Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 1 of 33 Page ID #:1

1 ELIZABETH YANG (SBN 249713) DOUGLAS E. EDE

YANG LAW OFFICES (Pro Hae Vice To Be Filed)
2 199 W. Garvey Ave., Suite 201 RUMBERGER, KIRK & CALDWELL
Monterey, CA 91754 80 Southwest 8th Street
3 Tel: (877) 492-6452 Suite 3000
Fax:(626) 988-8827 Miami, Florida 33130
4 elizabeth@yanglawoffices.com Tel.: (305) 358-5577
Local Counsel for Plaintiff Fax: (305) 371-7580
5 dede@rumberger.com
6 GUSTAVO D. LAGE JAMES WES CHRISTIAN
7 EL'AD D. BOTWIN (Pro Hae Vice To Be Filed)
(Pro Hae Vice To Be Filed)
SANCHEZ-MEDINA, GONZALEZ, Of Counsel To Plaintiff
8
QUESADA, LAGE, GOMEZ & CHRISTIAN ATTAR
9 MACHADO, LLP 1177 W Loop South
201 Alhambra Circ, Ste. 1205 Houston, Texas 77027
10 Coral Gables, Florida 33134 Tel.: (877) 710-5170
Tel.: (305) 377-1000 Fax: (713) 659-7641
11 Fax: (786) 304-2214 jchristian@christianattarlaw.com
glage@smgqlaw .com
12 ebotwm@smgqlaw.com
13 Attorneys for Plaintiff
BUCK G. WOODALL
14
15 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
16
BUCK G. WOODALL, an Case No.:
17 individual;
18 COMPLAINT FOR:
Plaintiff,
19 1) COPYRIGHT INFRINGEMENT,
vs. 17 U.S.C. § 50l(a);
20
THE WALT DISNEY COMPANY, 2) CONTINUING COPYRIGHT
21 a Delaware Corporation; WALT INFRINGEMENT, 17 U.S.C. §§
22 DISNEY PICTURES, a Division of 50l(a),50l(b);
The Walt Disney Company; WALT
23 3) WILLFUL COPYRIGHT
DISNEY PICTURES AND
24 INFRINGEMENT, 17 U.S.C. §§
TELEVISION, a Division of The 501(c);
25 Walt Disney Company; WALT
DISNEY TELEVISION 4) INJUNCTIVE RELIEF FOR
26 WILLFUL AND CONTINUING
ANIMATION, a Division of The
27 COPYRIGHT INFRINGEMENT,
Walt Disney Company; WALT 17 U.S.C. § 502(a)
28 DISNEY ANIMATION STUDIOS,
a Division of The Walt Disney
COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS
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Company; DISNEY ENTERPRISES,

1
INC., a Division of The Walt Disney
2 Company; BUENA VISTA HOME
3 ENTERTAINMENT, INC., a
4
California Corporation;
MANDEVILLE FILMS, INC., A
5
California Corporation;, JENNY
6
JURY TRIAL DEMANDED
MARCHICK, An Individual, and
7 DOES 1-10, inclusive
Defendants.
8
9
10
11 Plaintiff Buck G. Woodall, for his complaint against Defendants The Walt
12 Disney Company, Walt Disney Pictures, Walt Disney Pictures and Television, Walt
13 Disney Television Animation, Walt Disney Animation Studios, Disney Enterprises,
14 Inc., Buena Vista Home Entertainment, Inc., Mandeville Films, Inc.; Jenny
15 Marchick and DOES 1-10, claims and alleges as follows:
16 THE PARTIES
17 1. Plaintiff Buck G. Woodall, who also goes by Buck Woodall, is a
18 resident of Baja, Mexico, and Taos, New Mexico. Referred to in this Complaint as
19 "Plaintiff' or "Woodall," Plaintiff is a professional writer as well as a producer and
20 artist.
21 2. Defendant The Walt Disney Company is, and at all times mentioned
22 herein was, a Delaware corporation, qualified to do business in the State of
23 California, with its principal place of business in Burbank, California.
24 3. Defendant Walt Disney Pictures is, and at all times mentioned herein
25 was, a corporation duly organized and existing under the laws of the State of
26 California, with its principal place of business in Burbank, California. Walt Disney
27 Pictures is a subsidiary of Disney Enterprises, Inc., and its primary business activity
28 is the development and production of motion pictures.

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1 4. Defendant Walt Disney Pictures and Television is, and at all times
2 mentioned herein was, a business and juridic entity the exact nature and form of
3 which is currently unknown to Plaintiff, with its principal place of business in
4 Burbank, California. Walt Disney Pictures and Television is referred to by the
5 Defendants as a division of Walt Disney Studios, which is then referred to as a
6 division of The Walt Disney Company. Walt Disney Pictures and Television's
7 primary business activity is the creation of animated feature films and short films.
8 5. Defendant Walt Disney Television Animation is, and at all times
9 mentioned herein was, a business and juridic entity the exact nature and form of
10 which is currently unknown to Plaintiff, with its principal place of business in
11 Burbank, California. Walt Disney Television Animation is referred to by the
12 Defendants as a division of Walt Disney Studios, which is then referred to as a
13 division of The Walt Disney Company. Walt Disney Television Animation's
14 primary business activity is the creation of animated feature films and short films.
15 6. Defendant Walt Disney Animation Studios is, and at all times
16 mentioned herein was, a business and juridic entity the exact nature and form of
17 which is currently unknown to Plaintiff, with its principal place of business in
18 Burbank, California. Walt Disney Animation Studios is referred to by the
19 Defendants as a division of Walt Disney Studios, which is then referred to as a
20 division of The Walt Disney Company. Walt Disney Animation Studios' primary
21 business activity is the creation of animated feature films and short films.

22 7. Defendant Disney Enterprises, Inc. is, and at all times mentioned herein
23 was, a corporation duly organized and existing under the laws of the State of
24 Delaware and qualified to do business in the State of California, with its principal

25 place of business in Burbank, California. Disney Enterprises, Inc. is a subsidiary of

26
The Walt Disney Company, and its primary business activity is the licensing of
intellectual property rights related to motion pictures and television programs
27
produced by its affiliates and/or subsidiaries.
28

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1 8. Defendant Buena Vista Home Entertainment, Inc. is, and at all times
2 mentioned herein was, a corporation duly organized and existing under the laws of
3 the State of California, with its principal place of business in Burbank, California.
4 Buena Vista Home Entertainment, Inc. is a subsidiary of Disney Enterprises, Inc.,
5 and its primary business activity consists of distributing Digital Versatile and Blue-
6 Ray discs of motion pictures produced by affiliated entities.
7 9. At all times material hereto, The Walt Disney Company, Walt Disney
8 Pictures, Walt Disney Pictures and Television, Walt Disney Television Animation,
9 Walt Disney Animation Studios, Disney Enterprises, Inc., Disney+, Walt Disney
10 Studios Motion Pictures, Disney Entertainment and Buena Vista Home
11 Entertainment, Inc. (hereinafter collectively "Disney Entities") were and remain the
12 alter egos of each other and are all dominated and controlled by Defendant The Walt
13 Disney Company such that adhering to any separateness among the Disney Entities
14 would sanction a fraud or promote injustice. Indeed, during all relevant periods,
15 these entities have morphed in and out of separate corporate forms to suit The Walt
16 Disney Company's intention to obstruct and obscure its actual control over all
17 revenues and expenses of these and other Disney Entities. The alter ego
18 relationships are established and proven based at least on the following facts and
19 circumstances:
20 a. It is the express intention of The Walt Disney Company that none of
21 these Disney Entities shall have a separate and independent existence,
22 and in fact none of these entities are treated as having any separate
23 independence apart from The Walt Disney Company.
24 b. Instead, it is the intention of The Walt Disney Company that all of the
25 Disney Entities exist for the sole and exclusive purpose of hiding
26 documents, hiding evidence, hiding money and masking the modus
27 operandi of The Walt Disney Company, during all times material
28

