Page:Penguin Books v. New Christian Church of Full Endeavor.pdf/21

This page has been proofread, but needs to be validated.

Commencing in or before January of 1995, Defendants began to copy and print materials containing substantial verbatim quotations from the Course, which Defendants have distributed without charge, including the entire 488-page Workbook and a series of pamphlets containing significant portions of the Text arranged without commentary in a different order than appears in the Text. Defendants have also translated the Course into foreign languages. None of these activities were done with the authorization or consent of Plaintiffs.

FIP and FACIM were aware of Defendants' existence since 1985, and of Defendants' activities involving the Course since 1989. Plaintiffs did not become aware of Defendants' allegedly infringing activities, however, until early in 1995, at which point Plaintiffs requested that Defendants stop, and eventually sent Defendants a cease-and-desist letter. Defendants continued to copy and distribute substantial portions of the Course, however.

Defendants -- or members or students of the Church or Endeavor -- have posted, or have permitted the posting of, substantial portions of the Course and of the unpublished "Cayce" version on the internet, usually without any commentary or copyright legend.

21