Case 2:17-cv-08655 Document 1 Filed 11/30/17 Page 1 of 19 Page ID #:1

1 GLENN D. POMERANTZ (State Bar No. 112503)

glenn.pomerantz@mto.com
2 ROSE LEDA EHLER (State Bar No. 296523)
rose.ehler@mto.com
3 MUNGER, TOLLES & OLSON LLP
350 South Grand Avenue, 50th Floor
4 Los Angeles, California 90071-3426
Telephone: (213) 683-9100
5 Facsimile: (213) 687-3702
6 KELLY M. KLAUS (State Bar No. 161091)
kelly.klaus@mto.com
7 CAROLYN HOECKER LUEDTKE (State Bar No. 207976)
carolyn.luedtke@mto.com
8 STEPHANIE GOLDFARB HERRERA (State Bar No. 313887)
stephanie.herrera@mto.com
9 MUNGER, TOLLES & OLSON LLP
560 Mission Street, 27th Floor
10 San Francisco, California 94105-2907
Telephone: (415) 512-4000
11 Facsimile: (415) 512-4077
12 Attorneys for Plaintiffs
13
14 UNITED STATES DISTRICT COURT

15 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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17 DISNEY ENTERPRISES, INC., Case No. ______
BUENA VISTA HOME
18 ENTERTAINMENT, INC., COMPLAINT FOR COPYRIGHT
LUCASFILM LTD. LLC, and MVL INFRINGEMENT, BREACH OF
19 FILM FINANCE LLC, CONTRACT, TORTIOUS
INTERFERENCE WITH
20 Plaintiffs, CONTRACT, FALSE
ADVERTISING, AND UNFAIR
21 vs. COMPETITION
22 REDBOX AUTOMATED RETAIL, DEMAND FOR JURY TRIAL
LLC,
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Defendant.
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COMPLAINT
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1 Plaintiffs Disney Enterprises, Inc., Buena Vista Home Entertainment, Inc.,

2 Lucasfilm Ltd. LLC, and MVL Film Finance LLC (collectively, Plaintiffs) bring
3 this Complaint against Redbox Automated Retail, LLC (Redbox) for infringing
4 Plaintiffs exclusive rights under the Copyright Act (17 U.S.C. 101 et seq.), breach
5 of contract, tortious interference with contract, false advertising (Cal. Bus. & Prof.
6 Code 17500 et seq.), and unfair competition (id. 17200 et seq.). This Court has
7 subject matter jurisdiction pursuant to 28 U.S.C. 1331, 1338(a), and 1367(a), and
8 17 U.S.C. 501(b). Plaintiffs allege on personal knowledge as to themselves, and
9 information and belief as to others, as follows:
10 INTRODUCTION
11 1. Redbox operates a movie and video-game rental business. Redbox
12 rents physical DVDs and Blu-ray discs through self-service kiosks located at
13 grocery stores and other retail establishments.
14 2. Redbox recently began illegally selling Plaintiffs digital movie codes
15 (Codes) to Redbox customers in blatant disregard of clear prohibitions against
16 doing so and in violation of Plaintiffs copyrights.
17 3. Plaintiffs sell Codes as part of combination packages (Combo
18 Packs) that include a Blu-ray disc, a DVD, and a Code. The outside packaging is
19 clearly marked: Codes are not for sale or transfer.
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COMPLAINT
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1 8. Plaintiff Lucasfilm Ltd. LLC (Lucasfilm) is a limited liability