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 3

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1 hereto, of stealing and pirating the intellectual property of others,

2 including Plaintiff.
3 c. The foregoing has been the intention of The Walt Disney Company
4 regarding all of its related Disney Entities for at least the last two
5 decades, with its public securities filings discussing or listing the
6 foregoing Disney Entities as having varying functions from time-to-
7 time which are inconsistent from day-to-day and from year-to-year,
8 thus forming a tapestry of confusion meant by The Walt Disney
9 Company to be in fact a tapestry of confusion done for unlawful means.
10 For example, with the purpose of hiding documents and concealing
11 theft, The Walt Disney Company and those people acting as agents
12 thereof have loosely used the term "Disney TV" throughout public
13 records and even during litigation regarding the case at bar (a) to at
14 times to refer to Disney Studios, (b) to at times to refer to Walt Disney
15 Pictures and Television, (c) to at times to refer to Walt Disney
16 Television Animation and (d) to at times to refer to none of the above.
17 d. The alter ego nature of the Disney Entities has continued in varying
18 litigation matters where The Walt Disney Company uses the alter ego
19 status of the foregoing entities to hide documents by alleging one
20 portion of the alter ego bevy of entities possesses documents where
21 other portions of the alter ego do not possess documents. This is done
22 intentionally by The Walt Disney Company to hide evidence and fail
23 and refuse to produce documents in response to court orders. Because
24 of the alter ego status, The Walt Disney Company's intention is to
25 avoid contempt or sanctions awards by claiming one alter ego has fully
26 complied with its legal obligations while knowing that other alter ego
27 entities have not complied.
28

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1 e. In truth and in fact, there is no separateness in fact of any of the Disney

2 Entities.
3 f. In truth and in fact, all of the Disney Entities have been dominated and
4 controlled by The Walt Disney Company, at all times material hereto,
5 to the point that all of the Disney Entities are the alter ego of The Walt
6 Disney Company in innumerable ways, including (i) The Walt Disney
7 Company controls bank accounts of the Disney Entities, (ii) The Walt
8 Disney Company controls staff choices of the Disney Entities, (iii) The
9 Walt Disney Company controls day-to-day operations of the Disney
10 Entities, (iv) The Walt Disney Company controls staffing of the Disney
11 Entities, (v) The Walt Disney Company controls choices and business
12 purposes of each of the alter ego Disney Entities, (vi) The Walt Disney
13 Company controls the decision whether or not any one or more of the
14 Disney Entities shall continue in existence, (vii) The Walt Disney
15 Company controls the receiving of credits for films and projects among
16 the Disney Entities, (viii) The Walt Disney Company controls the hiring
17 of counsel for each of the Disney Entities, (ix) each of the Disney
18 Entities besides The Walt Disney Company are undercapitalized to
19 justify their existence being treated as anything other than a shill of The
20 Walt Disney Company, (x) the Disney Entities have commingled funds,
21 shared bank accounts, intermingled finances, used funds of one of the
22 entities to pay debts of the others without any rhyme or reason as
23 discussed in the public filings of The Walt Disney Company, (xi)
24 revenues and receipts from the Disney Entities' unlawful activities have
25 been diverted in order to hide the truthful persons involved in the
26 transactions and in order to hide the existence of money-flow for
27 purposes of avoiding legal liability, (xii) the Disney Entities regularly
28 fail to hold organizational meetings or otherwise conduct business as
lawful juridic entities are required to do, (xiii) the Disney Entities lack
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1 possession of required business and financial records as required by

2 law and under general accepted accounting principles, (ix) the Disney
3 Entities fail to maintain separate records while also failing to maintain
4 separate identities when their schemes call for such separateness, (x)
5 the Disney Entities have created public confusion regarding their
6 separate existence through the use of confusing logos and email
7 domains that blur the line of separateness between the Disney Entities,
8 (xi) management and control of the Disney Entities overlaps to such an
9 extent that key individuals hold roles in various Disney Entities,
10 effectively running multiple entities as a single or combined business
11 unit, (xii) staff are employed by all of the Disney Entities without clear
12 distinctions in their roles or responsibilities, (xiii) all business decisions
13 involving the Disney Entities favor the interests of the dominant entity,
14 The Walt Disney Company, even to the detriment of the balance of the
15 Disney Entities, (xiv) the Disney Entities Both operate out of the same
16 physical locations without appropriate rental or lease agreements, (xv)
17 the Disney Entities share equipment, assets, vehicles and intellectual
18 property is used interchangeably without any documentation of any
19 kind or even a trail of proof regarding where the initial development or
20 ownership of such assets may lie, (xvi) the Disney Entities frequently
21 advance money to or for the benefit of each other without properly
22 documenting loans between the entities let alone guaranteeing the debts
23 of the other, (xvii) The Walt Disney Company uses the Disney Entities
24 to evade legal obligations and to mask legal exposure, (xviii) The
25 Disney Entities are effectively operating as one enterprise but attempt
26 to present themselves as separate to shield liability, to shield improper
27 behavior and to create injustice and (xix) because of the foregoing, the
28 public perceives the Disney Entities as one entity because of indistinct
branding or lack of transparency as well as the public perceptions

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1 created by the Disney Entities' own branding and internet-based

