Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 1 of 102

COWAN, LIEBOWITZ & LATMAN, P.C.

114 West 47th Street
New York, NY 10036-1525
(212) 790-9200
Kieran G. Doyle ([email protected])
Thomas Kjellberg ([email protected])

Paul D. Polidoro ([email protected])

Watch Tower Bible and Tract Society of Pennsylvania
100 Watchtower Drive
Patterson, NY 12563
(845) 306-1000

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

WATCH TOWER BIBLE AND TRACT SOCIETY OF

PENNSYLVANIA,
Plaintiff,

-against- No. 20-cv-3366

THE TRUTH AND TRANSPARENCY FOUNDATION,

RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

COMPLAINT

Plaintiff Watch Tower Bible and Tract Society of Pennsylvania, by its attorneys, Cowan,

Liebowitz & Latman, P.C., for its Complaint against Defendants The Truth and Transparency

Foundation, Ryan C. McKnight, and Ethan G. Dodge alleges:

NATURE OF THE ACTION

1. This is a civil action for copyright infringement in violation of the Copyright Act,

17 U.S.C. § 101 et seq. This litigation seeks relief against the ongoing wholesale infringement of

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Plaintiff’s registered copyrights in 74 original motion pictures. Defendants, without

authorization or permission from Plaintiff, have made unauthorized copies of Plaintiff’s motion

pictures, and are reproducing, publicly displaying, publicly performing and distributing

Plaintiff’s works online. Plaintiff, accordingly, seeks injunctive relief and statutory damages for

willful copyright infringement.

PARTIES

2. Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (“Watch Tower”)

is a Pennsylvania non-profit corporation with its principal place of business at 200 Watch Tower

Drive, Patterson, New York 12563.

3. Upon information and belief, Defendant The Truth and Transparency Foundation

(“TTF”) is a Nevada non-profit corporation with its principal place of business at 109 Cascade

Meadow Court, Henderson, Nevada 89011.

4. Upon information and belief, Defendant Ryan C. McKnight (“McKnight”) is an

individual residing in Henderson, Nevada. Mr. McKnight is the President and Executive

Director and a founding owner of TTF.

5. Upon information and belief, Defendant Ethan G. Dodge (“Dodge”) is an

individual residing in Pleasant Grove, Utah. Mr. Dodge is the Secretary and Technical Director

and a founding owner of TTF.

6. Upon information and belief, McKnight and Dodge had and still have primary

responsibility for the control, management and operation of the affairs of TTF, with the right and

ability to supervise the infringing activities complained of in this Complaint.

7. Upon information and belief, Defendants, while engaging and participating in the

unlawful acts set forth herein, were agents of and collaborators with one another.

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8. Upon information and belief, Defendants operate and control websites located at

www.faithleaks.org and www.truthandtransparency.org.

JURISDICTION AND VENUE

9. This Court has original jurisdiction over claims arising under the Copyright Act

pursuant to 28 U.S.C. §§ 1331 and 1338.

10. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b) and (c).

11. This Court has personal jurisdiction over Defendants because, on information and

belief, Defendants, in person or through an agent,

(a) have transacted business, and have offered to supply goods, in New York,

including through their interactive website located at truthandtransparency.org, on which

merchandise is offered for sale to, and donations solicited from, New York residents;

and/or

(b) have committed tortious acts both within and outside New York, causing

injury to Watch Tower in New York.

FACTUAL BACKGROUND

12. Watch Tower over decades has created and published thousands of original works

of authorship, including literary works, works of visual art, musical works, and motion pictures,

and has secured over 3,300 federal copyright registrations for its original works. Under the

Copyright Act, Watch Tower has the exclusive rights, among other things, to “reproduce the

copyrighted work[s],” to “distribute copies or phonorecords of the copyrighted work[s] to the

public,” and in the case of its “motion pictures and other audiovisual works, to perform the

copyrighted work[s] publicly,” as well as to authorize or license others to engage in such

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activities. 17 U.S.C. § 106.

13. In mid-2018, Watch Tower learned that 487 of its copyrighted literary works were

being reproduced, displayed and distributed without license or permission by Defendants on the

faithleaks.org website.

14. On December 31, 2018, Watch Tower’s counsel notified Defendants that their

unauthorized publication of Watch Tower’s literary works on the faithleaks site was in violation

of Watch Tower’s exclusive rights under the Copyright Act, and demanded that such infringing

materials be removed from the faithleaks site.

15. Defendants, through counsel, declined Watch Tower’s demand that its literary

works be removed from the faithleaks site. Defendants did not contest Watch Tower’s

ownership of valid copyrights, or its prima facie case of infringement of those copyrights, but

instead asserted “the defense found in 17 U.S.C. § 107,” claiming that Defendants’ wholesale

reproduction and distribution of complete works, unaltered and unaccompanied by new matter,

was protected as fair use.

16. In May 2019, Watch Tower learned that a large number of motion pictures

created by Watch Tower, including the 74 motion pictures at issue here, had been uploaded to

and made available for public performance on Rutube, a Russian online video streaming service

located at rutube.ru and available to users worldwide.

17. Watch Tower submitted to Rutube notices of claimed infringement, objecting to

the unauthorized posting of its copyrighted works on the Rutube site and demanding their

removal. In response, Rutube removed the Watch Tower videos from its site.

18. Shortly thereafter, Defendants posted the Watch Tower videos that had been

“taken down” from Rutube to Defendants’ faithleaks.org site.

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19. In a May 2019 article titled “2019 Jehovah’s Witness Convention Videos

Published Again After Successful Takedown Request,” published on Defendants’

truthandtransparency.org website, Defendants boasted not only about their past infringements

and refusals to comply with Watch Tower’s efforts to enforce its copyrights, but also about these

new infringements, leaving no doubt as to Defendants’ willfulness.

20. The Watch Tower videos remain available on the faithleaks site to the present

day.

WATCH TOWER’S COPYRIGHTED MOTION PICTURES

AND DEFENDANTS’ INFRINGEMENTS

21. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Be a Courageous … Pioneer.” Watch Tower’s copyright in the “Be a Courageous …

Pioneer” video has been duly registered with the United States Copyright Office under

Registration No. PA0002121393, with an effective date of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Be a Courageous … Pioneer” video on Defendants’

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_23-

Be_a_Courageous%E2%80%94Pioneer-Video_1.mkv, where it is available, in its entirety and

without alteration, for public performance and for further reproduction and distribution via

download, without restriction:

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22. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Talk 33 - Video 1 - Learn Courage From Creation (Symposium) – Horses.” Watch

Tower’s copyright in the “Talk 33 - Video 1 - Learn Courage From Creation (Symposium) –

Horses” video has been duly registered with the United States Copyright Office under

Registration No. PA0002121074, with an effective date of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 33 - Video 1 - Learn Courage From Creation

(Symposium) – Horses” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:2017-No_33-

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Learn_Courage_From_Creation%E2%80%94Horses-Video_1.mkv, where it is available, in its

entirety and without alteration, for public performance and for further reproduction and

distribution via download, without restriction:

23. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Talk 40 - Video 1 - How Our Brothers Are Showing Courage In … (Symposium) - North

America.” Watch Tower’s copyright in the “Talk 40 - Video 1 - How Our Brothers Are

Showing Courage In … (Symposium) - North America” video has been duly registered with the

United States Copyright Office under Registration No. PA0002121104, with an effective date of

May 18, 2018.

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 40 - Video 1 - How Our Brothers Are Showing

Courage In … (Symposium) - North America” video on Defendants’ “Faith Leaks” website, at

the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_40-

How_Our_Brothers_Are_Showing_Courage_In%E2%80%94North_America-Video_1.mkv,

where it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

24. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Talk 44 - Video 1 - Future Events That Will Require Courage (Symposium) - The Cry of

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‘Peace and Security!’” Watch Tower’s copyright in the “Talk 44 - Video 1 - Future Events That

Will Require Courage (Symposium) - The Cry of ‘Peace and Security!’” video has been duly

registered with the United States Copyright Office under Registration No. PA0002121120, with

an effective date of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 44 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Cry of ‘Peace and Security!’” video on Defendants’ “Faith Leaks”

website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_44-

Future_Events_That_Will_Require_Courage%E2%80%94The_Cry_of_Peace_and_Security-

Video_1.mkv, where it is available, in its entirety and without alteration, for public performance

and for further reproduction and distribution via download, without restriction:

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25. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Talk 45 - Video 1 - Future Events That Will Require Courage (Symposium) - The

Destruction of Babylon the Great.” Watch Tower’s copyright in the “Talk 45 - Video 1 - Future

Events That Will Require Courage (Symposium) - The Destruction of Babylon the Great” video

has been duly registered with the United States Copyright Office under Registration No.

PA0002121121, with an effective date of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 45 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Destruction of Babylon the Great” video on Defendants’ “Faith

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Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_45-

Future_Events_That_Will_Require_Courage%E2%80%94The_Destruction_of_Babylon_the_Gr

eat-Video_1.mkv, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

26. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Talk 46-Video 1 - Future Events That Will Require Courage (Symposium) - The

Proclamation of the Hailstone Message.” Watch Tower’s copyright in the “Talk 46-Video 1 -

Future Events That Will Require Courage (Symposium) - The Proclamation of the Hailstone

Message” video has been duly registered with the United States Copyright Office under

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Registration No. PA0002121124, with an effective date of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 46-Video 1 - Future Events That Will Require

Courage (Symposium) - The Proclamation of the Hailstone Message” video on Defendants’

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_46-

Future_Events_That_Will_Require_Courage%E2%80%94The_Proclamation_of_the_Hailstone

_Message-Video_1.mkv, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

27. (a) In 2018, Watch Tower created, in-house, an original video motion picture

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titled “Talk 47 - Video 1 - Future Events That Will Require Courage (Symposium) - The Attack

by Gog of Magog.” Watch Tower’s copyright in the “Talk 47 - Video 1 - Future Events That

Will Require Courage (Symposium) - The Attack by Gog of Magog” video has been duly

registered with the United States Copyright Office under Registration No. PA0002121125, with

an effective date of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 47 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Attack by Gog of Magog” video on Defendants’ “Faith Leaks”

website, at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_47-

Future_Events_That_Will_Require_Courage%E2%80%94The_Attack_by_Gog_of_Magog-

Video_1.mkv, where it is available, in its entirety and without alteration, for public performance

and for further reproduction and distribution via download, without restriction:

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28. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Talk 48 - Video 1 - Future Events That Will Require Courage (Symposium) -

Armageddon.” Watch Tower’s copyright in the “Talk 48-Video 1 - Future Events That Will

Require Courage (Symposium) - Armageddon” video has been duly registered with the United

States Copyright Office under Registration No. PA0002121607, with an effective date of May

18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 48-Video 1 - Future Events That Will Require

Courage (Symposium) - Armageddon” video on Defendants’ “Faith Leaks” website, at the URL

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https://faithleaks.org/wiki/index.php?title=File:2017-No_48-

Future_Events_That_Will_Require_Courage%E2%80%94Armageddon-Video_1.mkv, where it

is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

29. (a) In 2018, Watch Tower created, in-house, an original video motion picture

titled “Talk 49 - Video 1 - Future Events That Will Require Courage (Symposium) - The Great

Reconstruction.” Watch Tower’s copyright in the “Talk 49 - Video 1 - Future Events That Will

Require Courage (Symposium) - The Great Reconstruction” video has been duly registered with

the United States Copyright Office under Registration No. PA0002121129, with an effective date

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of May 18, 2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 49 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Great Reconstruction” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:2017-No_49-

Future_Events_That_Will_Require_Courage%E2%80%94The_Great_Reconstruction-

Video_1.mkv, where it is available, in its entirety and without alteration, for public performance

and for further reproduction and distribution via download, without restriction:

30. (a) In 2018, Watch Tower created, in-house, an original video motion picture

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titled “Talk 50 - Video 1 - Future Events That Will Require Courage (Symposium) - The Final

Test.” Watch Tower’s copyright in the “Talk 50 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Final Test” video has been duly registered with the United States

Copyright Office under Registration No. PA0002121132, with an effective date of May 18,

2018.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 50 - Video 1 - Future Events That Will Require

Courage (Symposium) - The Final Test” video on Defendants’ “Faith Leaks” website, at the

URL https://faithleaks.org/wiki/index.php?title=File:2017-No_50-

Future_Events_That_Will_Require_Courage%E2%80%94The_Final_Test-Video_1.mkv, where

it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

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31. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1.” Watch Tower’s

copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191509, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video

Presentation 1” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_003_r720P.mp4, where it is

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available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

32. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 01 Video 1 - Chairman’s Address: ‘Love Never Fails - Why?’ (Romans 8:38, 39; 1

Corinthians 13:1-3, 8, 13).” Watch Tower’s copyright in the “Talk 01 Video 1 - Chairman’s

Address: ‘Love Never Fails - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191514, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

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performed and distributed Watch Tower’s “Talk 01 Video 1 - Chairman’s Address: ‘Love Never

Fails - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_006_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

33. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 01 Video 2 - Chairman’s Address: ‘Love Never Fails’ - Why?’ (Romans 8:38, 39; 1

Corinthians 13:1-3, 8, 13).” Watch Tower’s copyright in the “Talk 01 Video 2 - Chairman’s

Address: ‘Love Never Fails’ - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video has

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been duly registered with the United States Copyright Office under Registration No.

PA0002191517, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 01 Video 2 - Chairman’s Address: ‘Love Never

Fails’ - Why?’ (Romans 8:38, 39; 1 Corinthians 13:1-3, 8, 13)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_007_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

34. (a) In 2019, Watch Tower created, in-house, an original video motion picture

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titled “Talk 02 Video 1 - Symposium: Beware of Trusting in What Fails! - Wealth (Matthew

6:24).” Watch Tower’s copyright in the “Talk 02 Video 1 - Symposium: Beware of Trusting in

What Fails! - Wealth (Matthew 6:24)” video has been duly registered with the United States

Copyright Office under Registration No. PA0002191478, with an effective date of May 17,

2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 02 Video 1 - Symposium: Beware of Trusting in

What Fails! - Wealth (Matthew 6:24)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_009_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

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35. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 03 Video 1 - Symposium: Beware of Trusting in What Fails! - Status and Fame

(Ecclesiastes 2:16; Romans 12:16).” Watch Tower’s copyright in the “Talk 03 Video 1 -

Symposium: Beware of Trusting in What Fails! - Status and Fame (Ecclesiastes 2:16; Romans

12:16)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191475, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 03 Video 1 - Symposium: Beware of Trusting in

What Fails! - Status and Fame (Ecclesiastes 2:16; Romans 12:16)” video on Defendants’ “Faith

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Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_011_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

36. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 04 Video 1 - Symposium: Beware of Trusting in What Fails! - Human Wisdom

(Romans 12:1, 2).” Watch Tower’s copyright in the “Talk 04 Video 1 - Symposium: Beware of

Trusting in What Fails! - Human Wisdom (Romans 12:1, 2)” video has been duly registered with

the United States Copyright Office under Registration No. PA0002191487, with an effective date

of May 17, 2019.

