The complaint

Claire Esparros v. Parts N Supply, LLC, No. 2:26-cv-14595 (D.N.J.), is a 10-page complaint filed November 11, 2026, ECF No. 1, with a jury demand. The complaint describes Esparros as a professional photographer residing in Brooklyn, New York, who specializes in architectural photography. It alleges, upon information and belief, that Parts N Supply, LLC is a New Jersey limited liability company doing business in Jersey City, New Jersey, and describes it as a specialized home improvement contractor offering design consulting, remodeling, contracting, and sourcing services. It pleads jurisdiction under 28 U.S.C. §§ 1331 and 1338(a) and venue under 28 U.S.C. § 1391. The case is assigned to Judge Michael E. Farbiarz and Magistrate Judge Leda D. Wettre. (Compl. paras. 2 to 7, 12; docket entry of Nov. 11, 2026.)

The work

The complaint alleges that Esparros is the sole author and owner of the photograph at issue, which it depicts, and that it has been registered with the Copyright Office as Reg. No. VA 2-417-549 since September 2, 2024. In its first claim it also describes Esparros as an exclusive licensee with sufficient rights to bring suit. The Copyright Office public record for VA 2-417-549 shows a group registration titled "Claire Esparros Imagery - 2018" of 257 published photographs, registered September 2, 2024, with Claire Esparros as author and claimant and a publication date of October 31, 2018. (Compl. paras. 8 to 11, 22.)

What the complaint alleges

The complaint alleges Esparros found the photograph reproduced, distributed, used in a derivative work, and publicly displayed on Parts N Supply's website without authorization, and it shows screenshots. It alleges, upon information and belief, that Parts N Supply or someone acting for it found the photograph online, downloaded it, and used it in creating the website to sell its services, and that Parts N Supply had access through Esparros's licensing and public display of the photograph. It alleges the infringement was willful and, upon information and belief, deliberate. (Compl. paras. 13 to 19, 23, 25.)

The counts and relief

The first claim alleges direct copyright infringement under 17 U.S.C. § 501. The second claim alleges contributory copyright infringement, pleaded in the event Parts N Supply contends another entity did the infringing, and alleges that it materially contributed by providing the technology necessary for the infringement. The third claim alleges vicarious copyright infringement as an alternative theory, alleging that Parts N Supply had the right or ability to control the infringement and a financial interest in it. Each claim alleges that Esparros is entitled to actual damages and, at her election, profits under 17 U.S.C. § 504(b) or, in the alternative, maximum statutory damages of $150,000 under § 504(c) or such other amounts as may be proper (the first claim adds "to the extent allowed by 17 U.S.C. § 412"), and to a permanent injunction under § 502. The prayer asks for declarations of infringement and willfulness; an accounting; profits or statutory damages, including up to $150,000 for each instance of willful infringement; exemplary and punitive damages; costs and attorneys' fees under 17 U.S.C. § 505; interest, including pre-judgment interest; a permanent injunction; and other relief. (Compl. paras. 1, 20 to 47; prayer.)