2 campaigns and presentations.
3 g. Through the unprecedented confusion created by the innumerable trade
4 names given to the various Disney Entities and as a result of the
5 foregoing interrelationships and wrongdoing, The Walt Disney
6 Company has the intention of getting away with theft, secretion of
7 evidence and other wrongdoing by confusing the issues and hoping for
8 obfuscation and delay as a business stratagem to insulate against its
9 theft and bad faith.
10 10. Defendant Mandeville Films, Inc. was, and at all times mentioned
11 herein, a California corporation with its principal place of business in Los Angeles
12 County, California. Mandeville Films' primary business activity was the
13 development and production of motion pictures. Mandeville Films, Inc. is referred
14 to hereinafter as "Mandeville."
15 11. Defendant Jenny Marchick is an individual who resides in Los Angeles
16 County, California. She is referred to hereinafter as "Marchick."
17 12. Plaintiff is ignorant of the true names and capacities of Defendants
18 named in this complaint as DOES I through 10 and sues said Defendants by such
19 fictitious names. Plaintiff will amend this complaint to allege their true names and
20 capacities when they have been ascertained. Plaintiff is informed and believes, and
21 on that basis, alleges that each of the fictitiously named Defendants is responsible in
22 some manner for the occurrences alleged in this Complaint, and that Plaintiffs
23 damages as alleged in this Complaint were proximately caused by their conduct, or
24 that such Defendants ratified or participated in the conduct causing such damages.
25 13. At all times material hereto, each of the Defendants named in this
26 Complaint was acting as the agent, employee, independent contractor, representing
27 partner, or joint-venturer of the remaining Defendants with respect to the
28 conspiratorial scheme set forth herein. In doing the things set forth in this Complaint,
each of the Defendants was further acting within the course and scope of that
COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 7
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1 relationship. Each of the Defendants in this action willfully gave consent to, ratified,
2 aided-and-abetted and authorized the unlawful acts of the remaining Defendants as
3 alleged in this Complaint.
4 14. Defendants, and each of them, are individually sued as participants and
5 aiders and abettors in the wrongful conduct complained of in this Complaint, and
6 the liability of each Defendant arises from the fact that each has engaged in all or
7 part of the improper acts, plans, schemes, conspiracies, or transactions complained
8 of herein with a purpose of furthering the Defendants' overall wrongful objectives.
9 15. During their engagement in the wrongful conduct alleged in this
10 Complaint, each of the Defendants acted in concert with one another, intentionally
11 orchestrating and executing a calculated scheme designed to defraud, injure, and
12 irreparably harm Woodall. The Defendants, acting as co-conspirators and joint
13 venturers, participated in a fraudulent enterprise that encompassed the theft,
14 misappropriation, and extensive exploitation of Woodall's copyrighted materials,
15 intellectual property, and trade secrets as set forth in this Complaint. This conspiracy
16 was marked by a web of coordinated actions, including but not limited to: deliberate
17 misrepresentations to deceive Woodall; systematic concealment of critical evidence;
18 covert meetings to plan their infringing activities; and the distribution of stolen
19 materials across various platforms, thereby maximizing their illicit profits at
20 Woodall's expense.
21 16. The Defendants' conspiracy extended to publishing a new infringing
22 motion picture right under this Court's jurisdiction while intentionally disregarding
23 and actively violating this Court's orders compelling the disclosure of relevant
24 documentation and information, including that associated with Moana 2. In
25 furtherance of their scheme, the Defendants not only failed to produce the mandated
26 evidence as ordered by this Court, but also engaged in efforts to secrete, destroy, or
27 alter incriminating documents and digital files to further secrete the evidence. These
28 acts were undertaken with the singular purpose of obstructing justice and evading

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1 accountability, all while reaping billions of dollars in unlawful profits, and none of
2 which could have been achieved without the carefully planned conspiracy alleged
3 herein as well as the carefully implemented domination and control by The Walt
4 Disney Company over the entire process through its alter ego control over the
5 Disney Entities.
6 17. In addition, the conspiracy included fraudulent inducement and the
7 exploitation of third parties, including distributors, marketers, and digital platforms,
8 to facilitate the dissemination of the infringing works in violation of the Copyright
9 Act. The Defendants actively coordinated their actions, sharing resources,
1O proprietary technologies, and insider knowledge to ensure the success of their
11 scheme. The conspiracy also featured clandestine communications through
12 encrypted channels, fake shell companies to launder proceeds, and the deliberate
13 falsification of corporate records to conceal their wrongful activities.
14 18. The Defendants' conduct further involved threats, coercion, and
15 intimidation aimed at silencing whistleblowers, employees, and any individuals who
16 might expose their infringing activities. The conspiracy also included efforts to
17 manipulate public perception, including issuing false press releases, leveraging
18 industry relationships to stifle competition, and employing sophisticated public
19 relations strategies to undermine Woodall's credibility.
20 19. This concerted and highly orchestrated action among the Defendants
21 constitutes a civil conspiracy to inflict deliberate harm upon Woodall, according to
22 proof. Their actions reflect a flagrant disregard for intellectual property rights, the
23 rule of law, and this Court's authority. This conspiracy fully justifies a finding of
24 willful copyright infringement, an award of enhanced statutory damages, and
25 injunctive relief pursuant to 17 U.S.C. §§ 50l(c) and 502, as well as other equitable
26 relief sought in this Complaint.
27
JURISDICTION AND VENUE
28 20. This Action arises under Acts of Congress relating to copyright
infringement under 17 U.S.C. §§ 501, et seq.
COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 9
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1 21. This Court has subject matter jurisdiction over this action pursuant to
2 28 U.S.C. § 1331, as it arises under the laws of the United States, and 28 U.S.C. §
3 1338(a), which grants exclusive jurisdiction to federal courts over claims arising
4 under the Copyright Act.
5 22. The Court has personal jurisdiction over all Defendants, and venue is
6 proper in this Court pursuant to 28 U.S.C. § 139l(b) and other applicable law,
7 because, inter alia: (a) all corporate Defendants named in this Complaint maintain
8 their principal place of business in Los Angeles County, California; (b) all individual
9 Defendants named in this Complaint reside in this district; and (c) the acts and
10 omissions giving rise to the claims alleged herein occurred within this district, where
11 the individual Defendants were employed by the corporate Defendants.
12 NATURE OF THE CASE
13
23. This case arises from a two-decade-long scheme masterminded by
14
Marchick but ultimately joined in with malice and for profit by all Defendants
15
pursuant to the aforementioned conspiracy described in this Complaint. The scheme
16
started out as a plan by Marchick to support her thirst to gain success in her desired
17
career in the movie industry, at all costs, by working with the Defendants to steal all
18
the components of Plaintiffs Copyrighted Materials, as that term is defined in this
19
Complaint. This theft resulted in what would eventually become one of the most
20
unique and profitable animated film franchises in motion picture history revolving
21
around Plaintiffs Copyrighted Materials and directly resulting in the Disney
22
franchise known as Moana. The core of the entire Moana franchise is Plaintiffs
23
Copyrighted Materials. The Moana franchise resulted in the motion picture Moana
24
I, which Disney ultimately produced and released theatrically in November 2016.
25
It then resulted in the distribution of Moana I into secondary markets throughout
26
2017 and 2018, including home distribution. And the franchise then most recently
27
resulting in a sequel called Moana 2, released within 30 days of filing this
28
Complaint. This Moana franchise, which was developed off the back of Plaintiffs

