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Michael T. Jones (SBN 290660)
mjones@goodwinprocter.com
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025
Tel.: 650.752.3100
Fax: 650.853.1038

Attorney for Plaintiff
Teespring






UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

TEESPRING,

Plaintiff,

v.

VIRALSTYLE LLC,

Defendant.

Case No. __________________

COMPLAINT


JURY TRIAL DEMANDED

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COMPLAINT
Plaintiff Teespring (Plaintiff), by its attorneys, states as follows:
1. This is a copyright infringement action. Plaintiff seeks damages and injunctive relief
against Defendant Viralstyle LLC (Defendant), who knowingly and willfully infringed Plaintiffs
copyrighted works by copying Plaintiffs proprietary garment template images and posting them to
Defendants own website.
THE PARTIES
2. Plaintiff Teespring is a Delaware corporation with a principal office located at 460
Bryant St. Suite 200 San Francisco, California 94107.
3. On information and belief, Defendant Viralstyle LLC is a Florida corporation located
at 11800 Dr. Martin Luther King Jr St N, Unit 2302, St. Petersburg, FL 33716.
JURISDICTION AND VENUE
4. This Court has subject matter jurisdiction based upon 28 U.S.C. 1331, 1338(a).
5. This Court has personal jurisdiction over Defendant at least because Defendant has
transacted business in the state from which this action arises, and because the Defendant knowingly
engaged in infringement of property owned therein.
6. Venue in this Court is proper under 28 U.S.C. 1391(b) and 1400(a).
FACTS
7. Since 2011, Plaintiff provides a platform at teespring.com that allows users to upload
their own customized garment designs and crowdfund them. Specifically, Plaintiff allows users to
select colors and upload designs for a variety of apparel styles, choose a sales goal, and launch their
own clothing campaign. The user sets pricing and promotes their product. If a user reaches his or her
sales goal, Plaintiff handles the production and distribution of the users customized garment and
sends the user a check as agreed between the user and the Teespring service.
8. In order to allow users to envision what their garment designs will look like when
produced, teespring.com uses a series of transparent garment templates (Garment Templates).
These transparent images of the various apparel styles available for production on teespring.com
allow users to accurately gauge the appearance of their designs on an apparent three-dimensional
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garment. Below is an example of one of Plaintiffs transparent Garment Templates, as well as the
same template image placed over a color swatch to demonstrate the transparency effect:

Teespring Garment Template Garment Template over a Solid
Red Background







9. Each Garment Template is created by posing, lighting and photographing a particular
garment such that its folds and shadows create the impression of depth corresponding to a garment
that is being worn.
10. The completed transparent Garment Template can be placed over a color or uploaded
digital image to create an apparent three-dimensional version of a users clothing design.
11. The realism of Plaintiffs Garment Templates helps drive Plaintiffs business.
Potential designers that can clearly see what their designs will look like on a real garment are more
confident in seeking to sell their designs online. Similarly, potential buyers are more likely to
purchase a garment when they can see what it will look like when it is being worn.
12. Due to the way Plaintiffs Garment Templates are created, each is composed of a
unique arrangement of pixels and is thus identifiable via a pixel value analysis.
13. The following are some of the Garment Templates available on teespring.com: a
Mens Crewneck T-Shirt, front and back (Crewneck); a Womens T-Shirt, front and back
(Womens); a Long-Sleeve T-Shirt, front and back (Long-Sleeve); and a Hooded Sweatshirt, front
and back (Hoodie). Images of each Garment Template are attached as Exhibit 1.
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14. Plaintiff is the owner of the copyright registrations for the Long-Sleeve and Hoodie
Garment Templates. The Long-Sleeve template bears Copyright Registration No. VA0001926744.
The Hoodie template bears Copyright Registration No. VA0001926803.
15. Go Media, Inc., a company that produces and sells commercial images, is the owner
of the copyright registrations for the Crewneck and Womens Garment Templates. The Crewneck
template bears Copyright Registration No. VA0001926746. The Womens template bears Copyright
Registration No. VA0001926742.
16. Plaintiff owns the exclusive license to reproduce, display, distribute, create derivative
works of or otherwise use the Crewneck and Womens Garment Templates, in whole or in part, in
connection with any web-based and mobile design applications.
17. Defendant operates a website at viralstyle.com that is similar to the site found at
teespring.com.
18. On information and belief, Defendant also allows users to design custom apparel by
uploading images and designs to viralstyle.com, to set sales goals for the sale of such apparel, and to
sell the apparel when that sales goal is met.
19. During a review of viralstyle.com, Plaintiffs employees noticed that Defendant was
utilizing transparent garment images that appeared to be identical to the Garment Templates owned or
licensed by Plaintiff. The garment images on viralstyle.com have folds and shadows in exactly the
same configuration as found in the Garment Templates created by Plaintiff. The viralstyle.com
images are also transparent, allowing them to be placed over user selected colors or uploaded designs.
Copies of the garment images displayed on viralstyle.com are attached as Exhibit 2.
20. The following is a side by side comparison of images of mens T-shirts, taken from
viralstyle.com and teespring.com:

