The complaint
Marco Verch v. Wisconsin Plastic Products, LLC, No. 2:26-cv-02091 (E.D. Wis., Milwaukee Division), was filed November 10, 2026 (10 pages, with Exhibits 1 and 2), with a jury demand. The complaint describes Verch as a photographer based in Cologne, Germany. It describes the defendant as a Wisconsin limited liability company and custom plastic extrusion manufacturer based in Plymouth, Wisconsin, founded in 1994, that owned and operated the Wisconsin Plastic Facebook Page at all relevant times. The docket assigns the case to District Judge Pamela Pepper. (Compl. at 1 to 3; docket notice of judge assignment, Nov. 10, 2026.)
The work
The complaint alleges that the photograph, entitled "Sunflower-flower-and-colorful-autumn-leaves-on-white-background" (the "Work"), was created in 2019 by Liliya Krivorychko, that Verch owns it by written assignment, and that he registered it on December 28, 2020, as part of a group registration, No. VA 2-237-126 (Exhibit 1). It alleges Verch made the Work available on Flickr under a Creative Commons 2.0 license that conditions use on attribution, published it there on or about November 4, 2019, and displayed copyright management information next to it in the form of his name, the year of creation, and a link to the license terms. The Copyright Office public record for VA 2-237-126 shows a group registration of 236 published photographs, registered December 28, 2020, with Verch as claimant by written agreement and a publication date range of February 27, 2019 to October 18, 2019. (Compl. at 3 to 5.)
What the complaint alleges
The complaint alleges Wisconsin Plastic copied the Work without a license and then made further copies and distributed it on the internet to promote its engineered plastic business, and it points to Exhibit 2 as evidence. It alleges Verch learned of the use within three years before filing, on a Facebook page at a URL the complaint lists, and that he notified Wisconsin Plastic on November 4, 2025 and November 24, 2025 without a response. It alleges Wisconsin Plastic did not provide the attribution the license requires and that this failure is a removal of copyright management information under 17 U.S.C. § 1202(b). (Compl. at 2, 5 to 6.)
The counts and relief
Count I alleges direct copyright infringement under 17 U.S.C. § 501 and alleges willfulness. Count II alleges vicarious copyright infringement: it alleges, upon information and belief, that a third party copied, displayed, and made derivatives of the Work, and that Wisconsin Plastic had a direct financial interest and the ability to stop the display. Count III alleges addition of false copyright management information under 17 U.S.C. § 1202(a): it alleges Wisconsin Plastic added "Wisconsin Plastic Products, Inc." to the bottom right corner of the Work and then published it. Verch seeks preliminary and permanent injunctions against the acts alleged to violate 17 U.S.C. §§ 501 and 1203; his actual damages and Wisconsin Plastic's profits or, at his election, statutory damages under 17 U.S.C. §§ 504 and 1203; attorneys' fees and costs; pre- and post-judgment interest; and other relief. (Compl. at 6 to 9.)