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1 Copyrighted Materials and while the Defendants intentionally stole and utilized
2 these Copyrighted Materials acting as if the Defendants themselves owned them,
3 has garnered for the Defendants more than $10 billion in profits as of the date of
4 filing this Complaint.
5 24. The theft scheme has now been largely admitted to by the Defendants
6 in the pending case styled Buck G. Woodall v. The Walt Disney Company, etc. et al.,
7 Case No. 2:20-cv-03772-CBM-E (hereinafter "Woodall v. Disney I"). For example,
8 in Woodall v. Disney I, while dismissing some defendants on statute of limitations
9 grounds solely involving the 2016 theatrical release of Moana I, this Court found as
10 a matter of law that Defendant Jenny Marchi ck - who had received Plaintiffs
11 Copyrighted Materials in confidence from Plaintiff nearly 20 years ago - admitted
12 under oath that she (Marchick) provided the Copyrighted Materials "to ... an
13 individual at Disney Animation TV" prior to the beginning of the development of
14 the 2017 Moana motion picture. Id., Dkt. No. 558, page 19. The Court also found
15 triable issues of fact regarding both substantial similarity and striking similarity
16 between Plaintiffs Copyrighted Materials, on the one hand, and Moana I, on the
17 other hand. Id., at page 22, n. 15, and page 24.
18 25. Although the Defendants were subject to two of this Court's orders in
19 Woodall v. Disney I compelling the Defendants to produce all materials involving
20 or relating to the character named Moana, and although the Defendants stipulated
21 before this Court on August 22, 2023 to produce all such materials, the Defendants
22 - and each of them - defrauded this Court and violated the two orders of this Court
23 by suppressing hundreds of thousands of pages of responsive materials regarding
24 the character Moana' s development in connection with a brand new motion picture
25 called Moana 2, which film was theatrically released on November 26, 2024. At the
26 time the Defendants intentionally defrauded Plaintiff and this Court while knowing
27 that the responsive documentation it was secreting utilized all of Plaintiffs
28 Copyrighted Materials, the Defendants repeatedly represented that they had
produced all responsive documents regarding the character Moana when in truth and
COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 11
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1 in fact they knew that they were secretly developing images and documents daily
2 that were continuing to infringe upon Plaintiffs Copyrighted Materials. According
3 to proof, the foregoing illegal conduct by the Defendants has been identical to the
4 willful plan of infringement that they have utilized for the past two decades regarding
5 Plaintiffs Copyrighted Materials in launching the Moana franchise. The foregoing
6 fraud on this Court by the Defendants resulted from the Defendants' willfully
7 malicious motives, according to proof, leading to enhanced damages pursuant to
8 applicable law.
9 26. Plaintiff Buck G. Woodall now proceeds with this Complaint to recover
10 the billions of dollars of profit realized by the Defendants' decision to create
11 unauthorized derivative works of the Copyrighted Materials, without permission
12 and indeed utilizing actual malice and bad faith, in violation, inter alia, of 17 U.S.C.
13 § 106(2) which expressly provides that the copyright owner "has the exclusive
14 rights ... to prepare derivative works based upon the copyrighted work." Because
15 this Court has already found as a matter of law that Woodall is the owner of the
16 Copyrighted Materials - Woodall v. Disney I, Dkt. No. 558, page 16, Plaintiff now
17 proceeds with his causes of action for violations of the Copyright Act and presents
18 the following allegations.
19 ALLEGATIONS COMMON TO ALL COUNTS
20 Moanal
21
27. Disney's M oana I was produced in the wake of Woodall' s deli very to
22
the Defendants of virtually all constituent parts necessary for its development and
23
production after more than I 7 years of inspiration and work on his animated film
24
project with titles over the years ranging from "Bucky" to "Bucky the Wave Warrior"
25
(hereinafter "Bucky"). This project was inspired by Woodall's unique exposure to
26
Polynesian culture -- including living on Hanalei Bay for approximately a decade -
27
- as well as his expenditure of more than $500,000.00 in personally creating, writing
28
and developing a theatrical motion picture package associated with Bucky.

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1 Woodall's purpose in constructing the package was to gear it toward presentation to

2 major constituents and distributors within the animated movie industry. What
3 Woodall ultimately developed included major and unique themes, a complete
4 screenplay, distinctive character development and illustrations, as well as
5 comprehensive budgets for an animated film that was extraordinarily singular in
6 plot, sequence of events, themes, dialogue, mood and pace, settings and characters.
7 All of these features developed by Woodall with respect to Bucky were qualitatively
8 and quantitatively unique and distinctive, are referred to in this Complaint as the
9 "Presentation Package" and are comprised substantially of the materials a true and
10 correct copy of which are appended hereto as Exhibit "A."
11 28. In addition to registering both Bucky and the Presentation Package with
12 the Writers Guild of America, as is customary for professional writers in the motion
13 picture industry, portions of the Presentation Package were also granted Federal
14 Copyright protection by the United States Patent and Trademark Office in 2004 and
15 updated in 2014, containing approximately 203 pages of materials. This Court has
16 already ruled as a matter of law that Plaintiff indeed owns all of these copyrighted
17 materials, true and correct copies of which are collectively appended hereto as
18 Exhibit "B" and are referred to in this Complaint as "Copyrighted Materials." The
19 "Copyrighted Materials" also include a trailer Woodall delivered to the Disney
20 Entities, which is copyrighted and owned by Woodall and has been infringed on in
21 connection with the Defendants' conspiracy to publish portions of its Moana
22 franchise, including the motion picture known as Moana 2.
23 29. Woodall initially began interactions with Marchick regarding Bucky in
24 the early 2000s. Woodall was always careful to protect his ownership over all of his
25 intellectual property, trade secret ideas and materials developed pursuant thereto,
26 including, but not limited to, all elements of the Presentation Package. From the
27 first time he shared his Copyrighted Materials with Marchick, Woodall insisted that
28 Marchick commit to maintain the materials in confidence and Marchick consented
to do so. Plaintiffs filings with the Copyright Office were done in order to assure
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1 his ultimate protection over his Copyrighted Materials regardless of anybody's

2 nefarious intentions toward what had become his life's work.
3 30. From and after October of 2003, Woodall provided in confidence to
4 Marchick extremely large quantities of intellectual property and trade secrets
5 associated with Bucky. At all times thereafter, and totally ignorant of Marchick's
6 and the Defendants' fraudulent scheme set forth in this Complaint, Woodall
7 reasonably believed Marchick to be acting in good faith and respecting the
8 ownership by Woodall of his intellectual property and trade secrets associated with
9 Bucky.
10 31. In or about January of 2005, following Marchick's prodding of Woodall
11 to deliver more material regarding Bucky and her repeated assurances that she could
12 and would assist in commercializing the film, Woodall completed all or substantially
13 all of the content of what is attached hereto as Exhibit A as the Presentation Package
14 and delivered it to Marchick at Mandeville's offices located within the Disney studio
15 facilities in Burbank, California. Marchick was employed at the time by Mandeville,
16 which had a "first look" deal with Disney, which is a favored and highly sought-
17 after relationship from the standpoint of an independent producer for the possible
18 production and distribution of a theatrical feature product by a major studio. At the
19 meeting, Marchick told Woodall in words or substance that she would get the
20 Presentation Package "to the right people."
21 32. After Marchick's review of the Presentation Package shortly following
22 the January 2005 meeting, Marchick prodded Woodall to produce and provide to
23 Mandeville an animated trailer of the Presentation Package by continuing to assure
24 Woodall that Marchick could and would obtain successful commercialization of
25 Woodall's ideas. During the two years that followed this inducement, Woodall
26 worked on and completed a comprehensive animated trailer at his own cost and
27 expense and Woodall then provided the trailer to Marchick and Mandeville in or
28 about the middle of 2008. This trailer is copyrighted and owned by Woodall,

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1 registered as copyright-protected material pursuant to the laws of the United States

2 of America.
3 33. Later during this period, at Marchick's prodding and inducement,
4 Woodall also provided Mandeville and Marchick, in addition to an updated fully
5 animated concept trailer, with storyboards on a DVD, which at the time contained
6 background image references, story development, character illustrations, executive
7 summary, and other constituents to develop the film.
8 34. Based upon Marchick's continuing fraud, deceit and prodding him to
9 deliver script materials, Woodall then worked on completing his script for
10 submission to Marchick. Because of the intimate association with Disney regarding
11 the development of the project, Woodall was assisted by Kurt Weldon, a writer
12 affiliated with Disney, in completing the animated trailer. Always vigorous in
13 protecting his intellectual property and trade secrets associated with Bucky, Woodall
14 required Weldon to also sign a confidentiality agreement before providing Weldon
15 with access to and the right to work on the Bucky script. Weldon signed the
16 confidentiality agreement and provided it to Woodall through Buck Creations
17 Multimedia on November 18, 2006. After Woodall and Weldon completed the final
18 draft script in July 2011, Woodall sent Marchick a copy of it while she was then
19 working as a "Consultant, Original Movies" at Disney. Unbeknownst to Woodall at
20 the time, the script Marchick prodded Woodall to complete was virtually the final
21 cog in the Defendants' conspiratorial machinery of stealing Bucky and developing
22 Moana.
23 35. During this period, Marchi ck secretly provided the Copyrighted
24 Materials to the Disney Defendants. On the eve of the release of Moana I, Marchick
25 told Plaintiff that she was unaware of whether the Copyrighted Materials were ever
26 provided to anyone and indeed Marchick claimed in writing that she was unsure
27 whether these materials ever "made it beyond" her desk. Marchick' s representation
28 to Woodall in this regard was knowingly false at the time it was made and was

