Complaint filed against Taylor Swift for copyright infringement

Added: 2026-05-12

[00:00:01]Hey guys. So, um I've been asked by quite a few people, am I going to cover the Taylor Swift lawsuit?

[00:00:08]Um so, I went and had a look at it, and it looks like it's going to be one hell of a spicy one. So, the short answer is yes. I'm here for it. Um I'm going to have to catch up. So, what I'm going to do is I'll start this video. is going to be the initial complaint.

[00:00:30]Then I believe um the plaintiff Marine Flag has filed a uh notice of u motion for a preliminary injunction and then Taylor Swift has responded to that. So, I'm going to do a video for each of them and just kind of, you know, take continue then as things progress.

[00:00:58]So, let's start with this complaint.

[00:01:01]Let's see what she's saying.

[00:01:06]All right. Plaintiff Marine Flag alleges as follows. based on her personal knowledge as to her own conduct and on information and belief as to all other matters.

[00:01:20]Um, okay. Um, there's going to be trademark numbers and various things.

[00:01:24]I'm not going to read them out, okay?

[00:01:27]Cuz it'll be repetitive and I um I'm quite dyslexic with numbers actually, so I don't love doing numbers. But um yeah, we'll just say trademark, right? She's actually um included as exhibits the trademark documents. So, we can look at that, you know, as and when it comes up.

[00:01:51]Okay. In 2024, in the pages of Las Vegas Weekly, a working performer began writing candidly about her life inside the entertainment industry. Marine Flag, professionally known as Marine Wade, called it Confessions of a Showgirl. The name stuck.

[00:02:12]What began as a weekly column became a live show. The show became a touring production. Over the course of a decade, Confessions of a Showgirl grew into a brand encompassing performances, writing, and digital media built by one person city by city and showby show.

[00:02:34]Plaintiff has performed confessions of a showgirl across the United States, including at established venues such as New York's New York City's Lorie Beachman Theater and Myron's at the Smith Center in Las Vegas.

[00:02:51]She has appeared on television under that name, earned press coverage in national publications, and expanded the brand into a book, a podcast, and video content.

[00:03:04]In 2015, the United States Patent and Trademark Office registered Confessions of a Showgirl for entertainment services. After years of continuous use, Mark achieved incontestable status, a statutory recognition of the goodwill plaintiff earned through her sustained personal effort.

[00:03:28]Okay.

[00:03:31]Okay. And that was under um 15 United States Code section 1065.

[00:03:42]Okay.

[00:03:47]For more than a decade, Confessions of a Showgirl identified a single source, plaintiff.

[00:03:53]Then in 2025, defendant Taylor Swift and her affiliated business entities adopted the designation the life of a showgirl and began using it in commerce. They did not do so quietly. Within weeks, the designation was affixed to consumer goods, stamped onto labels, tags, and packaging, and deployed as a source identifier across retail channels. all directed at the same audience plaintiff had spent years cultivating.

[00:04:25]The similarity between Confessions of a Shogo and the life of a show girl is immediate. That's fair. It is.

[00:04:33][clears throat] It is. And they're targeting the same audience as well, which is very important.

[00:04:40]Both share the same structure, the same dominant phrase, and the same overall commercial impression. Both are used in overlapping markets and are directed at the same consumers.

[00:04:53]That similarity would not have escaped defendants notice. Even a cursory trademark search would have revealed plaintiff's federally registered mark and her years of continuous prior use.

[00:05:07]Defendants are sophisticated commercial actors with dedicated legal and brand management teams responsible for Swift's portfolio of more than 170 active and pending trademark registrations.

[00:05:23]Indeed, they are not merely familiar with trademark law. They are among its most vigorous enforcers, [laughter] having filed multiple federal actions to seize goods from vendors selling trademarked merchandise near concert venues.

[00:05:41]They possess direct knowledge of the harm that trademark infringement inflicts on a brand having leveraged that very harm in federal court when it served their interest to do so.

[00:05:52]Wow, that's a really strong start to [clears throat] this. That's an incredibly strong start to a complaint.

