2 because Midjourney controls and selects which of Warner Bros. Discovery’s Copyrighted
3 Works are copied and used to train its Service. Midjourney had the right and ability to
4 exclude Warner Bros. Discovery’s Copyrighted Works from its training data.
5 172. Second, Midjourney has the right and ability to control the prompts from its
6 subscribers that are submitted to its Service to generate an output and the ability to block
7 subscribers who request infringing content.
8 173. Third, Midjourney has protection measures already in place that expressly
9 block the generation of certain content (e.g., disrespectful images of public figures, hate
10 speech, violence, nudity, and culturally insensitive information). Moreover, Midjourney’s
11 actions reflect that it has the capability to recognize infringing outputs, but in defiance of
12 U.S. Copyright laws, has not implemented any measures to limit its Service from
13 generating, publicly displaying, and distributing images infringing Warner Bros.
14 Discovery’s Copyrighted Works. This is the case even though such copyright protection
15 measures are employed by a number of Midjourney’s competitors.
16 174. As evidenced by the Explore pages featuring infringing Warner Bros.
17 Discovery’s Copyrighted Works, and subscribers’ interest in using the Service to produce
18 infringing copies of Warner Bros. Discovery’s Copyrighted Works, the ability to use the
19 Service to obtain copies of Warner Bros. Discovery’s Copyrighted Works is plainly an
20 attraction and a draw for subscribers.
21 175. At all relevant times, Midjourney has derived a direct financial benefit from
22 each act of direct infringement at issue. Midjourney is a commercial service as Midjourney
23 subscribers must pay to access the Service. Thus, Midjourney receives revenue from all of
24 its subscribers. By providing more generations and features to subscribers with more
25 expensive plans, Midjourney encourages its subscribers to pay more for its Service.
26 Moreover, Midjourney surpassed $200 million in revenue in 2023, and hit $300 million in
27 revenue in 2024, despite the company’s relatively short existence. Midjourney reportedly
28 had nearly 21 million subscribers as of September 2024. Midjourney’s popularity and
81
COMPLAINT
 1 economic success is directly tied to the popularity of its Service and its ability to reproduce,
2 publicly display, publicly perform, and create derivatives of Warner Bros. Discovery’s
3 Copyrighted Works.
4 176. Midjourney is also secondarily liable for copyright infringement as a
5 contributory infringer (if Midjourney contends that its subscribers are the ones making the
6 infringing copies of Warner Bros. Discovery’s Copyrighted Works identified in this
7 Complaint) because Midjourney knowingly and materially contributes to, encourages, and
8 induces such infringement.
9 177. Midjourney has specific knowledge of, or is willfully blind to, the direct
10 infringement of Warner Bros. Discovery’s Copyrighted Works done through its Service.
11 At a minimum, Midjourney has knowledge of the direct infringement of Warner Bros.
12 Discovery’s Copyrighted Works through its ongoing relationship with its subscribers as
13 Midjourney publicly displays the infringing copies, reproductions, and derivatives
14 generated by its Service for its subscribers on the Midjourney Explore page. Midjourney
15 had actual knowledge of the infringement when it instituted some copyright protection
16 measures on its Service that limited the display and distribution of videos featuring Warner
17 Bros. Discovery’s copyrighted characters. Midjourney also had actual knowledge that its
18 Service infringes Warner Bros. Discovery’s copyrights when news outlets requested its
19 comments on the Marcus and Southen research article exposing and criticizing the
20 infringement. Midjourney also has specific knowledge that Warner Bros. Discovery is
21 being harmed in this District by its infringement of Warner Bros. Discovery’s Copyrighted
22 Works.
23 178. Midjourney specifically designed its Service to encourage, contribute to, and
24 induce the reproduction, public display, public performance, distribution, and preparation
25 of derivative works of copyrighted works. As alleged above, Midjourney intentionally
26 trained its Service to readily produce, display, and publicly perform reproductions and
27 derivatives of Warner Bros. Discovery’s Copyrighted Works. Midjourney would not be
28
82
COMPLAINT
 1 able to create such infringing outputs without its intentional design enabling that
2 infringement.