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 04 Video 1 - Symposium: Beware of Trusting in

What Fails! - Human Wisdom (Romans 12:1, 2)” video on Defendants’ “Faith Leaks” website, at

the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_013_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

37. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 05 Video 1 - Symposium: Beware of Trusting in What Fails! - Strength and Beauty

(Proverbs 31:30; 1 Peter 3:3, 4).” Watch Tower’s copyright in the “Talk 05 Video 1 -

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Symposium: Beware of Trusting in What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter

3:3, 4)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191489, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 05 Video 1 - Symposium: Beware of Trusting in

What Fails! - Strength and Beauty (Proverbs 31:30; 1 Peter 3:3, 4)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_015_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

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38. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 06 Video 1 - DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love

(Genesis 37:1-36; 39:1; 47:12).” Watch Tower’s copyright in the “Talk 06 Video 1 -

DRAMATIC BIBLE READING: Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1;

47:12)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191501, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 06 Video 1 - DRAMATIC BIBLE READING:

Jehovah Kept Showing Loyal Love (Genesis 37:1-36; 39:1; 47:12)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_018_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

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39. 40. (a) In 2019, Watch Tower created, in-house, an original video motion

picture titled “2019 ‘Love Never Fails’! Convention—Music-Video Presentation 2Talk 23 Video

1 - Symposium: Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32).”

Watch Tower’s copyright in the “2019 ‘Love Never Fails’! Convention—Music-Video

Presentation 2” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191510, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention—Music-Video

Presentation 2” video on Defendants’ “Faith Leaks” website, at the URL

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https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_023_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

40. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 08 Video 1 - Symposium: Love Never Fails Despite … A Loveless Upbringing

(Psalm 27:10).” Watch Tower’s copyright in the “Talk 08 Video 1 - Symposium: Love Never

Fails Despite … A Loveless Upbringing (Psalm 27:10)” video has been duly registered with the

United States Copyright Office under Registration No. PA0002191450, with an effective date of

May 17, 2019.

29

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 08 Video 1 - Symposium: Love Never Fails

Despite … A Loveless Upbringing (Psalm 27:10)” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_026_r720P.mp4, where it

is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

41. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 09 Video 1 - Symposium: Love Never Fails Despite … A Difficult Work

Environment (1 Peter 2:18-20).” Watch Tower’s copyright in the “Talk 09 Video 1 -

30

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Symposium: Love Never Fails Despite … A Difficult Work Environment (1 Peter 2:18-20)”

video has been duly registered with the United States Copyright Office under Registration No.

PA0002191453, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 09 Video 1 - Symposium: Love Never Fails

Despite … A Difficult Work Environment (1 Peter 2:18-20)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_028_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

31

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42. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 10 Video 2 - Symposium: Love Never Fails Despite … An Ungodly School

Environment (1 Timothy 4:12).” Watch Tower’s copyright in the “Talk 10 Video 2 -

Symposium: Love Never Fails Despite … An Ungodly School Environment (1 Timothy 4:12)”

video has been duly registered with the United States Copyright Office under Registration No.

PA0002191458, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 10 Video 2 - Symposium: Love Never Fails

Despite … An Ungodly School Environment (1 Timothy 4:12)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_031_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

32

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43. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 11 Video 1 - Symposium: Love Never Fails Despite … Chronic Health Problems (2

Corinthians 12:9, 10).” Watch Tower’s copyright in the “Talk 11 Video 1 - Symposium: Love

Never Fails Despite … Chronic Health Problems (2 Corinthians 12:9, 10)” video has been duly

registered with the United States Copyright Office under Registration No. PA0002191459, with

an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 11 Video 1 - Symposium: Love Never Fails

Despite … Chronic Health Problems (2 Corinthians 12:9, 10)” video on Defendants’ “Faith

33

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Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_033_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

44. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 12 Video 1 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12,

13).” Watch Tower’s copyright in the “Talk 12 Video 1 - Symposium: Love Never Fails Despite

… Poverty (Philippians 4:12, 13)” video has been duly registered with the United States

Copyright Office under Registration No. PA0002191460, with an effective date of May 17,

2019.

34

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 12 Video 1 - Symposium: Love Never Fails

Despite … Poverty (Philippians 4:12, 13)” video on Defendants’ “Faith Leaks” website, at the

URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_035_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

45. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 12 Video 2 - Symposium: Love Never Fails Despite … Poverty (Philippians 4:12,

13).” Watch Tower’s copyright in the “Talk 12 Video 2 - Symposium: Love Never Fails Despite

35

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 36 of 102

… Poverty (Philippians 4:12, 13)” video has been duly registered with the United States

Copyright Office under Registration No. PA0002191461, with an effective date of May 17,

2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 12 Video 2 - Symposium: Love Never Fails

Despite … Poverty (Philippians 4:12, 13)” video on Defendants’ “Faith Leaks” website, at the

URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_036_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

36

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46. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 13 Video 1 - Symposium: Love Never Fails Despite … Family Opposition (Matthew

5:44).” Watch Tower’s copyright in the “Talk 13 Video 1 - Symposium: Love Never Fails

Despite … Family Opposition (Matthew 5:44)” video has been duly registered with the United

States Copyright Office under Registration No. PA0002191455, with an effective date of May

17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 13 Video 1 - Symposium: Love Never Fails

Despite … Family Opposition (Matthew 5:44)” video on Defendants’ “Faith Leaks” website, at

the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_038_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

37

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47. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 14 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Heavens (Psalm

8:3, 4; 33:6).” Watch Tower’s copyright in the “Talk 14 Video 1 - Symposium: Creation

Reveals Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)” video has been duly registered with

the United States Copyright Office under Registration No. PA0002191432, with an effective date

of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 14 Video 1 - Symposium: Creation Reveals

Jehovah’s Love - The Heavens (Psalm 8:3, 4; 33:6)” video on Defendants’ “Faith Leaks”

38

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website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_041_r720P.mp4,

where it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

48. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 15 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Earth (Psalm

37:29; 115:16).” Watch Tower’s copyright in the “Talk 15 Video 1 - Symposium: Creation

Reveals Jehovah’s Love - The Earth (Psalm 37:29; 115:16)” video has been duly registered with

the United States Copyright Office under Registration No. PA0002191434, with an effective date

of May 17, 2019.

39

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 15 Video 1 - Symposium: Creation Reveals

Jehovah’s Love - The Earth (Psalm 37:29; 115:16)” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_043_r720P.mp4, where it

is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

49. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 16 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Plants (Genesis 1:11,

29; 2:9, 15; Acts 14:16, 17).” Watch Tower’s copyright in the “Talk 16 Video 1 - Symposium:

40

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 41 of 102

Creation Reveals Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191437, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 16 Video 1 - Symposium: Creation Reveals

Jehovah’s Love - Plants (Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_045_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

41

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50. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 17 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Animals (Genesis

1:27; Matthew 6:26).” Watch Tower’s copyright in the “Talk 17 Video 1 - Symposium: Creation

Reveals Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)” video has been duly

registered with the United States Copyright Office under Registration No. PA0002191444, with

an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 17 Video 1 - Symposium: Creation Reveals

Jehovah’s Love - Animals (Genesis 1:27; Matthew 6:26)” video on Defendants’ “Faith Leaks”

website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_047_r720P.mp4,

where it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

42

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51. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 18 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Human Body

(Psalm 139:14; Ecclesiastes 3:11).” Watch Tower’s copyright in the “Talk 18 Video 1 -

Symposium: Creation Reveals Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes

3:11)” video has been duly registered with the United States Copyright Office under Registration

No. PA0002191446, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 18 Video 1 - Symposium: Creation Reveals

Jehovah’s Love - The Human Body (Psalm 139:14; Ecclesiastes 3:11)” video on Defendants’

43

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“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_049_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

52. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 19 Video 1 - ‘Those Whom Jehovah Loves He Disciplines’ (Hebrews 12:5-11;

Psalm 19:7, 8, 11).” Watch Tower’s copyright in the “Talk 19 Video 1 - ‘Those Whom Jehovah

Loves He Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)” video has been duly registered

with the United States Copyright Office under Registration No. PA0002191504, with an

effective date of May 17, 2019.

44

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 19 Video 1 - ‘Those Whom Jehovah Loves He

Disciplines’ (Hebrews 12:5-11; Psalm 19:7, 8, 11)” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_051_r720P.mp4, where it

is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

53. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14).” Watch Tower’s

copyright in the “Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14)” video

45

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has been duly registered with the United States Copyright Office under Registration No.

PA0002191471, with an effective date of May 17, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 20 Video 1 - ‘Clothe Yourselves With Love’

(Colossians 3:12-14)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_053_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

54. (a) In 2019, Watch Tower created, in-house, an original video motion picture

46

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titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 3.” Watch Tower’s

copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 3” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191139, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video

Presentation 3” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_058_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

47

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55. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 21 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Those

Taking the Lead (1 Thessalonians 5:12, 13).” Watch Tower’s copyright in the “Talk 21 Video 1

- Symposium: Display Unfailing Love in the Congregation - To Those Taking the Lead (1

Thessalonians 5:12, 13)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191157, with an effective date of May 22, 2019, and

Supplementary Registration No. PA0002214841, dated August 19, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 21 Video 1 - Symposium: Display Unfailing

48

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Love in the Congregation - To Those Taking the Lead (1 Thessalonians 5:12, 13)” video on

Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_061_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

56. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To the

Elderly (Leviticus 19:32).” Watch Tower’s copyright in the “Talk 23 Video 1 - Symposium:

Display Unfailing Love in the Congregation - To the Elderly (Leviticus 19:32)” video has been

49

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 50 of 102

duly registered with the United States Copyright Office under Registration No. PA0002191160,

with an effective date of May 22, 2019, and Supplementary Registration No. PA0002216893,

dated September 4, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 23 Video 1 - Symposium: Display Unfailing

Love in the Congregation - To the Elderly (Leviticus 19:32)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_065_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

50

31653/001/3453468.2
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57. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 24 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Full-

Time Ministers (1 Thessalonians 1:3).” Watch Tower’s copyright in the “Talk 24 Video 1 -

Symposium: Display Unfailing Love in the Congregation - To Full-Time Ministers (1

Thessalonians 1:3)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191146, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 24 Video 1 - Symposium: Display Unfailing

Love in the Congregation - To Full-Time Ministers (1 Thessalonians 1:3)” video on Defendants’

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_067_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

51

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58. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 25 Video 1 - Symposium: Display Unfailing Love in the Congregation - To Foreign

Residents (Leviticus 19:34; Romans 15:7).” Watch Tower’s copyright in the “Talk 25 Video 1 -

Symposium: Display Unfailing Love in the Congregation - To Foreign Residents (Leviticus

19:34; Romans 15:7)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191155, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 25 Video 1 - Symposium: Display Unfailing

Love in the Congregation - To Foreign Residents (Leviticus 19:34; Romans 15:7)” video on

52

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Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_069_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

59. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers Meeting.” Watch

Tower’s copyright in the “ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers

Meeting” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191149, with an effective date of May 22, 2019.

53

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “ANNOUNCEMENT: Invitation to School for

Kingdom Evangelizers Meeting” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_071_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

60. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 26 Video 1 - Symposium: Display Unfailing Love in the Ministry - Show Your Love

for God (1 John 5:3).” Watch Tower’s copyright in the “Talk 26 Video 1 - Symposium: Display

54

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Unfailing Love in the Ministry - Show Your Love for God (1 John 5:3)” video has been duly

registered with the United States Copyright Office under Registration No. PA0002191683, with

an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 26 Video 1 - Symposium: Display Unfailing

Love in the Ministry - Show Your Love for God (1 John 5:3)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_073_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

55

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61. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 27 Video 1 - Symposium: Display Unfailing Love in the Ministry – ‘Love Your

Neighbor as Yourself’ (Matthew 22:39).” Watch Tower’s copyright in the “Talk 27 Video 1 -

Symposium: Display Unfailing Love in the Ministry – ‘Love Your Neighbor as Yourself’

(Matthew 22:39)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191148, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 27 Video 1 - Symposium: Display Unfailing

Love in the Ministry – ‘Love Your Neighbor as Yourself’ (Matthew 22:39)” video on

Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_075_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

56

31653/001/3453468.2
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62. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 28 Video 1 - Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s

Word (Psalm 119:97; Matthew 13:52).” Watch Tower’s copyright in the “Talk 28 Video 1 -

Symposium: Display Unfailing Love in the Ministry - Love Jehovah’s Word (Psalm 119:97;

Matthew 13:52)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191684, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 28 Video 1 - Symposium: Display Unfailing

Love in the Ministry - Love Jehovah’s Word (Psalm 119:97; Matthew 13:52)” video on

57

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Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_077_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

63. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4 (v2).” Watch

Tower’s copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4

(v2)” video has been duly registered with the United States Copyright Office under Registration

No. PA0002193286, with an effective date of June 5, 2019.

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video

Presentation 4 (v2)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_082_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

64. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In …

Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians

59

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9:22), Oceania (Psalm 35:18), South America (Acts 1:8).” Watch Tower’s copyright in the

“Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love In … Africa

(Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1 Corinthians 9:22),

Oceania (Psalm 35:18), South America (Acts 1:8)” video has been duly registered with the

United States Copyright Office under Registration No. PA0002191713, with an effective date of

May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 30 Video 1 - Symposium: How Our Brothers

Are Showing Unfailing Love In … Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John

4:35), North America (1 Corinthians 9:22), Oceania (Psalm 35:18), South America (Acts 1:8)”

video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_085_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

60

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65. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 31 Video 1 - Display Unfailing Love in Your Family - Love Your Wife (Ephesians

5:28, 29).” Watch Tower’s copyright in the “Talk 31 Video 1 - Display Unfailing Love in Your

Family - Love Your Wife (Ephesians 5:28, 29)” video has been duly registered with the United

States Copyright Office under Registration No. PA0002191714, with an effective date of May

22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 31 Video 1 - Display Unfailing Love in Your

Family - Love Your Wife (Ephesians 5:28, 29)” video on Defendants’ “Faith Leaks” website, at

61

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the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_087_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

66. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 32 Video 1 - Display Unfailing Love in Your Family - Love Your Husband

(Ephesians 5:33; 1 Peter 3:1-6).” Watch Tower’s copyright in the “Talk 32 Video 1 - Display

Unfailing Love in Your Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191715, with an effective date of May 22, 2019.

62

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 32 Video 1 - Display Unfailing Love in Your

Family - Love Your Husband (Ephesians 5:33; 1 Peter 3:1-6)” video on Defendants’ “Faith

Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_089_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

67. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 33 Video 1 - Display Unfailing Love in Your Family - Love Your Children (Titus

2:4).” Watch Tower’s copyright in the “Talk 33 Video 1 - Display Unfailing Love in Your

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Family - Love Your Children (Titus 2:4)” video has been duly registered with the United States

Copyright Office under Registration No. PA0002191717, with an effective date of May 22,

2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 33 Video 1 - Display Unfailing Love in Your

Family - Love Your Children (Titus 2:4)” video on Defendants’ “Faith Leaks” website, at the

URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_091_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

64

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68. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part I (2 Chronicles 33:10-24;

34:1, 2).” Watch Tower’s copyright in the “The Story of Josiah: Love Jehovah; Hate What Is

Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)” video has been duly registered with the United

States Copyright Office under Registration No. PA0002191144, with an effective date of May

22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “The Story of Josiah: Love Jehovah; Hate What Is

Bad - Part I (2 Chronicles 33:10-24; 34:1, 2)” video on Defendants’ “Faith Leaks” website, at the

URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_094_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

65

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69. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 35 Video 1 - Teach Your Children How to Show Love (2 Timothy 3:14, 15).”

