What was filed

The complaint is Document 1 in No. 5:26-cv-06085, U.S. District Court for the Central District of California, filed October 15, 2026. It runs 25 pages. Counsel for the plaintiff is Kinney Law, P.C. The plaintiff demands a jury trial. (Compl. pp. 1, 24 to 25.)

The plaintiff is Shahin Khazey, who the complaint says owns an engineering company and runs the fitness Instagram account @probably_shawn_. The defendants are an individual the complaint places in Los Angeles County and, on information and belief, says controls the Instagram account @Cassiexmillzz and related TikTok and YouTube accounts, and Does 1 to 35. (Compl. paras. 3 to 5, 8 to 9.)

What the complaint alleges

It alleges Khazey published a short video of himself doing bicep exercises on Instagram on or about April 5, 2026, registered as PAu 4-309-110, effective June 8, 2026. It alleges that on May 28, 2026 the defendant re-edited the full video into an Instagram Reel, adding captions and footage of the defendant that presented the defendant as the man in the video, and posted the same video at least four more times on two TikTok accounts and YouTube between May 28 and July 9, 2026. It says the Instagram Reel alone had 3.3 million views. (Compl. paras. 10, 12 to 14.)

It alleges a pinned "Check my highlights" comment pointed viewers to highlights containing a link to the defendant's paid subscription account; that in a direct message the defendant wrote "It's obvious we're not the same person" but publicly replied "nah it's me" to a commenter who asked; that the defendant did not remove the posts after three requests and blocked Khazey; and that counsel sent a cease-and-desist letter on September 2, 2026. It alleges hostile comments aimed at Khazey and the loss of a client engagement worth about $9,000. (Compl. paras. 16, 18, 20 to 25, 27, 58.)

Counts and relief

Count I alleges willful copyright infringement under 17 U.S.C. 501 and seeks actual damages and profits under 17 U.S.C. 504(b) or statutory damages under 17 U.S.C. 504(c), plus fees under 17 U.S.C. 505. Count II alleges false designation of origin and false association under 15 U.S.C. 1125(a)(1)(A), with profits and damages under 15 U.S.C. 1117(a). Counts III to VIII allege statutory misappropriation of publicity under Cal. Civ. Code 3344, common law misappropriation of publicity, intentional infliction of emotional distress, false light, common law unfair competition and passing off, and unfair competition under Cal. Bus. & Prof. Code 17200. The prayer seeks damages, profits, enhanced damages for willfulness, fees, costs, and interest. (Compl. paras. 32 to 86; pp. 23 to 24.)