What was filed

The complaint is Document 1 in No. 8:26-cv-03037, U.S. District Court for the Middle District of Florida, Tampa Division, filed October 6, 2026. The plaintiff is David Gordon Oppenheimer, whom the complaint describes as an independent travel, aerial, and concert photographer. The defendant is Rehab Media Group LLC, which the complaint describes as a Delaware limited liability company registered to do business in Florida, with its principal address in St. Petersburg, Florida, and as the owner and operator of Addictions.com and Rehabs.org. The complaint demands a jury trial. (Compl. pp. 1 to 4, 13.)

What the complaint alleges

According to the complaint, the works are two photographs Oppenheimer made in 2018 on a helicopter flight: an aerial of the Ritz-Carlton Half Moon Bay resort and an aerial of the Santa Clara County Government Center in San Jose, California. The complaint says both are part of a group registration of published photographs, No. VA 2-169-384, registered August 26, 2019, and that each was published with a visible copyright notice bearing his name and the year 2018, copyright management information embedded in the metadata, and a caption crediting him. (Compl. pp. 4 to 6.)

It alleges that Rehab Media, without a license, displayed the Ritz-Carlton photo on an Addictions.com page about rehab centers in Half Moon Bay, California, and the Santa Clara photo on a Rehabs.org page about rehab centers in Santa Clara, California, and that the posted versions lacked the watermark, metadata, and caption information. It says Oppenheimer notified Rehab Media on January 30, 2025 and February 19, 2025, and that the parties have not resolved the matter. (Compl. pp. 7 to 8.)

Count I alleges willful direct infringement under 17 U.S.C. 501. Count II alleges vicarious infringement to the extent a third party performed the acts. Count III alleges that Rehab Media intentionally removed or altered Oppenheimer's copyright management information, or caused its removal or alteration, in violation of 17 U.S.C. 1202(b)(1), and distributed and publicly displayed copies knowing it had been removed or altered, in violation of 17 U.S.C. 1202(b)(3). The complaint seeks preliminary and permanent injunctions under 17 U.S.C. 502(a) and 1203(b)(1), actual damages and profits or statutory damages under 17 U.S.C. 504, damages including statutory damages under 17 U.S.C. 1203(c), costs and fees under 17 U.S.C. 505 and 1203(b)(4) and (5), and pre- and post-judgment interest. (Compl. pp. 9 to 13.)