Watch Tower’s copyright in the “Talk 35 Video 1 - Teach Your Children How to Show Love (2

Timothy 3:14, 15)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191678, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 35 Video 1 - Teach Your Children How to

Show Love (2 Timothy 3:14, 15)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_096_r720P.mp4, where it is

66

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available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

70. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 35 Video 3 - Teach Your Children How to Show Love (2 Timothy 3:14, 15).”

Watch Tower’s copyright in the “Talk 35 Video 3 - Teach Your Children How to Show Love (2

Timothy 3:14, 15)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002192006, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 35 Video 3 - Teach Your Children How to

67

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Show Love (2 Timothy 3:14, 15)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_098_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

71. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 35 Video 4 - Teach Your Children How to Show Love (2 Timothy 3:14, 15).”

Watch Tower’s copyright in the “Talk 35 Video 4 - Teach Your Children How to Show Love (2

Timothy 3:14, 15)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002192007, with an effective date of May 22, 2019.

68

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 35 Video 4 - Teach Your Children How to

Show Love (2 Timothy 3:14, 15)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_099_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

72. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 5.” Watch Tower’s

copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 5” video has

69

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been duly registered with the United States Copyright Office under Registration No.

PA0002191679, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video

Presentation 5” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_104_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

73. (a) In 2019, Watch Tower created, in-house, an original video motion picture

70

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titled “Talk 36 Video 1 - Symposium: Remember How Love Behaves - Is Patient and Kind (1

Corinthians 13:4).” Watch Tower’s copyright in the “Talk 36 Video 1 - Symposium: Remember

How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video has been duly registered

with the United States Copyright Office under Registration No. PA0002192010, with an

effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 36 Video 1 - Symposium: Remember How

Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video on Defendants’ “Faith Leaks”

website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_107_r720P.mp4,

where it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

71

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74. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 36 Video 2 - Symposium: Remember How Love Behaves - Is Patient and Kind (1

Corinthians 13:4).” Watch Tower’s copyright in the “Talk 36 Video 2 - Symposium: Remember

How Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video has been duly registered

with the United States Copyright Office under Registration No. PA0002192009, with an

effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 36 Video 2 - Symposium: Remember How

Love Behaves - Is Patient and Kind (1 Corinthians 13:4)” video on Defendants’ “Faith Leaks”

72

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website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_108_r720P.mp4,

where it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

75. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 37 Video 1 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not

Brag (1 Corinthians 13:4).” Watch Tower’s copyright in the “Talk 37 Video 1 - Symposium:

Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191147, with an effective date of May 22, 2019.

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(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 37 Video 1 - Symposium: Remember How

Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video on Defendants’

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_110_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

76. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 37 Video 2 - Symposium: Remember How Love Behaves - Is Not Jealous; Does Not

Brag (1 Corinthians 13:4).” Watch Tower’s copyright in the “Talk 37 Video 2 - Symposium:

74

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Remember How Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191150, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 37 Video 2 - Symposium: Remember How

Love Behaves - Is Not Jealous; Does Not Brag (1 Corinthians 13:4)” video on Defendants’

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_111_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

75

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77. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 38 Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up;

Does Not Behave Indecently (1 Corinthians 13:4, 5).” Watch Tower’s copyright in the “Talk 38

Video 1 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not

Behave Indecently (1 Corinthians 13:4, 5)” video has been duly registered with the United States

Copyright Office under Registration No. PA0002191151, with an effective date of May 22,

2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 38 Video 1 - Symposium: Remember How

Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”

video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_113_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

76

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78. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 38 Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up;

Does Not Behave Indecently (1 Corinthians 13:4, 5).” Watch Tower’s copyright in the “Talk 38

Video 2 - Symposium: Remember How Love Behaves - Does Not Get Puffed Up; Does Not

Behave Indecently (1 Corinthians 13:4, 5)” video has been duly registered with the United States

Copyright Office under Registration No. PA0002191152, with an effective date of May 22,

2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 38 Video 2 - Symposium: Remember How

77

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Love Behaves - Does Not Get Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”

video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_114_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

79. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its

Own Interests; Does Not Become Provoked (1 Corinthians 13:5).” Watch Tower’s copyright in

the “Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look for Its Own

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Interests; Does Not Become Provoked (1 Corinthians 13:5)” video has been duly registered with

the United States Copyright Office under Registration No. PA0002191156, with an effective date

of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 39 Video 1 - Symposium: Remember How

Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1

Corinthians 13:5)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_116_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

79

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80. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its

Own Interests; Does Not Become Provoked (1 Corinthians 13:5).” Watch Tower’s copyright in

the “Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look for Its Own

Interests; Does Not Become Provoked (1 Corinthians 13:5)” video has been duly registered with

the United States Copyright Office under Registration No. PA0002191153, with an effective date

of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 39 Video 2 - Symposium: Remember How

80

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 81 of 102

Love Behaves - Does Not Look for Its Own Interests; Does Not Become Provoked (1

Corinthians 13:5)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_117_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

81. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not Keep Account

of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6).” Watch Tower’s

copyright in the “Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not

81

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Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”

video has been duly registered with the United States Copyright Office under Registration No.

PA0002191154, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 40 Video 1 - Symposium: Remember How

Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness

(1 Corinthians 13:5, 6)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_119_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

82

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82. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not Keep Account

of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6).” Watch Tower’s

copyright in the “Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not

Keep Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”

video has been duly registered with the United States Copyright Office under Registration No.

PA0002191719, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 40 Video 2 - Symposium: Remember How

83

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Love Behaves - Does Not Keep Account of the Injury; Does Not Rejoice Over Unrighteousness

(1 Corinthians 13:5, 6)” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_120_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

83. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 41 Video 1 - Symposium: Remember How Love Behaves - Rejoices With the Truth;

Bears All Things (1 Corinthians 13:6, 7).” Watch Tower’s copyright in the “Talk 41 Video 1 -

Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1

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Corinthians 13:6, 7)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191722, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 41 Video 1 - Symposium: Remember How

Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)” video on

Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_122_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

85

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84. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 41 Video 2 - Symposium: Remember How Love Behaves - Rejoices With the Truth;

Bears All Things (1 Corinthians 13:6, 7).” Watch Tower’s copyright in the “Talk 41 Video 2 -

Symposium: Remember How Love Behaves - Rejoices With the Truth; Bears All Things (1

Corinthians 13:6, 7)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191723, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 41 Video 2 - Symposium: Remember How

Love Behaves - Rejoices With the Truth; Bears All Things (1 Corinthians 13:6, 7)” video on

Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_123_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

86

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85. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 42 Video 1 - Symposium: Remember How Love Behaves - Believes All Things;

Hopes All Things 1 Corinthians 13:7).” Watch Tower’s copyright in the “Talk 42 Video 1 -

Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1

Corinthians 13:7)” video has been duly registered with the United States Copyright Office under

Registration No. PA0002191724, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 42 Video 1 - Symposium: Remember How

Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)” video on

87

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Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_125_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

86. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 42 Video 2 - Symposium: Remember How Love Behaves - Believes All Things;

Hopes All Things 1 Corinthians 13:7).” Watch Tower’s copyright in the “Talk 42 Video 2 -

Symposium: Remember How Love Behaves - Believes All Things; Hopes All Things 1

Corinthians 13:7)” video has been duly registered with the United States Copyright Office under

88

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 89 of 102

Registration No. PA0002191727, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 42 Video 2 - Symposium: Remember How

Love Behaves - Believes All Things; Hopes All Things 1 Corinthians 13:7)” video on

Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_126_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

87. (a) In 2019, Watch Tower created, in-house, an original video motion picture

89

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 90 of 102

titled “Talk 43 Video 1 - Symposium: Remember How Love Behaves - Endures All Things;

Love Never Fails (1 Corinthians 13:7, 8).” Watch Tower’s copyright in the “Talk 43 Video 1 -

Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1

Corinthians 13:7, 8)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191729, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 43 Video 1 - Symposium: Remember How

Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)” video on

Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_128_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

90

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 91 of 102

88. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 43 Video 2 - Symposium: Remember How Love Behaves - Endures All Things;

Love Never Fails (1 Corinthians 13:7, 8).” Watch Tower’s copyright in the “Talk 43 Video 2 -

Symposium: Remember How Love Behaves - Endures All Things; Love Never Fails (1

Corinthians 13:7, 8)” video has been duly registered with the United States Copyright Office

under Registration No. PA0002191159, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 43 Video 2 - Symposium: Remember How

Love Behaves - Endures All Things; Love Never Fails (1 Corinthians 13:7, 8)” video on

91

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 92 of 102

Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_129_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

89. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 44 Video 1 - Public Bible Discourse: True Love in a Hate-Filled World - Where?

(John 13:34, 35).” Watch Tower’s copyright in the “Talk 44 Video 1 - Public Bible Discourse:

True Love in a Hate-Filled World - Where? (John 13:34, 35)” video has been duly registered

with the United States Copyright Office under Registration No. PA0002191418, with an

92

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 93 of 102

effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 44 Video 1 - Public Bible Discourse: True Love

in a Hate-Filled World - Where? (John 13:34, 35)” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_132_r720P.mp4, where it

is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

90. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 44 Video 2 - Public Bible Discourse: True Love in a Hate-Filled World - Where?

93

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 94 of 102

(John 13:34, 35).” Watch Tower’s copyright in the “Talk 44 Video 2 - Public Bible Discourse:

True Love in a Hate-Filled World - Where? (John 13:34, 35)” video has been duly registered

with the United States Copyright Office under Registration No. PA0002191141, with an

effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 44 Video 2 - Public Bible Discourse: True Love

in a Hate-Filled World - Where? (John 13:34, 35)” video on Defendants’ “Faith Leaks” website,

at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_133_r720P.mp4, where it

is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

94

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 95 of 102

91. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25;

2 Chronicles 34:3-33; 35:1-19).” Watch Tower’s copyright in the “The Story of Josiah: Love

Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)”

video has been duly registered with the United States Copyright Office under Registration No.

PA0002191682, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “The Story of Josiah: Love Jehovah; Hate What Is

Bad - Part II (2 Kings 22:3-20; 23:1-25; 2 Chronicles 34:3-33; 35:1-19)” video on Defendants’

95

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 96 of 102

“Faith Leaks” website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-

v19_E_141_r720P.mp4, where it is available, in its entirety and without alteration, for public

performance and for further reproduction and distribution via download, without restriction:

92. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 47 Video 1 - ‘Carefully Consider Jehovah’s Acts of Loyal Love’ (Psalm 107:43;

Ephesians 5:1, 2).” Watch Tower’s copyright in the “Talk 47 Video 1 - ‘Carefully Consider

Jehovah’s Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)” video has been duly registered

with the United States Copyright Office under Registration No. PA0002191138, with an

effective date of May 22, 2019.

96

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 97 of 102

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 47 Video 1 - ‘Carefully Consider Jehovah’s

Acts of Loyal Love’ (Psalm 107:43; Ephesians 5:1, 2)” video on Defendants’ “Faith Leaks”

website, at the URL https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_144_r720P.mp4,

where it is available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

93. (a) In 2019, Watch Tower created, in-house, an original video motion picture

titled “Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8)).” Watch Tower’s copyright in the

“Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8))” video has been duly registered with the

97

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 98 of 102

United States Copyright Office under Registration No. PA0002191706, with an effective date of

May 24, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “Talk 47 Video 5 - Unfailing Love (1 Corinthians

13:8))” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_148_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

94. (a) In 2019, Watch Tower created, in-house, an original video motion picture

98

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 99 of 102

titled “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 6.” Watch Tower’s

copyright in the “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 6” video has

been duly registered with the United States Copyright Office under Registration No.

PA0002191143, with an effective date of May 22, 2019.

(b) Defendants have unlawfully copied, reproduced, publicly displayed, publicly

performed and distributed Watch Tower’s “2019 ‘Love Never Fails’! Convention - Music-Video

Presentation 6” video on Defendants’ “Faith Leaks” website, at the URL

https://faithleaks.org/wiki/index.php?title=File:CO-v19_E_083_r720P.mp4, where it is

available, in its entirety and without alteration, for public performance and for further

reproduction and distribution via download, without restriction:

99

31653/001/3453468.2
 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 100 of 102

95. Defendants McKnight and Dodge personally participated in, and supervised and

directed, the infringing acts described above. Indeed, they personally conceived of, and directed

and approved all key aspects of, TTF’s infringing activities. They were the moving force behind

those infringing acts.

96. The acts of Defendants described above were committed without the permission,

license or consent of Watch Tower.

97. Upon information and belief, the acts of Defendants described above were

committed with knowledge or in reckless disregard of Watch Tower’s exclusive rights in the

Watch Tower videos.

CLAIM FOR RELIEF

(Copyright Infringement)

98. Watch Tower repeats and realleges the assertions contained in paragraphs 1

through 97 above.

99. Watch Tower is the author of, and sole proprietor of all right, title and interest in

and to the copyrights in, each of the Watch Tower videos described above. Under 17 U.S.C. §

106, Watch Tower has the exclusive right to reproduce, distribute, publicly display, publicly

perform, and prepare derivative works based on the Watch Tower videos.

100. As alleged above, Defendants have infringed the copyrights in each of the above-

described Watch Tower videos by unlawfully reproducing, distributing, publicly displaying,

publicly performing and/or distributing the Watch Tower videos.

101. As alleged above, Defendants’ infringements are willful in that they are

committed with knowledge or in reckless disregard of Watch Tower’s exclusive rights in its

copyrighted videos.

100

31653/001/3453468.2
 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 101 of 102

102. Watch Tower is entitled to recover from Defendants its actual damages as well as

the profits of Defendants attributable to each of the infringements and not taken into account in

computing actual damages, pursuant to 17 U.S.C. § 504(b); or, at Watch Tower’s election, an

award of statutory damages pursuant to 17 U.S.C. § 504(c) with respect to each of the Watch

Tower videos infringed by Defendants that meets the requirements of 17 U.S.C. § 412.

103. Pursuant to 17 U.S.C. § 505, Watch Tower is also entitled to recover its costs and

attorneys’ fees from Defendants with respect to each of the Watch Tower videos infringed by

Defendants that meets the requirements of 17 U.S.C. § 412.

104. As a result of Defendants’ copyright infringements, Watch Tower has suffered,

and will continue to suffer, irreparable injury not fully compensable in monetary damages, and is

therefore entitled to an injunction enjoining Defendants from engaging in their infringing

activities.

WHEREFORE, Watch Tower prays that the Court:

1. Find that Defendants have willfully infringed Watch Tower’s registered

copyrights in the Watch Tower videos;

2. Preliminarily and permanently enjoin Defendants, their officers, agents,

employees, and related companies, and all persons acting for, with, by, through, or under them,

from copying, reproducing, publicly displaying, publicly performing, distributing, advertising,

promoting, offering for sale or selling the Watch Tower videos;

3. (a) Award to Watch Tower, pursuant to 17 U.S.C. § 504(c), its actual

damages incurred as a result of Defendants’ acts of copyright infringement, and all profits

Defendants realized as a result of such unlawful acts, in amounts to be determined at trial; or

101

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 Case 1:20-cv-03366 Document 1 Filed 04/30/20 Page 102 of 102

(b) In the alternative, with respect to each of the Watch Tower Videos infringed by

Defendants that meets the requirements of 17 U.S.C. § 412, award to Watch Tower, at its

election, statutory damages pursuant to 17 U.S.C. § 504(c);

4. Award to Watch Tower, pursuant to 17 U.S.C. § 505, its costs and attorneys’ fees

incurred as a result of Defendants’ unlawful acts; and

5. Grant such other and further relief as the Court deems necessary and proper under

the circumstances.