2 company formed under the laws of the State of California with its principal place of
3 business in San Francisco, California.
4 9. Plaintiff MVL Film Finance LLC (Marvel) is a limited liability
5 company formed under the laws of the State of Delaware with its principal place of
6 business in Burbank, California.
7 10. Plaintiffs Disney, Lucasfilm, and Marvel own the copyrights in the
8 motion pictures and television programs that they or their affiliates produce and
9 distribute (the Copyrighted Works). The Copyright Office has issued Certificates
10 of Copyright Registration for the Copyrighted Works. Exhibit A includes a
11 representative list of Copyrighted Works, along with their corresponding Certificate
12 of Copyright Registration numbers, that are the subject of Plaintiffs claims.
13 11. Defendant Redbox is a limited liability company formed under the
14 laws of the State of Delaware with its principal place of business at One Tower
15 Lane, Suite 900, Oakbrook Terrace, Illinois 60181. Redbox has established and
16 maintains kiosk locations throughout this District and the State of California from
17 which it sells the Codes. Redbox also makes Codes available for sale online to
18 consumers located in California.
19 JURISDICTION AND VENUE
20 12. This Court has subject matter jurisdiction over Plaintiffs copyright
21 infringement claims pursuant to 28 U.S.C. 1331, 1338(a) and 17 U.S.C.
22 501(b).
23 13. This Court has supplemental jurisdiction over Plaintiffs state law
24 claims pursuant to 28 U.S.C. 1367(a).
25 14. Venue is proper in this District pursuant to 28 U.S.C. 1391(b)(2)
26 and 1400(a).
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COMPLAINT
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1 BACKGROUND FACTS
2 Plaintiffs and Their Copyrighted Works
3 15. Plaintiffs or their affiliates own, produce, and distribute some of the
4 most popular and critically acclaimed motion pictures in the world.
5 a. Well-known feature-length motion pictures in which Disney
6 holds the copyrights include: Pirates of the Caribbean: Dead Men Tell No Tales
7 (2017), Beauty and the Beast (2017), Finding Dory (2016), The Jungle Book (2016),
8 Moana (2016), Inside Out (2015), and Frozen (2013).
9 b. Well-known feature-length motion pictures in which Lucasfilm
10 holds the copyrights include: Rogue One: A Star Wars Story (2016) and Star Wars:
11 Episode VII The Force Awakens (2015).
12 c. Well-known feature-length motion pictures in which Marvel
13 holds the copyrights include: Doctor Strange (2017), Guardians of the Galaxy Vol.
14 2 (2017), and Iron Man 3 (2013).
15 16. Redbox currently engages in the unauthorized sale of Codes for all of
16 the foregoing titles, and other Copyrighted Works, both online and at its physical
17 kiosks.
18 17. Plaintiffs or their affiliates own or have the exclusive U.S. rights
19 (among others) to reproduce and distribute the Copyrighted Works.
20 18. Plaintiffs or their affiliates distribute the Copyrighted Works in various
21 formats and through multiple distribution channels, including: for exhibition in
22 theaters; through cable and direct-to-home satellite services (including basic,
23 premium, pay-per-view, and video-on-demand services); through licensed digital
24 services; and through physical copies on Blu-ray discs and DVDs.
25 19. Consumers can access Plaintiffs digital content through the
26 ReedeemDigitalMovie.com website, the Movies Anywhere service, or other
27 websites hosted by Plaintiffs or their affiliates. These sites provide online portals
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COMPLAINT
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1 through which consumers with authorization to do so are permitted to redeem

2 Codes for access to the underlying motion picture.
3 Plaintiffs Combo Packs and Digital Movie Codes
4 20. Plaintiffs Combo Packs are single retail units that contain three
5 separate consumer offerings bundled together: a Blu-ray disc containing a copy of
6 the work; a DVD containing a copy of the work; and a Code, which the purchaser
7 of the Combo Pack can redeem through authorized online services.
8 21. Combo Packs are sold at a discount from the price that a consumer
9 would pay separately to purchase the individual discs and obtain an authorized
10 digital copy. Plaintiffs offer Codes as part of the Combo Packs as a way of
11 providing consumers who typically utilize physical playback media with access to
12 the online entertainment ecosystem. The discounted aggregate price is also an
13 incentive for consumers to upgrade to the purchase of Combo Packs instead of a
14 single disc package or digital download.
15 22. Combo Packs are sold subject to terms and conditions that govern both
16 the purchase and use of the included offerings. One such term, stated twice on the
17 outside of the Combo Pack packaging, states: Codes are not for sale or transfer.
18 23. The Code is printed on an insert included with the Combo Pack. The
19 insert provides instructions for redeeming the Code to download or access a digital
20 stream of the motion picture. A consumer can redeem a Code through
21 RedeemDigitalMovie.com, the Movies Anywhere service, or, in some cases,
22 through other authorized services. The bottom of the insert states again that Codes
23 are not for sale or transfer.
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COMPLAINT
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1 Vista Home Entertainment, Inc. reserves the right to invalidate any