3 179. Additionally, Midjourney has the means to take simple steps not to materially
4 contribute to the specific infringing activity but fails to do so. Midjourney has failed to
5 take reasonable, readily available, and cost-effective steps to purge its Service of Warner
6 Bros. Discovery’s Copyrighted Works identified in highly publicized articles that it had
7 knowledge of, its own website promotional pages, and by its implementation of some
8 copyright protection measures that limit videos featuring Warner Bros. Discovery’s
9 characters by its video Service. Even more, Midjourney has the right and ability to limit
10 its Service’s ability to copy, reproduce, publicly perform, and prepare derivatives of
11 Warner Bros. Discovery’s Copyrighted Works. Midjourney has failed to implement simple
12 measures, such as copyright protection measures, that would limit its Service’s ability to
13 copy, reproduce, publicly perform, and prepare derivatives of Warner Bros. Discovery’s
14 Copyrighted Works despite the availability of such copyright protection measures and their
15 use by other AI services.
16 180. Instead of taking simple, available steps to not materially contribute,
17 encourage, or induce to the specific infringing activity, Midjourney actively facilitates the
18 ongoing infringement through its actions above. As a direct and proximate result,
19 Midjourney has secondarily infringed Warner Bros. Discovery’s Copyrighted Works.
20 181. Each act of secondary infringement by Midjourney constitutes a separate and
21 distinct act of infringement.
22 182. Midjourney’s acts of secondary infringement are willful, in disregard of and
23 with indifference to Warner Bros. Discovery’s rights.
24 183. Midjourney is purposefully exploiting Warner Bros. Discovery’s valuable
25 intellectual property to attract subscribers to Midjourney, and it is profiting by providing
26 subscribers with endless copies and derivatives of Warner Bros. Discovery’s Copyrighted
27 Works.
28
83
COMPLAINT
 1 184. Midjourney has failed to take reasonable steps to prevent the copyright
2 infringement of its subscribers. As a direct and proximate result of Midjourney’s
3 infringement, Warner Bros. Discovery is entitled to damages and Midjourney’s profits in
4 an amount according to proof.
5 185. Alternatively, and at its election, Warner Bros. Discovery is entitled to
6 statutory damages, up to $150,000 per infringed work by virtue of Midjourney’s willful
7 infringement, or for such other amounts as may be proper under 17 U.S.C. § 504.
8 186. Warner Bros. Discovery is further entitled to recover its attorneys’ fees and
9 full costs pursuant to 17 U.S.C. § 505.
10 187. As a direct and proximate result of the foregoing acts and conduct, Warner
11 Bros. Discovery has sustained and will continue to sustain substantial and irreparable
12 injury, for which there is no adequate remedy at law. Unless enjoined and restrained by
13 this Court, Midjourney will continue to infringe Warner Bros. Discovery’s rights in its
14 Copyrighted Works. Warner Bros. Discovery is entitled to injunctive relief under 17
15 U.S.C. § 502.
16 PRAYER FOR RELIEF
17 WHEREFORE, Warner Bros. Discovery prays for judgment as follows:
18 1. For Warner Bros. Discovery’s damages and Midjourney’s profits in such
19 amount as may be found; alternatively, at Warner Bros. Discovery’s election, for maximum
20 statutory damages, or for such other amounts as may be proper pursuant to 17 U.S.C. §
21 504(c);
22 2. For an accounting, the imposition of a constructive trust, restitution of
23 Midjourney’s unlawful proceeds from copyright infringement, and damages according to
24 proof;
25 3. For preliminary and/or permanent injunctive relief enjoining and restraining
26 Midjourney and all of its officers, agents, servants, and employees and all persons acting
27 in concert or participation with Midjourney, from: (a) infringing Warner Bros. Discovery’s
28 exclusive rights under the Copyright Act by copying, publicly displaying, publicly
84
COMPLAINT
 1 performing, and/or distributing Warner Bros. Discovery’s Copyrighted Works, (b) offering
2 its image Service without appropriate copyright protection measures to prevent such
3 infringement, (c) offering its video Service without appropriate copyright protection
4 measures to prevent such infringement, and (d) otherwise engaging in the copyright
5 infringement conduct described above;
6 4. For prejudgment interest according to law;
7 5. For attorneys’ fees and costs pursuant to 17 U.S.C. § 505; and
8 6. Any further and additional relief the Court may deem just and proper.
