The complaint

The Everything Editions LLC d/b/a The Dog Book v. Remus Collection, Inc.; Ryan Rouche; Neil Azouz; Lancelot Morin; and John Doe 1, No. 1:26-cv-27881 (S.D. Fla., Miami Division), is a 25-page Complaint for Damages and Injunctive Relief entered on the docket November 5, 2026, ECF No. 1, with a jury demand. The plaintiff is a Florida limited liability company based in Miami-Dade County that sells photographic coffee table books about dog breeds as The Dog Book. The complaint describes Remus Collection, Inc. as a Delaware corporation based in Miami that sells dog and cat breed coffee table books, and Rouche, Azouz, and Morin as its founders or principals. It describes John Doe 1 as an individual who sells social media account takedowns for a fee.

What it alleges

The complaint alleges that after Remus accused The Dog Book of infringing its intellectual property in August 2026, Instagram posts in September 2026 urged followers to report The Dog Book's accounts, and Instagram suspended its account on September 7, 2026. It alleges that on September 8, 2026, Remus's counsel wrote that Remus would stop publishing such posts or soliciting reports, and that The Dog Book relied on that agreement and did not sue. It alleges that on October 8 and 9, 2026, six notices of claimed copyright infringement were submitted to Meta against The Dog Book's Instagram posts and reels, each naming "The dog book" as rights owner and claiming the complainant was the original creator, and that Meta removed the content. It alleges the content was The Dog Book's own and bore its copyright notice, and that the person who filed the notices later told The Dog Book he was being paid to have its pages banned and identified the individual defendants as the persons paying him and Remus as his regular clients. It alleges continuing account suspensions, loss of its Instagram handle, and platform warnings shown to prospective customers.

Counts and relief

Count I pleads misrepresentation in notifications of claimed infringement under 17 U.S.C. § 512(f), against all defendants. Count II pleads false advertising and commercial disparagement under 15 U.S.C. § 1125(a)(1)(B), against all defendants. Count III pleads breach of contract against Remus Collection, Inc. Count IV pleads tortious interference with contractual and advantageous business relationships, Count V pleads defamation per se, Count VI pleads violation of the Florida Deceptive and Unfair Trade Practices Act, and Count VII pleads civil conspiracy, each against all defendants. The prayer asks for compensatory damages it says exceed $600,000; damages, costs, and fees under 17 U.S.C. § 512(f); profits, enhanced damages, costs, and fees under 15 U.S.C. § 1117(a); presumed damages on the defamation claim; fees and costs under § 501.2105, Fla. Stat.; punitive damages; a permanent injunction against submitting or procuring reports or notices about its accounts and against certain statements; an order to withdraw the six notices; transfer of its former Instagram handle; interest; and other relief.

On the docket

On November 6, 2026, the docket shows the AO 120/121 report form, summonses issued, and the clerk's notice of judge assignment and optional consent.