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 15

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 17 of 33 Page ID #:17

1 insinuated by Marchick in order to protect the Defendants' desires to exploit a

2 franchise surrounding their theft of the Copyrighted Materials.
3 36. The Disney theatrical animated feature film Moana was released into
4 theatrical distribution in November 2016, depicting similarities to the trade secrets
5 and intellectual property of the Presentation Package materials that are
6 extraordinarily stark and greater than most every reported example of copyright
7 infringement in U.S. history. With incredible and often breathtaking scope and
8 breadth, the similarities in the scripts and all materials surrounding the two stories
9 include, but are not limited to, the following duplications which could not possibly
10 have been accidental or innocent in derivation:
11
a. Both Bucky and Moana tell the story about a teenager who defies
12 parental warnings and embarks on a dangerous voyage across
13 Polynesian waters to save the endangered land of a Polynesian island;
14 b. Both Bucky and Moana celebrate what the Bucky script refers to as the
15 Polynesian people's "unfettered access to the sea [as] a native right;"
16 c. Both Bucky and Moana involve protagonists who learn about ancient
17 Polynesian culture during a sea voyage;
18 d. Both Bucky and Moana contain a recurring theme of the Polynesian
19 belief in spiritual ancestors, to wit: ancient spirits manifested as animals
20
which guide and guard the living;
21 e. Both Bucky and Moana have as the backdrop an ancient Polynesian
22 village with its inhabitants weaving baskets, fishing, pounding taro,
23 and telling stories of ancient Polynesia;
24 f. Both Bucky and Moana comprise an opening scene which is a flight
25 into an island;
26
g. Both Bucky and Moana have as a part of its opening sequence the
27
protagonist being as a baby at the Polynesian beach facing destiny;
28

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 16

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 18 of 33 Page ID #:18

1 h. Both Bucky and Moana involve a journey by the main character which
2 starts with a turtle;
3 1. Both Bucky and Moana involve plots where a symbolic necklace plays
4 a special role;
5 J. Both Bucky and Moana incorporate the concept of sea navigation by
6 the stars;
7 k. Both Bucky and Moana involve a main character who specifically
8 encounters a goddess-like creature emanating from volcanic lava;
9 1. Both Bucky and Moana involve a main character who encounters a
10 demigod with a giant hook and tattoos;
11 m. Both Bucky and Moana introduce the demigod in a dark cave;
12 n. Both Bucky and Moana involve the demigod turning into different
13 creatures including a Polynesian hawk and a shark;
14 o. Both Bucky and Moana involve characters shapeshifting into bugs;
15 p. Both Bucky and Moana involve the main character surviving a storm
16 on the sea;
17 q. Both Bucky and Moana involve a protagonist who also faces an army
18 of small-armored warrior characters;
19 r. Both Bucky and Moana involve the protagonist encountering a
20 whirlpool in the ocean;
21 s. Both Bucky and Moana involve a giant creature that is concealed within
22 a mountain and actually lies down and takes the mountain's shape;
23 t. Both Bucky and Moana conclude with the teenager returning as a hero
24 to the parents on the island, having saved it from destruction; and
25 u. Both Bucky and Moana contain striking similarities in the animated

26 visual depictions used in the productions, including, by way of

27 example, the face of the goddess of creation/lava creature and the
28 location and surroundings of the island.

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 17

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 19 of 33 Page ID #:19

1 37. In Woodall v. Disney I, the Defendants consistently - in writing on

2 innumerable occasions and in filings before the Court - refused to produce any
3 documents or information of any kind other than documents or information
4 possessed by Walt Disney Animation Studios. This Court repeatedly ordered the
5 Defendants, and each of them, to produce all responsive documents which included,
6 inter alia, all information and materials regarding the character Moana. This Court
7 refused to hold the Defendants accountable in any way, shape or form and permitted
8 the Defendants to only conduct a full search with respect to the archives of Walt
9 Disney Animation Studios for documents. This Court made such rulings on
1o numerous occasions so repetitive as to be significant in the context of any litigation
11 (far more than simply a couple of court orders). Despite protecting the Defendants'
12 stated desire to not search for documents, however, this Court was unable at
13 summary judgment to make any ruling other than that the issues of substantial
14 similarity, striking similarity and access must go to the jury because they presented
15 triable issues of fact as a matter of law. See generally, Dkt. No. 558.
16 38. Although this Court's summary judgment order in Woodall v. Disney
17 J dismissed, on statute of limitations grounds, all claims regarding the initial
18 theatrical distribution of Moana I that took place in late 2016, Plaintiff had predicted
19 in that matter and in the operative complaint therein that the Defendants' intention
20 all along was to develop a longstanding, multi-billion-dollar franchise utilizing the
21 Copyrighted Materials. In other words, the case at bar was fully predicted by Plaintiff
22 in the operative complaint in Woodall v. Disney I, and no judicial sanction of a party
23 openly hiding responsive documents in discovery can fully get around the detailed
24 provisions of the Copyright Act, including its protection of a Copyright owner like
25 Plaintiff so that his right to prepare all derivative works is sacrosanct. The carefully
26 laid plans of the Defendants and others associated with Woodall v. Disney I have
27 been substantially arrested by the new release of Moana 2.
28 Moana 2

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 18

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 20 of 33 Page ID #:20

l 39. On November 26, 2024, Defendants - in furtherance of their

2 conspiracy to maximize the profits from the theft of Plaintiffs Copyrighted
3 Materials and after suppressing the truth from this Court despite multiple orders by
4 this Court compelling production, after contempt proceedings and after defrauding
5 this Court by representing that all documents appertaining to the character Moana
6 had been produced - effectuated the theatrical release of the motion picture known
7 as Moana 2. Promotional materials, trailers, and plot summaries for the film admit
8 that the sequel continues to misappropriate Plaintiffs Copyrighted Materials,
9 characters, and plot devices as well as all other motifs from Plaintiffs Copyrighted
1o Materials that have been part and parcel of Woodall v. Disney I.
11 40. Specifically, "Moana 2" blatantly copies core elements of Plaintiffs
12 works, presenting strikingly similar themes, character journeys, and imagery as
13 those set forth in the Copyrighted Materials. These similarities in Moana 2, which
14 go beyond superficial resemblance and indicate direct infringement, include but are
15 not limited to the following:
16 a. Moana once again embarks on a daring voyage on an outrigger canoe,
17 a central motif of Plaintiffs Presentation Package as included in the
18 Copyrighted Materials;
19 b. Moana once again voyages across the vast Oceanic waters accompanied
20 by a crew, mirroring Bucky's own journey in Plaintiffs Copyrighted
21 Materials;
22 c. This time, Moana's companions on the canoe include both the pig and
23 the rooster, an image uncannily similar to one found in Plaintiffs
24 Copyrighted Materials depicting a similar dynamic and actually
25 representing even a more stark similarity than the infringement
26 represented by Moana I;
27
28

