The complaint
Rockefeller Photos, LLC v. Selinsgrove Hotel, Inc. and Cup O Code Limited Liability Company, No. 4:26-cv-03315 (M.D. Pa.), is a nine-page complaint filed November 9, 2026. District Judge Matthew William Brann is assigned. Rockefeller Photos is a Delaware limited liability company with its principal place of business in Miami-Dade County, Florida. Selinsgrove Hotel is a Pennsylvania corporation that, according to the complaint, owns and operates a hotel with a bar and grill in Selinsgrove, Pennsylvania. Cup O Code is a Pennsylvania limited liability company that, according to the complaint, owns and operates a digital marketing and web development company in Northumberland, Pennsylvania, with additional locations in New Jersey and North Carolina.
The photograph and standing
The complaint concerns a photograph of chicken wings on a plate. It says a professional photographer employed by Prepared Food Photos, Inc., formerly Adlife Marketing & Communications Co., Inc., created the work, and that Prepared Food Photos registered it with the Register of Copyrights. The registration number is identified in exhibits to the complaint. The complaint says that under a December 12, 2024 agency agreement, Prepared Food Photos conveyed to Rockefeller Photos the unrestricted, exclusive right to distribute, license, and/or exploit the works in its library worldwide, and the exclusive right to pursue infringement claims for violations of those exclusive interests, including infringements that began before the agreement.
The alleged use
The complaint alleges that the defendants maintained a contractual relationship under which, on information and belief, Cup O Code created advertisements that were then published to market Selinsgrove Hotel's business. It says that on multiple dates after the copyright registration, the defendants displayed or published the photograph on the hotel's website, webpage, social media, and/or printed media to advertise, promote, or market that business, and that Cup O Code created each posting and selected the photograph. It says the defendants were never licensed to use the work and never sought permission. It alleges, on information and belief, that the defendants located a copy of the work on the internet and copied it for commercial use. It says Rockefeller Photos and/or Prepared Food Photos first discovered the use in March 2024 and then notified the defendants in writing.
The claim and the prayer
Count I pleads copyright infringement under 17 U.S.C. § 501 and alleges the infringement was direct, vicarious, and/or contributory, and willful. The complaint asks for a declaration that the defendants have infringed the copyrights in the work and that the infringement is willful; an award of actual damages and disgorgement of profits, or, at the plaintiff's election, statutory damages for each photograph comprising the work; costs and reasonable attorneys' fees under 17 U.S.C. § 505; interest, including prejudgment interest; a permanent injunction under 17 U.S.C. § 502 prohibiting infringement and continued display, transfer, advertising, reproduction, or marketing of works derived or copied from the work; and other just relief.