9
10 Dated: September 4, 2025 JENNER & BLOCK LLP
11
12 By: /s/ David R. Singer
David R. Singer
13
Julie A. Shepard
14 Lauren M. Greene
15
Attorneys for Plaintiffs
16
17 WARNER BROS. ENTERTAINMENT
INC., DC COMICS, TURNER
18 ENTERTAINMENT CO., HANNA-
19 BARBERA PRODUCTIONS, INC., THE
CARTOON NETWORK, INC.
20
21
22
23
24
25
26
27
28
85
COMPLAINT
 1 DEMAND FOR JURY TRIAL
2 Warner Bros. Discovery hereby demands a jury trial.
3 Dated: September 4, 2025 JENNER & BLOCK LLP
4
5 By: /s/ David R. Singer
6 David R. Singer
Julie A. Shepard
7 Lauren M. Greene
8
Attorneys for Plaintiffs
9
10 WARNER BROS. ENTERTAINMENT
INC., DC COMICS, TURNER
11 ENTERTAINMENT CO., HANNA-
12 BARBERA PRODUCTIONS, INC., THE
CARTOON NETWORK, INC.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
86
COMPLAINT
 Exhibit A
Title of Work Registration Number Copyrighted Copyright Claimant Registration
Characters Date
Include

BATMAN: THE ANIMATED PA0000582970 Batman Warner Bros., a division of 09-09-1992

SERIES “THE CAT AND THE Time Warner Entertainment
CLAW PART I” Company, L.P.*
BATMAN: THE ANIMATED PA0000586437 Batman, The Warner Bros., a division of 09-15-1992
SERIES – JOKER'S FAVOR Joker Time Warner Entertainment
Company, L.P.*
BATMAN: THE ANIMATED PA0000604700 Batman, The Warner Bros., a division of 03-19-1993
SERIES “JOKER’S WILD” Joker Time Warner Entertainment
Company, L.P*
BATMAN: THE ANIMATED PA0000607510 Batman, The Warner Bros., a division of 03-23-1993
SERIES “THE LAUGHING Joker Time Warner Entertainment
FISH” Company, L.P*
BATMAN: THE ANIMATED PA0000711888 Batman Warner Bros., a division of 11-07-1994
SERIES “HOUSE AND Time Warner Entertainment
GARDEN” Company, L.P.*
THE NEW BATMAN PA0000991093 Batman Warner Bros., a division of 06-29-2000
SUPERMAN ADVENTURES Time Warner Entertainment
SHOW #18 & SHOW #86 Company, L.P.*
LIVEWIRE; HOLIDAY
KNIGHTS
THE NEW BATMAN PA0000991070 Batman Warner Bros., a division of 06-29-2000
SUPERMAN ADVENTURES Time Warner Entertainment
SHOW #93 GROWING PAINS; Company, L.P.*
THE HAND OF FATE
THE BATMAN (SERIES) THE PA0001665821 Batman Warner Bros. Entertainment 08-28-2009
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THE BATMAN (SERIES) Supp. Reg. Batman Warner Bros. Entertainment 05-29-2015
BATGIRL BEGINS - PART 1 PA0001397880 Inc. 06-28-2013
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STORY: PT. 1
JUSTICE LEAGUE PA0001695864 Batman, The Warner Bros. Entertainment 08-02-2010
UNLIMITED (SERIES) Flash Inc.
