The complaint
Tara Mapes d/b/a Tara Mapes Photography v. Meta Platforms, Inc., No. 1:26-cv-09559 (S.D.N.Y.), is a 124-page complaint filed November 2, 2026, ECF No. 1, with a jury demand. Mapes is a photographer and visual artist of Guilford, Indiana, doing business as Tara Mapes Photography. The sole defendant is Meta Platforms, Inc., which the complaint describes as a Delaware corporation based in Menlo Park, California, that operates Facebook. The complaint says the Facebook infringement it pleads is not a handful of isolated user uploads but a recurring stream of copying and redistribution, and it pursues Meta only on secondary liability and § 1202(b)(3) theories.
The works
The complaint's representative listing names eight registrations: VA0002151851 (Santa with Magic Snow Globe), VA0002227723 (Dinosaur Chase in Florida Forest Tunnel on Dirt Path), VA0002248504 (Santa Reading Book on Couch), VA0002284642 (Black Santa Sleeping on Couch), VA0002464853 (Horror Halloween), VA0002467149 (Faceless Dolls), VA0002451268 (2025-1Q), and VA0002528196 (HOMESCHOOL). The Copyright Office public catalog lists Tara Mapes as claimant on all eight; the first four are single works, and the other four are group registrations of published photographs (729 photographs in 2025-1Q, 59 in Horror Halloween, 38 in Faceless Dolls, and 11 in Homeschool). Where a registration covers a group, Mapes says she asserts infringement only of the particular constituent works identified in Exhibit A and her supporting evidence. The complaint also explains that two September 29, 2026 notices initially cited VA0002465949 and that correction emails gave VA0002151851, and that VA0002464858 appears in a separate dispute and is not presently alleged as part of the Facebook claims.
What it alleges
Mapes alleges an editing-group ecosystem on Facebook in which a source work or template is uploaded, members create unauthorized composites, and those derivatives are displayed and redistributed. She details extensive notice to Meta. In March 2025, she says, she submitted 17 Facebook copyright reports in one day about a non-party Facebook page operator, after which Facebook restricted her ability to submit more reports, and she turned to support tickets, email, telephone support, and certified notices. A September 2026 campaign of 53 direct notices identified 145 distinct Facebook URLs. She alleges Meta continued to host and distribute the accused content after particularized notice. The complaint says allegations about Meta's internal conduct are made on information and belief where the external evidence supports the inference and Meta holds the confirming records.
Counts and relief
Count I pleads contributory copyright infringement against Meta, including inducement. Count II pleads vicarious copyright infringement. Count III pleads violation of 17 U.S.C. § 1202(b)(3), alleging that Meta distributed copies of her works knowing that copyright management information had been removed or altered without authority, with post-notice distribution acts alleged on information and belief. Mapes seeks a declaration of liability, preliminary and permanent injunctive relief, actual damages and profits, statutory damages for eligible works, fees and costs, and interest.
Docket activity
The same day as the complaint, Mapes filed an AO 121 copyright form, a civil cover sheet, and a request for issuance of summons as to Meta (ECF Nos. 2 to 4).