Messages

871

Hawaiian Letters & Lawsuits Forum / Re: Vincent K. Tylor vs. Vermont Woods Studios - Round 2

« on: August 09, 2014, 03:39:01 PM »

Jerry has a good point. How many times can VKT use different legal representatives and attack Vermont Woods over an alleged single incident? How many radically different arguments can VKT make on jurisdiction?  It appears to be an abuse of the federal judicial system and copyright enforcement systems.

872

Hawaiian Letters & Lawsuits Forum / Re: Vincent K Tylor strikes again

« on: August 09, 2014, 03:35:58 PM »

Yes, ELI does excellent organic SEO!  The nice thing is everything we do Google absolutely loves because we don't resort to bullshit trickery, black-hat or grey-hat tactics.  No need to adjust and change how we do things unlike so many questionable SEO operations.  I have always insisted on focusing on producing, generating, and encouraging relevant and legitimate discussions and the content comes naturally.

There is nothing forced about ELI's discussions.  They simply ebb and flow organically depending on what is going on and Google loves us and rewards us for it.

What I will absolutely take credit for in 2008 is making the decision to launch an open discussion forum where Oscar and I did not elevate ourselves and write articles for others comment on.  We are one of the many users here engaging in open conversation.

I know many people would prefer if we wrote definitive articles on the ELI blog but the fact of the matter is, it is far easier to write and generate organic, relevant content this way, than writing articles.

And if someone wants to take a screenshot of my post, let's make sure we get the ENTIRE context captured, not a quote fragment or this one reply post.  And to those people who are trying to shut me up, I have a First Amendment right to share my opinions with everyone.  If someone doesn't like our content, they need to stop visiting and reading ELI.  Simple as that.

873

Getty Images Letter Forum / Re: Copyright Infringement Lawsuit Statistics in Stock Photo Industry

« on: August 09, 2014, 03:20:10 PM »

I know our copyright extortionist adversaries will be happy to hear me say this.... I even say it within my ELI Support Calls.

If our information, reporting, and insights are insufficient to ease the pain and suffering of the extortion letter victim, to the extent they actually lose sleep, creates abnormal levels of stress, and it detrimentally affects their health, I honestly believe they need to just go pay up then.  Health is more important than money.  Money is replaceable, time and health are not.  3-years worth of detrimentally hurting your physical and mental well-being is not worth it.

And for some people, their emotions trumps their reasoning/intellect/ability to suppress stress/etc.

However, the problem with just giving in is what happens if, in life, there are repeats of these types of stress-inducing incidents.  Do those people really want to succumb to perceived powerful interests all business lives? I say NO!

As I have said many times, I take a much broader view of conflict.  Even if I am going up against tough odds AND it causes me stress, if I feel the principle is sound, it matters not.  I fight on and upwards. It is just the way I am built but I also realize many people are not that way.

Ultimately, it is a very personal decision.  All the reasoning, logic, and rationale in the world can take stress reduction so far. It is only money. I absolutely believe that Getty will never recuperate even a small portion of money from Virtual Clinics.  It will be yet another paper win for Getty but they paid a heavy financial price in pursuing the case.  I understand why Getty did it but it set them back nearly half-million dollars to prove a point.

The Virtual Clinics case is all about saving face since Getty Images and their ilk, through ELI, are so heavily mocked, hated, and disrespected.

Ironically enough, with Getty Images pursuing Virtual Clinics so hard and Virtual Clinics dodging it and "fighting it" by being so inaccessible and unwilling to cooperate, it caused a big financial hit to Getty Images.  In many ways, Virtual Clinics has done everyone else a big favor.  I learned a lot of lessons reading the judges rulings.

I have no love for Getty Images, nor do I condone the egregiousness of what Virtual Clinics did, but VC did serve a greater good for all ELI readers and the fact it was a financial blow to Getty Images gladdens my heart. We can condemn Virtual Clinics and their egregiousness but I received a ton of insights and knowledge from that case that works to OUR favor.

And the fact that Getty Images has decided to pursue a largely uncollectible case with another legal motion revealed even information and insights.

When I have time, I need to write and share the very helpful and informative lessons I learned from the Virtual Clinics.  In many ways, the rest of us have to thank VC because they set a whole new standard of egregiousness that required Getty Images to spend a ton of time and legal fees.  But most importantly, generated several pages of public documents with all kinds of revealing information answering questions I previously didn't have the answers for!