[00:06:01]Um, okay. [clears throat] The USPTO confirmed what any competent search would have revealed. When defendants applied to register the life of a showgirl, the office refused on the ground that defendants designation is confusingly similar to plaintiff's established mark.

[00:06:25]Defendants were therefore placed on actual notice that their chosen designation was likely to be confused with a mark that already belonged to someone else.

[00:06:38]O they continued using it anyway, expanding it across a coordinated commercial program and distributing it through retail channels reaching millions of consumers. Plaintiff was never contacted.

[00:06:55]The result is textbook reverse confusion. A junior user's overwhelming commercial presence drowns out the senior users mark until consumers begin to assume that the original is the imitation.

[00:07:12]What plaintive had built over 12 years defendants threatened to swallow in weeks.

[00:07:20]Defendants may contend that the life of a show girl as the title of a musical work is beyond the reach of trademark law. Not so. Whatever protection might attach to creative expression, it does not immunize defendants separate decision to adopt a confusingly similar designation as a trademark, affix it to goods and deploy it as a source identifier in commerce.

[00:07:47]plaintiff as a performer herself respect ta respects Taylor Swift's right to creative expression and nothing in this action challenges it. But what defendants did here was not expression.

[00:07:59]It is infringing trademark use.

[00:08:03]The US PTO told defendants as much when it refused their application. They proceeded anyway at a scale that threatens to erase plaintiff from her very brand.

[00:08:14]Those are not artistic choices. They are commercial decisions and they have consequences.

[00:08:22]Plaintive brings this action to protect the goodwill she has built to halt further confusion in the marketplace and to ensure that the identity of her brand remains hers.

[00:08:36]Okay, so that was incredibly well written.

[00:08:41]Um obviously I want to see further read we continue reading and everything and I want to see the uh motion for preliminary um injunction that was filed and the response from Taylor Swift but you know like all the elements are there. They are incredibly similar. I would get confused. Um the you know this plaintiff has had 10 years head start on using that. So, she's built up her brand. It is her brand. Um, Taylor Swift has it definitely is of a size um in terms of star power that she would engulf this poor lady. Um, and pe, you know, she's right. People will start thinking that she was the one who originally came up with the design with the um with the name and she didn't.

[00:09:36]Um, but also like how much brazeness is there? Like you filed for the trademark, you were told no, there is this similarity. It's too confusing. So, we're not going to give it to you. And then you go with it anyway because you think you're too big to be, you know, you don't want to be told no, and you think, well, I'll just get my lawyers to deal with it. You know, I I'll squeeze the life out of this poor person and they'll cave to me. um a bit like you know Blake Brown Beauty did to that um that small business you know where they were try you know she was trying to sue someone over uh a similar name and it's not even as similar as it is in this situation.

[00:10:21]So a very strong start here but I do want to see what Taylor Swift's response will be.

[00:10:28]Okay so jurisdiction and venue um won't go into detail. They're basically saying, you know, well, California applies. Um, the court has personal jurisdiction over defendants because they purposely d purposefully directed commercial activities toward California, including the sale of goods bearing the life of a showgirl designation to consumers in this district.

[00:10:56]And plaintiff's claims arose from those activities. Okay.

[00:11:02]>> [snorts] >> Dependent Swift is an individual who directs substantial commercial activity from this district, including recording, production, and management of her entertainment projects through facilities and business relationships located in Los Angeles County. Swift also maintains a residence in the in this district, including a property in Beverly Hills, California.

[00:11:27]Defendant TAS conducts business in California and participates in the ownership, control, licensing, and commercialization of intellectual property associated with Swift's entertainment projects, including the life of a Shogill.

[00:11:44]TAS authorized, directed, and/or approved the use of the life of a showgo designation in connection with goods offered for sale to customers to consumers in California, including through retail channels operated by or in coordination with dependent UMG and bravado.

[00:12:06]DAS's activities are not limited to passive licensing but include active participation in the commercial exploitation of the designation in this district.