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 19

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 21 of 33 Page ID #:21

1 d. Moana sets out in search of an ancient and mysterious island, echoing

2 the central quest in Plaintiffs work as protected by Plaintiffs
3 Copyrighted Materials;
4 e. Moana undertakes a mission to break a curse, directly paralleling
5 narrative elements that Plaintiff uniquely developed in his Presentation
6 Package and as set forth in the Copyrighted Materials;
7 f. During her journey in Moana 2, Moana and her crew are sucked into
8 a perilous whirlpool-like oceanic portal, another dramatic and unique
9 device-imagery found in Plaintiffs materials that could not possibly
10 have been developed by chance or without malicious intentions on the
11 part of the Defendants;
12 g. Moana and her crew expenence profound connections with their
13 ancestors, a recurring and spiritual theme central to Plaintiffs story;
14 h. Moana and her crew once again encounter the "kakamora," a tribe of
15 tiny armored warriors whose depiction aligns with the small warrior
16 characters described in Plaintiffs Presentation Package;
17 1. Moana engages in time-travel, both to the past and to see her ancestors
18 as well as to a predicted future;
19 J. Moana shapeshifts several times into tiny bugs;
20 k. Moana is shown climbing a mountain as part of her journey, yet another
21 visual and thematic element originating in Plaintiffs materials;
22 I. Moana continues to wear the symbolic necklace central to her character
23 and actually expands the timing and usage of the necklace, further
24 infringing on Plaintiffs concept of a significant artifact with spiritual
25 and narrative importance; and
26 m. Displaying demonstrating overt defiance toward this Court's
27 jurisdiction and the Copyright Act, the Defendants even installed in
28 Moana 2 the imagery of surfing the waves, identical in motif and
imagery to the story depicted in Bucky the Wave Warrior.
COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 20
Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 22 of 33 Page ID #:22

1 41. In addition to the foregoing specific instances of copying, Moana 2

2 perpetuates the wholesale appropriation of other significant elements from
3 Plaintiffs work, including:
4 a. The integration of Polynesian mythological figures into the plot, in
5 ways that align with Plaintiffs specific depiction of such figures in his
6 Presentation Package.
7 b. The continued portrayal of the ocean as a sentient spirit, a concept
8 distinctly developed and copyrighted by Plaintiff.
9 c. The use of shapeshifting as a recurring narrative and visual device, an
10 idea originally and uniquely articulated in Plaintiffs work.
11 42. The foregoing elements, taken collectively, represent an egregious
12 pattern of infringement, as Defendants now knowingly and willfully persist in
13 exploiting Plaintiffs Copyrighted Materials and intellectual property to their own
14 financial benefit.
15 43. Plaintiff has suffered and will continue to suffer irreparable harm,
16 including loss of recognition, financial damages, and the emotional toll of witnessing
17 the systematic exploitation of his original creations.
18 44. Defendants' production and promotion of Moana 2 constitute ongoing
19 acts of copyright infringement, appropriating Plaintiffs original works without
20 authorization or compensation.
21
45. The Defendants' inclusion into Moana 2 of the elements detailed above
22
demonstrates deliberate and intentional copying and adaptation of Plaintiffs
23
materials. Defendants acted with full knowledge of Plaintiffs rights, as already
24
explicitly set forth and demonstrated from an evidentiary standpoint in Woodall v.
25
Disney I. Despite this, Defendants have brazenly chosen to proceed in clear defiance
26
of their legal obligations. This calculated disregard reflects an apparent belief by the
27
Defendants that their actions will somehow be shielded by this Court, a perception
28
likely rooted in the history of judicial outcomes favoring Disney in Los Angeles

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 21

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 23 of 33 Page ID #:23

1 County, California. Such conduct not only underscores Defendants' lack of respect
2 for the judicial process but also suggests an expectation of insulation from
3 accountability-a belief that threatens the very integrity of copyright protections
4 and the principles of fairness in this forum.
5 46. Plaintiff has suffered substantial damages, including lost opportunities
6 for financial gain, diminished value of his intellectual property, and profound
7 reputational harm as a result of Defendants' actions.
8 FIRST CAUSE OF ACTION
9
(Copyright Infringement, 17 U.S.C. § 50l(a) - Against All Defendants)
10
47. Plaintiff incorporates paragraphs 1 through 46 of this Complaint as
11 though fully set forth at length.
12
48. Plaintiff has duly complied with all statutory formalities of the
13 Copyright Act of 1976 with respect to the registration of protectible elements of
14 Bucky, of the Presentation Package and of the underlying work, all of which are the
15 subject of U.S. Registration No. VAu 000624809 and PAu 003749546, collectively
16 Exhibit "B" hereto and of all Copyrighted Materials, according to proof. (All such
17 protected materials are referred to in this Complaint as "Copyrighted Materials.")
18 49. On November 26, 2024, this Court found as a matter of law that
19 Plaintiff owns all of the Copyrighted Materials and that the Defendants own no
20 portion of the Copyright Materials, Woodall v. Disney I, Case No. 2:20-cv-03772-
21 CBM-E, Dkt. No. 558.
22 50. The foregoing acts by Defendants in and with respect to the theatrical
23 release of Moana 2, as specifically set forth in this Complaint, constitute
24 unauthorized copying, reproduction, distribution, display, licensing, sale and
25 commercial exploitation of Plaintiffs copyrighted work, as reflected in U.S.
26 registration no. VAu 000624809 and PAu 003749546, which infringe Plaintiffs
27 exclusive rights in violation of the Copyright Act of 1976, 17 U.S.C. § IOI et seq.
28

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 22

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 24 of 33 Page ID #:24

1 51. Defendants' infringing works in and with respect to Moana 2 copy

2 quantitatively and qualitatively distinct, important, and recognizable portions of
3 Plaintiffs copyrighted work.
4 52. Such infringement of Plaintiffs copyrighted work includes
5 Defendants' copying of the literal elements of Plaintiffs copyrighted work including
6 the major themes and ideas, script outline, character development, illustrations and
7 budgets.
8 53. Defendants and each of them did not seek or receive permission or
9 consent from Plaintiff to copy any portion of Plaintiffs Copyrighted Materials, and
10 did so willfully, maliciously and intentionally.
11
54. Defendants' conduct has at all times been knowing, willful, and with
12 complete disregard for Plaintiffs rights.
13
55. As a proximate and foreseeable result of Defendants' wrongful conduct,
14
Plaintiff has been irreparably harmed and will continue to sustain injury and damage
15
unless Defendants and each of them are enjoined.
16
56. The inclusion of signature elements of Plaintiffs Copyrighted
17
Materials greatly enhances the financial value of Defendants' infringing products
18
associated with Moana 2.
19
57. As a result of Defendants' copyright infringement set forth in this Cause
20
of Action, Plaintiff is entitled to his actual damages and profits in the sum of more
21
than $4 billion, according to proof either upon entry of summary judgment in
22
Woodall's favor or at trial before a duly impaneled jury.
23
24
58. From the date of first production of Defendants' infringing works

25
regarding Moana 2, the Defendants have infringed Plaintiffs copyright interests in
his copyrighted work, including by: (a) authorizing the reproduction, distribution
26
and sale of the infringing and/or distributing Defendants' infringing works through
27
various sources; (b) copying and displaying the infringing works in related
28
marketing and promotional materials for the sale of the infringing works; and (c)

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 23

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 25 of 33 Page ID #:25

1 participating in and furthering the aforementioned infringing acts, and/or sharing in