digital movie codes it suspects have been sold, distributed, purchased
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or transferred in a manner inconsistent with these terms and conditions.
3 In addition, Buena Vista Home Entertainment, Inc. will have the right
to take appropriate legal action, in its sole discretion.
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13 Figure 4: Terms and Conditions for
RedeemDigitalMovie.com
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Consumers must agree to these terms and conditions when entering Codes and
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before streaming or downloading the content.
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26. The Movies Anywhere service is likewise subject to terms of use,
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which provide the following regarding redemption of Codes:
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Digital Copy Code Redemption. You can enter authorized, unexpired,
19 valid, and unused Digital Copy codes from a Digital Copy enabled and
20 Movies Anywhere-eligible physical product that is owned by you in the
Redeem section of the Movies Anywhere Service. . . . You will not
21 transfer, sell or rent (or offer to transfer, sell or rent) any Digital Copy
22 codes. . . . The sale, distribution, purchase or transfer of Digital Copy
codes outside of the methods set forth in such terms and conditions is
23 strictly prohibited.
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Consumers cannot access or use Movies Anywhere without creating an account,
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which requires them to click a box acknowledging that they have read and agree to
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the terms of use.
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COMPLAINT
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1 Redboxs Unlawful Resale of Codes

2 27. Redbox purchases and disassembles Combo Packs, separating the
3 Codes from the physical discs. Redbox rents or sells the discs through its kiosks.
4 Redbox separately re-packages the Code insertthat states Codes are not for sale
5 or transferinto a Redbox case for resale.
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Figure 5: Redbox Re-packaging of Digital Movie Codes
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28. Redbox sells these Codes through its retail kiosks as well as online (to
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be picked up at a nearby Redbox kiosk). Redbox markets its offering of the Codes
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as cheap, a Smart buy, and a low-price alternative to authorized digital
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services. Redbox does so to attract customers who would otherwise purchase a
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Combo Pack or licensed digital offering through an authorized distributor.
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COMPLAINT
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Figure 6: Redbox Website
11 http://redbox.com/

