While developing Call of Duty: Modern Warfare, these companies hired Alex Zedra to help create a “strong, skilled female fighter” for the game. Furthermore, Haugen claims they also asked her to obtain the same clothing and gear used in the Cade Janus photoshoot.
The same makeup artist for the Cade Janus shoots was also hired and was instructed to not only recreate the look, but even use “the same hair extension piece.” Haugen also claims the original photographs were posted to “the wall of the studio” and “were used as a framing guide before the model was 3D scanned.”
“To conceal their planned infringement of Haugen’s Cade Janus Photographs and his Cade Janus character, Defendants required the talent and the makeup professional to sign Non-Disclosure Agreements,” the complaint notes. “The resulting photographs were intended to be, and were, copies of Haugen’s Cade Janus Photographs.”
Not only were the resulting photographs and 3D images used to develop the character known as Mara, they were also “deployed as key assets in Modern Warfare’s marketing campaign.”“Haugen is entitled to recover all monetary remedies from Defendants’ infringement, including all of their profits attributable to their infringements, to the full extent permitted by 17 U.S.C. § 504,” the complaint concludes, demanding a trial by jury.
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