The complaint

Colette Miller v. Wingstop, Inc., No. 2:26-cv-11153 (C.D. Cal.), was filed September 25, 2026 (19 pages). Miller is an artist based in Los Angeles who, the complaint says, began the Global Angel Wings Project in 2012, painting human-scale feathered angel wings on public walls for people to stand in front of and be photographed. Wingstop is a Delaware corporation headquartered in Dallas, Texas. Miller demands a jury trial. (Compl. caption; paras. 4, 15 to 16, 22 to 28.)

The work

The complaint alleges Miller owns the copyright in her mural Melrose Wings, registered as VA 2-169-006 on July 10, 2019. The Copyright Office public record for VA 2-169-006 lists the title Melrose Wings, author and claimant Colette Miller, and a registration date of July 10, 2019. (Compl. para. 31; Ex. B cited; Copyright Office record.)

What it alleges

The complaint alleges that on or before July 1, 2026 Wingstop commissioned mural artists to create at least five murals installed around Los Angeles for a campaign titled Flavor Wings, and that the murals imitate Melrose Wings and a prior advertising campaign Miller licensed. It alleges that Wingstop also placed sidewalk advertisements with QR codes next to Melrose Wings and next to the licensed mural, with the phrases "THOSE WINGS NEED RANCH" and "NICE WINGS WANT FIVE MORE?", and that the advertisements implied Miller sponsored or endorsed Wingstop. It alleges Miller received messages from members of the public who assumed she had taken part, and that the murals and the first sidewalk advertisement remained in place when she filed. (Compl. paras. 5 to 7, 33 to 41, 57 to 58, 88.)

The counts and relief

Count I pleads direct copyright infringement, Count II unfair competition and false endorsement under section 43(a) of the Lanham Act, Count III vicarious copyright infringement, Count IV contributory copyright infringement, and Count V trade dress infringement under 15 U.S.C. 1125. The complaint alleges, upon information and belief, that the copyright infringement was willful. It describes the claimed trade dress as feathered angel wings painted as a mural in human proportion in public spaces, in vivid colors with a white highlight. The prayer asks for a declaration of copyright infringement, a permanent injunction against further display of the murals and the sidewalk advertisements, and damages and profits, and the complaint also seeks Lanham Act relief under 15 U.S.C. 1116 and 1117. (Compl. paras. 13 to 14, 44 to 109; Prayer.)

On the docket

The docket shows a waiver of service executed for Wingstop. (Docket, ECF No. 11.)