IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Agence France Presse,
CIVIL ACTION NO.: 1:05CV00546 (GK)
Initial Scheduling Conference:
June 20, 2005
PLAINTIFFS STATEMENT OF THE CASE
Pursuant to this Court’s May 25, 2005 Order Setting Initial Scheduling
Conference, Plaintiff Agence France Presse (“AFP”), hereby submits its statement of the
case, including the jurisdiction basis for its claims against Defendant Google Inc.
Jurisdictional basis for claim:
Plaintiff’s underlying claim is for copyright infringement. Pursuant to 28 U.S. C.
§1331 and §1338, original jurisdiction over claims of copyright infringement vests
exclusively with the United States District Courts. AFP holds certificates of copyright
registrations for the works in question, which were duly issued by the United States
Copyright Office. Plaintiff’s Complaint also includes a state unfair competition claim for
Case 1:05-cv-00546-GK Document 15 Filed 06/15/2005 Page 1 of 5
AGENCE FRANCE PRESSE v. GOOGLE INC.
which this Court has pendant jurisdiction. In addition, there is complete diversity of
citizenship between the parties and the dispute exceeds $75,000 in value.
Nature of the case:
AFP is one of the world’s foremost and largest wire services. AFP supplies news
stories (in multiple languages), headlines (in multiple languages), photographs and
graphics to newspapers, wire services, magazines, web sites, news aggregators,
governments and corporations around the world. The news is provided on a real time
basis from AFP bureaus around the world.
Google is a company that offers an Internet search engine, which members of the
public use to search for information. Google also owns and runs a business called