Dated: New York, New York

April 30, 2020
Respectfully submitted,

COWAN, LIEBOWITZ & LATMAN, P.C.

By: s/Kieran G. Doyle

Kieran G. Doyle ([email protected])
Thomas Kjellberg ([email protected])

114 West 47th Street

New York, New York 10036-1525
(212) 790-9202

Paul Polidoro
Watch Tower Bible and Tract Society of Pennsylvania
100 Watchtower Drive
Patterson, New York 12563

Attorneys for Plaintiff

102

31653/001/3453468.2
JS 44C/SDNY Case 1:20-cv-03366 Document 2 Filed
CIVIL COVER SHEET04/30/20 Page 1 of 2
REV. 06/01/17
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or
other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the
United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet.

PLAINTIFFS DEFENDANTS
Watch Tower Bible and Tract Society of Pennsylvania The Truth and Transparency Foundation, Ryan McKnight, and Ethan Gregory
Dodge

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN)
Cowan, Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036-1525

CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)

17 U.S.C. § 101 et seq. - Copyright Infringement

Judge Previously Assigned

Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No ✔ Yes

If yes, was this case Vol. Invol. Dismissed. No Yes If yes, give date _______________________ & Case No. ______________________

IS THIS AN INTERNATIONAL ARBITRATION CASE? No Yes

(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT

TORTS ACTIONS UNDER STATUTES

CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

[ ] 367 HEALTHCARE/
PHARMACEUTICAL PERSONAL [ ] 375 FALSE CLAIMS
[ ] 110 INSURANCE [ ] 310 AIRPLANE [ ] 625 DRUG RELATED [ ] 422 APPEAL
[ ] 120 MARINE [ ] 315 AIRPLANE PRODUCT INJURY/PRODUCT LIABILITY 28 USC 158 [ ] 376 QUI TAM
SEIZURE OF PROPERTY
[ ] 130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY 21 USC 881 [ ] 423 WITHDRAWAL [ ] 400 STATE
[ ] 140 NEGOTIABLE [ ] 320 ASSAULT, LIBEL & PRODUCT LIABILITY 28 USC 157 REAPPORTIONMENT
[ ] 690 OTHER
INSTRUMENT SLANDER [ ] 368 ASBESTOS PERSONAL [ ] 410 ANTITRUST
[ ] 150 RECOVERY OF [ ] 330 FEDERAL INJURY PRODUCT [ ] 430 BANKS & BANKING
OVERPAYMENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS [ ] 450 COMMERCE
ENFORCEMENT LIABILITY [ ] 460 DEPORTATION
OF JUDGMENT [ ] 340 MARINE PERSONAL PROPERTY [✖] 820 COPYRIGHTS [ ] 470 RACKETEER INFLU-
[ ] 151 MEDICARE ACT [ ] 345 MARINE PRODUCT [ ] 830 PATENT ENCED & CORRUPT
[ ] 152 RECOVERY OF LIABILITY [ ] 370 OTHER FRAUD ORGANIZATION ACT
[ ] 835 PATENT-ABBREVIATED NEW DRUG APPLICATION
DEFAULTED [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING (RICO)
STUDENT LOANS [ ] 355 MOTOR VEHICLE [ ] 840 TRADEMARK [ ] 480 CONSUMER CREDIT
(EXCL VETERANS) PRODUCT LIABILITY SOCIAL SECURITY [ ] 490 CABLE/SATELLITE TV
[ ] 153 RECOVERY OF [ ] 360 OTHER PERSONAL
OVERPAYMENT INJURY [ ] 380 OTHER PERSONAL LABOR [ ] 861 HIA (1395ff) [ ] 850 SECURITIES/
OF VETERAN'S [ ] 362 PERSONAL INJURY - PROPERTY DAMAGE [ ] 862 BLACK LUNG (923) COMMODITIES/
BENEFITS MED MALPRACTICE [ ] 385 PROPERTY DAMAGE [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g)) EXCHANGE
[ ] 160 STOCKHOLDERS PRODUCT LIABILITY STANDARDS ACT [ ] 864 SSID TITLE XVI
SUITS [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g))
[ ] 190 OTHER PRISONER PETITIONS RELATIONS [ ] 890 OTHER STATUTORY
CONTRACT [ ] 463 ALIEN DETAINEE [ ] 740 RAILWAY LABOR ACT ACTIONS
[ ] 195 CONTRACT [ ] 510 MOTIONS TO [ ] 751 FAMILY MEDICAL FEDERAL TAX SUITS [ ] 891 AGRICULTURAL ACTS
PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE LEAVE ACT (FMLA)
LIABILITY 28 USC 2255 [ ] 870 TAXES (U.S. Plaintiff or
[ ] 196 FRANCHISE CIVIL RIGHTS [ ] 530 HABEAS CORPUS [ ] 790 OTHER LABOR Defendant) [ ] 893 ENVIRONMENTAL
[ ] 535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY MATTERS
[ ] 540 MANDAMUS & OTHER [ ] 791 EMPL RET INC 26 USC 7609 [ ] 895 FREEDOM OF
[ ] 440 OTHER CIVIL RIGHTS
SECURITY ACT (ERISA) INFORMATION ACT
(Non-Prisoner)
REAL PROPERTY [ ] 896 ARBITRATION
[ ] 441 VOTING IMMIGRATION [ ] 899 ADMINISTRATIVE
[ ] 210 LAND [ ] 442 EMPLOYMENT PRISONER CIVIL RIGHTS
CONDEMNATION [ ] 443 HOUSING/ [ ] 462 NATURALIZATION PROCEDURE ACT/REVIEW OR
[ ] 220 FORECLOSURE ACCOMMODATIONS [ ] 550 CIVIL RIGHTS APPLICATION APPEAL OF AGENCY DECISION
[ ] 230 RENT LEASE & [ ] 445 AMERICANS WITH [ ] 555 PRISON CONDITION [ ] 465 OTHER IMMIGRATION [ ] 950 CONSTITUTIONALITY OF
EJECTMENT DISABILITIES - [ ] 560 CIVIL DETAINEE ACTIONS
EMPLOYMENT STATE STATUTES
[ ] 240 TORTS TO LAND CONDITIONS OF CONFINEMENT
[ ] 245 TORT PRODUCT [ ] 446 AMERICANS WITH
LIABILITY DISABILITIES -OTHER
[ ] 290 ALL OTHER [ ] 448 EDUCATION
REAL PROPERTY

Check if demanded in complaint:

DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.
CHECK IF THIS IS A CLASS ACTION AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13?
UNDER F.R.C.P. 23 IF SO, STATE:

DEMAND $______________ OTHER ______________ JUDGE _________________________________ DOCKET NUMBER_________________

Check YES only if demanded in complaint

JURY DEMAND: YES NO NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
 Case 1:20-cv-03366 Document 2 Filed 04/30/20 Page 2 of 2
(PLACE AN x IN ONE BOX ONLY) ORIGIN
✖ Multidistrict Appeal to District
1 Original 2 Removed from 3 Remanded 4 Reinstated or 5 Transferred from 6 Litigation
7 Judge from
Proceeding State Court from Reopened (Specify District)
(Transferred) Magistrate Judge
Appellate
a. all parties represented Court
8 Multidistrict Litigation (Direct File)
b. At least one party
is pro se.
(PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE
1 U.S. PLAINTIFF 2 U.S. DEFENDANT ✖ 3 FEDERAL QUESTION 4 DIVERSITY CITIZENSHIP BELOW.
(U.S. NOT A PARTY)

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

(Place an [X] in one box for Plaintiff and one box for Defendant)

PTF DEF PTF DEF PTF DEF

CITIZEN OF THIS STATE [ ]1 [ ]1 CITIZEN OR SUBJECT OF A [ ]3[ ]3 INCORPORATED and PRINCIPAL PLACE [ ]5 [ ]5
FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE

CITIZEN OF ANOTHER STATE [ ]2 [ ]2 INCORPORATED or PRINCIPAL PLACE [ ]4[ ]4 FOREIGN NATION [ ]6 [ ]6

OF BUSINESS IN THIS STATE

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)

200 Watch Tower Drive, Patterson, New York 12563 - Putnam County

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)

The Truth and Transparency Foundation: 109 Cascade Meadow Court, Henderson, Nevada 89011 -
Clark County

Ryan C. McKnight: 109 Cascade Meadow Court, Henderson, Nevada 89011 - Clark County

DEFENDANT(S) ADDRESS UNKNOWN

REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
Ethan G. Dodge

COURTHOUSE ASSIGNMENT
I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.

Check one: THIS ACTION SHOULD BE ASSIGNED TO: WHITE PLAINS ✖ MANHATTAN
04/30/2020
DATE ADMITTED TO PRACTICE IN THIS DISTRICT
SIGNATURE OF ATTORNEY OF RECORD
[ ] NO
10
[✖] YES (DATE ADMITTED Mo. _______ Yr. 2003
_______)
RECEIPT # Attorney Bar Code # TK-0605

Magistrate Judge is to be designated by the Clerk of the Court.

Magistrate Judge _________________________________________________________ is so Designated.

Ruby J. Krajick, Clerk of Court by _____________ Deputy Clerk, DATED _____________________.

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

 Case 1:20-cv-03366 Document 3 Filed 04/30/20 Page 1 of 1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

WATCH TOWER BIBLE AND TRACT SOCIETY OF

PENNSYLVANIA,
Plaintiff,

-against- No. 20-cv-3366

THE TRUTH AND TRANSPARENCY FOUNDATION,

RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

RULE 7.1 STATEMENT

Pursuant to Rule 7.1 of the Federal Rules of Civil Procedure, the undersigned attorney of

record for Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (a private non-

governmental party) certifies that there is no parent company of Watch Tower Bible and Tract

Society of Pennsylvania, and no publicly held company owns 10% or more of its stock.

Dated: New York, New York

April 30, 2020 Respectfully submitted,

COWAN, LIEBOWITZ & LATMAN, P.C.

By: s/ Kieran G. Doyle _

Kieran G. Doyle
114 West 47th Street
New York, New York 10036
(212) 790-9200

31653/001/3452979.1
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 1 of 9
AO 121 (5HY6/)
TO:

5HJLVWHURI&RS\ULJKWV REPORT ON THE

86&RS\ULJKW2IILFH FILING OR DETERMINATION OF AN
,QGHSHQGHQFH$YH6( ACTION OR APPEAL
:DVKLQJWRQ'& REGARDING A COPYRIGHT

In compliance with the provisions of 17 U.S.C. 508, you are hereby advised that a court action or appeal has been filed
on the following copyright(s):
COURT NAME AND LOCATION
✔ ACTION
G G APPEAL USDC-Southern District of New York
DOCKET NO. DATE FILED
20-cv-3366 4/30/2020
PLAINTIFF DEFENDANT
Watch Tower Bible and Tract Society of Pennsylvania The Truth and Transparency Foundation, Ryan C.
McKnight and Ethan G. Dodge

COPYRIGHT
TITLE OF WORK AUTHOR OR WORK
REGISTRATION NO.

1 PA0002121393 “Be a Courageous … Pioneer” Watch Tower Bible and Tract Soc.

2 PA0002121074 Talk 33 - Video 1 - Learn Courage From Creation... Watch Tower Bible and Tract Soc.

3 PA0002121104 Talk 40 - Video 1 - How Our Brothers Are Showing... Watch Tower Bible and Tract Soc.

4 PA0002121120 Talk 44 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.

5 PA0002121121 Talk 45 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.
See Attached Schedule for Complete List

In the above-entitled case, the following copyright(s) have been included:

DATE INCLUDED INCLUDED BY
G Amendment G Answer G Cross Bill G Other Pleading
COPYRIGHT
TITLE OF WORK AUTHOR OF WORK
REGISTRATION NO.

3 .

In the above-entitled case, a final decision was rendered on the date entered below. A copy of the order or judgment
together with the written opinion, if any, of the court is attached.
COPY ATTACHED WRITTEN OPINION ATTACHED DATE RENDERED

G Order G Judgment G Yes G No

CLERK (BY) DEPUTY CLERK DATE

1) Upon initiation of action, 2) Upon filing of document adding copyright(s), 3) Upon termination of action,
mail copy to Register of Copyrights mail copy to Register of Copyrights mail copy to Register of Copyrights
DISTRIBUTION:
4) In the event of an appeal, forward copy to Appellate Court 5) Case File Copy
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 2 of 9

COPYRIGHT TITLE OF WORK AUTHOR OR WORK

REGISTRATION NO.
PA0002121124 Talk 46-Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Proclamation of the Hailstone
Message
PA0002121125 Talk 47 - Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Attack by Gog of Magog
PA0002121607 Talk 48-Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) -
Armageddon
PA0002121129 Talk 49 - Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Great Reconstruction
PA0002121132 Talk 50 - Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Final Test
PA0002191509 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 1
PA0002191514 Talk 01 Video 1 - Chairman’s Watch Tower Bible and Tract
Address: ‘Love Never Fails - Society of Pennsylvania
Why?
PA0002191517 Talk 01 Video 2 - Chairman’s Watch Tower Bible and Tract
Address: ‘Love Never Fails’ - Society of Pennsylvania
Why?
PA0002191478 Talk 02 Video 1 - Watch Tower Bible and Tract
Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Wealth (Matthew 6:24)
PA0002191475 Talk 03 Video 1 - Watch Tower Bible and Tract
Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Status and Fame (Ecclesiastes
2:16; Romans 12:16)
PA0002191487 Talk 04 Video 1 - Watch Tower Bible and Tract
Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Human Wisdom (Romans
12:1, 2)
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 3 of 9

PA0002191489 Talk 05 Video 1 - Watch Tower Bible and Tract

Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Strength and Beauty
(Proverbs 31:30; 1 Peter 3:3,
4)
PA0002191501 Talk 06 Video 1 - Watch Tower Bible and Tract
DRAMATIC BIBLE Society of Pennsylvania
READING: Jehovah Kept
Showing Loyal Love
(Genesis 37:1-36; 39:1;
47:12)
PA0002191510 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention—Music-Video Society of Pennsylvania
Presentation 2Talk 23 Video
1 - Symposium: Display
Unfailing Love in the
Congregation - To the
Elderly (Leviticus 19:32)
PA0002191450 Talk 08 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … A Loveless
Upbringing (Psalm 27:10)
PA0002191453 Talk 09 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … A Difficult
Work Environment (1 Peter
2:18-20)
PA0002191458 Talk 10 Video 2 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … An Ungodly
School Environment (1
Timothy 4:12)
PA0002191459 Talk 11 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … Chronic
Health Problems (2
Corinthians 12:9, 10)
PA0002191460 Talk 12 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … Poverty
(Philippians 4:12, 13)
PA0002191461 Talk 12 Video 2 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … Poverty
(Philippians 4:12, 13)
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 4 of 9

