What was filed
The complaint is Document 1 in No. 4:26-cv-01572, U.S. District Court for the Eastern District of Missouri, filed October 1, 2026. It runs 8 pages. Counsel for the plaintiff is CopyCat Legal PLLC. (Compl. paras. 11 to 12; p. 8.)
The plaintiff is Science Photo Library, Ltd., a London company that licenses scientific and medical stock images. The defendant is NPN Environmental Engineers, Inc., a Missouri corporation in Fenton that the complaint describes as a multi-service environmental engineering and consulting firm. (Compl. paras. 1 to 2, 6, 15.)
What the complaint alleges
The work is a scanning electron microscope photograph of an acellular slime mould sporangium by Dennis Kunkel Microscopy, Inc., which the complaint says registered and owns it and conveyed exclusive reproduction, distribution, and enforcement rights to the plaintiff by written agreement, giving it standing under 17 U.S.C. 501(b). It alleges the defendant displayed the work on its website, social media, and/or printed media to market its business in June 2017, that the plaintiff discovered the use in June 2025 and notified the defendant in writing, and that willfulness is shown in part by the "©2023 NPN Environmental Engineers, Inc." notice on the defendant's website. (Compl. paras. 11 to 14, 16 to 17, 22, 31.)
Counts and relief
The single count alleges direct, vicarious, and/or contributory infringement under 17 U.S.C. 501, pleaded as willful. The prayer seeks declarations of infringement and willfulness, actual damages and profits under 17 U.S.C. 504(b) or statutory damages under 17 U.S.C. 504(c), fees and costs under 17 U.S.C. 505, interest, and a permanent injunction under 17 U.S.C. 502. No damages amount is stated. (Compl. paras. 24 to 36; pp. 7 to 8.)