7. ...Defendant Quality Restaurant Concepts, LLC is an Alabama limited liability company... that operates at least two eating and drinking establishment in Tennessee, each under the name “Applebee’s”.
19. Bob Eaton d/b/a Night Train Karaoke previously worked as KJ at Defendant’s restaurants at two or more locations.
Declaration of Bob Eaton, Averments 5-6.37. KJ Bob Eaton (d/b/a Night Train Karaoke) (a/k/a Robert Eaton) loaded his computer with downloaded Chartbuster brand digital files from William Marston (KJ Bill).
Declaration of Bob Eaton, Averment 4.39. According to an audit performed on a true copy of the hard disk drive provided by Sword & Shield which forensically mirrored the hard drive of the computer which Bob Eaton used on the nights of October 4, 2012 and October 11, 2012 at Defendant’s restaurants, Bob Eaton’s computer hard drive included no fewer than 5,429 Chartbuster brand songs, none of which were properly licensed from Plaintiffs.
Declaration of David Grimes, Averment 18.40. Therefore, the digital karaoke song files plus associated graphics on KJ Bob Eaton’s computer were necessarily pirated, and such trademarks shown in the graphics were necessarily counterfeit because they originated from an unlicensed third-party, namely, William Marston (KJ Bill).
72. Accordingly, Defendant is vicariously liable for the copyright and trademark infringement complained of herein, even if they did not own, possess or play the infringing karaoke.
http://www.scribd.com/doc/241253124/Wor ... ntertainmeAnd The Hits Keep On Coming! 
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