PA0002191455 Talk 13 Video 1 - Watch Tower Bible and Tract

Symposium: Love Never Society of Pennsylvania
Fails Despite … Family
Opposition (Matthew 5:44)
PA0002191432 Talk 14 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
The Heavens (Psalm 8:3, 4;
33:6)
PA0002191434 Talk 15 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
The Earth (Psalm 37:29;
115:16)
PA0002191437 Talk 16 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
Plants (Genesis 1:11, 29; 2:9,
15; Acts 14:16, 17)
PA0002191444 Talk 17 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
Animals (Genesis 1:27;
Matthew 6:26)
PA0002191446 Talk 18 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
The Human Body (Psalm
139:14; Ecclesiastes 3:11)
PA0002191504 Talk 19 Video 1 - ‘Those Watch Tower Bible and Tract
Whom Jehovah Loves He Society of Pennsylvania
Disciplines’ (Hebrews 12:5-
11; Psalm 19:7, 8, 11)
PA0002191471 Talk 20 Video 1 - ‘Clothe Watch Tower Bible and Tract
Yourselves With Love’ Society of Pennsylvania
(Colossians 3:12-14)
PA0002191139 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 3
PA0002191157 Talk 21 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To Those
Taking the Lead (1
Thessalonians 5:12, 13)
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 5 of 9

PA0002191160 Talk 23 Video 1 - Watch Tower Bible and Tract

Suppl. Reg. PA0002216893 Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To the
Elderly (Leviticus 19:32)
PA0002191146 Talk 24 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To Full-Time
Ministers (1 Thessalonians
1:3)
PA0002191155 Talk 25 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To Foreign
Residents (Leviticus 19:34;
Romans 15:7)
PA0002191149 ANNOUNCEMENT: Watch Tower Bible and Tract
Invitation to School for Society of Pennsylvania
Kingdom Evangelizers
Meeting
PA0002191683 Talk 26 Video 1 - Watch Tower Bible and Tract
A0002191683: Display Society of Pennsylvania
Unfailing Love in the
Ministry - Show Your Love
for God (1 John 5:3)
PA0002191148 Talk 27 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Ministry – ‘Love Your
Neighbor as Yourself’
(Matthew 22:39)
PA0002191684 Talk 28 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Ministry - Love Jehovah’s
Word (Psalm 119:97;
Matthew 13:52)
PA0002193286 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 4 (v2)
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 6 of 9

PA0002191713 Talk 30 Video 1 - Watch Tower Bible and Tract

Symposium: How Our Society of Pennsylvania
Brothers Are Showing
Unfailing Love In … Africa
(Genesis 16:13), Asia (Acts
2:44), Europe (John 4:35),
North America (1 Corinthians
9:22), Oceania (Psalm 35:18),
South America (Acts 1:8)
PA0002191714 Talk 31 Video 1 - Display Watch Tower Bible and Tract
Unfailing Love in Your Society of Pennsylvania
Family - Love Your Wife
(Ephesians 5:28, 29)
PA0002191715 Talk 32 Video 1 - Display Watch Tower Bible and Tract
Unfailing Love in Your Society of Pennsylvania
Family - Love Your Husband
(Ephesians 5:33; 1 Peter 3:1-
6)
PA0002191717 Talk 33 Video 1 - Display Watch Tower Bible and Tract
Unfailing Love in Your Society of Pennsylvania
Family - Love Your Children
(Titus 2:4)
PA0002191144 The Story of Josiah: Love Watch Tower Bible and Tract
Jehovah; Hate What Is Bad - Society of Pennsylvania
Part I (2 Chronicles 33:10-24;
34:1, 2)
PA0002191678 Talk 35 Video 1 - Teach Watch Tower Bible and Tract
Your Children How to Show Society of Pennsylvania
Love (2 Timothy 3:14, 15)
PA0002192006 Talk 35 Video 3 - Teach Watch Tower Bible and Tract
Your Children How to Show Society of Pennsylvania
Love (2 Timothy 3:14, 15)
PA0002192007 Talk 35 Video 4 - Teach Watch Tower Bible and Tract
Your Children How to Show Society of Pennsylvania
Love (2 Timothy 3:14, 15)
PA0002191679 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 5
PA0002192010 Talk 36 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Patient and
Kind (1 Corinthians 13:4)
PA0002192009 Talk 36 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Patient and
Kind (1 Corinthians 13:4)
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 7 of 9

PA0002191147 Talk 37 Video 1 - Watch Tower Bible and Tract

Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Not
Jealous; Does Not Brag (1
Corinthians 13:4)
PA0002191150 Talk 37 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Not
Jealous; Does Not Brag (1
Corinthians 13:4)
PA0002191151 Talk 38 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not Get
Puffed Up; Does Not Behave
Indecently (1 Corinthians
13:4, 5)
PA0002191152 Talk 38 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not Get
Puffed Up; Does Not Behave
Indecently (1 Corinthians
13:4, 5)
PA0002191156 Talk 39 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Look for Its Own Interests;
Does Not Become Provoked
(1 Corinthians 13:5)
PA0002191153 Talk 39 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Look for Its Own Interests;
Does Not Become Provoked
(1 Corinthians 13:5)
PA0002191154 Talk 40 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Keep Account of the Injury;
Does Not Rejoice Over
Unrighteousness (1
Corinthians 13:5, 6)
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 8 of 9

PA0002191719 Talk 40 Video 2 - Watch Tower Bible and Tract

Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Keep Account of the Injury;
Does Not Rejoice Over
Unrighteousness (1
Corinthians 13:5, 6)
PA0002191722 Talk 41 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Rejoices
With the Truth; Bears All
Things (1 Corinthians 13:6,
7)
PA0002191723 Talk 41 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Rejoices
With the Truth; Bears All
Things (1 Corinthians 13:6,
7)
PA0002191724 Talk 42 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Believes All
Things; Hopes All Things 1
Corinthians 13:7)
PA0002191727 Talk 42 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Believes All
Things; Hopes All Things 1
Corinthians 13:7)
PA0002191729 Talk 43 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Endures All
Things; Love Never Fails (1
Corinthians 13:7, 8)
PA0002191159 Talk 43 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Endures All
Things; Love Never Fails (1
Corinthians 13:7, 8)
PA0002191418 Talk 44 Video 1 - Public Watch Tower Bible and Tract
Bible Discourse: True Love Society of Pennsylvania
in a Hate-Filled World -
Where? (John 13:34, 35)
 Case 1:20-cv-03366 Document 4 Filed 04/30/20 Page 9 of 9

PA0002191141 Talk 44 Video 2 - Public Watch Tower Bible and Tract

Bible Discourse: True Love Society of Pennsylvania
in a Hate-Filled World -
Where?
(John 13:34, 35)
PA0002191682 The Story of Josiah: Love Watch Tower Bible and Tract
Jehovah; Hate What Is Bad - Society of Pennsylvania
Part II (2 Kings 22:3-20;
23:1-25; 2 Chronicles 34:3-
33; 35:1-19)
PA0002191138 Talk 47 Video 1 - ‘Carefully Watch Tower Bible and Tract
Consider Jehovah’s Acts of Society of Pennsylvania
Loyal Love’ (Psalm 107:43;
Ephesians 5:1, 2)
PA0002191706 Talk 47 Video 5 - Unfailing Watch Tower Bible and Tract
Love (1 Corinthians 13:8)) Society of Pennsylvania
PA0002191143 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 6
 Case 1:20-cv-03366 Document 5 Filed 04/30/20 Page 1 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
Southern District
__________ DistrictofofNew York
__________

WATCH TOWER BIBLE AND TRACT SOCIETY OF )

PENNSYLVANIA )
)
)
Plaintiff(s) )
)
v. Civil Action No. 20-cv-3366
)
THE TRUTH AND TRANSPARENCY )
FOUNDATION, RYAN C. McKNIGHT, )
and ETHAN G. DODGE )
)
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) The Truth and Transparency Foundation
109 Cascade Meadow Court
Henderson, Nevada 89011

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kieran G. Doyle
Thomas Kjelberg
Cowan, Liebowitz & Latman, P.C.
114 West 47th Street
21st Floor
New York, NY 10036

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 1:20-cv-03366 Document 5 Filed 04/30/20 Page 2 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No. 20-cv-3366

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

u I personally served the summons on the individual at (place)

on (date) ; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

u I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

u I returned the summons unexecuted because ; or

u Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

 Case 1:20-cv-03366 Document 6 Filed 04/30/20 Page 1 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
Southern District
__________ DistrictofofNew York
__________

WATCH TOWER BIBLE AND TRACT SOCIETY OF )

PENNSYLVANIA )
)
)
Plaintiff(s) )
)
v. Civil Action No. 20-cv-3366
)
THE TRUTH AND TRANSPARENCY )
FOUNDATION, RYAN C. McKNIGHT, )
and ETHAN G. DODGE )
)
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) Ryan C. McKnight

109 Cascade Meadow Court
Henderson, Nevada 89011

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kieran G. Doyle
Thomas Kjelberg
Cowan, Liebowitz & Latman, P.C.
114 West 47th Street
21st Floor
New York, NY 10036

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 1:20-cv-03366 Document 6 Filed 04/30/20 Page 2 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No. 20-cv-3366

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

u I personally served the summons on the individual at (place)

on (date) ; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

u I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

u I returned the summons unexecuted because ; or

u Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

 Case 1:20-cv-03366 Document 7 Filed 04/30/20 Page 1 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
Southern District
__________ DistrictofofNew York
__________

WATCH TOWER BIBLE AND TRACT SOCIETY OF )

PENNSYLVANIA )
)
)
Plaintiff(s) )
)
v. Civil Action No. 20-cv-3366
)
THE TRUTH AND TRANSPARENCY )
FOUNDATION, RYAN C. McKNIGHT, )
and ETHAN G. DODGE )
)
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) Ethan G. Dodge

12597 Cresthaven Drive
Groveland, CA 95321-9316

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kieran G. Doyle
Thomas Kjelberg
Cowan, Liebowitz & Latman, P.C.
114 West 47th Street
21st Floor
New York, NY 10036

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 1:20-cv-03366 Document 7 Filed 04/30/20 Page 2 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No. 20-cv-3366

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

u I personally served the summons on the individual at (place)

on (date) ; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

u I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

u I returned the summons unexecuted because ; or

u Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

 Case 1:20-cv-03366-MKV Document 24 Filed 07/17/20 Page 1 of 2

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

WATCH TOWER BIBLE AND TRACT SOCIETY OF

PENNSYLVANIA,
Plaintiff,
No. 1:20-cv-03366 (MKV)
-against-

THE TRUTH AND TRANSPARENCY FOUNDATION,

RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

NOTICE OF SETTLEMENT AND

MOTION FOR ENTRY OF JUDGMENT ON CONSENT
Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (“Watch Tower”), by its

attorneys, Cowan, Liebowitz & Latman, P.C., and Defendants The Truth and Transparency

Foundation, Ryan C. McKnight, and Ethan G. Dodge (“Defendants”), by their attorneys, Long &

Associates PLLC (collectively, the “Parties”), hereby notify the Court of their settlement of this

action and respectfully move the Court to enter a Final Order and Judgment on Consent in the form

submitted herewith.

1. This motion for entry of a Consent Judgment represents part of the Parties’

amicable settlement of this action.

2. Except for the injunctive relief provided by the Final Order and Judgment on

Consent, and subject to entry of the Final Order and Judgment on Consent, Watch Tower agrees to

dismiss with prejudice all other claims in this action against Defendants.

3. The Final Order and Judgment on Consent shall be enforceable upon entry. Watch

Tower and Defendants hereby waive findings of fact, conclusions of law, a statement of decision

and any right to set aside the Final Order and Judgment on Consent, appeal therefrom, or otherwise

contest the validity of the Final Order and Judgment on Consent.

 Case 1:20-cv-03366-MKV Document 24 Filed 07/17/20 Page 2 of 2

4. This Court shall retain jurisdiction to enforce the terms of the Parties’ settlement

agreement and the Final Order and Judgment on Consent in the form submitted herewith.

Dated: July 17, 2020 Dated: July 17, 2020

/s/ Thomas Kjellberg /s/ Ryan E. Long

Thomas Kjellberg ([email protected]) Ryan E. Long ([email protected])
COWAN, LIEBOWITZ & LATMAN, P.C. LONG & ASSOCIATES PLLC
114 West 47th Street 18 West 18th St. – 8th Floor
New York, NY 10036-1525 New York, New York 10011
(212) 790-9200 (212) 381-9637
Case 1:20-cv-03366-MKV Document 24-1 Filed 07/17/20 Page 1 of 5

[PROPOSED]
Case 1:20-cv-03366-MKV Document 24-1 Filed 07/17/20 Page 2 of 5
Case 1:20-cv-03366-MKV Document 24-1 Filed 07/17/20 Page 3 of 5
 Case 1:20-cv-03366-MKV Document 24-1 Filed 07/17/20 Page 4 of 5

(h) This Final Order and Judgment on Consent shall be binding on the parties and

their heirs, successors and assigns.

(i) All of the parties hereto consent to the issuance and entry of this Final Order and

Judgment on Consent and waive the right to appeal from or otherwise contest this Final Order

and Judgment on Consent, which may be entered in the form and content set forth above without

further notice to any party.

AGREED AS TO FORM AND SUBSTANCE:

Dated: New York, New York COWAN, LIEBOWITZ & LATMAN, P.C.
July 14, 2020 Attorneys for Plaintiff

By: :il::;LJ!~om)
114 West 47th Street
New York, New York 10036-1525

Dated: Patterson, New York WATCH TOWER BIBLE AND TRACT

Jul 14, 2020 SOCIETY OF PENNSYLVANIA

By: Phili p Brumley (Jul 14, 2020 16:39 EDT)

Philip Brumley
General Counsel

Dated: New York, New York LONG ASSOCIATES PLLC

Attorneys for Defendants

By: _ _ _ _ _ _ _ _ __ _ __
Ryan E. Long ([email protected])

Long & Associates PLLC

18 West 18th St. - lOthFloor
New York, New York 10011

3
Case 1:20-cv-03366-MKV Document 24-1 Filed 07/17/20 Page 5 of 5

07/14/2020
 Case 1:20-cv-03366-MKV Document 25 Filed 09/09/20 Page 1 of 2

USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK
DOC #:
WATCH TOWER BIBLE AND TRACT SOCIETY OF DATE FILED: 9/9/2020
PENNSYLVANIA,

Plaintiff,
20-cv-3366 (MKV)
-against-
ORDER
THE TRUTH AND TRANSPARENCY FOUNDATION, et al.,

Defendants.

MARY KAY VYSKOCIL, United States District Judge:

The Court is in receipt of the parties’ joint motion for entry of judgment in this case [ECF

#24, 24-1 (“Proposed Judgment”)]. IT IS HEREBY ORDERED that, on Thursday, September

17, 2020 at 12:00 PM, the parties shall appear for a conference to discuss their Proposed

Judgment. Specifically, the parties propose that “[t]his Court shall retain continuing jurisdiction

over the parties and over the subject matter of this action for the purposes of interpreting and

enforcing the terms of th[e] Final Order and Judgment on Consent.” Proposed Judgment at 2.

However, as the Court states in its Individual Rules of Practice in Civil Cases, the Court typically

will not retain jurisdiction to enforce settlement agreements.

The parties have not cited any reason for the Court to conclude that this case may only be

dismissed, pursuant to Rule 41(a)(2) of the Federal Rules of Civil Procedure, by order of the

court “and upon such terms and conditions as the court deems proper.” Fed. R. Civ. P. 41(a)(2);

Hester Indus., Inc. v. Tyson Foods, Inc., 160 F.3d 911, 916 (2d Cir. 1998) (explaining that Rule

41(a)(2) does not apply to circumstances where the plaintiff can secure consent to a stipulated

dismissal). The parties are free to settle this case, pursuant to Rule 41(a)(1)(A)(ii), on any terms

they wish, and they will be bound by the terms and conditions of their stipulation of voluntary

dismissal. 9 Wright & Miller, Federal Practice & Procedure § 2363 (3d ed. 2008). Such a
 Case 1:20-cv-03366-MKV Document 25 Filed 09/09/20 Page 2 of 2

voluntary dismissal by stipulation does not require judicial approval. Torres v. Walker, 356 F.3d

238, 243 (2d Cir. 2004). However, if the Court enters the parties’ Proposed Judgment and retains

jurisdiction to enforce the terms of their agreement to dispose of this case, that disposition will

carry the Court’s “judicial imprimatur.” Id.

