What was filed
The complaint is Document 1 in No. 2:26-cv-11880, U.S. District Court for the Central District of California, filed October 12, 2026 (11 pages, with Exhibits A and B). The plaintiffs are Jill Greenberg, a photographer, and Jill Greenberg Studio, Inc., the New York corporation through which she licenses her work, both based in Tivoli, New York. The defendants are Narrative PR, described as an entertainment public relations firm of unknown business form with an office in Sherman Oaks, California, and Does 1 through 50. The plaintiffs demand a jury trial. The same plaintiffs filed a separate complaint the same day over the same photograph, No. 2:26-cv-11882.
The photograph and the license
The complaint alleges that Greenberg photographed Kinnear on October 24, 2018, in a shoot arranged by an online magazine for an editorial series, and that the photograph at issue is registered as part of a group registration of published photographs, Registration No. VA 2-127-693, effective November 15, 2018. The Copyright Office public record for VA0002127693 shows a November 15, 2018 registration of 713 published photographs, lists Jill Greenberg Studio, Inc., employer for hire of Jill Greenberg, as author and Jill Greenberg as claimant, and includes the file name the complaint gives for the photograph.
According to the complaint, in February 2019 Narrative PR, then Kinnear's publicist, asked for an unwatermarked, high-resolution copy so that Kinnear could have a few prints made for charity, stating the request was not for online use. The studio delivered the retouched file on February 27, 2019, with an invoice granting "One year editorial and PR usage only" and excluding advertising and third-party use. The complaint alleges the license expired on or about February 26, 2020, was never renewed, was the only license ever granted for the photograph, and that Narrative PR is the only party ever given an unwatermarked copy.
What the complaint alleges
The complaint alleges that the photograph has since appeared without authorization on several websites, including a radio station site whose operator pointed to a news audio service as its source, and, on information and belief, in other uses by persons to be identified in discovery. It alleges that when Greenberg contacted Narrative PR in June 2026, the firm replied that it had not used the image and would alert its team, but gave no accounting of the file, and that Narrative PR did not respond to an August 11, 2026 demand letter seeking a list of recipients and confirmation that use had stopped.
Count I, against Narrative PR only, alleges, on information and belief, that Narrative PR retained, reproduced, distributed, or made the photograph available after the license expired, infringing the reproduction and distribution rights under 17 U.S.C. § 106, and alleges willfulness. Count II alleges contributory infringement against Narrative PR and the Doe defendants, based on alleged direct infringement by the radio station website operator and the Doe defendants. The prayer seeks a preliminary and permanent injunction, an order requiring Narrative PR to identify everyone it gave the photograph to and notify them to stop using it, impoundment under 17 U.S.C. § 503, actual damages and profits under 17 U.S.C. § 504(b) or statutory damages of up to $150,000 per work under 17 U.S.C. § 504(c), attorneys' fees, costs, and expert witness fees under 17 U.S.C. § 505, and prejudgment and postjudgment interest.