Oh, I want to remind everyone the fact that I have been pumping out new ELI insights and commentary is directly attributable to Timmy B. McCormack who would not leave me the fuck alone forcing me out in Jan. 2014 even though I was in a self-imposed silent, non-participatory exile for an indefinite period of time. Everyone give Timmy a round of applause for restoring ELI to its whole again. And we thank his female partner-in-crime and fellow copyright extortionist for giving ELI the visibility, press, and huge public platform to speak out and reinforce the value of free speech and the First Amendment. Win or lose, the important things is ELI has publicly accessibility to valuable contacts in a way it never did before.  That bell cannot be unrung.  Not only that, the lessons ELI has learned collectively will ultimately be published and disseminated for other ELI readers to learn.

Finally, when I get around to it, I will share with everyone how Getty Images spent half-million dollars to legally pursue Virtual Clinics helps all ELI readers. There are going to be a few more groans and upset stomachs in the world when I get done writing it.

Stay tuned...

Thanks Matthew. Good points. I guess the scary thing resulting from the Virtual Clinics case is the potential for a very very high statutory potentially almost automatic damages amount so that will pressure the small corporation or llc  they are targeting to settle up to some usurious amount - more obviously than the pic was worth, and will now include attorneys fees on all sides and court costs. The problem is that by law many are not "innocent" but simply ignorant in using the pic. Maybe they got it from what they thought was a free site, didn't have a watermark on it etc. If they used it on a commercial website -  and are incorporated - even if they pulled it down after getting the letter - I think Getty will be more likely to go after them.

874

Getty Images Letter Forum / Re: Putting My Money Where My Mouth Is

« on: August 09, 2014, 02:40:02 PM »

If hot-linking was illegal, I am guessing someone would have been screaming about it by now.

Also, if hot-linking was a universally hated practiced, it would be informally banned through default software settings.  Typically, I turn off hot-linking because I have limits on bandwidth as part of my subscription and one never knows when your website might suddenly spike to an unusual referral or popularity hit like ELI received in 2012 when I was writing about the "Reality Steve" lawsuit thing.

In some ways, hot-linking is a compliment in that they are "crediting" the source of the content.

As Lucia says, just because someone doesn't like it or even hate it, doesn't automatically make it illegal. Of course, some of our "screenshot-based readers" who are allegedly lawyers don't have the mental bandwidth to make finer distinctions that "disliked/hated/unpopular practice does not illegal practice".  They simply cry "Boo hoo, I am being bullied by people writing on THEIR website and we need a bright line rule so that their feelings are not hurt or injured by content sitting of said website".

875

Getty Images Letter Forum / Re: Another Getty Letter Story

« on: August 08, 2014, 02:02:31 PM »

I don't mean to sound callous but if your friends have read this forum in its entirety and still wondering "what to do", then would they like someone to tell them to call Getty up and negotiate to pay?  Do they expect Getty to simply say, "We changed our minds. Since you successfully ignored and dodged us for a year, we are going to be good guys and send you a reward letter saying that we are not pursuing you for money anymore."

If it is too quiet for them, that can easily be changed with one email and phone call to Getty. If they are unwilling to negotiate and pay, then don't expect worry-free closure until the 3 years statute of limitations is up. It is that simple.  They just need to sit and wait quietly. Or lawyer up if that makes them feel better.

The honest truth is that ELI would do financially much better if we distorted the facts and said the likelihood of getting sued is very high.  It is amazing to me how badly people seem to want to disregard favorable news as if we stand to benefit from it.  If Getty were to suddenly fire up 20 lawsuits, our website traffic would increase and we would make more money.

I've told Oscar we probably SHOULD let people believe that lawsuits are likely. He and I would get a lot more clients that way. But we don't because we feel it is sleazy to do unnecessary fear-mongering. But we can't give absolute guarantees either. We only report what we see.

EVERYONE pays a price. It is all a matter of choice.  You can pay with simply sitting silently and have lack of closure for 3 years.  Or you can negotiate and pay up to get closure.  Or you can lawyer up to feel better.  Everyone needs to pick their poison.

But too many people have this "irrational" thought, "I just want them to go away peacefully without me paying a penny and guarantee they will not contact me again". Well, hell, I want traffic to clear out of the way each time I get in my car to drive also. Being irrational doesn't serve anyone.  Life is about making choices.