Due to the ongoing COVID-19 pandemic, the conference to discuss the parties’ Proposed

Judgment will be held by telephone. The conference can be accessed by calling the Court’s

teleconference line at 888-278-0296 at the scheduled time. When prompted, enter Access Code

5195844. The Court will join once all of the parties are on the line.

SO ORDERED.
_________________________________
Date: September 9, 2020 MARY KAY VYSKOCIL
New York, NY United States District Judge

2
 Case 1:20-cv-03366-MKV Document 26 Filed 09/30/20 Page 1 of 2

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

WATCH TOWER BIBLE AND TRACT SOCIETY OF

PENNSYLVANIA,
Plaintiff,
No. 1:20-cv-03366 (MKV)
-against-

THE TRUTH AND TRANSPARENCY FOUNDATION,

RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

NOTICE OF MOTION FOR ENTRY OF

FINAL JUDGMENT AND PERMANENT INJUNCTION ON CONSENT

Plaintiff Watch Tower Bible and Tract Society of Pennsylvania (“Watch Tower”), by its

attorneys, Cowan, Liebowitz & Latman, P.C., and Defendants The Truth and Transparency

Foundation, Ryan C. McKnight, and Ethan G. Dodge (“Defendants”), by their attorneys, Long &

Associates PLLC (collectively, the “Parties”), hereby respectfully move the Court to enter a

Final Judgment and Permanent Injunction on Consent in the form submitted herewith.

1. This motion for entry of a Final Judgment and Permanent Injunction on Consent

is a component of the Parties’ amicable settlement of this action.

2. Except for the injunctive relief provided by the Final Judgment and Permanent

Injunction on Consent, and subject to entry of the Final Judgment and Permanent Injunction on

Consent, Watch Tower agrees to dismiss with prejudice all other claims in this action against

Defendants.

3. The Final Judgment and Permanent Injunction on Consent shall be enforceable

upon entry. Watch Tower and Defendants hereby waive findings of fact, conclusions of law, a

statement of decision, and any right to set aside the Final Judgment and Permanent Injunction on
 Case 1:20-cv-03366-MKV Document 26 Filed 09/30/20 Page 2 of 2

Consent, appeal therefrom, or otherwise contest the validity of the Final Judgment and

Permanent Injunction on Consent.

Dated: September 30, 2020 Dated: September 30, 2020

/s/ Thomas Kjellberg /s/ Ryan E. Long

Thomas Kjellberg ([email protected]) Ryan E. Long ([email protected])
COWAN, LIEBOWITZ & LATMAN, P.C. LONG & ASSOCIATES PLLC
114 West 47th Street 135 West 27th Street, 8th Floor
New York, NY 10036-1525 New York, New York 10001
(212) 790-9200 (212) 381-9637
 Case 1:20-cv-03366-MKV Document 26-1 Filed 09/30/20 Page 1 of 3

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

WATCH TOWER BIBLE AND TRACT SOCIETY OF

PENNSYLVANIA,
Plaintiff,
No. 1:20-cv-03366 (MKV)
-against-

THE TRUTH AND TRANSPARENCY FOUNDATION,

RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

[PROPOSED] FINAL JUDGMENT AND PERMANENT INJUNCTION ON CONSENT

IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff Watch Tower

Bible and Tract Society of Pennsylvania (“Watch Tower”) and Defendants The Truth and

Transparency Foundation, Ryan C. McKnight, and Ethan G. Dodge (together, “Defendants”),

that this Final Judgment and Permanent Injunction on Consent be entered in the present action as

set forth below without further notice or process:

WHEREAS, Watch Tower is responsible for the creation and publication of works of

authorship including literary works, works of visual art, musical works, and motion pictures;

WHEREAS, Defendants without permission or license copied, reproduced, publicly

displayed, publicly performed and distributed the 74 registered copyrighted motion pictures of

Watch Tower identified on Schedule A hereto (the “Copyrighted Works”); and

WHEREAS Watch Tower and Defendants have agreed to end this dispute on terms that

include the entry of this Final Judgment and Permanent Injunction on Consent, and have

consented to the entry of this Final Judgment and Permanent Injunction on Consent;
 Case 1:20-cv-03366-MKV Document 26-1 Filed 09/30/20 Page 2 of 3

NOW THEREFORE, upon the consent and request of Watch Tower and Defendants, IT

IS HEREBY ORDERED, ADJUDGED, and DECREED that:

1. Defendants, and their agents, representatives, employees and other persons and

entities acting in concert with them, are permanently enjoined, restrained and prohibited from

(a) using or causing to be used, or inducing, authorizing or facilitating any third

party to use, any of the Copyrighted Works in any medium including but not limited to

the faithleaks.org website, and any other website operated or controlled, in whole or in

part, by Defendants or any of them; and

(b) using or causing to be used, or inducing, authorizing or facilitating any third

party to use, any copyrighted works other than the Copyrighted Works, now in existence

or to be created in the future, that are owned by Watch Tower or by entities that

cooperate with Watch Tower.

2. No bond or posting of security is required in connection with the entry of this

Permanent Injunction.

3. All of the parties waive the right to appeal from or otherwise contest this Final

Order and Judgment on Consent, which may be entered in the form and content set forth above

without further notice to any party.

Dated: September 30, 2020 Dated: September 30, 2020

/s/ Thomas Kjellberg /s/ Ryan E. Long

Thomas Kjellberg ([email protected]) Ryan E. Long ([email protected])
COWAN, LIEBOWITZ & LATMAN, P.C. LONG & ASSOCIATES PLLC
114 West 47th Street 135 West 27th Street, 8th Floor
New York, NY 10036-1525 New York, New York 10001
(212) 790-9200 (212) 381-9637
Case 1:20-cv-03366-MKV Document 26-1 Filed 09/30/20 Page 3 of 3

IT IS SO ORDERED this day of , 2020.

___________________________________________
Mary Kay Vyskocil
United States District Judge
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 1 of 15

SCHEDULE A
TO FINAL JUDGMENT AND PERMANENT INJUNCTION ON CONSENT

Registered Copyrighted Works

1. Title: “Be a Courageous … Pioneer”

Type of Work: Motion Picture
Registration Number / Date: PA0002121393 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
2. Title: “Talk 33 - Video 1 - Learn Courage From Creation (Symposium) – Horses”
Type of Work: Motion Picture
Registration Number / Date: PA0002121074 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
3. Title: “Talk 40 - Video 1 - How Our Brothers Are Showing Courage In … (Symposium)
- North America”
Type of Work: Motion Picture
Registration Number / Date: PA0002121104 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
4. Title: “Talk 44 - Video 1 - Future Events That Will Require Courage (Symposium) - The
Cry of “Peace and Security!”
Type of Work: Motion Picture
Registration Number / Date: PA0002121120 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
5. Title: “Talk 45 - Video 1 - Future Events That Will Require Courage (Symposium) - The
Destruction of Babylon the Great”
Type of Work: Motion Picture
Registration Number / Date: PA0002121121 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 2 of 15

Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,

employer for hire
6. Title: “Talk 46-Video 1 - Future Events That Will Require Courage (Symposium) - The
Proclamation of the Hailstone Message”
Type of Work: Motion Picture
Registration Number / Date: PA0002121124 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
7. Title: “Talk 47 - Video 1 - Future Events That Will Require Courage (Symposium) - The
Attack by Gog of Magog”
Type of Work: Motion Picture
Registration Number / Date: PA0002121125 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
8. Title: “Talk 48 - Video 1 - Future Events That Will Require Courage (Symposium) -
Armageddon”
Type of Work: Motion Picture
Registration Number / Date: PA0002121607 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
9. Title: “Talk 49 - Video 1 - Future Events That Will Require Courage (Symposium) - The
Great Reconstruction”
Type of Work: Motion Picture
Registration Number / Date: PA0002121129 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
10. Title: “Talk 50 - Video 1 - Future Events That Will Require Courage (Symposium) - The
Final Test”
Type of Work: Motion Picture
Registration Number / Date: PA0002121132 / 2018-05-18
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 3 of 15

Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,

employer for hire
11. Title: “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 1”
Type of Work: Motion Picture
Registration Number / Date: PA0002191509 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
12. Title: “Talk 01 Video 1 - Chairman’s Address: ‘Love Never Fails - Why?’ (Romans
8:38, 39; 1 Corinthians 13:1-3, 8, 13)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191514 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
13. Title: “Talk 01 Video 2 - Chairman’s Address: ‘Love Never Fails’ - Why?’ (Romans
8:38, 39; 1 Corinthians 13:1-3, 8, 13)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191517 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
14. Title: “Talk 02 Video 1 - Symposium: Beware of Trusting in What Fails! - Wealth
(Matthew 6:24)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191478 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
15. Title: “Talk 03 Video 1 - Symposium: Beware of Trusting in What Fails! - Status and
Fame (Ecclesiastes 2:16; Romans 12:16)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191475 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 4 of 15

16. Title: “Talk 04 Video 1 - Symposium: Beware of Trusting in What Fails! - Human
Wisdom (Romans 12:1, 2)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191487 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
17. Title: “Talk 05 Video 1 - Symposium: Beware of Trusting in What Fails! - Strength and
Beauty (Proverbs 31:30; 1 Peter 3:3, 4)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191489 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
18. Title: “Talk 06 Video 1 - DRAMATIC BIBLE READING: Jehovah Kept Showing
Loyal Love (Genesis 37:1-36; 39:1; 47:12)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191501 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
19. Title: “Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To
the Elderly (Leviticus 19:32)”
Type of Work: Motion Picture
Registration Number / Date: PA0002216893 / 2019-09-04
Supplement to: PA0002191160 / 2019
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
20. Title: “Talk 08 Video 1 - Symposium: Love Never Fails Despite … A Loveless
Upbringing (Psalm 27:10)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191450 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 5 of 15

21. Title: “Talk 09 Video 1 - Symposium: Love Never Fails Despite … A Difficult Work
Environment (1 Peter 2:18-20)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191453 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
22. Title: “Talk 10 Video 2 - Symposium: Love Never Fails Despite … An Ungodly School
Environment (1 Timothy 4:12)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191458 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
23. Title: “Talk 11 Video 1 - Symposium: Love Never Fails Despite … Chronic Health
Problems (2 Corinthians 12:9, 10)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191459 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
24. Title: “Talk 12 Video 1 - Symposium: Love Never Fails Despite … Poverty (Philippians
4:12, 13)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191460 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
25. Title: “Talk 12 Video 2 - Symposium: Love Never Fails Despite … Poverty (Philippians
4:12, 13)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191461 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 6 of 15

26. Title: “Talk 13 Video 1 - Symposium: Love Never Fails Despite … Family Opposition
(Matthew 5:44)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191455 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
27. Title: “Talk 14 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Heavens
(Psalm 8:3, 4; 33:6)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191432 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
28. Title: “Talk 15 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Earth
(Psalm 37:29; 115:16)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191434 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
29. Title: “Talk 16 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Plants
(Genesis 1:11, 29; 2:9, 15; Acts 14:16, 17)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191437 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
30. Title: “Talk 17 Video 1 - Symposium: Creation Reveals Jehovah’s Love - Animals
(Genesis 1:27; Matthew 6:26)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191444 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 7 of 15

31. Title: “Talk 18 Video 1 - Symposium: Creation Reveals Jehovah’s Love - The Human
Body (Psalm 139:14; Ecclesiastes 3:11)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191446 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
32. Title: “Talk 19 Video 1 - ‘Those Whom Jehovah Loves He Disciplines’ (Hebrews 12:5-
11; Psalm 19:7, 8, 11)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191504 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
33. Title: “Talk 20 Video 1 - ‘Clothe Yourselves With Love’ (Colossians 3:12-14)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191471 / 2019-05-17
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
34. Title: “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 3”
Type of Work: Motion Picture
Registration Number / Date: PA0002191139 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
35. Title: “Talk 21 Video 1 - Symposium: Display Unfailing Love in the Congregation - To
Those Taking the Lead (1 Thessalonians 5:12, 13)”
Type of Work: Motion Picture
Registration Number / Date: PA0002214841 / 2019-08-19
Supplement to: PA0002191157 / 2019
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania. Address:
200 Watchtower Dr., Patterson, NY, 12563-9204, United States.
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 8 of 15

36. Title: “Talk 23 Video 1 - Symposium: Display Unfailing Love in the Congregation - To
the Elderly (Leviticus 19:32)”
Type of Work: Motion Picture
Registration Number / Date: PA0002216893 / 2019-09-04
Supplement to: PA0002191160 / 2019
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire; Citizenship: United States. Authorship: entire motion picture.
37. Title: “Talk 24 Video 1 - Symposium: Display Unfailing Love in the Congregation - To
Full-Time Ministers (1 Thessalonians 1:3)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191146 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
38. Title: “Talk 25 Video 1 - Symposium: Display Unfailing Love in the Congregation - To
Foreign Residents (Leviticus 19:34; Romans 15:7)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191155 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
39. Title: “ANNOUNCEMENT: Invitation to School for Kingdom Evangelizers Meeting”
Type of Work: Motion Picture
Registration Number / Date: PA0002191149 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
40. Title: “Talk 26 Video 1 - Symposium: Display Unfailing Love in the Ministry - Show
Your Love for God (1 John 5:3)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191683 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 9 of 15

41. Title: “Talk 27 Video 1 - Symposium: Display Unfailing Love in the Ministry – ‘Love
Your Neighbor as Yourself’ (Matthew 22:39)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191148 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
42. Title: “Talk 28 Video 1 - Symposium: Display Unfailing Love in the Ministry - Love
Jehovah’s Word (Psalm 119:97; Matthew 13:52)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191684 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
43. Title: “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 4 (v2
Type of Work: Motion Picture
Registration Number / Date: PA0002193286 / 2019-06-05
Application Title: 2019 "Love Never Fails"! Convention?Music-Video Presentation 4
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
44. Title: “Talk 30 Video 1 - Symposium: How Our Brothers Are Showing Unfailing Love
In … Africa (Genesis 16:13), Asia (Acts 2:44), Europe (John 4:35), North America (1
Corinthians 9:22), Oceania (Psalm 35:18), South America (Acts 1:8)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191713 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
45. Title: “Talk 31 Video 1 - Display Unfailing Love in Your Family - Love Your Wife
(Ephesians 5:28, 29)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191714 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 10 of 15

46. Title: “Talk 32 Video 1 - Display Unfailing Love in Your Family - Love Your Husband
(Ephesians 5:33; 1 Peter 3:1-6)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191715 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
47. Title: “Talk 33 Video 1 - Display Unfailing Love in Your Family - Love Your Children
(Titus 2:4)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191717 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
48. Title: “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part I (2 Chronicles
33:10-24; 34:1, 2)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191144 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
49. Title: “Talk 35 Video 1 - Teach Your Children How to Show Love (2 Timothy 3:14,
15)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191678 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
50. Title: “Talk 35 Video 3 - Teach Your Children How to Show Love (2 Timothy 3:14,
15)”
Type of Work: Motion Picture
Registration Number / Date: PA0002192006 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 11 of 15

