The complaint

Blue Brain Productions LLC v. Paul Sinacore Casting LLC, No. 8:26-cv-02516 (C.D. Cal.), is a 24-page original complaint filed September 2, 2026, ECF No. 1, with a jury demand. The caption names the defendant as Paul Sinacore Casting LLC d/b/a FIVE-TOOL PLAYER. The complaint pleads diversity jurisdiction under 28 U.S.C. § 1332(a) and supplemental jurisdiction over state-law claims under 28 U.S.C. § 1367(a), and it states that the action partially arises under the Copyright Act, 17 U.S.C. §§ 101 et seq., and the Lanham Act, 15 U.S.C. §§ 1051 et seq. It alleges personal jurisdiction and venue on the ground that the defendant was formed in, does business in, and is at home in California, and it also states that the plaintiff disputes that the Central District of California is the only venue or a proper venue.

The parties

The complaint describes Blue Brain Productions LLC as a Texas limited liability company. It alleges, on information and belief, that Paul Sinacore Casting LLC does business as FIVE-TOOL PLAYER and is a limited liability company formed under the laws of California.

The work

The complaint alleges that the case concerns copyright ownership of a motion picture project and associated screenplay with the working title "Towpath," an audiovisual derivative work, and the rights in each. It alleges that the project began under the working title "Dovey's Promise," a screenplay about Dovey Roundtree, and that the working title later became "Towpath." It alleges that principal photography took place from May 5 to May 14, 2024, in Blanco County and Bexar County, Texas.

The complaint alleges that on November 10, 2025, Blue Brain Productions obtained a copyright registration for the production, direction, cinematography, and editing of footage for the project known as Towpath, Reg. No. PAu 4-291-793, covering cinematographic material and production as a motion picture. The Copyright Office public record lists PAu004291793, "Towpath Footage.," a motion picture, unpublished, registered November 10, 2025, with a creation year of 2025, Blue Brain Productions, LLC as claimant and as author, and an authorship statement of production, direction, cinematography, and editing, as a work made for hire. The record lists the script or screenplay as material excluded.

What it alleges

The complaint alleges that on April 6, 2024, crew-member deal memos for the project, then identified as "Dovey's Promise," assigned the proceeds of the contracted services to Blue Brain Productions, stated that the producer is the sole author and owner of the proceeds, and provided that the agreements are to be interpreted under Texas law, with exclusive jurisdiction in the courts located in San Antonio, Texas. It says two of the memos are with Five-Tool Player and three indicate that Five-Tool Player LLC is the contracting party. The complaint alleges, on information and belief, that Five-Tool Player LLC does not exist and that the defendant does regular business under the name FIVE-TOOL PLAYER.

It alleges that Blue Brain Productions authorized and paid for a trailer using the registered footage, and that the authorized trailer credits Blue Brain Productions first, within the first two seconds, and also credits the defendant. It alleges, on information and belief, that the defendant owns and operates pages titled Towpath on IMDb, The Movie Database, and Letterboxd and a YouTube page titled Five-Tool Player, that it can post to the IMDb, The Movie Database, and YouTube pages, and that it edited, or commissioned the editing of, a trailer without authorization (the Edited Trailer). It alleges that the Edited Trailer removes the first two seconds and any reference to Blue Brain Productions, that the IMDb page hosts that trailer and The Movie Database page links to it, and that the defendant uploaded the Edited Trailer to the YouTube page on or about October 12, 2024. It alleges that the pages identify the defendant or an individual associated with the defendant as the producer, production company, or studio, without mentioning Blue Brain Productions, and that the YouTube description of the trailer includes a 2025 copyright notice in an individual's name rather than Blue Brain Productions.

The complaint also alleges, on information and belief, that the defendant copied and distributed raw footage to a third-party editor without authorization, oversaw that editing, and accepted an assignment of the editor's work under a side agreement that Blue Brain Productions was not aware of and that, the complaint says, conflicts with the deal memos. It cites a related action in the same court, No. 2:25-cv-03251.

Counts and relief

Count I pleads copyright infringement under 17 U.S.C. § 501 et seq., alleging that posting and distributing the Edited Trailer through the movie-database websites was an unauthorized distribution, copying, and public performance of the registered footage, and that the defendant's unauthorized distribution, reproduction, preparation of derivative works, and public performance each constitute separate infringements. Count II pleads vicarious copyright infringement, alleging that the defendant had the right and ability to supervise the infringement and a direct financial interest in exploiting the Edited Trailer. Count III pleads contributory copyright infringement. Each of those counts alleges that the acts were willful and seeks maximum statutory damages under 17 U.S.C. § 504(c) or, at the plaintiff's election, actual damages plus the defendant's profits under 17 U.S.C. § 504(b), and costs and attorney's fees under 17 U.S.C. § 505.

Count IV pleads breach of contract, alleging that the defendant breached deal memos, including a section stating that the crew member irrevocably assigns all rights in the proceeds to the producer and that the producer is the sole author and owner of the proceeds, by later claiming ownership, releasing footage assigned to the plaintiff, and signing a side agreement that conflicts with those obligations. The plaintiff seeks relief under Texas Civil Practice and Remedies Code § 38.001, including damages, restitution, consequential damages, unpaid royalties, pre- and post-judgment interest, and attorney's fees.

Count V pleads false designation of origin under 15 U.S.C. § 1125(a), alleging reverse passing-off, including that the defendant is listed as the sole production company or studio on the IMDb, YouTube, The Movie Database, and Letterboxd pages and in the Edited Trailer, and that the defendant applied its name to footage the plaintiff owns. Count VI pleads slander of title in the copyright, alleging that the defendant falsely represented that it had authority to continue production and to post trailers, and that the plaintiff suffered a pecuniary loss. Count VII pleads violations of the Digital Millennium Copyright Act, 17 U.S.C. § 1202(b)(1) et seq., and also cites 17 U.S.C. § 1202(a) and (b), alleging distribution of the Edited Trailer with false or incomplete copyright management information and intentional removal of Blue Brain Productions' credit. It seeks separate statutory damages for each violation, attorney's fees, and other damages.

The prayer asks for injunctions against promoting Towpath in any capacity and against submitting Towpath for any awards or certificates; an order preserving or disclosing social-media and internet posts about Towpath or Dovey's Promise that the defendant controls or that are made on its behalf; an order that the defendant, and anyone acting in concert with it, remove all posts mentioning Towpath or Dovey's Promise from social-media accounts and the internet under their possession, custody, and control; an order that the defendant disclose the identity and location of any third parties it has authorized to edit, possess, or control footage or documents related to those titles; a declaratory judgment that the defendant's copyright registration is invalid and ineligible for federal copyright protection; a declaratory judgment that the defendant committed fraud on the Copyright Office in prosecuting the application for that registration; that the court seek the advice of the Register of Copyrights on whether the inaccurate information, if known, would have caused the Register to refuse registration; and costs and attorney's fees under 17 U.S.C. §§ 101, 505, and 1202, 15 U.S.C. § 1117, and Texas Civil Practice and Remedies Code § 38.001 et seq., plus fees relating to a tort-of-another theory. The complaint also seeks declaratory and injunctive relief under 28 U.S.C. § 2202, including an injunction against further representations of ownership of the copyright in the project's screenplay and audiovisual works, and it demands a jury trial.