ELI helps extortion letter victims with the various issues and give people lots of options to choose from including publicly saying "lay low and be quiet".  But very few here are going to provide counseling services and ongoing assurances to quell people's fears.  Some people can take the stress and uncertainty of waiting 3 years, others can't.  It is best to be honest about it with yourself. If they are going to lose sleep and get an ulcer over it even after this forum explains everything so bluntly, then I say go pay up and be done with it and move on. It is that simple.

Our friends received one letter but did not answer it over a year ago. A few other letters came to the office where their mailbox is but it was addressed to a person or "department" they don't have and sent back unopened. They haven't heard anything in about a year and are unsure of what to do. Yes they read every post  and suggestion on here and know the options. LOL.

876

Getty Images Letter Forum / Re: Copyright Infringement Lawsuit Statistics in Stock Photo Industry

« on: August 07, 2014, 12:00:34 PM »

This has already been covered in another thread.

For the five Jan. 2014 cases , the common denominators were they were all small corporations with a registered agent that could easily be found and served. It saves on process service costs. They were also small corporations that were perceived as likely to settle, not simply let it go into default.  They were perceived as likely not to put up a fight.

And they could financially "afford it" without too much stress unlike many smaller parties such as single-owner businesses/entrepreneurs/proprietors/parties. Getty Images, through Scott "Towels" Wilsdon's legal genius (billing out at $465/hour), wanted to send a symbolic message to less discriminating minds that they will file boilerplate lawsuits against single-image infringements.

And there was the oddball Virtual Clinics case from 2013 and carrying over into 2014 which ELI can't possibly defend or support because of the scale and egregiousness of their infringements.  They are a unique case all unto themselves.

There isn't really much of a true pattern to analyze when you only have 5 cases out of thousands of extortion letters. The sample is too small.

Getty Images is going to have to crank out another 90 lawsuits or so to hit the 1% mark.  However, if they "only" cranked out 10 more "cheap" lawsuits for 2014, it will be "big news" to report.

The filing fee cost to file a federal civil/copyright infringement lawsuit is $400 for each case.  $350 plus a $50 additional admin fee for civil cases.

http://www.uscourts.gov/FormsAndFees/Fees/USCourtOfFederalClaimsFeeSchedule.aspx

It doesn't include attorney fees Getty has to pay Scotty Wilsdon and/or his paralegals nor does it include attorney fees for the local attorney sponsoring Scotty pro hac vice. There might even be an application fee for any attorney admitted into a given state/district pro hac vice.

All of this doesn't include the time spent by the internal Getty lawyers and staff members that work on the case.

The details and nuances go on and on for the legally curious.

877

Getty Images Letter Forum / Copyright Infringement Lawsuit Statistics in Stock Photo Industry

« on: August 06, 2014, 06:35:19 AM »

Over the years, there has been speculation over how many copyright infringement lawsuits are actually being filed by stock photo companies. And out of those lawsuits that were filed, what were the outcomes?  I have taken the position that in recent years the PROPORTION of lawsuits filed vs. extortion letters is very low, less than 1%. I have also said that the "success" rates for the stock photo industry is very low. What I define as "success" is from the stock photo industry perspective.

They not only have to win a lawsuit but they have to get a judgment that exceeded their legal fees & expenses and actually collect on those "winning cases".  Getting a default judgment is relatively easy if defendants don't show up. However, actually collecting on those default judgments are an entirely different animal.  In many cases, default judgments are simply "paper wins", not actual monetary wins. The stock photo company is often left with a big legal bill with very little financial reward to show for that "paper win". It is my belief that Masterfile was left with a crushing legal bill with relatively little financial rewards after 2010 which accounted for the sudden drop of their filing lawsuits. It appears that both Getty Images and Corbis did not enjoy much financial success either through their early attempts in filing copyright infringement lawsuits. This is consistent with prior attempts by RIAA, Righthaven, and Prenda. Each of these parties either stopped because of losses from the lawsuit strategy or were entirely put out of business.

People CHOOSING to settle is not counted as a legal victory but would likely be counted as a financial victory for the stock photo company. However, even then, each of the stock photo companies would have incurred a fair amount of legal expenses (such as court costs, filing fees, and attorney fees) along the way.

