The complaint
Image Professionals GmbH d/b/a StockFood v. Universal Seafood, Inc., No. 2:26-cv-11127 (C.D. Cal.), is a 9-page complaint filed September 25, 2026, ECF No. 1, with Exhibit A, a spreadsheet identifying the work, its registration number, and screenshots of the alleged use, and Exhibit B, the registration certificate. The exhibits are not available. Image Professionals is a German company based in Munich. Universal Seafood is a California corporation based in North Hollywood. The complaint pleads jurisdiction under 28 U.S.C. §§ 1331 and 1338(a) and venue under 28 U.S.C. § 1400(a).
The work
The work is a professional photograph of two red mullet fish titled 00855336, created by one of StockFood's contributor photographers. The complaint alleges that Image Professionals' then wholly owned U.S. subsidiary registered the work, and that the subsidiary transferred its copyrights and registrations to Image Professionals in November 2020. It alleges that written agreements with the photographer give Image Professionals exclusive reproduction and distribution rights and the right to sue.
What the complaint alleges
The complaint alleges that Universal Seafood runs a seafood wholesale business and markets it through its website and social media, and that on August 30, 2017, after the registration, it displayed the photograph on its website, webpage, social media, and/or printed media to advertise its business. It alleges, upon information and belief, that Universal Seafood copied the photograph from the internet instead of licensing it. It says StockFood found the use in November 2024 and notified Universal Seafood in writing.
The count and relief
Count I alleges willful copyright infringement under 17 U.S.C. § 501, on direct, vicarious, and/or contributory theories. Image Professionals seeks declarations of infringement and willfulness; actual damages and profits or, at its election, statutory damages under 17 U.S.C. § 504(c); costs and attorneys' fees under § 505; interest; and a permanent injunction under § 502.