Our office represents the Church of Scientology International ("CSI"), the owner of the copyrights to the published work entitled , "The Volunteer Minister's Handbook," including all photographs contained therein. This work is registered with the United States Copyright Office under registration number A 864258.

We have been notified that someone copied a number of our client's copyrighted photographs contained in the Volunteer Minister's Handbook and placed them on Speakeasy's website without our client's authorization. The URLs where these works can be found are:

(formerly right here)

106, it is unlawful to reproduce or distribute someone else's copyrighted work without that person's authorization. The reproduction of a photograph in its entirety constitutes copyright infringement. See Rogers v. Koons, 751 F.Supp. 474, 478 (S.D.N.Y. 1990) aff'd, 960 F.2d 301 (2nd Cir.), cert. denied, 506 U.S. 934 (1992); see also, Playboy Enterprises, Inc. v. Russ Hardenburgh, Inc., 982 F.Supp. 503, 513 (N.D.Ohio 1997) (where defendants were found to have violated plaintiff's exclusive publication right by moving subscriber-uploaded photographs to common bulletin board service files); Playboy Enterprises, Inc. v. Webbworld, Inc., 991 F.Supp. 543 (N.D.Texas 1997) (where court found that the owner of an internet site infringed a magazine publisher's copyrights by displaying copyrighted images on its web site); Kelly v. Arriba Soft Corporation, 280 F.3d 934 (9th Cir. 2002) (where court found that displaying plaintiff's copyrighted photographs on defendant's web site infringed plaintiff's "exclusive right to display the copyrighted work publicly" under the Copyright Act).

Accordingly, I am asking for your help in removing these copyrighted works from your service.

I have a good faith belief, and in fact know for certain, that the posting of these works through your system was not authorized by my client, any agent of my client, or the law.

I declare under penalty of perjury that this information is accurate and that I am authorized to act on behalf of CSI in this matter. I appreciate your help with this matter.


Ava Paquette

Moxon & Kobrin

3055 Wilshire Boulevard Suite

900 Los Angeles, California 90010

Tel: (213) 487-4468 Fax: (213) 487-5385