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Todd Dotson' lawsuit against Russ Whitney 3 30. In addition, on information and belief, she has engaged in business and other conduct in the State of Texas out of which this action arises by, among other things, selling products in Texas with purposeful direction and in a substantial volume. 31. She has also committed tortious conduct in whole or part in, or directed to Texas based on information and belief. 32. She maintains neither a regular place of business, nor a registered agent for service of process in Texas. 33. Accordingly, under Texas Civil Practice and Remedies Code. '§ 17.044, she is deemed to have appointed the Texas Secretary of State as agent for service, and may be served by serving the Texas Secretary of State with two copies of process along with the accompanying copies of this Complaint with the instruction to forward same by certified mall, return receipt requested to Jessanne Jonhnson at 4100 Highbrook Trail, Raleigh, North Carolina 27606. 34. Defendant, Tim Veler. Tim Veler is an individual. He is a resident and citizen of the State of Texas. He can be served with citation at his residence, 3732 Creek Road, Arlington, Texas 76001. 35. Defendant, Margaret Shorts. Shorts is an individual. On information and belief, she is a citizen and resident of the State of Ohio. 36. She has done business with a Texas resident out of which this action arises by entering into contract(s) with a Texas resident to be performed by at least one party in the State of Texas. 37. In addition, on information and belief, she has engaged in business and other conduct in the State of Texas out of which this action arises by, among other things, selling products in Texas with purposeful direction and in a substantial volume. 38. She has also committed tortious conduct in whole or part in, or directed to Texas based on information and belief. 39. She maintains neither a regular place of business, nor a registered agent for service of process in Texas. 40. Accordingly, underTexas Civil Practice and Remedies Code. '§ 17.044, Shorts is deemed to have appointed the Texas Secretary of State as agent for service, and may be served by serving the Texas Secretary of State with two copies of process along with the accompanying copies of this Complaint with the instruction to forward same by certified mall, return receipt requested to Margaret Shorts, 24496 Briarwood Drive, Olmstead Falls, Ohio 44138. 41. Defendant, Dana Van Hoose. Van Hoose is an individual. On

information and belief, Van Hoose is a citizen and resident of the State of Arizona. 42. He has done business with a Texas resident out of which this action arises by entering into contract(s) with the Texas resident to be performed by at least one party in the State of Texas. 43. In addition, on information and belief, he has engaged in business and other conduct in the State of Texas out of which this action arises by, among other things, selling products in Texas with purposeful direction and in a substantial volume. 44. He has also committed tortious conduct in whole or part in, or directed to Texas based on information and belief. 45. He maintains neither a regular place of business, nor a registered agent for service of process in Texas. 46. Accordingly, under Texas Civil Practice and Remedies Code. '§ 17.044, Van Hoose is deemed to have appointed the Texas Secretary of State as agent for service, and may be served by serving the Texas Secretary of State with two copies of process along wth the accompanying copies of this Complaint with the instruction to forward same by certified mall, return receipt requested to Dana Van Hoose, 3743 East Fruitville Avenue, Gilbert, Arizona 85297. 47. Defendant, Todd Trygier. Trygier is an individual. On information and belief, he is a citizen of the State of Michigan. 48. Trygier has done business with a Texas resident out of which this action arises by entering into contract(s) with a Texas resident to be performed by at least one party in the State of Texas. 49. In addition, on information and belief, he has engaged in business and other conduct in the State of Texas out of which this action arises by, among other things, selling products in Texas with purposeful direction and in a substantial volume. 50. He has also committed tortious conduct in whole or part in, or directed to Texas based on information and belief. 51. He maintains neither a regular place of business, nor a registered agent for service of process in Texas. 52. Accordingly, under Texas Civil Practice and Remedies Code. '§ 17.044, he is deemed to have appointed the Texas Secretary of State as agent for service, and may be served by serving the Texas Secretary of State with two copies of process along with the accompanying copies of this Complaint with the instruction to forward same by certified mall, return receipt requested to Todd Trygier at 7186 Delta River Drive, Lancing Michigan 48906. 53. James V. ("Jimmy") Reed is an individual residing in Fort Worth, Texas and may be served with process at his address at 2716 Southpark Lane, Fort Worth, Texas 76133. 