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Executive Lens LLC v. Rapkin – Complaint (N.D. Cal. 25-cv-06048-NC)

On July 17, 2025, Executive Lens LLC filed a complaint in the U.S. District Court for the Northern District of California against attorney Lee Rapkin and John Doe d/b/a “The Exposer,” operator of the YouTube channel 1A Audits Exposé. The suit alleges misrepresentation under 17 U.S.C. § 512(f) and seeks declaratory relief for copyright infringement.

According to the complaint, Rapkin, admitted to the Quebec bar in 2024, submitted a blanket DMCA counter-notice on behalf of the Exposer covering 17 videos, including 16 YouTube Shorts and one long-form video. The filing asserts that many of these videos contained no commentary at all, while others included only token pop-culture clips, undermining Rapkin’s sworn claim that they were “significantly transformed by detailed editing and elaborate commentary.” Executive Lens contends the Exposer’s channel monetizes Auditor footage without transformation, disguising infringement as “fair use”.