What was filed
The complaint is Document 1 in No. 5:26-cv-05930, U.S. District Court for the Central District of California, Eastern Division, filed October 7, 2026 (8 pages). Counsel for the plaintiff is SRIPLAW, P.A. The plaintiff demands a jury trial. (Compl. pp. 1, 7 to 8.)
What the complaint alleges
Radic is described as a professional photographer since 2017. According to the complaint, the work is a 2021 photograph titled "Close up of an electric car charging," registered September 17, 2021 as part of a group registration, No. VA 2-446-637. The complaint says Radic published it on Flickr under a Creative Commons 2.0 license that requires attribution, and that the Flickr display included CMI in the form of his name, the year of creation, and a link to the license terms. (Compl. pp. 2 to 4.)
Freedom Transport Service LLC is described as a California LLC based in Canyon Lake, California, that owned and operated freedomtransportservice.com. The complaint alleges that Freedom copied the work without a license; that Radic found it in use on the website at an image address on static.wixstatic.com; that Freedom distributed the work on the internet to promote its vehicle shipping services; and that Freedom displayed it on the website without any of the attributions, which it pleads under 17 U.S.C. 1202(b). It says Radic notified Freedom on May 21, July 1, July 16, and August 3, 2026, and that the matter was not resolved. (Compl. pp. 2 to 6.)
Count I alleges willful direct infringement under 17 U.S.C. 501. Count II alleges that, to the extent a third party alone performed the acts, Freedom is vicariously liable. Count III, captioned as a claim for removal of copyright management information, alleges under 17 U.S.C. 1202(b) that Freedom knowingly displayed the work on its website without any of the attributions and distributed it knowing that the CMI had been removed or altered. The complaint asks that Freedom be preliminarily and permanently enjoined from the acts alleged, which it describes as violations of 17 U.S.C. 501 and 1203, and seeks actual damages and profits or, at Radic's election, statutory damages under 17 U.S.C. 504 and 1203, attorneys' fees and costs, and pre- and post-judgment interest. (Compl. pp. 5 to 7.)