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Teespring Garment Template Image Found on viralstyle.com







21. A pixel analysis of the images obtained from viralstyle.com showed a 100% pixel
match between the images found on Defendants site and Plaintiffs Garment Templates.
22. A 100% pixel match can only come from a direct and exact copy. Even if Defendant
had made or obtained similarly staged apparel photographs to make transparent garment templates,
those newly created templates would not be an exact pixel match to Plaintiffs Garment Templates.
23. On information and belief, Defendant obtained the garment images displayed upon
viralstyle.com by navigating to teespring.com and copying the Garment Templates from Plaintiffs
website.
24. By copying and utilizing Plaintiffs Garment Templates, Defendant unfairly reaps the
benefits of Plaintiffs exclusive copyright interest in the images in connection with web-based and
mobile design applications.
25. On September 10, 2014, counsel for Plaintiff sent a letter to Defendant identifying the
infringing garment images, explaining the pixel analysis demonstrating that Defendants images
were, in fact, exact copies of Plaintiffs Garment Templates and requesting that all infringing copies
of Teespring Garment Templates be removed from viralstyle.com.
26. Defendant responded on October 6, 2014 stating that it would make the appropriate
changes to its website to address the issues set forth in Plaintiffs September 10, 2014 letter.
27. On October 7, 2014 Plaintiff again directed a letter to Defendant requesting the
removal of all copies of Plaintiffs Garment Template images from viralstyle.com.
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28. As of October 22, 2014, the infringing images were still being used on Defendants
site.
29. On information and belief, Defendant intends to continue its infringement of
Plaintiffs copyrights unless restrained by this court.
COUNT I COPYRIGHT INFRINGEMENT
30. Paragraphs 1 through 29 are incorporated by reference as if fully set forth herein.
31. Plaintiff is the sole owner of the Long-Sleeve and Hoodie templates, as well as the
corresponding copyrights and Certificates of Registration.
32. Plaintiff is the exclusive licensee of the Crewneck and Womens templates, both of
which bear Certificates of Registration.
33. Defendant has intentionally infringed the copyrights underlying Plaintiffs Garment
Templates by the unauthorized copying and displaying of infringing materials in the United States.
34. Defendants infringement has led to its own unjust enrichment and injured Plaintiff
in amounts to be determined at trial.
35. On information and belief, Defendant intends to continue their infringement of
Plaintiffs copyrights unless restrained by this court.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Teespring respectfully requests that this Court enter a Judgment
against Defendant as follows:
A. Awarding damages in an amount to be determined at trial, including without
limitation compensatory, restitutionary, punitive and exemplary damages;
B. Requiring Defendant, including its officers agents, servants, employees and any and
all persons in active concert or participation with it who receive actual notice of the Order, be
enjoined and restrained, by preliminary and permanent injunction and ordered:
(i) To cease all use or display of Plaintiffs Garment Templates; and
(ii) To deliver to this Court by a date which the Court shall direct for impounding
during the pendency of this action, all such infringing materials in Defendants
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possession, custody or control.
C. That at the conclusion of this action the preliminary injunction prayed for above be
made permanent, and that all infringing materials impounded by the Court during the
pendency of this action shall be destroyed; and
D. Granting Plaintiff such other and further relief as the Court deems just and proper.

JURY DEMAND
Plaintiff demands a trial by jury on all issues so triable.


Dated: October 23, 2014 Respectfully submitted,
GOODWIN PROCTER LLP


/s/ Michael T. Jones
Michael T. Jones
mjones@goodwinprocter.com
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025
Tel.: 650.752.3100
Fax: 650.853.1038

