The complaint
Level 12 Productions, LLC v. Star News Digital Media, Inc., No. 3:26-cv-01816 (M.D. Tenn.), is a 9-page complaint filed November 11, 2026, ECF No. 1, with a demand for jury trial. Level 12 Productions, LLC is described as a New York limited liability company with its principal place of business in Wayne County, Michigan, and as a professional videography company that commercially licenses its videos. Star News Digital Media, Inc. is described as a Tennessee corporation and a media company with its principal place of business in Nashville, Tennessee. The complaint pleads subject matter jurisdiction under 28 U.S.C. §§ 1338(a) and 1331, personal jurisdiction because the company maintains its principal place of business in Tennessee, and venue under 28 U.S.C. § 1391(b)(2). (Compl. caption; paras. 3, 5 to 10, 62.) The case is assigned to Judge William L. Campbell, Jr.
The video
The complaint alleges that Brendan Gutenschwager, an independent video journalist, created a video of protests near the Consulate General of Israel in New York City, and that Level 12 owns the copyright by written assignment. It alleges that Level 12 is his production company and that, under a written agreement dated January 1, 2023, he assigned to Level 12 all right, title, and interest in and to the video works he creates, including this video, together with the right to sue for and recover damages for past infringements. It alleges that he first published the video on October 8, 2023, and that the Copyright Office registered it on December 2, 2023, under Registration No. PA 2-448-947. It alleges that the video was registered within three months after its first publication and that Level 12 is entitled to an award of statutory damages and attorney's fees under 17 U.S.C. § 412(2) notwithstanding that the alleged infringements commenced before the effective date of registration. (Compl. paras. 2, 11, 16, 18, 19, 21.)
The Copyright Office public record for Registration No. PA 2-448-947 is a motion picture registration titled "10.08.2023.Chants Near Consulate General of Israel in New York." It lists a first publication date of October 8, 2023, a registration date of December 2, 2023, Brendan Gutenschwager a/k/a BGONTHESCENE as author, and Level 12 Productions, LLC as claimant by written agreement.
What the complaint alleges
The complaint alleges that Star News Digital Media owns and operates twelve state-branded news and commentary websites, The Tennessee Star, The Ohio Star, The Minnesota Sun, The Michigan Star, The Georgia Star News, The Florida Capital Star, The Arizona Sun Times, The Wisconsin Daily Star, The Pennsylvania Daily Star, The Connecticut Star, The Virginia Star, and The Star News Network, and that it syndicates the same stories across those sites. It alleges that the sites carry paid display advertisements, sponsored posts, and affiliate links, and promote the company's affiliated talk radio programming and, upon information and belief, that the company profits from those activities. It alleges that on or about November 7, 2023, without permission, the company displayed a still frame from the video as the lead image of the same online stories on all twelve sites, and that republishing the same story, with the same lead image, across the twelve sites multiplied the audience and the advertising inventory generated by the video, without paying for it. (Compl. paras. 3, 4, 25, 26, 28, 30, 32.)
The complaint alleges that Level 12 first discovered the displays on November 15, 2023, and that Level 12, through counsel, wrote to the company on July 31, 2025, and September 1, 2025. It alleges that on September 8, 2025, the company responded by identifying the source as a post on Gutenschwager's own account on X, and that the response confirmed the company took the image from that publication. It alleges that the displays remained up: as of November 2, 2026, the first of the twelve displays remained at its original URL, and the original URLs of the second through the eleventh automatically redirected to the twelfth, which also remained displayed. It alleges that on November 2, 2026, Level 12 preserved each display on the Internet Archive's Wayback Machine. It alleges that the use harmed the actual market for the video and that the use, if widespread, would harm the potential market. (Compl. paras. 33 to 35, 49, 50.)
The count and the prayer
The First Count, Direct Copyright Infringement under 17 U.S.C. § 501 et seq., alleges that the video is an original work in which Level 12 owns a valid copyright, that it is registered, and that Level 12 has not granted the company a license or the right to use the video in any manner, nor assigned any of its exclusive rights in the copyright to the company. It alleges that, without permission and in willful violation of Level 12's rights under 17 U.S.C. § 106, the company copied, reproduced, distributed, adapted, and/or publicly displayed the video, and that the reproduction and display constitute willful copyright infringement. It alleges, upon information and belief, that the company willfully used, published, communicated, posted, publicized, and otherwise held the video out to the public for commercial benefit on the websites, without consent or authority. The prayer asks for a finding that the company infringed Level 12's copyright in the video by copying and displaying it without a license or consent; actual damages and disgorgement of all of the company's profits attributable to the infringements, as provided by 17 U.S.C. § 504(b), in an amount to be proven, or, at Level 12's election, statutory damages under 17 U.S.C. § 504(c) for each work infringed, whichever is larger; an order under 17 U.S.C. § 502(a) enjoining the company from any infringing use of any of Level 12's works; costs of litigation and reasonable attorney's fees under 17 U.S.C. § 505; pre-judgment interest as permitted by law; and any other relief the court deems just and proper. (Compl. paras. 53 to 58; Prayer paras. a to f.)