12 29. Redbox knows the terms and conditions that govern use of the Codes,
13 including the express prohibition that appears twice on the outside of the packaging
14 (and again on the inside packaging containing the Code): Codes are not for sale or
15 transfer.
16 30. Redbox does not tell its customers that the Codes were sold as part of
17 a Combo Pack; that the Codes may not be resold or transferred; that a customer
18 who purchases a Code separate from the rest of the Combo Pack does not have
19 authorization to redeem the Code, or to download or otherwise access a copy of the
20 Copyrighted Work; or that BVHE has the right to invalidate any Code it suspects
21 has been sold, distributed, purchased, or transferred in a manner inconsistent with
22 the governing terms and conditions.
23 31. Redbox knows that Plaintiffs digital content licenses are subject to
24 terms of use. This is a practice that Redbox itself follows. When Redbox offers
25 online programs and services, its customers must create an account and agree to
26 Redboxs terms of use. Redbox knows that the online redemption of Codes and the
27 use of services like RedeemDigitalMovie.com and Movies Anywhere also are
28 subject to terms of use. And, Redbox knows from the language on the outside
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COMPLAINT
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1 packaging of Combo Packs that terms and conditions apply to the redemption of
2 Codes. Redbox has knowledge of the RedeemDigitalMovie.com and Movies
3 Anywhere terms of use either because Redbox read those terms of use before
4 starting to sell the Codes or because Redbox willfully blinded itself to those terms
5 of use.
6 Redboxs Conduct Causes Immediate and Irreparable Harm
7 32. If not enjoined, Redboxs continued unlawful conduct will harm
8 Plaintiffs relationships with its authorized distributors and retailers. Because
9 Redbox resells Codes without authorization and in violation of the terms of the
10 contract, Redbox significantly undercuts the prices offered by licensed services for
11 accessing the Copyrighted Works online. Redboxs conduct interferes with, among
12 other things, Plaintiffs goodwill with those licensees and ability to negotiate with
13 licensees.
14 33. Redboxs illegal conduct will continue to undermine Plaintiffs
15 relationships with its customers. Redbox markets its sale of the Codes to its
16 customers as a legitimate and lawful alternative to purchasing digital access
17 through authorized online services. Redbox misleads customers into believing that
18 they are entering into authorized transactions when they redeem Codes and induces
19 those customers to download digital copies of titles when Redbox knows those
20 customers have no legal authorization or right to do so. Redboxs illegal conduct
21 threatens to confuse and frustrate customers regarding the authorized use of Codes.
22 FIRST CAUSE OF ACTION
23 (Disney, Lucasfilm, and Marvel:
24 Contributory Copyright Infringement, 17 U.S.C. 106)
25 34. Plaintiffs incorporate herein by reference each and every averment
26 contained in paragraphs 1 through 33 inclusive.
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COMPLAINT
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1 35. When Redboxs customers download Copyrighted Works using a

2 Code purchased from Redbox, they do so without authorization and in violation of
3 Plaintiffs exclusive rights under copyright, including the right of reproduction.
4 36. Redbox is contributorily liable for copyright infringement because it
5 (a) has knowledge that its customers will be reproducing the Copyrighted Works
6 without authorization when they use the Codes to download copies of those works,
7 and (b) induces, encourages, or materially contributes to the violation of Plaintiffs
8 rights through its unlawful resale of the Codes.
9 37. Redboxs acts of infringement are willful, in disregard of, and done
10 with indifference to Plaintiffs rights.
11 38. As a direct and proximate result of the infringements for which
12 Redbox is responsible, Plaintiffs are entitled to damages and Redboxs profits in
13 amounts to be proven at trial.
14 39. Alternatively, at their election, Plaintiffs are entitled to statutory
15 damages, up to the maximum amount of $150,000 per statutory award, by virtue of
16 Redboxs willful infringement, or for such other amounts as may be proper under
17 17 U.S.C. 504.
18 40. Plaintiffs are further entitled to recover their attorneys fees and full
19 costs pursuant to 17 U.S.C. 505.
20 41. As a direct and proximate result of the foregoing acts and conduct,
21 Plaintiffs are threatened with continuing substantial, immediate, and irreparable
22 injury for which there is no adequate remedy at law. Unless enjoined and
23 restrained by this Court, Redbox will continue to infringe Plaintiffs rights in their
24 Copyrighted Works. Plaintiffs are entitled to injunctive relief under 17 U.S.C.
25 502.
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COMPLAINT
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1 SECOND CAUSE OF ACTION

2 (BVHE:
3 Breach of Contract)
4 42. Plaintiffs incorporate herein by reference each and every averment
5 contained in paragraphs 1 through 41 inclusive.
6 43. Redbox enters into a contract with BVHE when it purchases Combo
7 Packs. That contract prohibits sale or transfer of the Codes.
8 44. BVHE has performed its obligations under the contract.
9 45. Redbox has breached the contract by reselling the Codes to its
10 customers.
11 46. Redboxs breach causes Plaintiffs to suffer damages and threatens
12 them with continuing substantial, immediate, and irreparable injury.
13 47. Plaintiffs are entitled to specific performance and an injunction
14 restraining Redbox from continuing to violate the terms of the contract because
15 there is no adequate legal remedy, Cal. Civ. Code 3366 et seq.
16 THIRD CAUSE OF ACTION
17 (BVHE:
18 Tortious Interference with Plaintiffs Contracts with Customers)
19 48. Plaintiffs incorporate herein by reference each and every averment
20 contained in paragraphs 1 through 47 inclusive.
21 49. BVHE has valid contracts with customers through the
22 RedeemDigitalMovie.com terms of service. These contracts prohibit the
23 redemption of Codes by customers who do not own the accompanying physical
24 product sold as part of the Combo Pack.
25 50. Redbox at all relevant times has known of these contracts.
26 51. Redbox intentionally induced and is continuing to induce breach and
27 disruption of these contractual relationships between BVHE and customers by
28 selling Codes disassembled from the Combo Packs that cannot be redeemed
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COMPLAINT
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1 without violating the terms and conditions of the RedeemDigitalMovie.com terms

