The notice of removal

On November 12, 2026, Warner Bros. Entertainment Inc. filed a notice of removal under 28 U.S.C. § 1446 in the Southern District of New York, No. 1:26-cv-09939, ECF No. 1. The notice states that Ronald Jones and Regina Jones filed a complaint on October 5, 2026, in the New York State Supreme Court, County of New York, Index No. 101007/2026, asserting copyright infringement claims against Warner Bros. Entertainment Inc., David Falk Legal Team, and The SpringHill Co./Lebron James. Warner Bros. removed the action to the district covering the county in which the state case was pending.

The notice states that removal is required under 28 U.S.C. § 1338(a) because the action includes claims arising under the Copyright Act of 1976, 17 U.S.C. § 101 et seq., that the district court would have had original and exclusive jurisdiction over those claims under 28 U.S.C. § 1331, and that it would have had supplemental jurisdiction over any remaining claims under 28 U.S.C. § 1367. It states that the complaint was served on Warner Bros. on October 16, 2026, and that the notice was filed within 30 days of its receipt of the complaint, and therefore timely under 28 U.S.C. § 1446(b). It further states, upon information and belief, that Warner Bros. was the only defendant who had been served as of the date of the notice, and that the summons, complaint, and exhibits served on Warner Bros. are annexed to the notice.

The state-court complaint

The annexed state-court complaint is a verified form complaint dated October 5, 2026, signed by Ronald Jones and Regina Jones and captioned in New York Supreme Court, New York County. In numbered paragraphs, Ronald Jones describes himself as a member of a consulting team for a person the complaint identifies as the copyright owner, and he and Regina Jones allege “a major copyright infringement involving the motion picture industry.”

The complaint alleges that use of “the copyright owner’s name within the original airing of the film (Space Jam)” and “the names of characters within it” constitute “egregious harm” to “the creator and owner of the franchise, the manuscript, and the characters within the screenplay,” and it states that “the copyright” has been “filed” “since 1986, on June 19th.” An attached handwritten outline identifies that person as the claimed owner of an “original screenplay ‘Spacejam’” it says was “submitted” on June 19, 1986, and of “the Spacejam franchise.” It lists a “first copyright infringement” as the “original airing of Spacejam” on November 15, 1996, and the “original airing” of “‘Spacejam’ the sequel” on July 16, 2021, in theaters and on HBO Max, with a listed “grievance” of copyright infringement and derivative copyright infringement, including use of that person’s name and of family members. Paragraph 3 of the form complaint alleges that “a second infringement occurred in 2021” by “the company owned by Mr. LeBron James, (Spring Hill Company).”

The complaint asks the court to review evidence the plaintiffs say is submitted as a multi-page exhibit of approximately 30 pages, to allow time for attorneys to review the matter, and to “hold, delay, or suspend” a planned merger involving Warner Brothers until, in its words, “the plaintiff and creator of the IP involving copyrights, films, franchises, and ongoing business related to them, can fairly compensate the creator and copyright owner.”

Assignment

The case is assigned to Judge Gregory H. Woods.