51. Title: “Talk 35 Video 4 - Teach Your Children How to Show Love (2 Timothy 3:14,
15)”
Type of Work: Motion Picture
Registration Number / Date: PA0002192007 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
52. Title: “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 5”
Type of Work: Motion Picture
Registration Number / Date: PA0002191679 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
53. Title: “Talk 36 Video 1 - Symposium: Remember How Love Behaves - Is Patient and
Kind (1 Corinthians 13:4)”
Type of Work: Motion Picture
Registration Number / Date: PA0002192010 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
54. Title: “Talk 36 Video 2 - Symposium: Remember How Love Behaves - Is Patient and
Kind (1 Corinthians 13:4)”
Type of Work: Motion Picture
Registration Number / Date: PA0002192009 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
55. Title: “Talk 37 Video 1 - Symposium: Remember How Love Behaves - Is Not Jealous;
Does Not Brag (1 Corinthians 13:4)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191147 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
56. Title: “Talk 37 Video 2 - Symposium: Remember How Love Behaves - Is Not Jealous;
Does Not Brag (1 Corinthians 13:4)”
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 12 of 15

Type of Work: Motion Picture

Registration Number / Date: PA0002191150 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
57. Title: “Talk 38 Video 1 - Symposium: Remember How Love Behaves - Does Not Get
Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191151 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
58. Title: “Talk 38 Video 2 - Symposium: Remember How Love Behaves - Does Not Get
Puffed Up; Does Not Behave Indecently (1 Corinthians 13:4, 5)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191152 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
59. Title: “Talk 39 Video 1 - Symposium: Remember How Love Behaves - Does Not Look
for Its Own Interests; Does Not Become Provoked (1 Corinthians 13:5)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191156 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
60. Title: “Talk 39 Video 2 - Symposium: Remember How Love Behaves - Does Not Look
for Its Own Interests; Does Not Become Provoked (1 Corinthians 13:5)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191153 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
61. Title: “Talk 40 Video 1 - Symposium: Remember How Love Behaves - Does Not Keep
Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”
Type of Work: Motion Picture
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 13 of 15

Registration Number / Date: PA0002191154 / 2019-05-22

Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
62. Title: “Talk 40 Video 2 - Symposium: Remember How Love Behaves - Does Not Keep
Account of the Injury; Does Not Rejoice Over Unrighteousness (1 Corinthians 13:5, 6)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191719 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
63. Title: “Talk 41 Video 1 - Symposium: Remember How Love Behaves - Rejoices With
the Truth; Bears All Things (1 Corinthians 13:6, 7)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191722 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
64. Title: “Talk 41 Video 2 - Symposium: Remember How Love Behaves - Rejoices With
the Truth; Bears All Things (1 Corinthians 13:6, 7)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191723 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
65. Title: “Talk 42 Video 1 - Symposium: Remember How Love Behaves - Believes All
Things; Hopes All Things 1 Corinthians 13:7)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191724 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
66. Title: “Talk 42 Video 2 - Symposium: Remember How Love Behaves - Believes All
Things; Hopes All Things 1 Corinthians 13:7)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191727 / 2019-05-22
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 14 of 15

Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania

Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
67. Title: “Talk 43 Video 1 - Symposium: Remember How Love Behaves - Endures All
Things; Love Never Fails (1 Corinthians 13:7, 8)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191729 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
68. Title: “Talk 43 Video 2 - Symposium: Remember How Love Behaves - Endures All
Things; Love Never Fails (1 Corinthians 13:7, 8)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191159 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
69. Title: “Talk 44 Video 1 - Public Bible Discourse: True Love in a Hate-Filled World -
Where? (John 13:34, 35)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191418 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
70. Title: “Talk 44 Video 2 - Public Bible Discourse: True Love in a Hate-Filled World -
Where? (John 13:34, 35)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191141 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
71. Title: “The Story of Josiah: Love Jehovah; Hate What Is Bad - Part II (2 Kings 22:3-20;
23:1-25; 2 Chronicles 34:3-33; 35:1-19)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191682 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
 Case 1:20-cv-03366-MKV Document 26-2 Filed 09/30/20 Page 15 of 15

Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,

employer for hire
72. Title: “Talk 47 Video 1 - ‘Carefully Consider Jehovah’s Acts of Loyal Love’ (Psalm
107:43; Ephesians 5:1, 2)”
Type of Work: Motion Picture
Registration Number / Date: PA0002191138 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
73. Title: “Talk 47 Video 5 - Unfailing Love (1 Corinthians 13:8))”
Type of Work: Motion Picture
Registration Number / Date: PA0002191706 / 2019-05-24
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
74. Title: “2019 ‘Love Never Fails’! Convention - Music-Video Presentation 6”
Type of Work: Motion Picture
Registration Number / Date: PA0002191143 / 2019-05-22
Copyright Claimant: Watch Tower Bible and Tract Society of Pennsylvania
Authorship on Application: Watch Tower Bible and Tract Society of Pennsylvania,
employer for hire
 Case 1:20-cv-03366-MKV Document 27 Filed 10/02/20 Page 1 of 3

USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK DOC #:
DATE FILED: 10/2/2020

WATCH TOWER BIBLE AND TRACT SOCIETY OF

PENNSYLVANIA,
Plaintiff,
No. 1:20-cv-03366 (MKV)
-against-

THE TRUTH AND TRANSPARENCY FOUNDATION,

RYAN C. McKNIGHT, and ETHAN G. DODGE,

Defendants.

[PROPOSED] FINAL JUDGMENT AND PERMANENT INJUNCTION ON CONSENT

IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff Watch Tower

Bible and Tract Society of Pennsylvania (“Watch Tower”) and Defendants The Truth and

Transparency Foundation, Ryan C. McKnight, and Ethan G. Dodge (together, “Defendants”),

that this Final Judgment and Permanent Injunction on Consent be entered in the present action as

set forth below without further notice or process:

WHEREAS, Watch Tower is responsible for the creation and publication of works of

authorship including literary works, works of visual art, musical works, and motion pictures;

WHEREAS, Defendants without permission or license copied, reproduced, publicly

displayed, publicly performed and distributed the 74 registered copyrighted motion pictures of

Watch Tower identified on Schedule A hereto (the “Copyrighted Works”); and

WHEREAS Watch Tower and Defendants have agreed to end this dispute on terms that

include the entry of this Final Judgment and Permanent Injunction on Consent, and have

consented to the entry of this Final Judgment and Permanent Injunction on Consent;
 Case 1:20-cv-03366-MKV Document 27 Filed 10/02/20 Page 2 of 3

NOW THEREFORE, upon the consent and request of Watch Tower and Defendants, IT

IS HEREBY ORDERED, ADJUDGED, and DECREED that:

1. Defendants, and their agents, representatives, employees and other persons and

entities acting in concert with them, are permanently enjoined, restrained and prohibited from

(a) using or causing to be used, or inducing, authorizing or facilitating any third

party to use, any of the Copyrighted Works in any medium including but not limited to

the faithleaks.org website, and any other website operated or controlled, in whole or in

part, by Defendants or any of them; and

(b) using or causing to be used, or inducing, authorizing or facilitating any third

party to use, any copyrighted works other than the Copyrighted Works, now in existence

or to be created in the future, that are owned by Watch Tower or by entities that

cooperate with Watch Tower.

2. No bond or posting of security is required in connection with the entry of this

Permanent Injunction.

3. All of the parties waive the right to appeal from or otherwise contest this Final

Order and Judgment on Consent, which may be entered in the form and content set forth above

without further notice to any party.

Dated: September 30, 2020 Dated: September 30, 2020

/s/ Thomas Kjellberg /s/ Ryan E. Long

Thomas Kjellberg ([email protected]) Ryan E. Long ([email protected])
COWAN, LIEBOWITZ & LATMAN, P.C. LONG & ASSOCIATES PLLC
114 West 47th Street 135 West 27th Street, 8th Floor
New York, NY 10036-1525 New York, New York 10001
(212) 790-9200 (212) 381-9637
 Case 1:20-cv-03366-MKV Document 27 Filed 10/02/20 Page 3 of 3

IT IS SO ORDERED this 2 day of October , 2020.

___________________________________________
Mary Kay Vyskocil
United States District Judge

The Clerk of Court is respectfully directed to terminate the motions pending at docket entries 24 and 26
and then to close this case.
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 1 of 10

United States District Court

Southern District of New York

Ruby J. Krajick
Clerk of Court

Dear Litigant:

Enclosed is a copy of the judgment entered in your case. If you disagree with a judgment or
final order of the district court, you may appeal to the United States Court of Appeals for
the Second Circuit. To start this process, file a “Notice of Appeal” with this Court’s Pro Se
Intake Unit.

You must file your notice of appeal in this Court within 30 days after the judgment or order
that you wish to appeal is entered on the Court’s docket, or, if the United States or its officer
or agency is a party, within 60 days after entry of the judgment or order. If you are unable
to file your notice of appeal within the required time, you may make a motion for extension
of time, but you must do so within 60 days from the date of entry of the judgment, or
within 90 days if the United States or its officer or agency is a party, and you must show
excusable neglect or good cause for your inability to file the notice of appeal by the
deadline.

Please note that the notice of appeal is a one-page document containing your name, a
description of the final order or judgment (or part thereof) being appealed, and the name of
the court to which the appeal is taken (the Second Circuit) – it does not include your reasons
or grounds for the appeal. Once your appeal is processed by the district court, your notice
of appeal will be sent to the Court of Appeals and a Court of Appeals docket number will
be assigned to your case. At that point, all further questions regarding your appeal must be
directed to that court.

The filing fee for a notice of appeal is $505 payable in cash, by bank check, certified check,
or money order, to “Clerk of Court, S.D.N.Y.” No personal checks are accepted. If you are
unable to pay the $505 filing fee, complete the “Motion to Proceed in Forma Pauperis on
Appeal” form and submit it with your notice of appeal to the Pro Se Intake Unit. If the
district court denies your motion to proceed in forma pauperis on appeal, or has certified
under 28 U.S.C. ' 1915(a)(3) that an appeal would not be taken in good faith, you may file a
motion in the Court of Appeals for leave to appeal in forma pauperis, but you must do so
within 30 days after service of the district court order that stated that you could not proceed
in forma pauperis on appeal.

For additional issues regarding the time for filing a notice of appeal, see Federal Rule of
Appellate Procedure 4(a). There are many other steps to beginning and proceeding with
your appeal, but they are governed by the rules of the Second Circuit Court of Appeals and
the Federal Rules of Appellate Procedure. For more information, visit the Second Circuit
Court of Appeals website at http://www.ca2.uscourts.gov/.

THE DANIEL PATRICK MOYNIHAN THE CHARLES L. BRIEANT, JR.

UNITED STATES COURTHOUSE UNITED STATES COURTHOUSE
500 PEARL STREET 300 QUARROPAS STREET
NEW YORK, NY 10007-1312 WHITE PLAINS, NY 10601-4150
Rev. 5/23/14
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 2 of 10

U NITED S TATES D ISTRICT C OURT

S OUTHERN D ISTRICT OF N EW Y ORK

(List the full name(s) of the plaintiff(s)/petitioner(s).) _____CV________ ( )( )

-against-
NOTICE OF APPEAL

(List the full name(s) of the defendant(s)/respondent(s).)

Notice is hereby given that the following parties:

(list the names of all parties who are filing an appeal)

in the above-named case appeal to the United States Court of Appeals for the Second Circuit

from the  judgment  order entered on:

(date that judgment or order was entered on docket)
that:

(If the appeal is from an order, provide a brief description above of the decision in the order.)

*
Dated Signature

Name (Last, First, MI)

Address City State Zip Code

Telephone Number E-mail Address (if available)

*
Each party filing the appeal must date and sign the Notice of Appeal and provide his or her mailing address and telephone
number, EXCEPT that a signer of a pro se notice of appeal may sign for his or her spouse and minor children if they are parties
to the case. Fed. R. App. P. 3(c)(2). Attach additional sheets of paper as necessary.
Rev. 12/23/13
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 3 of 10

U NITED S TATES D ISTRICT C OURT

S OUTHERN D ISTRICT OF N EW Y ORK

_____CV________ ( )( )
(List the full name(s) of the plaintiff(s)/petitioner(s).)

-against- MOTION FOR EXTENSION

OF TIME TO FILE NOTICE
OF APPEAL

(List the full name(s) of the defendant(s)/respondent(s).)

I move under Rule 4(a)(5) of the Federal Rules of Appellate Procedure for an extension of time

to file a notice of appeal in this action. I would like to appeal the judgment

entered in this action on but did not file a notice of appeal within the required
date
time period because:

(Explain here the excusable neglect or good cause that led to your failure to file a timely notice of appeal.)

Dated: Signature

Name (Last, First, MI)

Address City State Zip Code

Telephone Number E-mail Address (if available)

Rev. 3/27/15
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 4 of 10

U NITED S TATES D ISTRICT C OURT

S OUTHERN D ISTRICT OF N EW Y ORK

_____CV_________ ( )( )
(List the full name(s) of the plaintiff(s)/petitioner(s).)

-against- MOTION FOR LEAVE TO

PROCEED IN FORMA
PAUPERIS ON APPEAL

(List the full name(s) of the defendant(s)/respondent(s).)

I move under Federal Rule of Appellate Procedure 24(a)(1) for leave to proceed in forma

pauperis on appeal. This motion is supported by the attached affidavit.

Dated Signature

Name (Last, First, MI)

Address City State Zip Code

Telephone Number E-mail Address (if available)

Rev. 12/23/13
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 5 of 10

Application to Appeal In Forma Pauperis

______________________v. ______________________ Appeal No. __________________

District Court or Agency No. _________________

Affidavit in Support of Motion Instructions

I swear or affirm under penalty of perjury that, Complete all questions in this application and then
because of my poverty, I cannot prepay the docket sign it. Do not leave any blanks: if the answer to a
fees of my appeal or post a bond for them. I believe question is "0," "none," or "not applicable (N/A),"
I am entitled to redress. I swear or affirm under write that response. If you need more space to answer
penalty of perjury under United States laws that my a question or to explain your answer, attach a separate
answers on this form are true and correct. (28 sheet of paper identified with your name, your case's
U.S.C. § 1746; 18 U.S.C. § 1621.) docket number, and the question number.

Signed: _____________________________ Date: _____________________________

My issues on appeal are: (required):

1. For both you and your spouse estimate the average amount of money received from each
of the following sources during the past 12 months. Adjust any amount that was received
weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use
gross amounts, that is, amounts before any deductions for taxes or otherwise.

Income source Average monthly Amount expected next

amount during the past month
12 months
You Spouse You Spouse
Employment $ $ $ $
Self-employment $ $ $ $
Income from real property (such as $ $ $ $
rental income)

-1-
12/01/2013 SCC
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 6 of 10

Interest and dividends $ $ $ $

Gifts $ $ $ $
Alimony $ $ $ $
Child support $ $ $ $
Retirement (such as social security, $ $ $ $
pensions, annuities, insurance)
Disability (such as social security, $ $ $ $
insurance payments)
Unemployment payments $ $ $ $
Public-assistance (such as welfare) $ $ $ $
Other (specify): $ $ $ $

Total monthly income: $0 $0 $0 $0

2. List your employment history for the past two years, most recent employer first. (Gross
monthly pay is before taxes or other deductions.)

