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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND LTVN HOLDINGS LLC, et al. v. NADER ANTHONY ODEH, et al. : : : : : ...o0o... MEMORANDUM Now pending before the court is a motion to dismiss for lack of jurisdiction and improper venue or, in the alternative, to transfer venue filed by defendants Nader Anthony Odeh and his company, Claims Consulting LLC. Plaintiffs LTVN Holdings LLC (hereinafter "LTVN") and Irwin R. Kramer filed a complaint containing eight counts relating to alleged copyright infringement of marketing videos produced by LTVN. The issues in this motion have been fully briefed and no oral argument is necessary. For the reasons stated below, defendants' motion will be denied. BACKGROUND The factual underpinning of this case relates to alleged copyright infringement of twelve marketing videos produced and distributed by plaintiffs.1 Mr. Kramer is the managing member of LTVN, a limited liability company organized and existing under the laws of Maryland. LTVN produces videos pertaining to fields such as insurance, real estate, finance, employment law, criminal justice, entrepreneurship and consumer protection, and distributes them on its website, clientelevision.com. The videos are specifically designed to help professionals, including accountants, adjusters, insurance brokers and lawyers, market their services to consumers. By registering as a "network affiliate" and accepting the terms of LTVN's "Network
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Civil Action No. CCB-09-0789

The complaint alleges various state law claims, including breach of contract and conversion, as well as copyright and federal Lanham Act violations. 1

Affiliation Agreement" (hereinafter "the Agreement"), professionals can play LTVN's videos free of charge on their own websites through "channels", even though they are not permitted to download or copy the videos. (Compl. at

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Maryland Law