INITIATION
JUSTICE LEAGUE PA0001696133 Batman, The Warner Bros. Entertainment 8/2/2010
UNLIMITED (SERIES) THE Flash Inc.
CAT AND THE CANARY
JUSTICE LEAGUE PA0001695876 Batman, The Warner Bros. Entertainment 08-02-2010
UNLIMITED (SERIES) Flash Inc.
FLASHPOINT
JUSTICE LEAGUE PA0001695888 Batman, The Warner Bros. Entertainment 08-02-2010
UNLIMITED (SERIES) Flash Inc.
DIVIDED WE FALL
JUSTICE LEAGUE PA0001695909 Batman, The Warner Bros. Entertainment 08-02-2010
UNLIMITED (SERIES) Flash Inc.
EPILOGUE
Title of Work Registration Number Copyrighted Copyright Claimant Registration
Characters Date
Include

JUSTICE LEAGUE PA0001855885 Batman, The Warner Bros. Entertainment 06-14-2013

UNLIMITED (ANIMATED Flash Inc.
SERIES) I AM LEGION
JUSTICE LEAGUE PA0001855894 Batman, The Warner Bros. Entertainment 06-14-2013
UNLIMITED (ANIMATED Flash Inc.
SERIES) THE GREAT BRAIN
ROBBERY
JUSTICE LEAGUE (SERIES) PA0001117260 Batman, Warner Bros., a division of 12-10-2002
SECRET ORIGINS Superman, Time Warner Entertainment
Wonder Company, L.P.*
Woman
JUSTICE LEAGUE (SERIES) PA0001117267 Batman, Warner Bros., a division of 12-10-2002
PARDISE LOST – PART I Superman, Time Warner Entertainment
Wonder Company, L.P.*
Woman
JUSTICE LEAGUE (SERIES) PA0001119623 Batman, Warner Bros., a division of 12-10-2002
THE BRAVE AND THE BOLD Superman, Time Warner Entertainment
– PART I Wonder Company, L.P.*
Woman, The
Flash
JUSTICE LEAGUE (SERIES) PA0001119620 Batman, Warner Bros., a division of 12-10-2002
FURY – PART II Superman, Time Warner Entertainment
Wonder Company, L.P.*
Woman
JUSTICE LEAGUE (SERIES) PA0001242809 Batman, Warner Bros. Entertainment 10-7-2004
TWILIGHT Superman, Inc.
Wonder
Woman
JUSTICE LEAGUE PA0001242798 Batman, Warner Bros. Entertainment 10-7-2004
(ANIMATED SERIES) SECRET Superman, Inc.
SOCIETY – PART II Wonder
Woman, The
Flash
STATIC SHOCK (Series) PA0001079581 Batman Warner Bros., a division of 03-26-2002
SHOCK TO THE SYSTEM Time Warner Entertainment
(Pilot) Company, L.P.*
STATIC SHOCK (Series) THE PA0001119555 Batman Warner Bros., a division of 02-20-2003
BIG LEAGUES Time Warner Entertainment
Company, L.P.*
STATIC SHOCK (Series) HARD PA0001246178 Batman Warner Bros. Entertainment 10-07-2004
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STATIC SHOCK (Series) PA0001612918 Batman Warner Bros. Entertainment 05-27-2008
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BATMAN FOREVER PA0000720192 Batman Warner Bros., a division of 06-26-1995
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Company, L.P.*
JUSTICE LEAGUE DOOM PA0001800105 Batman, Warner Bros. Entertainment 07-13-2012
(DTV) Wonder Inc.
