izmo Digital sues TintZoom over alleged use of at least 35 registered auto photographs

The complaint

izmo Digital, Inc. v. TintZoom, LLC, No. 4:26-cv-09563 (S.D. Tex., Houston Division), was filed October 29, 2026 (11 pages, with Exhibits A and B). The plaintiff is izmo Digital, Inc., a Delaware corporation with its principal place of business in San Francisco, California. The defendant is TintZoom, LLC, which the complaint describes as organized under Florida law with a place of business in Oviedo, Florida. The complaint demands a jury trial. (Compl. caption; paras. 1 to 2; jury demand.)

The works

The complaint alleges izmo creates photographic images of automobiles and accessories, registers those images with the U.S. Copyright Office, and licenses them. It identifies 35 images in a table of image names and U.S. copyright registration numbers (including, for example, VA0002148062 and VA0002234266), alleges each is a separate work, and points to Exhibit B for the 35 images. It alleges that izmo owns the images under a written assignment and that every registration predates November 2023. The Copyright Office public records for VA0002148062 and VA0002234266 show group registrations of published photographs with izmo, Inc. as claimant. (Compl. paras. 14 to 17, 23, 26 to 27, 32 to 33.)

What the complaint alleges

The complaint alleges, on information and belief, that TintZoom sells tint kits, paint-protection kits, and related automotive products in Texas, and alleges that it sells through tintzoom.com and keeps in contact with customers through social media such as Facebook. It alleges TintZoom displayed izmo's photographs on its website to promote those products without a license, that izmo discovered the use in or around November 2023, and that TintZoom knew the images belonged to izmo and were available only under license at least as early as January 31, 2024 but never took a license. It alleges, on information and belief, that TintZoom used additional images and that the infringement was willful, intentional, and/or reckless. (Compl. paras. 3 to 10, 18 to 22, 25, 28, 34.)

The relief sought

The single count alleges infringement of izmo's rights under 17 U.S.C. 106(1), (2), and (5) in violation of 17 U.S.C. 501. izmo seeks, at its election, actual damages and profits or statutory damages under 17 U.S.C. 504, including for willful infringement; an accounting; a permanent injunction under 17 U.S.C. 502; attorney fees and costs under 17 U.S.C. 505; and pre- and post-judgment interest. (Compl. paras. 29 to 39; prayer.)

The docket

On October 30, 2026, the clerk issued a notice regarding consent to a magistrate judge, the court entered its form order for an initial conference, and the docket records that the Register of Copyrights was notified. (Docket entries 5 to 7.)