2 of service.
3 52. Plaintiffs are damaged by Redboxs interference with their
4 relationships with their customers as well as lost sales; and are threatened with
5 continuing substantial, immediate, and irreparable injury for which there is no
6 adequate remedy at law, thereby entitling Plaintiffs to injunctive relief.
7 53. Redboxs actions were done with malice, oppression, and fraud and in
8 wanton disregard for Plaintiffs rights. Plaintiffs are therefore entitled to punitive
9 damages, under California Civil Code 3294, to punish Redbox for its conduct and
10 to deter it from engaging in similar conduct in the future.
11 FOURTH CAUSE OF ACTION
12 (All Plaintiffs:
13 Violation of the False Advertising Law, Cal. Bus. & Prof. Code 17500)
14 54. Plaintiffs incorporate herein by reference each and every averment
15 contained in paragraphs 1 through 53 inclusive.
16 55. California Business and Professions Code 17500 et seq., prohibits
17 false advertising, i.e., untrue or misleading statements with the intent to induce
18 members of the public to enter into a transaction.
19 56. Redbox knowingly disseminates false and misleading information by
20 not disclosing to consumers that the Codes may only be redeemed by the owner of
21 the physical product sold as part of the Combo Pack. Redbox deceives customers
22 into believing that the Codes that Redbox sells grant those customers authorized
23 access to a digital copy of the motion picture, when they do not.
24 57. Plaintiffs are entitled to injunctive relief and restitution pursuant to
25 California Business and Professions Code 17535.
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COMPLAINT
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1 FIFTH CAUSE OF ACTION

2 (All Plaintiffs:
3 Violation of the Unfair Competition Law, Cal. Bus. & Prof. Code 17200)
4 58. Plaintiffs incorporate herein by reference each and every averment
5 contained in paragraphs 1 through 57 inclusive.
6 59. California Business and Professions Code 17200 et seq. (UCL),
7 prohibits unfair competition in the form of any unlawful, unfair, or fraudulent
8 business acts or practices.
9 60. Redbox engages in conduct that violates the UCL by, as further
10 explained in paragraphs 1 through 57 inclusive, competing in the marketplace on
11 unfair terms by engaging in unlawful conduct and misleading its customers into
12 believing that their purchase of the illegally re-packaged and resold Codes grants
13 those customers authorized access to a digital copy of the motion picture.
14 61. This conduct is unlawful because it constitutes tortious interference
15 with contracts and false advertising under Cal. Bus. & Prof. Code 17500.
16 62. This conduct is unfair because (a) it is contrary to legislatively
17 declared policies, including the policies expressed and embodied in Cal. Bus. &
18 Prof. Code 17500; and (b) the impact of the conduct on Plaintiffs, when weighed
19 against Redboxs reasons, motivations, and justifications for such conduct,
20 establish that the conduct is unfair.
21 63. This conduct is fraudulent in that it is likely to deceive customers
22 into believing they have purchased a Code that grants them authorized access to a
23 digital copy of a Copyrighted Work, when in fact customers are only authorized to
24 use a Code if they have purchased the accompanying physical product as part of the
25 Combo Pack.
26 64. Plaintiffs have lost and will continue to lose sales as a direct result of
27 Redboxs unlawful, unfair, and fraudulent conduct.
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COMPLAINT
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1 65. Plaintiffs are entitled to injunctive relief and restitution pursuant to