Vincent K. Tylor, a private photographer from Hawaii, is currently on a tear on the lawsuit front. From what I can tell, there hasn't been a single lawsuit that has "gone all the way". He has successfully scared people into settling. It remains to be seen how long he can keep up his current record.  Prior to VKT, Masterfile had the most aggressive lawsuit record from 2009-2011.

I am happy to say that with some exceptions, legal "success" by the stock photo industry has been very low. Sure, there have been occasional lawsuits filed and many were settled along the way.  But proportionally speaking, in the last 5 years, less than 1% of all extortion letters ever became a lawsuit. The reason for this low percentage has to do with the large numbers of extortion letters being issued each year. I conservatively estimate the number of extortion letters issued by the stock photo industry/photographers to be around 10,000 per year. To hit a 1% lawsuit filing ratio, 100 copyright infringement lawsuits would have to be filed per year by the entire stock photo industry. And while ELI doesn't track every single company that issues extortion letters, we follow the largest and major players reported to ELI.

In my investigation using dockets.justia.com, I physically tracked and counted copyright infringement lawsuits filed for six companies in the last five years. However, I did not take the time to track the outcome of each of these lawsuits.  In the case of Masterfile, it would be a very time-consuming project for the years 2009-2011 to manually analyze 64 lawsuit outcomes.  A cursory review shows that many of them settled out of court.

Here are my results with some commentary for unusual deviations.

Getty Images
2014 - 6 so far (5 were boilerplate & settled)
2013 - 2 (1 was for the infamous Virtual Clinics who defaulted.)
2012 - None
2011 - None
2010 - None
2009 - 1 (Advernet, Getty lost even though Advernet stop defending the case!)
2008 - 5

Masterfile
2014 - 1 so far
2013 - None
2012 - 5
2011 - 10
2010 - 39
2009 - 15
2008 - 2
2007 - 1

Corbis
2014 - 1 so far
2013 - None
2012 - None
2011 - None
2010 - 1
2009 - 8
2008 - 0
2007 - 8

Hawaiian Art Network
2014 - None so far
2013 - 1
2012 - 1
2011 - 3 (Filed with Vincent Tylor. 1 was Aloha Plastic Surgery that counter-sued them into a settlement)
2010 - None
2009 - None

Vincent K. Tylor (VKT)
2014 - 13 so far (Vermont Woods twice because their lawyer dropped the earlier one)
2013 - 14
2012 - None
2011 - 3 (Filed via Hawaiian Art Network)
2010 - None
2009 - None

Realtor Jennifer Sherrouse/Atlanta Photgraphy
2013 - 1 so far (still being litigated)
2012 - None
2011 - 1 (settled)
2010 - None

I will be adding to and updating this list as I discover new information and discover other companies and photographers that actively engage in sending extortion letters and filing lawsuits. If anyone has notable companies and photographers we should start tracking, please respond to this thread.

878

Getty Images Letter Forum / EFF writes a white paper on fixing copyright law on civil penalties

« on: August 05, 2014, 08:41:20 PM »

Mitch Stolz of EFF writes an interesting white paper making a proposal to fix copyright law's civil penalties.

https://www.eff.org/deeplinks/2014/07/congress-tackles-copyright-remedies-eff-pitches-whitepaper-broken-penalty-system

The link to the whitepaper is here.

https://www.eff.org/wp/collateral-damages-why-congress-needs-fix-copyright-laws-civil-penalties

879

Hawaiian Letters & Lawsuits Forum / Re: Vincent K. Tylor vs. Vermont Woods Studios - Round 2

« on: August 05, 2014, 02:19:48 PM »

Another interesting nugget in this case relates to Typepad.  I have an interesting email snippet allegedly from Typepad.

Typepad is a hosted service, so we try to make it difficult for users to remove content on accident. That means that the folders that images are uploaded to via the Insert Image tool are hidden to prevent accidental loss of content. It's a protective measure we've put in place.

WTF! Are you kidding me?  To permanently delete files, you have to go through tech support?  This has HUGE negative ramifications for Typepad users. What this means is that even if a user DELETES an image that might infringe a copyright, Typepad DOESN'T ALLOW IT!  The images are still exposed and shown to the public. Only Typead tech support can delete these files with a "backend tool." Deleting an image file on Typepad simply means it is "hidden" from the user as a "protective measure" according to Typepad, NOT truly deleted.