2 the proceeds therefrom, all through substantial illegal use of Plaintiffs copyrighted
3 work alleged in this Complaint.
4 59. With knowledge of the aforementioned infringement, each Defendant
5 has induced, caused or materially contributed to the infringing conduct of each other,
6 such that each and all should be found to be contributorily liable for the acts of the
7 others separate and apart from their alter ego and conspiratorial status alleged in
8 detail in this Complaint.
9 60. Defendants and each of them had the right and ability to control other
10 infringers and have derived a direct financial benefit from that infringement such
11 that Defendants and each of them also should be found to be vicariously liable.
12 61. The infringement is continuing as the infringing products continue to
13 be produced and sold or licensed by Defendants, while unwitting customers continue
14 to purchase or license from Defendants the stolen and infringed work and related
15 products.
16
62. Defendants' conduct is causing and, unless enjoined by this Court, will
17
continue to cause to Plaintiff, as well as the innocent buyers or licensees of
18
Defendants' infringing products, irreparable injury that cannot fully be compensated
19
for or measured in monetary terms; Plaintiff has no adequate remedy at law.
20
63. As a result of the aforesaid infringement regarding the release of Moana
21
2, Plaintiff has suffered and will continue to suffer substantial injury, loss and
22
damages to his ownership rights in Plaintiffs copyrighted work. Defendants have
23
unlawfully derived and will continue to derive income and profits from the
24
infringing acts thereby unjustly enriching themselves to the detriment of Plaintiff.
25
As a direct and proximate result of the conduct of Defendants, and each of them,
26
Plaintiff has suffered actual damages including lost profits, lost opportunities, and
27
loss of goodwill, in an amount well in excess of two-point-five percent (2.5%) of all
28
gross revenue earned by Disney from Moana 2 the feature film and all products

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 24

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 26 of 33 Page ID #:26

1 derived thereof, an exact amount to be proven at trial, which damages are

2 recoverable separate and apart from all other damages inuring in Plaintiffs favor.
3 SECOND CAUSE OF ACTION
4 (Continuing Copyright Infringement Under 17 U.S.C. § 106 and§ 501 - against All
5 Defendants)
6
64. Plaintiff incorporates paragraphs 1 through 63 of this Complaint as
7
though fully set forth at length.
8
65. Defendants' conduct over the past two decades constitutes continuing
9
copyright infringement Pursuant to the Copyright Act, 17 U.S.C. § 106 and§ 501,
10
by repeatedly exploiting Plaintiffs Copyrighted Materials without authorization
11
through the creation, distribution, and promotion of Moana 2 and related derivative
12
works following what has already been admitted by the Defendants to be the
13
transference and receipt of Plaintiffs Copyrighted Materials by the Disney Entities
14
prior to them even beginning to develop Moana 1 and therefore years before the
15
openly and brazenly infringing Moana 2.
16
66. Each unauthorized use, distribution, and derivative creation constitutes
17
a separate and distinct act of infringement regardless of any prior order of this Court.
18
This Court lacks the judicial power to prospectively overrule the mandate of 17
19
U.S.C. § 106(2). Despite this Court's ruling that all Defendants were saved, on
20
statute of limitations grounds only, regarding the 2016 theatrical release of Moana
21
I, the Court never was asked to consider in connection with Woodall v. Disney 1 -
22
let alone was the Court asked to attempt to prospectively overrule - Plaintiffs
23
absolute rights pursuant to 17 U.S.C. § 106(2) to control all derivative works of his
24
Copyrighted Material. Defendants' ongoing and repeated violations of Plaintiffs
25
exclusive derivative rights have caused and continue to cause significant harm to
26
Plaintiff.
27
67. Defendants' actions reflect a pattern of continuous disregard for
28
Plaintiffs copyright, warranting relief under the Copyright Act.

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 25

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 27 of 33 Page ID #:27

1 68. As a result of Defendants' copyright infringement, Plaintiff is entitled

2 to his actual damages and profits in the sum of more than $10 billion, according to
3 proof either upon entry of summary judgment in Woodall's favor or at trial before
4 a duly impaneled jury.
5 69. From the date of first production of Defendants' infringing works, the
6 Defendants have infringed Plaintiffs copyright interests in its copyrighted work,
7 including by: (a) authorizing the reproduction, distribution and sale of the infringing
8 and/or distributing Defendants' infringing works through various sources; (b)
9 copying and displaying the infringing works in related marketing and promotional
1O materials for the sale of the infringing works; and (c) participating in and furthering
11 the aforementioned infringing acts, and/or sharing in the proceeds therefrom, all
12 through substantial illegal use of Plaintiffs copyrighted work alleged in this
13 Complaint.
14 70. With knowledge of the aforementioned infringement, each Defendant
15 has induced, caused or materially contributed to the infringing conduct of each other,
16 such that each and all should be found to be contributorily liable for the acts of the
17 others.
18 71. Defendants and each of them had the right and ability to control other
19 infringers and have derived a direct financial benefit from that infringement such
20 that Defendants and each of them also should be found to be vicariously liable.
21
72. The infringement is continuing as the infringing products continue to
22
be produced and sold or licensed by Defendants, while unwitting customers continue
23
to purchase or license from Defendants the stolen and infringed work and related
24
products.
25
73. Defendants' conduct is causing and, unless enjoined by this Court, will
26
continue to cause to Plaintiff, as well as the innocent buyers or licensees of
27
Defendants' infringing products, irreparable injury that cannot fully be compensated
28
for or measured in monetary terms; Plaintiff has no adequate remedy at law.

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 26

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 28 of 33 Page ID #:28

1 74. As a result of the aforesaid infringement, Plaintiff has suffered and will
2 continue to suffer substantial injury, loss and damages to its ownership rights in
3 Plaintiffs copyrighted work. Defendants have unlawfully derived and will continue
4 to derive income and profits from the infringing acts thereby unjustly enriching
5 themselves to the detriment of Plaintiff. As a direct and proximate result of the
6 conduct of Defendants, and each of them, Plaintiff has suffered actual damages
7 including lost profits, lost opportunities, and loss of goodwill, in an amount well in
8 excess of two-point-five percent (2.5%) of all gross revenue earned by Disney from
9 Moana the feature film and all products derived thereof, an exact amount to be
10 proven at trial, separate and apart from all damages otherwise recoverable by
11 Plaintiff.
12 THIRD CAUSE OF ACTION
13 (Willful Copyright Infringement Under 17 U.S.C. § 504(c)-Against All Defendants)
14 75. Plaintiff incorporates paragraphs I through 74 of this Complaint as
15 though fully set forth at length.
16
76. Defendants' acts of copyright infringement, including the creation and
17
distribution of Moana 2, were willful, deliberate, and undertaken with knowledge of
18
Plaintiffs ownership of the Copyrighted Materials and exclusive right to prepare
19
sequels and derivative works. These willful acts were done in part because the
20
Defendants sincerely believe they will never be subject to any substantial judgment
21
in any forum within the Central District of California, thus enhancing their liability.
22
77. Defendants' conduct demonstrates an intentional disregard for
23
Plaintiffs exclusive rights under the Copyright Act, as well as a calculated attempt
24
to profit from their unauthorized use of Plaintiffs intellectual property.
25
78. Pursuant to 17 U.S.C. § 504(c), Plaintiff is entitled to statutory damages
26
for Defendants' willful infringement, in addition to actual damages and Defendants'
27
profits attributable to their infringement.
28

