What was filed

The complaint is Document 1 in No. 1:26-cv-03635, U.S. District Court for the District of Columbia, filed October 19, 2026. It runs seven pages and refers to a Schedule A that sets out, in summary form, the plaintiffs, works, writers, publication dates, registrations, and dates of infringement. The defendants are Culture L.L.C., alleged on information and belief to be a District of Columbia limited liability company that owns and operates a venue for public entertainment known as Vera/Culture in Northeast Washington, D.C., and four individuals, Nayef Issa, Fadi Alaeddin, Nour Chaaban, and Mazen Zaatari, alleged on information and belief to be its principals, owners, directors, or officers. Counsel is Venable LLP. Jurisdiction is pleaded under 28 U.S.C. 1338(a) and venue under 28 U.S.C. 1400(a). (Compl. paras. 1 to 13; p. 7.)

What the complaint alleges

It alleges the plaintiffs are members of ASCAP, which licenses its members' public performance rights on a non-exclusive basis, that since June 2023 ASCAP representatives have contacted the defendants or their representatives, agents, or employees to offer a license for Vera, attempting contact by mail, email, and telephone, and that the defendants refused every offer. It alleges the defendants have continued to present public performances of ASCAP members' works at Vera without permission. It alleges, on information and belief, that the defendants jointly had the right and ability to supervise and control the performances, and it alleges that each defendant derives a direct financial benefit from them and that the infringement was knowing, intentional, and willful. (Compl. paras. 14 to 30.)

Counts and relief

Each count covers one composition: Count I, "Party Up (Up in Here)," Registration No. PA 1-107-707; Count II, "Another Love," Registration No. PA 1-898-421; and Count III, "Gonna Make You Sweat," Registration No. PA 520-228. The prayer seeks a permanent injunction against performing those or any other compositions owned by the plaintiffs at Vera or any place the defendants control, statutory damages under 17 U.S.C. 504 in each cause of action, and costs and a reasonable attorney's fee under 17 U.S.C. 505. It states no dollar amount. (Compl. paras. 31 to 42; p. 6.)

The U.S. Copyright Office public catalog lists PA0001107707 as "Party up (up in here)," registered December 10, 2002; PA0001898421 as "Grow Old With Me, et al.," registered March 10, 2014, a registration whose listed contents include "Another Love"; and PA0000520228 as "Gonna make you sweat (everybody dance now)," registered May 6, 1991.