This is actually quite problematic for anyone who wants to be copyright-compliant. I did a Google Search on Typepad and could find no reference to this "undocumented feature".  In fact, Typepad should be avoided until they correct this potentially lethal copyright compliance trap.

In fact, I would say that Typepad could potentially be partially responsible for this or any copyright-related fiasco and the Vermont Woods may want to consider legally subpoenaing them or otherwise compel them to cooperate.

Typepad is endangering all its users by not informing their community of users that when they delete their files, they are not truly deleted.  They are simply "hidden" from their view.  That is a huge misrepresentation on their part that subjects their users to unnecessary and inflated copyright claims for alleged "non-compliance".

880

Hawaiian Letters & Lawsuits Forum / Re: Vincent K. Tylor vs. Vermont Woods Studios - Round 2

« on: August 05, 2014, 01:45:25 PM »

It appears that a correction made to the original post.  The first letter was received in 2012, not 2010.

881

Getty Images Letter Forum / Re: Getty Images Washington State Lawsuit Against Virtual Clinics

« on: August 04, 2014, 08:22:00 PM »

In an update on the Virtual Clinics case, Getty Images obtained a default judgment of over $600K against Virtual Clinics.

http://docs.justia.com/cases/federal/district-courts/washington/wawdce/2:2013cv00626/191997/47/0.pdf

On March 20, 2014, the court awarded Getty Images actual damages of $21,433 for 10 unregistered images and $300,000 maximum statutory damages for 2 registered images. Virtual Clinics made 2 attempts to defend the case and then subsequently abandoned it.

The court awarded Getty Images attorney's fees in the amount of $276,680.

http://docs.justia.com/cases/federal/district-courts/washington/wawdce/2:2013cv00626/191997/53/0.pdf

How Getty Images arrived at $276,680 of attorney fees for a default judgment case is mind blowing. Scott "Towels" Wilsdon charges $465/hour.  (Are you freaking kidding me?). A staff attorney charged $385/hour.  And two paralegals billed out at $180/hour. Getty lawyers allegedly spent 1,124 hours on this case allegedly because of the motions, discovery, "deception and stonewalling" by the Camps.  If Getty actually pays all this to their law firm, then I would say that Getty got raped by the law firm.

There is no way Getty Images will ever get collect this judgment or attorney fees in any meaningful way.  They can try to garnish but no way the Camps will have $600K worth of assets to pay Getty or the attorneys.

It should be noted that ELI does not support Virtual Clinics in that their infringements were numerous, egregious, and willful unlike the vast majority of cases we deal with.

These folks received "worst case scenario" because their case was simply the "worst of the worst" and is by far, NOT REPRESENTATIVE of most innocent/nonwillful infringers we encounter.

On July 30, 2014, Getty Images filed for a propose writ of garnishment against one of Virtual Clinics clients to partially collect on the remaining $600K outstanding.

Declaration of Attorney In Support of Issuance of Write of Garnishment
http://www.scribd.com/doc/235860701/Getty-Images-v-Virtual-Clinics-In-Support-of-Garnishment

Proposed Writ of Garnishment
http://www.scribd.com/doc/235860600/Getty-Images-v-Virtual-Clinics-Proposed-Writ-of-Garnishment

882

Getty Images Letter Forum / Re: Realtor Jennifer Sherrouse files suit with the help of Carolyn Wrights office

« on: August 04, 2014, 07:33:55 PM »

In reviewing lawsuit status for various cases, I got curious about the Jennifer Sherrouse case, our favorite Atlanta discriminatory realtor. The battle is still going strong.  Ian Marshall is definitely fighting back.

Updated Docket as of August 4, 2014
http://www.scribd.com/doc/235858978/Jennifer-Sherrouse-v-Marshall-Docket

Amended Complaint
http://www.scribd.com/doc/235858980/Jennifer-Sherrouse-v-Marshall-Amended-Complaint

Answer Amended Complaint by Ian Marshall
http://www.scribd.com/doc/235858979/Jennifer-Sherrouse-v-Marshall-Answer-to-Amended-Complaint-by-Marshall

The Joint Report and Discovery Plan.
http://www.scribd.com/doc/235859861/Jennifer-Sherrouse-v-Marshall-Joint-Discovery-Plan