54. Individual Defendants, A.C. and Jessanne Johnson and Veler, Shorts, Van Hoose, Reed and Trygier, on information and belief, have infringed on Plaintiffs' copyrighted works by using, and teaching from them for profit in certain seminars described more fully below and/or selling or promoting Defendants' seminars. Those individual Defendants are referred to collectively as "Trainers" or "Mentors". JURISDICTION AND VENUE 55. This is an action seeking, among other things, injunctive relief and damages for copyright infringement pursuant to the laws of the United States, Title 17 U.S.C. 56. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C.. '§'§ 1331, 1338 and 1367. 57. Venue is proper in this district pursuant to 28 U.S.C.. '§'§ 1391 and 1400. Among other things, a substantial part of the events or omissions giving rise to these claims occurred in this judicial district, and one defendant resides in this district. Moreover, WEG and WLG are subject to personal jurisdiction here, and Defendants may be found or reside in this judicial district. Thus, venue is proper here. 58. The Court has personal jurisdiction over each of the Defendants, as set out above. BACKGROUND 59. Several years ago, Plaintiff, Dotson Consulting created original works of authorship known as the "Mentor Manual," "The Wholesale Buying Camp Manual" and "The Purchase Option Camp Manual" (the "Dotson Manuals"). 60. The Dotson Manuals constitute original copyrighted works for which Dotson Consulting obtained copyright registrations by fully complying with Copyright Act of 1976, 17 U.S.C.. '§ 101 et seq. True and correct copies of the Certificates of Registration for these works are attached to this Complaint as Exhibits "A", "B" and "C", and those exhibits are incorporated herein by reference. 61. Dotson Consulting, along with the other Plaintiffs here own all right, title and interest in, and have registered copyrights for the Dotson Manuals. [FN1] FN1. For business purposes, Dotson Consulting assigned to Dotson Training certain rights in the copyrighted works and permitted Dotson Training to become a co-owner of the copyrighted Dotson Manuals described hereinabove. 62. In 2002, most of the parties to this action were engaged in litigation in the 153rd District Court of Tarrant County, Texas. That case was settled pursuant to the terms of a "Compromise Settlement Agreement and Release" (the "Settlement Agreement") during the early stages of discovery. All of the Defendants here, except Russ Whitney, James V. Reed and WLG, are parties to that Settlement Agreement, and are referred to here as "Settling Parties." 63. As part of the Settlement Agreement, the Settling Parties specifically agreed, acknowledged and recognized the ownership of the copyrighted materials in Dotson and Dotson Consulting. 64. Even so, without any authorization of, or license from any of the Plaintiffs here, some or all the Defendants have made derivative works of Plaintiffs' works and have infringed the copyrights covering the Dotson Manual or Manuals. 65. Dotson has obtained a copy of a document titled "Purchase Option Manual," which Defendant, WEG apparently uses in certain seminars it presents. A review of that Purchase Option Manual clearly indicates that it is derived from, and infringes the copyright of Plaintiffs' copyrighted Purchase Option Manual. 66. Plaintiffs have also seen promotional and related information relating to WEG's seminar on wholesale buying and mentoring, demonstrating that the materials used by Defendants in connection with those seminars in all reasonable likelihood, and on information and belief, also were derived from Plaintiffs' copyrighted Dotson Manuals. 67. Further, on information and belief, the Mentor Defendants use the various infringing manuals and other materials in training they provide to students at Defendants' seminars. 68. Thus, on information and belief, Defendants have made copies of the Dotson Manuals, and/or made derivative works based on the Dotson Manuals and have distributed them to customers and used them generating substantial income from that commercial activity, and used Plaintiffs' works in other works of Defendants. 69. Defendants' conduct constitutes breach of contract and an unlawful taking and use of Plaintiffs' works and constitutes copyright infringement as well under 17 U.S.C.. '§ 106, among other things. 70. In addition, priorto the events that led to the Settlement Agreement described above, Dotson had previously provided teaching services for the Whitney Defendants. Then, in 2002, WEG, WLG and/or Whitney asked Dotson to, and Dotson agreed to write and provide certain materials relating to wholesale real estate buying and selling techniques, purportedly to be included in a book to be published by those Defendants, 71. Dotson authored, as an original work of authorship protected by copyright, the work titled "Wholesaling Houses for Quick Cash." See Exhibit "D" a true copy of Certificate of Registration, incorporated herein by reference.

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