Melanie Born and EDA Public Relations sue Group Voyagers, alleging continued use of her marketing copy for the Globus family of brands after their PR engagement ended

What was filed

The complaint is Document 1 in Born v. Group Voyagers, Inc., No. 8:26-cv-03042, U.S. District Court for the Central District of California, filed and dated October 15, 2026 (21 pages). The plaintiffs are Melanie Born, who the complaint says lived in Orange County, California at relevant times and now resides in Tennessee, and EDA Public Relations, Inc., a California corporation with its principal place of business in Ladera Ranch, California. The defendants are Group Voyagers, Inc., which the complaint alleges, upon information and belief, is a New York corporation, and which the plaintiffs are informed and believe does business as the Globus family of brands, including Globus, Cosmos, and Avalon Waterways, and manages their sales, operations, and marketing in the United States; and Does 1 to 10. Counsel for the plaintiffs is Stephen Z. Vegh of Vegh IP Legal, Manhattan Beach, California. Jurisdiction is pleaded under 28 U.S.C. 1331, 1338, and 1332, and venue under 28 U.S.C. 1391 and 1400(a). The plaintiffs demand a jury trial. The 55 exhibits attached to the complaint, including the agreements, the works, the registration certificates, and copies of the accused uses, are not publicly available. (Compl. paras. 1 to 7; pp. 1, 21; Dkt. 1.)

The engagement and how it ended

According to the complaint, EDA provided public relations and communications services to Group Voyagers under a series of independent contractor agreements from January 1, 2008 through an October 8, 2025 Agency Services Agreement with a 24-month term, and none of those agreements made the relationship a work for hire, assigned intellectual property to Group Voyagers, listed detailed deliverables, or gave it an unrestricted right to use the works. It alleges that Born was the sole author of what it calls the MB Creative Works, which it says number in the hundreds and include messaging architecture and playbooks, campaign systems, website copy, email content, social media, video scripts, taglines, and sub-brand expressions for the Globus family of brands, and that Group Voyagers' right to use them was conditioned on the ongoing services relationship. The complaint says that before July 14, 2026 Group Voyagers used some of the works under circumstances it may contend gave rise to a limited implied license, but alleges that no unrestricted or perpetual license was granted. (Compl. paras. 11 to 16, 18.)

The complaint alleges that in May 2026 Group Voyagers proposed a new agreement that, for the first time, sought a retroactive assignment of the works, and that its corporate counsel told Born the assignment was needed because the company recognized it did not own or have unlimited rights to the works. It alleges that on July 14, 2026 the plaintiffs declined the assignment and offered interim use only while the parties negotiated a license or purchase, conditioned on assurances of good-faith negotiation; that Group Voyagers neither agreed nor gave the assurances; and that the same day it terminated EDA's services. According to the complaint, the plaintiffs wrote again on September 1, 2026, stating that any implied authorization had ended on July 14 and identifying five registrations, and on October 8, 2026 demanded that all use stop. It alleges the use has continued. (Compl. paras. 17 to 24.)

The works and registrations

The claim identifies 22 works, each described as a literary work. Five are pleaded as registered: Touring Messaging Playbook (TXu 2-560-799), River Cruising Messaging Playbook (TXu 2-560-800), and Globus Choice Excursions (TX 2-560-801), each effective June 25, 2026, and Cruising Elevated Website Landing Pages (TXu 2-561-182) and Touring Website Landing Page (TXu 2-561-179), each effective July 7, 2026. Nine more works are the subject of applications the complaint says were filed between June 25 and July 7, 2026 and are pending, and eight are identified without a registration or application number. (Compl. paras. 22, 26 to 62.)

The alleged uses

The complaint alleges that after July 14, 2026 Group Voyagers used content from the works in paid Meta ads, marketing emails, Instagram and other social media posts, website and landing pages for the United States, Canada, the United Kingdom, Australia, and New Zealand, the Avalon Waterways website, videos on its YouTube channels, and ad copy in a travel trade publication, on dates it lists from July 18 through October 9, 2026. It alleges that one paid ad was run by an outside travel agency, which it says indicates that a playbook was shared with an agency partner. For several works, it alleges use on information and belief and says the evidence is in the defendants' possession; for three of those it seeks, at minimum, a permanent injunction. (Compl. paras. 28 to 63.)

Claim and relief

The single claim alleges copyright infringement under 17 U.S.C. 501, and alleges that the infringement was knowing and intentional or, alternatively, in reckless disregard of or willful blindness to the plaintiffs' rights, and willful. For works that satisfy 17 U.S.C. 412, it seeks statutory damages under 17 U.S.C. 504(c), including enhanced damages under 504(c)(2). (Compl. paras. 25 to 71.)

The prayer asks for judgment on all causes of action; a determination of infringement under 17 U.S.C. 501; preliminary and permanent injunctive relief under 17 U.S.C. 502 against reproducing, distributing, publicly displaying, preparing derivative works based on, licensing to third parties, or otherwise using the works, including to market and sell the defendants' travel and tourism services; an immediate preliminary order to preserve evidence; a permanent order for impounding, destruction, and disposition of infringing literature, playbooks, guides, emails, landing pages, marketing, advertising, and other materials; a sworn compliance report within 30 days after service of the injunction; actual, incidental, consequential, and special damages according to proof; an accounting and disgorgement of gains, profits, and advantages; a reasonable royalty; a determination of willfulness; statutory damages under 17 U.S.C. 504(c), including enhanced statutory damages of up to $150,000 for each eligible work infringed willfully, as permitted by 17 U.S.C. 504(c)(2) and 412, at the plaintiffs' election; unjust enrichment and restitution damages according to proof; reputational damage; costs, expenses, and reasonable attorney's fees under 17 U.S.C. 505; prejudgment interest at the maximum legal rate; post-judgment interest; and other relief. (Compl. pp. 19 to 20.)

The public docket, as last updated on October 19, 2026, shows the complaint and its exhibits, a civil cover sheet, a request for a summons, a certificate of interested parties, and a report on the filing of a copyright action, all filed October 15, 2026. Watch for issuance and service of the summons and for Group Voyagers' response.