Indiana Intellectual Property Law News

Photographer Morgan Howarth has filed a federal lawsuit in Indiana against Angie’s List Inc., doing business as Angi, alleging copyright infringement. The complaint accuses Angi of copying and distributing one of Howarth’s registered photographs without permission to promote its home services business online. The case centers on a single copyrighted image titled “1881_Nash_Glickman_Bath_Shower_2_f.jpg,” created in 2015 and registered in early 2016.

Howarth, a Washington, D.C.-based photographer with over 25 years of experience, claims the image was used without a license on Angi’s Home Advisor website. According to the suit, he discovered the unauthorized use in June 2024 and attempted to resolve the issue with Angi later that year, but those efforts were unsuccessful.

The complaint, however, contains several noticeable errors, suggesting it may have been compiled using a copy-and-paste approach—likely due to the high volume of similar lawsuits Howarth has filed. Over the past 21 years, he has initiated 133 federal cases, nearly all involving copyright infringement. This places him among a small group of photographers who regularly go to court to protect their creative work.

A group of music publishers and copyright owners—including Broadcast Music, Inc. (BMI), Howe Sound Music Publishing LLC, d/b/a Cypress Park Music, House of Cash, Inc., Showbilly Music, Muscle Shoals Sound Publishing Co., Peermusic III Ltd., Sony/ATV Songs LLC, d/b/a Sony/ATV Tree Publishing, Buffalo Prairie Songs, Fame Publishing Company LLC, and Southeastern Publishing LLC—has filed a lawsuit against That Place Bar LLC, and an individual named Scott Coyle. The plaintiffs have made claims of willful copyright infringement, alleging that the bar played or permitted the public performance of songs from the BMI music collection without obtaining the required license.

BMI manages the rights to over 22 million songs and is authorized to grant licenses that allow businesses to play these songs in public. According to the lawsuit, That Place Bar, located in Indianapolis, Indiana and operated by That Place Bar LLC, played music from BMI’s collection without getting the required license. Since March 2024, BMI says it contacted the bar more than 50 times—by phone, email, and mail—to explain the need for a license and to warn them to stop playing the music. These efforts included formal notices ordering them to stop, but the bar allegedly continued to use the music without permission.

The lawsuit includes seven separate claims of copyright infringement, each involving different songs owned by the plaintiffs. It also states that Scott Coyle, as the manager of the bar, had control over the business and a financial interest in its operation. Therefore, he is also being held responsible.