Woman
BATMAN BEYOND: RETURN PA0001883120 Batman, The Warner Bros. Entertainment 10-25-2023
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THE DARK KNIGHT PA0001606857 Batman Warner Bros. Entertainment 09-26-2008
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Title of Work Registration Number Copyrighted Copyright Claimant Registration
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DARK KNIGHT, THE VA0001635636 Batman Warner Bros. Entertainment 07-08-2008

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THE BATMAN PA0002338664 Batman Warner Bros. Entertainment 03-03-2022
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BATMAN Volume 42, #336 June TX000772535 Batman DC Comics 09-22-1981
1981
BATMAN: THE DARK TX0007314244 Batman DC Comics 01-24-2011
KNIGHT #1, January 2011
BATMAN #704, January 2011 TX0007267071 Batman DC Comics 12-13-2010
SUPERMAN (SERIES) THE PA0000881352 Superman Warner Bros. A division of 04-21-1998
LAST SON OF KRYPTON – Time Warner Entertainment
PART I Company, L.P. *
SUPERMAN (SERIES) THE PA0000881353 Superman Warner Bros. A division of 04-21-1998
MAIN MAN PART II Time Warner Entertainment
Company, L.P.*
THE NEW BATMAN PA0000991087 Superman Warner Bros. A division of 06-29-2000
SUPERMAN ADVENTURES Time Warner Entertainment
SHOW #14 BLASTS FROM Company, L.P.*
THE PAST PART I
THE NEW BATMAN PA0000991082 Superman Warner Bros. A division of 07-07-2000
SUPERMAN ADVENTURES Time Warner Entertainment
SHOW #24 SOLAR POWER Company, L.P.*
THE NEW BATMAN PA0000991082 Superman Warner Bros. A division of 07-07-2000
SUPERMAN ADVENTURES Time Warner Entertainment
SHOW #42 & SHOW #99 Company, L.P.*
WHERE THERE’S SMOKE;
CRITTERS
SUPERMAN VS. THE ELITE PA0001838078 Superman Warner Bros. Entertainment 03-26-2013
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PA0002332303
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BENEATH
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Title of Work Registration Number Copyrighted Copyright Claimant Registration
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BATMAN V SUPERMAN: PA0001981624 Wonder Warner Bros. Entertainment 03- 30- 2016
DAWN OF JUSTICE Woman, Inc. & Ratpac-Dune
Batman, Entertainment LLC*
Superman
HARLEY QUINN (Season 2) PA0002333078 Wonder Warner Bros. Entertainment 12-08-2021
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Daffy Duck
SPACE JAM PA0000813952 Bugs Bunny, Warner Bros., a division of 11-21-1996
Daffy Duck Time Warner Entertainment
Company, L.P.*
THE SYLVESTER & TWEETY PA0000843825 Tweety Warner Bros., a division of 06-20-1997
MYSTERIES (SERIES) THE Time Warner Entertainment
CAT WHO KNEW TOO MUCH Company, L.P.*
THE SYLVESTER & TWEETY PA0000884581 Tweety Warner Bros., a division of 05-15-1998
MYSTERIES (SERIES) SHOW Time Warner Entertainment
#14: SPACED OUT / Company, L.P.*
AUTUMN’S LEAVING
THE SYLVESTER & TWEETY PA0000969298 Tweety Warner Bros., a division of 02-01-2000
MYSTERIES (SERIES) SHOW Time Warner Entertainment
22: THE STAR OF BOMBAY / Company, L.P.*
HAPPY PRANKSGIVING
THE SYLVESTER & TWEETY PA0001108337 Tweety Warner Bros., a division of 08-07-2002
MYSTERIES (SERIES) SHOW Time Warner Entertainment
35: THE STILTED PERCH / A Company, L.P.*
GAME OF CAT AND
MONSTER!
THE SYLVESTER & TWEETY PA0001106528 Tweety Warner Bros., a division of 08-16-2002
MYSTERIES (SERIES) SHOW Warner Entertainment
48: WHEN HARRY MET Company, L.P.*
SALIERI / THE EARLY WOIM
GETS THE BOID
LOONEY TUNES CARTOONS PA0002427658 Bugs Bunny, Warner Bros. Entertainment 07-14-2023
(ANIMATED SERIES) CURSE Daffy Duck, Inc.
