Nova Marketing sues a content creator it manages, claiming her content was assigned to it

The complaint

Nova Marketing LLC v. Lucero, No. 1:26-cv-01432 (D. Del.), is an 8-page complaint filed November 6, 2026, ECF No. 1, with Exhibits A-C and a jury demand. Nova is a Delaware limited liability company that provides content creator management and social media services. The complaint alleges, on information and belief, that the defendant is an individual residing in Argentina who works as a digital content creator under contract with Nova on a subscription content platform. It pleads jurisdiction under 28 U.S.C. §§ 1331 and 1338, personal jurisdiction based on a Delaware forum consent in the agreement, and venue under 28 U.S.C. § 1391(c)(3) and the agreement's Delaware venue clause.

The works and the assignment

The complaint alleges that on May 29, 2026, the defendant signed a Content Creation and Copyright Assignment Agreement, Exhibit A, that irrevocably assigned to Nova all right, title, and interest in all content she created, produced, or provided under the agreement, including photographs and videos, and barred her from using or distributing the content without Nova's written consent. It describes the works as foreign works created by a non-U.S. national and/or first published in Argentina, and says Nova has not registered them with the Copyright Office but may sue under 17 U.S.C. § 411(a) and the Berne Convention.

What the complaint alleges

The complaint alleges, on information and belief, that beginning as early as October 6, 2026, the defendant distributed content created under the agreement to third parties in violation of it. It says Nova sent a DMCA takedown notice to the platform on October 6, 2026, Exhibit B, that, on information and belief, the platform then deactivated the defendant's accounts, and that on October 7, 2026, the defendant filed a counter-notification, Exhibit C, stating that the content was removed by mistake or misidentification and that she is the original creator of the content and the individual depicted in it.

The count and relief

Count I alleges willful copyright infringement under 17 U.S.C. § 501. Nova seeks judgment of willful infringement, a permanent injunction, actual damages and profits, and other relief.