The complaint
Stephen Yang, LLC v. Lexipol LLC, No. 4:26-cv-01667 (E.D. Tex.), is a 14-page complaint filed November 9, 2026, with a jury demand. The case is assigned to District Judge Michael J. Truncale. The plaintiff is a New Jersey limited liability company with its principal place of business in Somerset County, New Jersey. The complaint says Stephen Yang, a professional photojournalist and the plaintiff's sole member, created the photograph and, by a written copyright assignment dated May 22, 2026, assigned to the plaintiff all of his right, title, and interest in the copyrights in his photographic works, including the photograph, together with all causes of action accrued or accruing under them. Lexipol LLC is a Delaware limited liability company with a principal place of business in Frisco, in Denton County, Texas.
The photograph
The complaint concerns a close-up photograph of a fire department patch for the City of New York. It says Yang first published the photograph on April 10, 2016, by commercially licensing it to a newspaper, and that it was registered on June 30, 2016 under Registration No. VA 2-010-395. The Copyright Office record for VA0002010395 is a group registration of 121 published photographs, titled as a 2016 photo collection of works published from January 1, 2016 to June 21, 2016, with a registration date of June 30, 2016. It names Stephen Yang as author and claimant. Its title list includes "FDNY 1/1/2016" and "FDNY2 4/10/2016."
The alleged use
The complaint says Lexipol owns and operates the website firerescue1.com and a Facebook account known as @firerescue1, and that through its Lexipol Media Group it owns and operates FireRescue1 and other online public-safety publications, and that it sells subscription policy, training, wellness, and grant-assistance products to public-safety agencies. It alleges that on or about December 4, 2023, without permission, Lexipol reproduced and publicly displayed the photograph in an online story on the website and in a Facebook post. It alleges, on information and belief, that Lexipol also stored a copy of the photograph on its own servers. It says the plaintiff first observed the use on December 25, 2023, that counsel notified Lexipol in writing on or about January 22, 2024, and that counsel sent follow-up communications on or about August 11, 2025 and November 3, 2026. It alleges, on information and belief, that after receiving notice Lexipol removed the photograph from the article page but did not remove the Facebook post or the server copy, and it says that as of November 5, 2026 the photograph remained displayed on the Facebook account and accessible at the server-copy URL.
The claims and the prayer
The First Cause of Action pleads direct copyright infringement under 17 U.S.C. § 501. The Second Cause of Action pleads vicarious copyright infringement. The complaint asks the court to find that Lexipol infringed the plaintiff's copyright by copying, reproducing, distributing, publishing, and publicly displaying the photograph without a license; to award actual damages and disgorgement of profits under 17 U.S.C. § 504(b) or, at the plaintiff's election, statutory damages under 17 U.S.C. § 504(c), whichever is larger; to enjoin any infringing use of the plaintiff's works under 17 U.S.C. § 502(a); to award costs and reasonable attorney's fees under 17 U.S.C. § 505; and to award pre-judgment interest and other just relief. It says the photograph was registered within three months of first publication and more than seven years before the alleged infringement began, and it seeks statutory damages and attorney's fees under 17 U.S.C. §§ 412, 504(c), and 505.