2 California Business and Professions Code 17203.
3 PRAYER FOR RELIEF
4 WHEREFORE, Plaintiffs pray for judgment against Redbox for the following
5 relief:
6 1. For preliminary and permanent injunctions enjoining Redbox and all
7 persons acting in concert or participation with it, from reselling Codes; from
8 infringing in any manner, directly or indirectly, any copyrighted work owned or
9 controlled by Plaintiffs or their affiliates (including without limitation any
10 Copyrighted Work); from breaching the terms of Redboxs contracts with any
11 Plaintiff; from interfering with any Plaintiffs contracts with customers; from
12 disseminating false and misleading information regarding Codes; and from
13 unlawfully, unfairly, or fraudulently competing by reselling Codes.
14 2. For Plaintiffs damages and Redboxs profits in such amount as may
15 be found; alternatively, at Plaintiffs election, for maximum statutory damages; or
16 for such other amounts as may be proper pursuant to 17 U.S.C. 504(c).
17 3. For Plaintiffs damages and restitution to the fullest extent allowed
18 pursuant to the common law and Cal. Bus. & Prof. Code 17203.
19 4. For an award of punitive damages pursuant to Cal. Civ. Code 3294.
20 5. For prejudgment interest pursuant to Cal. Civ. Code 3287.
21 6. For Plaintiffs attorneys fees and full costs incurred in this action
22 pursuant to 17 U.S.C. 505 and Cal. Civ. Code 1021.5.
23 7. For all such further and additional relief, in law or in equity, to which
24 Plaintiffs may be entitled or which the Court deems just and proper.
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COMPLAINT
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1 DEMAND FOR JURY TRIAL

2 Plaintiffs demand a trial by jury on all issues triable by jury.
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4 DATED: November 30, 2017 MUNGER, TOLLES & OLSON LLP
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By: /s/ Kelly M. Klaus
8 KELLY M. KLAUS
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Attorneys for Plaintiffs
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COMPLAINT
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EXHIBIT A
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Complaint Exhibit A
Plaintiff Title U.S. Copyright
Reg. Number
Disney Enterprises, Inc. Alice Through the Looking Glass PA 1-991-651
Disney Enterprises, Inc. Beauty and the Beast (2017) PA 2-031-209
Disney Enterprises, Inc. Cars 3 PA 2-048-714
Disney Enterprises, Inc. Finding Dory PA 1-994-819
Disney Enterprises, Inc. Frozen PA 1-871-077
Disney Enterprises, Inc. Inside Out PA 1-949-250
Disney Enterprises, Inc. Jungle Book, The (2016) PA 1-988-129
Disney Enterprises, Inc. Lone Ranger, The PA 1-848-181
Disney Enterprises, Inc. Maleficent PA 1-899-203
Disney Enterprises, Inc. Moana PA 2-012-015
Disney Enterprises, Inc. Muppets Most Wanted PA 1-887-658
Disney Enterprises, Inc. Oz the Great and Powerful PA 1-830-872
Disney Enterprises, Inc. Pirates of the Caribbean: Dead PA 2-045-629
Men Tell No Tales
Disney Enterprises, Inc. Planes PA 1-856-767
Disney Enterprises, Inc. Planes: Fire & Rescue PA 1-907-149
Lucasfilm Ltd. LLC Star Wars: Episode VII The PA 1-975-592
Force Awakens
Lucasfilm Ltd. LLC Rogue One: A Star Wars Story PA 2-016-306
MVL Film Finance, LLC Doctor Strange PA 2-008-618
MVL Film Finance, LLC Guardians of the Galaxy Vol. 2 PA 2-033-904
MVL Film Finance, LLC Iron Man 3 PA 1-836-301

COMPLAINT, EX. A
CASE NO. ____