OF THE MONKEYBIRD / Tweety,
MARVIN FLAG GAG: Sylvester
Title of Work Registration Number Copyrighted Copyright Claimant Registration
Characters Date
Include

DEFLATING PLANET / HARM

WRESTLING
LOONEY TUNES CARTOONS PA0002427661 Bugs Bunny Warner Bros. Entertainment 08-29-2023
(ANIMATED SERIES) PAIN IN Inc.
THE ICE/ TUNNEL VISION/
POOL BUNNY
LOONEY TUNES CARTOONS PA0002427664 Bugs Bunny Warner Bros. Entertainment 07-18-2023
(ANIMATED SERIES) Inc.
SIBERIAN SAM/ HOLE GAG:
FISHING POLE/ FLEEXE AND
DESIST/ MARVIN FLAG GAG:
MIRROR/ SPLIT SCREN
MARVIN
LOONEY TUNES CARTOONS PA0002427899 Tweety, Warner Bros. Entertainment 07-19-2023
(ANIMATED SERIES) Sylvester Inc.
DAFFUCCINO / HOLE GAG:
MOVING HOLE / KITTY
LIVIN’
LOONEY TUNES CARTOONS PA0002430732 Bugs Bunny Warner Bros. Entertainment 07-25-2023
(ANIMATED SERIES) RED, Inc.
WHITE AND BRUISED /
BEAKY BUZZARD GAGS:
BUNNY / JET PORKPELLED
LOONEY TUNES CARTOONS PA0002429457 Bugs Bunny, Warner Bros. Entertainment 07-28-2023
(ANIMATED SERIES) SAM- Tweety, Inc.
MERICA / PUT THE CAT OUT Sylvester
– DOOR SPIN / BBQ BANDIT
LOONEY TUNES CARTOONS PA0002430365 Bugs Bunny, Warner Bros. Entertainment 08-01-2023
(ANIMATED SERIES) RING Tweety, Inc.
MASTER DISASTER / PUT Sylvester
THE CAT OUT: EYEBALL /
PAIN EVENT
LOONEY TUNES CARTOONS PA0002430371 Daffy Duck Warner Bros. Entertainment 08-01-2023
(ANIMATED SERIES) BOOBY Inc.
PRIZE / END OF THE LEASH
GAGS: PEA SHOOTER /
BALLOON SALESMAN:
PORKY’S HEAD
LOONEY TUNES CARTOONS PA0002430373 Daffy Duck Warner Bros. Entertainment 08-01-2023
(ANIMATED SERIES) Inc.
FUNERAL FOR A FUDD /
LOVE GOAT
LOONEY TUNES CARTOONS PA0002431929 Bugs Bunny, Warner Bros. Entertainment 08-10-2023
(ANIMATED SERIES) Tweety, Inc.
LOONEY TUNES CARTOONS Sylvester
VALENTINE’S
EXTWAVAGANZA DUCK
CHOCOLATE / DAFFY
TRAFFIC COP STOP: LEAD
FOOT / BUNNY AND THE
BEAST
LOONEY TUNES CARTOONS PA0002431887 Tweety, Warner Bros. Entertainment 08-10-2023
(ANIMATED SERIES) Sylvester Inc.
SKYSCRAPER SCRAP /
BALLOON SALESMAN:
FEELING DOWN / THE DEVIL
AND THE DEEP BLUE SEA
Title of Work Registration Number Copyrighted Copyright Claimant Registration
Characters Date
Include

LOONEY TUNES CARTOONS PA0002431885 Bugs Bunny Warner Bros. Entertainment 08-10-2023
(ANIMATED SERIES) CRUMB Inc.
