The complaint
Zachary Hiller v. Tone Body, Inc., No. 2:26-cv-14250 (E.D. Mich., Southern Division), was filed November 6, 2026, as Document 1 (15 pages; complaint dated November 3, 2026). The plaintiff is Zachary Hiller, an individual residing in Nassau County, New York, described as founder of an independent music publishing and rights company and as legal owner of the copyright in the Recording. The named defendant is Tone Body, Inc., a California corporation with its principal place of business in Santa Monica, California, alleged to market personal care products under the TONE brand through the stores of a national retail chain, Amazon, and its own website, tone.shop, together with Does 1 through 10. The docket record lists Judge Matthew F. Leitman as the assigned judge. The complaint demands a jury trial. The docket through November 6, 2026, shows the complaint and a notice to parties of the consent-to-magistrate option.
The work
Hiller alleges ownership of the sound recording Take it Off "Lights Off" Beat (the Recording), first published August 1, 2025, acquired by written agreement dated April 6, 2026, and registered as U.S. Copyright Registration No. SR 1-075-539 with an effective date of April 14, 2026. The Copyright Office public record lists Zac Hiller as claimant by written agreement, title Take it Off "Lights Off" Beat, a sound recording created in 2025, first published August 1, 2025, and registration date April 14, 2026. He alleges he licenses the Recording for commercial advertising uses.
What it alleges
The complaint alleges that on June 25, 2026, a sponsored TikTok video promoting TONE Island Breeze was published with the Recording as its audio, bearing a paid-partnership disclosure, tagging Tone's brand account, carrying the hashtag #TONEpartner, and directing viewers to buy Island Breeze at that retail chain. It alleges Tone's TikTok account commented on and reposted the video the same day, that the audio came from a user-uploaded TikTok sound rather than TikTok's Commercial Music Library, and that no defendant obtained a license. The complaint states that its allegations about Hiller and his own acts are made on personal knowledge and that all other allegations are made on information and belief. Hiller says he sent written notice on August 27, 2026, to Tone's designated copyright-agent address and to others, that the advertisement was later removed, and that the infringement was willful.
The counts and relief
Count I alleges direct copyright infringement under 17 U.S.C. §§ 106 and 501 against Tone and the Doe defendants. Count II alleges contributory copyright infringement. Count III alleges vicarious copyright infringement. The prayer seeks a declaration of willful infringement; actual damages and profits under 17 U.S.C. § 504(b) or statutory damages under 17 U.S.C. § 504(c), including enhanced damages for willfulness; a permanent injunction under 17 U.S.C. § 502; costs and attorneys' fees under 17 U.S.C. § 505; prejudgment and post-judgment interest; and further relief.