[00:12:20]Dependent UMG remains its principal base of business in Santa Monica, California and directs and participates in the commercial exploitation of goods associated with the life of a showgirl.

[00:12:35]Defendant Bravado maintains its principal um place of business uh is place his principal place of business in Santa Monica, California and is responsible for the design, manufacture and sale of good bearing the life of a Shogo designation.

[00:12:59]Defendants have purposefully availed themselves of the privilege of conducting business in California by offering and selling goods bearing the life of a showgirl designation to consumers in this district through online and retail channels, including through coordinated activities directed, authorized and controlled in part by swift and tas in conjun in conjunction with UMG and bravado.

[00:13:25]Those goods are offered through websites accessible to and used by consumers in this district and are fulfilled, distributed and/or otherwise provided to consumers here through operations directed from UMG and Bravado which are headquartered in this district.

[00:13:52]venue is proper in this district pursuant to title 28 USC section 1391 B1 and B2. Swift maintains a residence in this district and conduct substantial business here and UMG and Bardo maintain their principal places of business here.

[00:14:11]In addition, a substantial part of the events given rise to plaintiff's claims occurred in the district, including defendants authorization, direction and execution of the use of the life of a showgirl, designation in connection with goods offered to consumers in this district, the sale and distribution of those goods to consumers located here, and the resulting con consumer confusion and harm to plaintiff within this district.

[00:14:41]>> [clears throat] >> Okay.

[00:14:44]So, parties plaintiff Marine Flag, professionally known as Marine Wade, is an individual and a resident of Nevada. She is a singer, songwriter, comedian, and writer who has developed and performed under the confessions of a showgirl, Mark, since at least 2014.

[00:15:05]Defendant Swift is an individual and a resident of California. She is a performer who releases music and related goods and services under her name and associated designations.

[00:15:18]Defendant TAS is a limited liability company organized under the laws of Tennessee with its principal place of business in Nashville, Tennessee.

[00:15:28]TAS manages and licenses intellectual property associated with Swift's projects, including the life of a showgirl.

[00:15:38]Defendant UMG is a corporation organized under the laws of Delaware with its principal place of business in Santa Monica, California. UMG distributes and commercially exploits Swift's music releases and related projects, including those associated with the life of a showgirl.

[00:15:58]Defendant Bravado is a corporation organized under the laws of California with its principal place of business in Santa Monica, California.

[00:16:07]Bravado is responsible for the design, manufacture, distribution and sale of goods bearing the life of a showgirl designation.

[00:16:18]Plaintiff is informed and believes and on that basis alleges that defendants sued herein as those 1 through 25 are responsible in some manner for the acts alleged herein and that plaintiff's injuries were approximately caused by their conduct.

[00:16:37]The true names and capacities of these defendants are presently unknown to plaintiff. Plaintiff will amend this complaint to allege their true names and capacities when ascertained.

[00:16:52]At all relevant times, each defendant participated in, directed, [clears throat] controlled, or knowingly approved the adoption and use of the life of a showgirl designation in connection with the goods and commercial activities alleged herein.

[00:17:07]Defendants acted in concert with a unity of interest in developing, distributing, and selling goods bearing that designation, and each is liable for the acts of the others.

[00:17:19]Defendant Swift personally selected, approved, and promoted the life of a showgirl as the identifying designation for her album and associated commercial program. As the controlling creative and commercial principle of the enterprise, Swift is personally liable for the infringing activities she directed and controlled at all relevant times. Defendants acts alleged herein occurred in interstate commerce within the meaning on of the lenom actual allegations. So, plaintiff's development of the confessions of a showgirl brand.

[00:18:04]Plaintiff is a singer, songwriter, comedian, and writer who has developed and operated the Confessions of a Showgirl brand for more than a decade.

[00:18:14]Plaintiff began using the Confessions of a Showgirl mug in commerce in or about 2014 in connection with writing and entertainment content.

[00:18:24]The brand originated from a column she published in Las Vegas Weekly, writing candidly about her experiences as a working performer in the Las Vegas entertainment industry.