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 27

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 29 of 33 Page ID #:29

1 79. Defendants' actions reflect a pattern of continuous disregard for

2 Plaintiffs copyright, warranting relief under the Copyright Act.
3 80. As a result of Defendants' copyright infringement, Plaintiff is entitled
4 to his actual damages and profits in the sum of more than $10 billion, according to
5 proof either upon entry of summary judgment in Woodall's favor or at trial before
6 a duly impaneled jury.
7 81. From the date of first production of Defendants' infringing works, the
8 Defendants have infringed Plaintiffs copyright interests in its copyrighted work,
9 including by: (a) authorizing the reproduction, distribution and sale of the infringing
10 and/or distributing Defendants' infringing works through various sources; (b)
11 copying and displaying the infringing works in related marketing and promotional
12 materials for the sale of the infringing works; and (c) participating in and furthering
13 the aforementioned infringing acts, and/or sharing in the proceeds therefrom, all
14 through substantial illegal use of Plaintiffs copyrighted work alleged in this
15 Complaint.
16 82. With knowledge of the aforementioned infringement, each Defendant
17 has induced, caused or materially contributed to the infringing conduct of each other,
18 such that each and all should be found to be contributorily liable for the acts of the
19 others.
20
83. Defendants and each of them had the right and ability to control other
21
infringers and have derived a direct financial benefit from that infringement such
22
that Defendants and each of them also should be found to be vicariously liable.
23
84. The infringement is continuing as the infringing products continue to
24
be produced and sold or licensed by Defendants, while unwitting customers continue
25
to purchase or license from Defendants the stolen and infringed work and related
26
products.
27
85. Defendants' conduct is causing and, unless enjoined by this Court, will
28
continue to cause to Plaintiff, as well as the innocent buyers or licensees of

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 28

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 30 of 33 Page ID #:30

1 Defendants' infringing products, irreparable injury that cannot fully be compensated

2 for or measured in monetary terms; Plaintiff has no adequate remedy at law.
3 86. As a result of the aforesaid infringement, Plaintiff has suffered and will
4 continue to suffer substantial injury, loss and damages to its ownership rights in
5 Plaintiffs copyrighted work. Defendants have unlawfully derived and will continue
6 to derive income and profits from the infringing acts thereby unjustly enriching
7 themselves to the detriment of Plaintiff. As a direct and proximate result of the
8 conduct of Defendants, and each of them, Plaintiff has suffered actual damages
9 including lost profits, lost opportunities, and loss of goodwill, in an amount well in
10 excess of two-point-five percent (2.5%) of all gross revenue earned by Disney from
11 Moana the feature film and all products derived thereof, an exact amount to be
12 proven at trial, in addition to all other damages due and owing to Plaintiff.
13 FOURTH CAUSE OF ACTION
14 (Injunctive Relief for Copyright Violations Under 17 U.S.C. § 502 -Against All
15 Defendants)
16
87. Plaintiff incorporates by reference the allegations set forth m
17
Paragraphs I through 86 of this Complaint, as though fully set forth herein.
18
88. Defendants' ongoing infringement of Plaintiffs Copyrighted
19
Materials, including the development and distribution of Moana 2 and related
20
derivative works literally right under this Court's nose and violative of multiple
21
discovery orders, poses a continuing threat to Plaintiffs rights under the Copyright
22
Act.
23
89. Plaintiff has suffered and will continue to suffer irreparable harm for
24
which monetary damages are insufficient, as Defendants' conduct undermines the
25
integrity of Plaintiffs exclusive rights and diminishes the value of the Copyrighted
26
Materials and represents a disdain for the Copyright Act that is unprecedented in this
27
or any other jurisdiction.
28

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 29

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 31 of 33 Page ID #:31

1 90. Pursuant to 17 U.S.C. § 502, Plaintiff seeks an injunction restraining

2 Defendants, and all persons acting in concert with them, from further use,
3 reproduction, distribution, or exploitation of Plaintiffs Copyrighted Materials, as
4 prayed for herein.
5 PRAYER FOR RELIEF
6 WHEREFORE, Plaintiff respectfully requests that this Court enter judgment
7 in Plaintiffs favor and against Defendants as follows:
8 A. For a declaration that Defendants have infringed Plaintiffs
9
Copyrighted Materials pursuant to all Causes of Action;
10 B. For an award to Plaintiff of compensatory damages against all
11
Defendants, jointly and severally, in an amount exceeding two-
12 point-five percent (2.5%) of the gross revenues appertaining or
13 relating to Moana in the sum of at least $5 billion under the First,
14 Second and Third Causes of Action;
15
C. For an award of damages in the sum of at least $10 billion, including
16
all profits attributable to Defendants' infringement of Plaintiffs
17
Copyrighted Materials through and following the theatrical release
18
of Moana 2, pursuant to the First and Second Causes of Action;
19
D. For an accounting of all revenues of any kind generated by the
20
Defendants from each portion of the Moana franchise following the
21
theatrical release of Moana 1, or alternatively for an accounting of
22
all profits generated from, after or by reason of the theatrical release
23
of Moana 2 on November 26, 2022, pursuant to the First and Second
24
Causes of Action;
25
E. For statutory damages for willful infringement under 17 U.S.C. §
26
504(c), including enhanced compensatory damages for
27
Defendants' willful conduct in a sum exceeding $10 billion,
28
pursuant to the Third Cause of Action;

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 30

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 32 of 33 Page ID #:32

1 F. For a temporary, preliminary and permanent injunction restraining

2 and enjoining all Defendants named in this Complaint, as well as
3 their officers, agents, employees, and those persons in active
4 concert or participation with each or any of them, from any further
5 reproduction, distribution, or creation of derivative works based
6 upon or arising from Plaintiffs Copyrighted Materials, pursuant to
7 the Fourth Cause of Action;
8 G. For temporary, preliminary and permanent injunction restraining
9 and enjoining all Defendants named in this Complaint, as well as
10 their officers, agents, employees, and those persons in active
11 concert or participation with each or any of them, from directly or
12 indirectly infringing Plaintiffs copyrights, pursuant to the Fourth
13 Cause of Action;
14 H. For pre-judgment and post-judgment interest as allowed by law;
15 I. For Plaintiffs costs of litigation, including reasonable attorneys'
16 fees, under 17 U.S.C. § 505; and
17
J. For such other and further relief as the Court deems just and
18
proper.
19
Ill
20
Ill
21
22 Ill

23 Ill
24 Ill
25 Ill
26 Ill
27
Ill
28
Ill

COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 31

Case 2:25-cv-00273 Document 1 Filed 01/10/25 Page 33 of 33 Page ID #:33

DEMAND FOR JURY TRIAL

1
Plaintiff hereby demands a trial by jury as to all issues so triable in this action.
2
3 DATED: January 10, 2025 Respectfully Submitted,
4 YANG LAW OFFICES
5
SANCHEZ-MEDINA, GONZALEZ,
6 QUESADA?-. LAGE, GOMEZ &
MACHADv, LLP
7
8 By: s/Gustavo D. Lage
9 Gustavo D. Lage
Lead Counsel
10 (Pro Hae Vice App to be Filed)
201 Alhambra Circ, Ste. 1205
11 Coral Gables, Florida 33134
Tel.: (305) 377-1000
12 Fax: (786) 304-2214
glage@smgqlaw.com
13
14 Attorney for Plaintiff Buck
15 G. Woodall

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COMPLAINT FOR COPYRIGHT INFRINGEMENT CLAIMS 32