AND GET IT / BUGS HOLE
GAGS 2: MINI BUGS /
CONSTRUCTION
OBSTRUCCTION
LOONEY TUNES CARTOONS PA0002431881 Daffy Duck Warner Bros. Entertainment 08-10-2023
(ANIMATED SERIES) PAIN Inc.
RENT / NEST EFFORT
LOONEY TUNES CARTOONS PA0002457108 Bugs Bunny, Warner Bros. Entertainment 01-31-2024
(ANIMATED SERIES) Tweety, Inc.
BIRTHDAY GRIFTS / DAFFY Sylvester
MAGICIAN: VINTAGE
PORKYS / TUB-O-WAR
LOONEY TUNES CARTOONS PA0002457120 Bugs Bunny Warner Bros. Entertainment 01-31-2024
(ANIMATED SERIES) Inc.
ABDUCTED BUNNY DAFFY
PSYCHIC: A NEW JOB/ DUCK
HUNTING GAG: DECOY/
DAFFY MAGICIAN:
SKELETON
THE LOONEY TUNES SHOW PA0001885178 Daffy Duck Warner Bros. Entertainment 07-01-2013
(SERIES) BEST FRIENDS Inc.
THE LOONEY TUNES SHOW PA0001893450 Bugs Bunny Warner Bros. Entertainment 02-27-2014
(ANIMATED SERIES) Inc.
BOBCATS ON THREE!
LOONEY TUNES RABBITS PA0002019682 Bugs Bunny Warner Bros. Entertainment 09-16-2015
RUN (Direct To Video) Inc.
TINY TOONS LOONIVERSITY PA0002465232 Bugs Bunny, Warner Bros. Entertainment 03-28-2024
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ORIENTOONTION
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THE POWERPUFF GIRLS: PA0000972590 The The Cartoon Network LP, 02-28-2000
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THE POWERPUFF GIRLS: PA0010018156 The The Cartoon Network LP, 11-2-2000
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THE POWERPUFF GIRLS: PA0001217087 The The Cartoon Network LP, 03-09-2004
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THE POWERPUFF GIRLS: PA0001217095 The The Cartoon Network LP, 03-09-2004
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Bubble,
Buttercup)
THE POWERPUFF GIRLS: PA0001294787 The The Cartoon Network LP, 03-30-2004
LYING AROUND THE HOUSE Powerpuff LLLP*****
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Bubble,
Buttercup)
THE POWERPUFF GIRLS: PA0001294788 The The Cartoon Network LP, 03-30-2004
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Buttercup)
THE POWERPUFF GIRLS: PA0001227994 The The Cartoon Network LP, 06-11-2004
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THE POWERPUFF GIRLS PA0001991610 The The Cartoon Network, Inc. 06-15-2016
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SERVICE Girls
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* Warner Bros. Entertainment Inc., through assignments and/or corporate transactions and name changes, owns all
copyrights registered in the names of the following companies: Warner Bros. Inc., Warner Bros. Pictures, Inc.; United
Artists Television, Inc.; The Vitaphone Corp.; Warner Bros., a division of Time Warner Entertainment Company, L.P.;
Patalex III Productions Limited; and Ratpac-Dune Entertainment LLC.

** DC Comics, through assignments and/or corporate transactions and name changes, owns all copyrights registered in
the names of the following companies: Detective Comics, Inc.; National Periodical Publications, Inc.; National Comics
Publications, Inc.; DC Comics, Inc.; All-American Comics, Inc.; and Superman, Inc.

*** Turner Entertainment Co., through a series of corporate transactions, owns the copyrights in the works in this Exhibit
registered under Metro-Goldwyn-Mayer Inc.

**** On July 31, 2015, Hanna-Barbera Cartoons Inc. merged into Hanna-Barbera Productions, Inc., which now owns the
copyrights to all works in this Exhibit registered under both names.

***** On December 21, 2006, the entity known at the time as The Cartoon Network LP, LLLP changed its name to The
Cartoon Network, Inc.