What was filed
The complaint is Document 1 in No. 1:26-cv-02898, U.S. District Court for the Western District of Michigan, Southern Division, filed October 9, 2026. It runs 8 pages. Counsel for the plaintiff are Couzens, Lansky, Fealk, Ellis, Roeder & Lazar, P.C. and The Sladkus Law Group. The plaintiff demands a jury trial. (Compl. pp. 1, 8.)
The plaintiff is Foresite Design, Inc., a Southfield, Michigan landscape architecture firm that the complaint says focuses on athletic and recreational facilities. The defendant is VK Endeavours LLC, a Michigan limited liability company with a registered office in Byron Center, Michigan. (Compl. paras. 5 to 7.)
What the complaint alleges
It alleges some of Foresite's text design specifications are registered as TXu 2-557-477 and that, when used in a project manual, each carries a FORESITE DESIGN, INC. header or footer. It alleges Foresite learned around April 2026 that registered specs appeared in the Hopkins Public Schools Stadium Track Replacement project manual, and that they also appear in a Hemlock Public Schools project manual, both created at least in part by VK on information and belief. It alleges the Hopkins copies bear the notice "© 2026 Tower Pinkster Titus Associates" and the Hemlock copies bear 2022 and 2023 notices naming the same firm. Tower Pinkster Titus Associates is not a defendant. (Compl. paras. 11 to 24.)
Counts and relief
Count I alleges willful copyright infringement under the Copyright Act, citing 17 U.S.C. 504(c)(2) for willfulness, in the Hopkins manual and seeks damages and profits, or statutory damages of $750 to $150,000 per work under 17 U.S.C. 504(c), an injunction under 17 U.S.C. 502, and fees under 17 U.S.C. 505. Count II alleges removal or alteration of copyright management information under 17 U.S.C. 1202 and seeks damages or statutory damages of $2,500 to $25,000 per violation and relief under 17 U.S.C. 1203(b). No damages total is stated. (Compl. paras. 27 to 47; pp. 7 to 8.)