[00:18:41]The column evolved into a live theatrical production presented under the Confessions of a Showgirl name. That production combines original music, singing, storytelling, and comedy drawn from plaintiff's life as a working performer, including candid and often humorous accounts of the challenges and absurdities of a career in the entertainment industry. From getting stuck inside a giant birthday cake to impersonating a Madonna impersonator.

[00:19:16]Okay.

[00:19:19]Since 2014, Plaintiff has performed Confessions of a Showgirl at venues across the United States, including in Arizona, Florida, Indiana, Nevada, New Jersey, and New York.

[00:19:34]Performances have been staged at established venues such as the Lori Bechman Theater in New York City and Myron's at the Smith Center in Las Vegas and have been presented to audiences numbering in the thousands.

[00:19:50]Plaintiff most recently performed the production in January 2024, sorry, 2026.

[00:19:58]The production is musically directed by Keith Thompson, who credits include Jersey Boys, Mama Mia, and We Will Rock You. Wow.

[00:20:11]Plaintiff's performances have also been featured in entertainment publications, including Broadway World. She has made numerous television appearances and hosted entertainment segments under the confessions of a showgirl name. In addition to live performances, plaintiff has expanded the confessions of a showgirl brand across multiple platforms and consumerf facing offerings. She has published written books under that name, including a book um sorry she has published written works under that name including a book and has produced video content distributed online including through YouTube and social media.

[00:20:52]Plaintiff has also launched a podcast under the Confessions of a Showgirl name, extending the mark into an additional medium.

[00:21:00]Plaintiff maintains an online presence through the website ww.conessionsofoggirl.com and associated social media channels through which she promotes and offers her performances, media and related branded content.

[00:21:21]Plaintiff has continuously used Confessions of a Showgirl as the identifying name for her entertainment services and related works since 2014.

[00:21:34]Through this continuous use of uh sorry through this continuous use confessions do has come to identify plaintiff as the source um of those services and has developed goodwill in the marketplace reflected in plaintiff's sustained booking history at established venues across the US her audience recognition across multiple platforms more than a decade of exclusive unchallenged use of the mark and her continued expansion of the brand into new entertainment markets and media.

[00:22:09]Plaintiff owns a US trademark registration for Confessions of a Showgirl in connection with entertainment services in the international class 41. That registration is valid, subsistent, and has achieved un incontestable status under federal trademark law.

[00:22:28]defendants adoption and use of the life of the showgirl.

[00:22:34]In or around August 2025, defendant Swift personally has selected and adopted the designation the life of a showgirl for use in connection with a musical release and more broadly as a source identifying designation on public goods offered to the public.

[00:22:54]as a source identifying designation on goods offered to the public. Swift has personally promoted the designation through public appearances and social media. The remaining dependents executed the commercial program behind it. TAS authorized, directed, and controlled the use of the designation as a trademark across goods and services. UMG distributed and commercially exploited the musical recordings and related goods bearing the designation and Bravado designed, manufactured and fulfilled the consumer goods sold under it.

[00:23:30]Together, these entities operated as a coordinated enterprise to bring the life of a showgirl to market as a commercial brand through retail channels operated by or on behalf of defendants, including defendants online store. Defendants offer for sale numerous goods identified by the life of a go the life of a showgirl designation including through a dedicated retail section labeled the life of a showgirl shop.

[00:24:04]Within that retail program, defendants use the life of a showgirl as a product designation affixed to individual goods offered to consumers. Those goods span a range of products including drink wear, candles, personal care accessories, and home goods. Each bearing the life of a show girl not as an artistic expression but as a source identifying mark.

[00:24:30]Defendants use the life of a showgirl as a trademark in connection with these goods, including as part of product names. For example, the life of a showgirl candle, the life of a showgirl tumbler, and the life of a showgirl hairbrush, and as a source identifying label for those goods.

[00:24:52]Defendants further use the life of a showgirl on product labels and inventory tags. Apparel items include interior garment labels bearing the designation in the position customarily used to identify the source or product line of clothing and packaging labels likewise display the life of a showgirl designation.

