The complaint

KingdomBuilding Leadership, Inc. v. Norfolk Southern Railway Company and Norfolk Southern Corporation, No. 2:26-cv-01001 (E.D. Va., Norfolk Division), was filed September 20, 2026, ECF No. 1 (14 pages). The plaintiff, a consulting company that calls itself KBL, demands a jury trial.

The works

KBL alleges it owns leadership and safety training materials, including works it calls Candor, Committed Leadership, Speak Up Culture, and Conversation Planner. It pleads two Canadian copyright registrations and U.S. Registration Nos. TX 9-624-759 and TX 9-634-099. The Copyright Office public record lists TX 9-624-759 as "Safety Summit Living a Speak Up Culture" and TX 9-634-099 as "Safety Summit Committed Leadership," both with KingdomBuilding Leadership, Inc. as claimant.

What the complaint alleges

KBL alleges that Norfolk Southern retained it in April 2024 under a consulting services agreement and a series of statements of work to support the railroad's safety training programs, and that each agreement said the course materials stayed KBL's property and could not be reproduced. It alleges that in December 2024 it learned Norfolk Southern was distributing the materials without authorization and creating derivative works, that negotiations over a license or transfer failed, and that Norfolk Southern ended the last statement of work effective December 30, 2025. KBL alleges, on information and belief, that Norfolk Southern continues to display, use, and distribute derivative materials, including at safety camps and its training center and to third parties.

Claims and relief

Count I pleads copyright infringement against both defendants. Count II pleads copyright infringement against Norfolk Southern Corporation as a vicariously liable parent. Count III pleads breach of contract against Norfolk Southern Railway Company for fees KBL says went unpaid for November and December 2025. KBL asks for preliminary and permanent injunctions, impoundment and destruction of infringing copies, damages under 17 U.S.C. § 504(b), contract damages, and fees and costs under 17 U.S.C. § 505.

On the docket

Through October 30, 2026, the docket shows the complaint, a financial interest disclosure, proposed summonses, and the report to the Copyright Office, all filed September 20, 2026. No response from the defendants appears yet.