883

Hawaiian Letters & Lawsuits Forum / Re: Vincent K. Tylor vs. Vermont Woods Studios - Round 2

« on: August 04, 2014, 06:29:08 PM »

One of the strategies I found from 2012 is Aloha Plastic Surgery's move to file a counter-claim against VKT because there was a great deal of suspicion of how VKT operated, the way he submitted his images online years ago, and most importantly, how he comes up with his settlement numbers.

http://www.extortionletterinfo.com/forum/getty-images-letter-forum/aloha-plastic-surgery-submits-counter-claim/

VKT regularly takes advantages of victims who unknowingly find his images on free wallpaper websites and the like. In his lawsuit, VKT claims that extortion victims are intentionally cutting out the artist info and licensing info. I find that difficult to believe that so many people would do this.

I suspect there is more to the VKT operation than the public knows.  In my view, the only way to find out and sufficiently defend yourself is to file a counter-claim so that the discovery process is available to the extortion victim.

884

Hawaiian Letters & Lawsuits Forum / Re: Vincent K. Tylor vs. Vermont Woods Studios - Round 2

« on: August 04, 2014, 06:15:44 PM »

I forgot to mention the recent article by the Brattleboro Reformer where they reported the updated on the Vincent Tylor vs. VWS battle.

http://www.reformer.com/localnews/ci_26247454/lawsuit-against-vernon-company-dropped-refiled

From what I know, Vermont Woods doesn't appear to be taking this sitting down and they don't intend to just roll over and get raped by Vincent Tylor.

Now that VKT has filed suit from Hawaii, I believe it is time for Vermont Woods to connect with the folks at Aloha Plastic Surgery, one of the few parties who actively fought back against VKT and not simply settle quietly like a helpless dog.  Aloha Plastic may be able to provide some other Hawaii referrals and strategies that Vermont Woods can use.

885

Hawaiian Letters & Lawsuits Forum / Hawaii Attorney - "Jimbo" Stephen Street

« on: August 04, 2014, 06:03:20 PM »

James Stephen Street (J-Steph) aka known as the 65-year old, presumably Social Security collecting lawyer who pissed away 50-years of his life before he realized he really wanted to be a "painter of the Hawaiian ugly" (snark).

http://images.fasocdn.com/5604_117664m.jpg

An excerpt of his own words from his website jstephenstreet.com.

It was with very mixed emotions that I came to the realization in 2007 that I have been painting in oils for 50 years, in the "spare time" I could borrow away, first from school, then from practicing law, raising a family, .... and many, many life obligations that competed for my time.  Certainly it is a milestone, but there is so much more painting I want to do before I am through. 

My art has always been at the core of who I am and what I have longed to be doing.  My desire to create in oils on canvas was born out of the only formal art training I had (at age eight) and has only intensified and become more urgent as the years pass....

How does that sound to you?  It sounds like he became a lawyer because he was too much of a chicken-shit to pursue what he wanted in life.  He blames the other things like school, family, coaching, etc. that "competed" for his time.  Ummm.... this guy really sounds like a guy who had control over his life, right?  They didn't "compete" for his time. He simply didn't have the stones or what it took.  Instead he decided to "play it safe" and grind away at a large law firm for nearly 30 years.

I can't believe it took him until age 57 to figure out what his dreams were. And when he did figure it out, it took him another 4 years at age 61 to leave the Rush Moore law firm. I suppose all he needed to do is fill in the 4-years before his Social Security income kicked in.

Now, he is "tutoring" Dane K. Anderson, 31, in being a life success. Dane too can piss away 50 years of his life grinding away in law before becoming an arts-fartsy painter.

J-Steph appears to be calling his mainline business of "copyright extortion" as his "day job".  As far as I can tell, he is working for the standard 35%-40% commission that most extortion lawyers do.

He keeps such great company such as Glen Carner of Hawaiian Art Network and Vincent K. Tylor.

One of the more memorable moments ELI celebrated is when Aloha Plastic Surgery in 2012 (through Dr. Pasquale's guidance and direction) decided to go on the offensive and fought them so hard, they decided to "settle the lawsuit".  The terms of the settlement were never revealed but it sure seemed like Aloha Plastic Surgery was happy with its outcome.

http://www.extortionletterinfo.com/forum/getty-images-letter-forum/hawaiian-art-network-v-aloha-plastic-surgery/