- 2 - COMPLAINT

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JUAN MARCOS MONTES (“MONTES”), by and through his undersigned attorneys, hereby prays to this honorable Court for relief based on the following:

JURISDICTION AND VENUE

1.

This action arises under the Copyright Act of 1976, Title 17 U.S.C., §§ 101

et seq

. 2.

This Court has federal question jurisdiction under 28 U.S.C. §§ 1331 and 1338 (a) and (b). 3.

Venue in this judicial district is proper under 28 U.S.C. §§ 1391(c) and 1400(a) in that this is the judicial district in which a substantial part of the acts and omissions giving rise to the claims occurred.

PARTIES

4.

Plaintiff MONTES is an individual artist, creating art under the name “Juan Marco,” residing in Los Angeles, California. 5.

Plaintiff is informed and believes and thereon alleges that Defendant C3 PRESENTS, LLC (“C3”) is a limited liability company organized and existing under the laws of the State of Texas, and is doing business in California and this District. 6.

Plaintiff is informed and believes and thereon alleges that LIVE NATION ENTERTAINMENT, INC., individually and doing business as “LOLLAPALOOZA, LLC” (collectively “LIVE NATION”) is a corporation organized and existing under the laws of the State of Delaware, and is doing business in California and this District. 7.

Plaintiff is informed and believes and thereon alleges that THE UPRISING CREATIVE, (“UPRISING”) is a corporation organized and existing under the laws of the State of Delaware, and is doing business in California and this District. 8.

Plaintiff is informed and believes and thereon alleges that some of Defendants Does 1 through 3, inclusive, are manufacturers and/or vendors of product, which Do e Defendants have m anufactured and/or supplied and are