[00:25:16]Defendants have also incorporated the life of a show into consumerfacing commercial offerings with national brands including Uber, Uber Eats, KitchenAid, Starbucks and Crispy Creme directing consumers to defendants online store for the purchase of goods bearing the designation.

[00:25:37]Through these activities, defendants have used the life of a showgirl as a trademark and source identifying designation for a coordinated line of goods offered to the public, including in connection with the labeling, packaging, and sale of those goods across dependent retail channels.

[00:25:58]The USPTO's refusal and dependent continued use.

[00:26:04]Defendants sought federal trademark protection for the designation the life of the showgirl uh by filing US trademark application with the US PTO.

[00:26:15]The application seeks registration across multiple international classes including class 41 the same class in which plaintiff smark is registered encompassing musical performances and live entertainment services.

[00:26:30]The application extends well beyond that shared class to cover additional categories of goods and services, confirming that defendants intend the life of a showgirl to function as a broad commercial trademark across every category in which plaintiff operates and more.

[00:26:49]On November 5th, 2025, the US PTO issued an office action refusing registration of the life of a showgirl under section 2D of the Lannam Act. Title 15 USC section 1052D based on a likelihood of confusion with plaintiff's federally registered confessions of a showgirl mark. The examining attorney found that the marks are identical in their shared terms of in their shared terms of a showgirl are similar in appearance and sound and convey a similar overall commercial impression.

[00:27:29]The examining attorney further found that the parties goods and services are closely related, noting that both marks are used in connection with entertainment services involving musical and theatrical performances and that consumers encountering both marks would be likely to assume a connection between the parties.

[00:27:52]Defendants are sophisticated commercial actors with dedicated legal and brand management teams. Trademark clearance is a routine part of their operations. A standard search would have revealed plaintiff's federally registered mark and her longstanding prior use in commerce.

[00:28:10]Defendants are among trademark laws most active enforcers.

[00:28:16]Through Swift and TAS, defendants have filed multiple federal actions seeking injunctive relief and seizure orders against the sale of merchandise bearing their designations.

[00:28:29]In each action, Swift and TAS took the position that such designations function as trademarks on consumer goods and obtain federal core orders on that basis.

[00:28:40]Defendants thus possess direct firsthand knowledge that a fix in a designation associated with a musical release to consumer goods constitutes trademark use because they have repeatedly argued as much when it served their interest to do so.

[00:28:59]Despite the USPTO's refusal, defendants have continued to use Life of the Shogo in commerce as a trademark in connection with goods offered to the public.

[00:29:15]A little footnote here as well just to say as of the filing of this complaint, defendants application is suspended. The USPTO has maintained its likelihood of confusion refusal based on plaintiffs registered confessions of a showgirl mark and has indicated that the refusal will be made final once the suspension lifts.

[00:29:42]Three defendants, substantially greater commercial scale and retail reach, including the a global merchandi merchandising operation and national brand collaborations.

[00:29:53]Goods bearing the life of a showgirl designation have been widely offered and sold to consumers in the same channels in which plaintiff offer offers her services and related work.

[00:30:07]At no point have defendants sought or obtained plaintiff's consent or authorization to use the life of a shogo or any similar designation.

[00:30:17]Defendants use of the life of a shogo is ongoing and expanding. Defendants continue to manufacture, distribute, and offer for sale goods bearing the designation through retail channels reaching consumers nationwide. Each additional sale compounds the confusion in the marketplace and further erodess plaintiff's ability to be recognized as the sole source of her confessions of a showgirl brand. The harm brought to plaintiff's goodwill is not fully compensible through monetary damages.

[00:30:53]As a result, consumers encountering plaintiffs confessions of a showgirl mark, including through search engines and online platforms where defendants content now dominates results for plaintiff's mark, are likely to believe that plaintiff's services originate with, are affiliated with, or are authorized by defendants.

[00:31:15]The consequences of this reverse confusion have been felt by plaintiff directly. As a solo performer operating in the same entertainment space, she found herself having to navigate the wave of consumer attention defendants program had generated and attempting to maintain her presence in a conversation and a marketplace that defendants had overtaken.