Attorney for Plaintiff
Teespring


Case3:14-cv-04724 Document1 Filed10/23/14 Page7 of 7



EXHIBIT 1
Case3:14-cv-04724 Document1-1 Filed10/23/14 Page1 of 3

Teespring Crewneck Garment Template, Copyright Registration No. VA0001926746


Teespring Womans Garment Template, Copyright Registration No. VA0001926742


Case3:14-cv-04724 Document1-1 Filed10/23/14 Page2 of 3

Teespring Long-Sleeve Garment Template, Copyright Registration No. VA0001926744

Teespring Hoodie Garment Template, Copyright Registration No. VA0001926803

Case3:14-cv-04724 Document1-1 Filed10/23/14 Page3 of 3




EXHIBIT 2





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J S 44 (Rev. 12/07)
CIVIL COVER SHEET
The J S 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 J udicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating
the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
I. (a) PLAINTIFFS DEFENDANTS
(b) County of Residence of First ListedPlaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
LAND INVOLVED.
(c) Attorneys (FirmName, Address, and Telephone Number) Attorneys (If Known)
II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant
(Indicate Citizenship of Parties in ItemIII)
of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 610 Agriculture 422 Appeal 28 USC 158 400 State Reapportionment
120 Marine 310 Airplane 362 Personal Injury - 620 Other Food & Drug 423 Withdrawal 410 Antitrust
130 Miller Act 315 Airplane Product Med. Malpractice 625 Drug Related Seizure 28 USC 157 430 Banks and Banking
140 Negotiable Instrument Liability 365 Personal Injury - of Property 21 USC 881 450 Commerce
150 Recovery of Overpayment 320 Assault, Libel & Product Liability 630 Liquor Laws PROPERTY RIGHTS 460 Deportation
& Enforcement of J udgment Slander 368 Asbestos Personal 640 R.R. & Truck 820 Copyrights 470 Racketeer Influenced and
151 Medicare Act 330 Federal Employers Injury Product 650 Airline Regs. 830 Patent Corrupt Organizations
152 Recovery of Defaulted Liability Liability 660 Occupational 840 Trademark 480 Consumer Credit
Student Loans 340 Marine PERSONAL PROPERTY Safety/Health 490 Cable/Sat TV
(Excl. Veterans) 345 Marine Product 370 Other Fraud 690 Other 810 Selective Service
153 Recovery of Overpayment Liability 371 Truth in Lending LABOR SOCIAL SECURITY 850 Securities/Commodities/
of Veterans Benefits 350 Motor Vehicle 380 Other Personal 710 Fair Labor Standards 861 HIA (1395ff) Exchange
160 Stockholders Suits 355 Motor Vehicle Property Damage Act 862 Black Lung (923) 875 Customer Challenge
190 Other Contract Product Liability 385 Property Damage 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 12 USC 3410
195 Contract Product Liability 360 Other Personal Product Liability 730 Labor/Mgmt.Reporting 864 SSID Title XVI 890 Other Statutory Actions
196 Franchise Injury & Disclosure Act 865 RSI (405(g)) 891 Agricultural Acts
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 740 Railway Labor Act FEDERAL TAX SUITS 892 Economic Stabilization Act
210 Land Condemnation 441 Voting 510 Motions to Vacate 790 Other Labor Litigation 870 Taxes (U.S. Plaintiff 893 Environmental Matters
220 Foreclosure 442 Employment Sentence 791 Empl. Ret. Inc. or Defendant) 894 Energy Allocation Act
230 Rent Lease & Ejectment 443 Housing/ Habeas Corpus: Security Act 871 IRSThird Party 895 Freedomof Information
240 Torts to Land Accommodations 530 General 26 USC 7609 Act
245 Tort Product Liability 444 Welfare 535 Death Penalty IMMIGRATION 900Appeal of Fee Determination
290 All Other Real Property 445 Amer. w/Disabilities - 540 Mandamus & Other 462 Naturalization Application Under Equal Access
Employment 550 Civil Rights 463 Habeas Corpus - to J ustice
446 Amer. w/Disabilities - 555 Prison Condition Alien Detainee 950 Constitutionality of
Other 465 Other Immigration State Statutes
440 Other Civil Rights Actions
V. ORIGIN
Transferred from
another district
(specify)
Appeal to District
J udge from
Magistrate
J udgment
(Place an X in One Box Only)
1 Original
Proceeding
2 Removed from
State Court
3 Remanded from
Appellate Court
4 Reinstated or
Reopened
5 6 Multidistrict
Litigation
7
VI. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Brief description of cause:
VII. REQUESTED IN
COMPLAINT:
CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No
VIII. RELATED CASE(S)
IF ANY
(Seeinstructions):
J UDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP J UDGE MAG. J UDGE
TEESPRING
San Francisco
VIRALSTYLE LLC
Michael T. J ones, (SBN 290660)
GOODWIN PROCTER LLP, 135 Commonwealth Drive, Menlo Park, CA 94025
Tel.: 650.752.3100, mjones@goodwinprocter.com
28 U.S.C. 1331, 1338(a)
Plaintiff seeks damages and injunctive relief against Defendant Viralstyle LLC, who knowingly and
willfully infringed Plaintiffs copyrighted works.

10/23/2014 /s/ Michael T. J ones

Case3:14-cv-04724 Document1-3 Filed10/23/14 Page1 of 2
J S 44 Reverse (Rev. 12/07)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The J S 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required
by law, except as provided by local rules of court. This form, approved by the J udicial Conference of the United States in September 1974, is required for the use
of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint
filed. The attorney filing a case should complete the form as follows:
I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use only
the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giving
both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the time
of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases,
the county of residence of the defendant is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section (see attachment).
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an X in one
of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) J urisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an X in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box
1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of the
different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III. Residence (citizenship) of Principal Parties. This section of the J S 44 is to be completed if diversity of citizenship was indicated above. Mark this section
for each principal party.
IV. Nature of Suit. Place an X in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is sufficient
to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature of suit, select
the most definitive.
V. Origin. Place an X in one of the seven boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition
for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this box
is checked, do not check (5) above.
Appeal to District J udge from Magistrate J udgment. (7) Check this box for an appeal from a magistrate judges decision.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional statutes
unless diversity. Example: U.S. Civil Statute: 47 USC 553
Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action. Place an X in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
J ury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the J S 44 is used to reference related pending cases if any. If there are related pending cases, insert the docket numbers
and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
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