Employer Address Dates of Gross

employment monthly pay
$
$
$

3. List your spouse's employment history for the past two years, most recent employer first.
(Gross monthly pay is before taxes or other deductions.)

Employer Address Dates of Gross

employment monthly pay
$
$
$

-2-
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 7 of 10

4. How much cash do you and your spouse have? $________

Below, state any money you or your spouse have in bank accounts or in any other
financial institution.

Financial Institution Type of Account Amount you have Amount your

spouse has
$ $
$ $
$ $

If you are a prisoner seeking to appeal a judgment in a civil action or proceeding, you must
attach a statement certified by the appropriate institutional officer showing all receipts,
expenditures, and balances during the last six months in your institutional accounts. If you
have multiple accounts, perhaps because you have been in multiple institutions, attach one
certified statement of each account.

5. List the assets, and their values, which you own or your spouse owns. Do not list clothing
and ordinary household furnishings.

Home Other real estate Motor vehicle #1

(Value) $ (Value) $ (Value) $
Make and year:
Model:
Registration #:

Motor vehicle #2 Other assets Other assets

(Value) $ (Value) $ (Value) $
Make and year:
Model:
Registration #:

-3-
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 8 of 10

6. State every person, business, or organization owing you or your spouse money, and the
amount owed.

Person owing you or your spouse Amount owed to you Amount owed to your
money spouse
$ $
$ $
$ $
$ $

7. State the persons who rely on you or your spouse for support.

Name [or, if a minor (i.e., underage), initials only] Relationship Age

8. Estimate the average monthly expenses of you and your family. Show separately the
amounts paid by your spouse. Adjust any payments that are made weekly, biweekly,
quarterly, semiannually, or annually to show the monthly rate.

You Your Spouse

Rent or home-mortgage payment (including lot rented for $ $
mobile home)
Are real estate taxes included? [ ] Yes [ ] No
Is property insurance included? [ ] Yes [ ] No
Utilities (electricity, heating fuel, water, sewer, and telephone) $ $
Home maintenance (repairs and upkeep) $ $
Food $ $
Clothing $ $
Laundry and dry-cleaning $ $
Medical and dental expenses $ $

-4-
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 9 of 10

Transportation (not including motor vehicle payments) $ $

Recreation, entertainment, newspapers, magazines, etc. $ $
Insurance (not deducted from wages or included in mortgage payments)
Homeowner's or renter's: $ $
Life: $ $
Health: $ $
Motor vehicle: $ $
Other: $ $
Taxes (not deducted from wages or included in mortgage $ $
payments) (specify):
Installment payments
Motor Vehicle: $ $
Credit card (name): $ $
Department store (name): $ $
Other: $ $
Alimony, maintenance, and support paid to others $ $
Regular expenses for operation of business, profession, or $ $
farm (attach detailed statement)
Other (specify): $ $
Total monthly expenses: $0 $0

9. Do you expect any major changes to your monthly income or expenses or in your assets
or liabilities during the next 12 months?

[ ] Yes [ ] No If yes, describe on an attached sheet.

10. Have you spent — or will you be spending —any money for expenses or attorney fees in
connection with this lawsuit? [ ] Yes [ ] No

If yes, how much? $ ____________

-5-
 Case 1:20-cv-03366-MKV Document 27-1 Filed 10/02/20 Page 10 of 10

11. Provide any other information that will help explain why you cannot pay the docket fees
for your appeal.

12. Identify the city and state of your legal residence.

City __________________________ State ______________

Your daytime phone number: ___________________

Your age: ________ Your years of schooling: ________

Last four digits of your social-security number: _______

Print Save Reset Form

-6-
 Case 1:20-cv-03366-MKV Document 28 Filed 10/02/20 Page 1 of 9

USDC-Southern District of New York

20-cv-3366 4/30/2020

Watch Tower Bible and Tract Society of Pennsylvania The Truth and Transparency Foundation, Ryan C.
McKnight and Ethan G. Dodge

PA0002121393 “Be a Courageous … Pioneer” Watch Tower Bible and Tract Soc.

PA0002121074 Talk 33 - Video 1 - Learn Courage From Creation... Watch Tower Bible and Tract Soc.

PA0002121104 Talk 40 - Video 1 - How Our Brothers Are Showing... Watch Tower Bible and Tract Soc.

PA0002121120 Talk 44 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.

PA0002121121 Talk 45 - Video 1 - Future Events That Will Require... Watch Tower Bible and Tract Soc.
 Case 1:20-cv-03366-MKV Document 28 Filed 10/02/20 Page 2 of 9

COPYRIGHT TITLE OF WORK AUTHOR OR WORK

REGISTRATION NO.
PA0002121124 Talk 46-Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Proclamation of the Hailstone
Message
PA0002121125 Talk 47 - Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Attack by Gog of Magog
PA0002121607 Talk 48-Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) -
Armageddon
PA0002121129 Talk 49 - Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Great Reconstruction
PA0002121132 Talk 50 - Video 1 - Future Watch Tower Bible and Tract
Events That Will Require Society of Pennsylvania
Courage (Symposium) - The
Final Test
PA0002191509 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 1
PA0002191514 Talk 01 Video 1 - Chairman’s Watch Tower Bible and Tract
Address: ‘Love Never Fails - Society of Pennsylvania
Why?
PA0002191517 Talk 01 Video 2 - Chairman’s Watch Tower Bible and Tract
Address: ‘Love Never Fails’ - Society of Pennsylvania
Why?
PA0002191478 Talk 02 Video 1 - Watch Tower Bible and Tract
Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Wealth (Matthew 6:24)
PA0002191475 Talk 03 Video 1 - Watch Tower Bible and Tract
Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Status and Fame (Ecclesiastes
2:16; Romans 12:16)
PA0002191487 Talk 04 Video 1 - Watch Tower Bible and Tract
Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Human Wisdom (Romans
12:1, 2)
 Case 1:20-cv-03366-MKV Document 28 Filed 10/02/20 Page 3 of 9

PA0002191489 Talk 05 Video 1 - Watch Tower Bible and Tract

Symposium: Beware of Society of Pennsylvania
Trusting in What Fails! -
Strength and Beauty
(Proverbs 31:30; 1 Peter 3:3,
4)
PA0002191501 Talk 06 Video 1 - Watch Tower Bible and Tract
DRAMATIC BIBLE Society of Pennsylvania
READING: Jehovah Kept
Showing Loyal Love
(Genesis 37:1-36; 39:1;
47:12)
PA0002191510 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention—Music-Video Society of Pennsylvania
Presentation 2Talk 23 Video
1 - Symposium: Display
Unfailing Love in the
Congregation - To the
Elderly (Leviticus 19:32)
PA0002191450 Talk 08 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … A Loveless
Upbringing (Psalm 27:10)
PA0002191453 Talk 09 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … A Difficult
Work Environment (1 Peter
2:18-20)
PA0002191458 Talk 10 Video 2 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … An Ungodly
School Environment (1
Timothy 4:12)
PA0002191459 Talk 11 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … Chronic
Health Problems (2
Corinthians 12:9, 10)
PA0002191460 Talk 12 Video 1 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … Poverty
(Philippians 4:12, 13)
PA0002191461 Talk 12 Video 2 - Watch Tower Bible and Tract
Symposium: Love Never Society of Pennsylvania
Fails Despite … Poverty
(Philippians 4:12, 13)
 Case 1:20-cv-03366-MKV Document 28 Filed 10/02/20 Page 4 of 9

PA0002191455 Talk 13 Video 1 - Watch Tower Bible and Tract

Symposium: Love Never Society of Pennsylvania
Fails Despite … Family
Opposition (Matthew 5:44)
PA0002191432 Talk 14 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
The Heavens (Psalm 8:3, 4;
33:6)
PA0002191434 Talk 15 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
The Earth (Psalm 37:29;
115:16)
PA0002191437 Talk 16 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
Plants (Genesis 1:11, 29; 2:9,
15; Acts 14:16, 17)
PA0002191444 Talk 17 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
Animals (Genesis 1:27;
Matthew 6:26)
PA0002191446 Talk 18 Video 1 - Watch Tower Bible and Tract
Symposium: Creation Society of Pennsylvania
Reveals Jehovah’s Love -
The Human Body (Psalm
139:14; Ecclesiastes 3:11)
PA0002191504 Talk 19 Video 1 - ‘Those Watch Tower Bible and Tract
Whom Jehovah Loves He Society of Pennsylvania
Disciplines’ (Hebrews 12:5-
11; Psalm 19:7, 8, 11)
PA0002191471 Talk 20 Video 1 - ‘Clothe Watch Tower Bible and Tract
Yourselves With Love’ Society of Pennsylvania
(Colossians 3:12-14)
PA0002191139 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 3
PA0002191157 Talk 21 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To Those
Taking the Lead (1
Thessalonians 5:12, 13)
 Case 1:20-cv-03366-MKV Document 28 Filed 10/02/20 Page 5 of 9

PA0002191160 Talk 23 Video 1 - Watch Tower Bible and Tract

Suppl. Reg. PA0002216893 Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To the
Elderly (Leviticus 19:32)
PA0002191146 Talk 24 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To Full-Time
Ministers (1 Thessalonians
1:3)
PA0002191155 Talk 25 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Congregation - To Foreign
Residents (Leviticus 19:34;
Romans 15:7)
PA0002191149 ANNOUNCEMENT: Watch Tower Bible and Tract
Invitation to School for Society of Pennsylvania
Kingdom Evangelizers
Meeting
PA0002191683 Talk 26 Video 1 - Watch Tower Bible and Tract
A0002191683: Display Society of Pennsylvania
Unfailing Love in the
Ministry - Show Your Love
for God (1 John 5:3)
PA0002191148 Talk 27 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Ministry – ‘Love Your
Neighbor as Yourself’
(Matthew 22:39)
PA0002191684 Talk 28 Video 1 - Watch Tower Bible and Tract
Symposium: Display Society of Pennsylvania
Unfailing Love in the
Ministry - Love Jehovah’s
Word (Psalm 119:97;
Matthew 13:52)
PA0002193286 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 4 (v2)
 Case 1:20-cv-03366-MKV Document 28 Filed 10/02/20 Page 6 of 9

PA0002191713 Talk 30 Video 1 - Watch Tower Bible and Tract

Symposium: How Our Society of Pennsylvania
Brothers Are Showing
Unfailing Love In … Africa
(Genesis 16:13), Asia (Acts
2:44), Europe (John 4:35),
North America (1 Corinthians
9:22), Oceania (Psalm 35:18),
South America (Acts 1:8)
PA0002191714 Talk 31 Video 1 - Display Watch Tower Bible and Tract
Unfailing Love in Your Society of Pennsylvania
Family - Love Your Wife
(Ephesians 5:28, 29)
PA0002191715 Talk 32 Video 1 - Display Watch Tower Bible and Tract
Unfailing Love in Your Society of Pennsylvania
Family - Love Your Husband
(Ephesians 5:33; 1 Peter 3:1-
6)
PA0002191717 Talk 33 Video 1 - Display Watch Tower Bible and Tract
Unfailing Love in Your Society of Pennsylvania
Family - Love Your Children
(Titus 2:4)
PA0002191144 The Story of Josiah: Love Watch Tower Bible and Tract
Jehovah; Hate What Is Bad - Society of Pennsylvania
Part I (2 Chronicles 33:10-24;
34:1, 2)
PA0002191678 Talk 35 Video 1 - Teach Watch Tower Bible and Tract
Your Children How to Show Society of Pennsylvania
Love (2 Timothy 3:14, 15)
PA0002192006 Talk 35 Video 3 - Teach Watch Tower Bible and Tract
Your Children How to Show Society of Pennsylvania
Love (2 Timothy 3:14, 15)
PA0002192007 Talk 35 Video 4 - Teach Watch Tower Bible and Tract
Your Children How to Show Society of Pennsylvania
Love (2 Timothy 3:14, 15)
PA0002191679 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 5
PA0002192010 Talk 36 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Patient and
Kind (1 Corinthians 13:4)
PA0002192009 Talk 36 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Patient and
Kind (1 Corinthians 13:4)
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PA0002191147 Talk 37 Video 1 - Watch Tower Bible and Tract

Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Not
Jealous; Does Not Brag (1
Corinthians 13:4)
PA0002191150 Talk 37 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Is Not
Jealous; Does Not Brag (1
Corinthians 13:4)
PA0002191151 Talk 38 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not Get
Puffed Up; Does Not Behave
Indecently (1 Corinthians
13:4, 5)
PA0002191152 Talk 38 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not Get
Puffed Up; Does Not Behave
Indecently (1 Corinthians
13:4, 5)
PA0002191156 Talk 39 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Look for Its Own Interests;
Does Not Become Provoked
(1 Corinthians 13:5)
PA0002191153 Talk 39 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Look for Its Own Interests;
Does Not Become Provoked
(1 Corinthians 13:5)
PA0002191154 Talk 40 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Keep Account of the Injury;
Does Not Rejoice Over
Unrighteousness (1
Corinthians 13:5, 6)
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PA0002191719 Talk 40 Video 2 - Watch Tower Bible and Tract

Symposium: Remember How Society of Pennsylvania
Love Behaves - Does Not
Keep Account of the Injury;
Does Not Rejoice Over
Unrighteousness (1
Corinthians 13:5, 6)
PA0002191722 Talk 41 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Rejoices
With the Truth; Bears All
Things (1 Corinthians 13:6,
7)
PA0002191723 Talk 41 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Rejoices
With the Truth; Bears All
Things (1 Corinthians 13:6,
7)
PA0002191724 Talk 42 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Believes All
Things; Hopes All Things 1
Corinthians 13:7)
PA0002191727 Talk 42 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Believes All
Things; Hopes All Things 1
Corinthians 13:7)
PA0002191729 Talk 43 Video 1 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Endures All
Things; Love Never Fails (1
Corinthians 13:7, 8)
PA0002191159 Talk 43 Video 2 - Watch Tower Bible and Tract
Symposium: Remember How Society of Pennsylvania
Love Behaves - Endures All
Things; Love Never Fails (1
Corinthians 13:7, 8)
PA0002191418 Talk 44 Video 1 - Public Watch Tower Bible and Tract
Bible Discourse: True Love Society of Pennsylvania
in a Hate-Filled World -
Where? (John 13:34, 35)
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PA0002191141 Talk 44 Video 2 - Public Watch Tower Bible and Tract

Bible Discourse: True Love Society of Pennsylvania
in a Hate-Filled World -
Where?
(John 13:34, 35)
PA0002191682 The Story of Josiah: Love Watch Tower Bible and Tract
Jehovah; Hate What Is Bad - Society of Pennsylvania
Part II (2 Kings 22:3-20;
23:1-25; 2 Chronicles 34:3-
33; 35:1-19)
PA0002191138 Talk 47 Video 1 - ‘Carefully Watch Tower Bible and Tract
Consider Jehovah’s Acts of Society of Pennsylvania
Loyal Love’ (Psalm 107:43;
Ephesians 5:1, 2)
PA0002191706 Talk 47 Video 5 - Unfailing Watch Tower Bible and Tract
Love (1 Corinthians 13:8)) Society of Pennsylvania
PA0002191143 2019 ‘Love Never Fails’! Watch Tower Bible and Tract
Convention - Music-Video Society of Pennsylvania
Presentation 6