[00:31:41]defendants use of the life of a showgirl backed by a substantial commercial infrastructure of Swift, TAS, UMG and Bravado and amplified through national brand collaborations reaching millions of consumers has threatened to overwhelm plaintiff's senior mark and to impair plaintiff's ability to control the identity and goodwill associated with her brand.

[00:32:06]The life of a showgirl is one designation among more than 170 active or pending trademark registrations managed by Swift uh sorry managed by defendant TAS on behalf of Swift spanning names, phrases and commercial designations across one of the most extensive trademark portfolios in the entertainment industry.

[00:32:31]defendants broader enterprise does not depend on the continued use of any single designation.

[00:32:38]By contrast, confessions of a show is the sole trademark under which plaintiff has built her professional identity for more than a decade. It is not one mark among hundreds. It is the only one she has. The continued erosion of that mark threatens the entirety of plaintiff's brand.

[00:33:00]Wow.

[00:33:03]I mean, that's fair enough. That's a really fair comment. Like, Taylor Swift has got all of this. She's got one thing and Taylor Swift is over here like trying to basically, you know, take authorship of it.

[00:33:22]Defendants adopted the life of a show girl with knowledge of plaintiff's federally registered mark. continued to expand their use after the USPTO refused their application on likelihood of confusion grounds and have at no point sought plaintiff's consent. Plaintiff is entitled to relief.

[00:33:43]Okay, so the first count is trademark infringement.

[00:33:48]Um, I won't go through all of the stuff that's reading because it's basically just kind of rehashing what was already been said in the main body.

[00:34:00]So, trade uh, [clears throat] count one, trademark infringement.

[00:34:07]Count two, false designation of origin and unfair competition.

[00:34:14]Count three, unfair competition.

[00:34:20]Okay. So, prayer for relief.

[00:34:24]Wherefore, plaintiff respectfully requests that the court enter judgment in her favor and against defendants as follows. for a permanent injunction pursuant to title 15 USC section 1116 in California business and professional code section 17203 in joining defendants and their officers, agents, servants, employees, attorneys, successors, assigns and all persons acting in concert or participation with them from using the life of a showgirl or any other mark confusingly similar to plaintiff's confessions of of a showgo mark as a trademark or other source identifying designation in connection with goods or services in a manner likely to cause confusion.

[00:35:14]Two, for a preliminary injunction during dependency of this action on the same terms as the permanent injunction described above, restrain independence from using the life of a showgirl or any confusingly similar designation as a trademark or source identifying designation in connection with goods or services pending final resolution of this matter.

[00:35:39]Three, for an order requiring defendants to cease and permanently discontinue all of the life of a shoga or any confusingly similar designation as a trademark or source identifying designation in connection with any goods or services.

[00:35:58]Four, for an encountment of all profits earned by defendants attributable to the use of a life of a show girl, or any confusingly similar designation, including profits derived from the sailor goods bearing that designation and other source identifying uses thereof pursuant to title 15 USC section 1117.

[00:36:26]Five, for an award of plaintiff's actual damages sustained as a result of defendants's unlawful conduct.

[00:36:33]Six, for treble damages where appropriate pursuant to title 15 USC section 1117.

[00:36:41]Seven, for restitution and equitable relief pursuant to California Business and Professional Code section 17203.

[00:36:50]Eight, for an award of plaintiff's costs of suit.

[00:36:55]Nine, for an award of attorney's fees pursuant to title 15 USC section 1117A on the ground that this is an exceptional case. And then 10 for such other and further relief as the court deems just and proper. And then there's a demand for jury trial for any for all issues that are triable.

[00:37:17]All right. Well, I thought that was really good. So now she has um she's also filed the motion for a preliminary injunction that is seeking to stop Taylor Swift from continuing the use whilst the this action is pending. So I'm going to go and read that in a separate video. And then Swift has responded um quite hard actually um to that request for preliminary injunction. So I will then do then an additional video with that.