So, here's an update, with teh email thread!
Dear Sirs
Thank you for you email which I find somewhat curious. Before proceeding, I note that you email states:
“……we have been informed that ********* is likely using an image without permission and the client has exclusively commissioned us with the clarification, administration of the image rights for the territory of the Federal Republic of Germany….”
It goes on to claim that the holder of the image rights is “CONCEPT-PRODUCTION”, but provides no proof/evidence
To that extent I need to see proof that “CONCEPT-PRODUCTION” do indeed hold the image rights for this picture before submitting any information to you on the basis of nothing more than a “claim” that something “might” be wrong, where you haven’t named who the claimant is.
I would also need the original file name, as all our images are stored under that, so I need to file name to conduct a search.
As soon as you have provided all the required information I will expedite our relevant details.
Yours faithfully
CT:
Dear Sir or Madam,
Thank you very much for your message. We have now requested the necessary documents from our client and will get back to you as soon as we receive them.
We appreciate your patience in this matter.
So they didn't have the docs - followed by a week later with:
We would like to inform you that we have obtained the necessary documents confirming our client's ownership of the copyrighted materials, as well as the confirmation of the assignment. You can see them attached below.
We appreciate your cooperation in this matter and hope to resolve it in an amicable manner. Please be advised that payment of the compensation can be made via the following link: portal.copytrack.com by entering your case ID NNNNNNN
Failure to do so may result in legal action being taken against you.
Our response:
Thank you for confirming the image is by V******* (aka a ********),we are always careful to ensure content creators are properly remunerated for their work. That said, you have not supplied evidence I requested that V******* has engaged Concept Productions. You have merely sent me an internally produced digitally signed “confirmation of ownership“ claim from E***** D*****, with an address in France, who then claims to be a “PROD MANAGER for FOTOLIA STOCK ACQ” a Company that ceased trading in November 2019. However, E***** D*****works for Concept Productions
https://concept-production.com/ -
[then the name]
I still need to see the evidence that V********* has engaged Concept Productions. If you cannot supply the evidence within 7 days, I will consider that you have dropped the spurious, possibly vexatious claim. However, should you wish to proceed to court as E***** D***** threatens, then I look forward to hearing the explanation of the apparent fraud conducted by signing the internally produced document you have signing as an employee of a company that no longer exists and we will vigorously defend our position.
CT:
Thank you for your message
However, the documents, that we have provided you with my previous email, serve as valid confirmation of our client's rightful ownership and authorization over the said images.
[and repetition]
US:
Thank you for your email. As you can imagine we need to be very careful in respect of the number of phishing attempts that are made nowadays and therefore we have to ensure all unexpected/unusual requests are valid. We are sure you will hold the same views on Internet safety. However, we remain co-operative and hope that is mutual.
In that context, we find it rather curious that you seem to imply we are being anything but amenable, rather than carefully gathering actual facts. Further we find that the suggestion that we are not acting amenably and threatening legal action while we are attempting to establish facts, are examples of behaviours we would expect of those with less than good intent, though we are not implying that in this is the case in any way. Rest assured we will continue to act cooperatively but reiterate we do need facts and proof of the claims you are making. Proof is not an internally produced document post our request.
We note you request we review the document you sent carefully. We did when you sent it and that is why we asked for further evidence as what you claim is evidence isn’t, it is just a claim. I suggest you read our previous response in more detail and provide the factual evidence we asked, very politely, for. The concerns are set out once again below for ease.
You letter, which claims to be proof:
[Image]
comes from E**** D**** of Concept Productions.
The same person then signs (electronically, so technically anyone could do this), as:
[Image]
E***** is now (on the same page) a product manager for a company that ceased to exist several years ago, that doesn’t seem right and is clearly worthy of an explanation. We fully appreciate that he might have two jobs, but not for a company that doesn’t exist. The claim is also dated after our request for information on 26 Sep, so has clearly been created in response our request. In other words, it did not exist at the time you first approached us. We find this timeline and multiple use of the same person troubling and consistent with malicious actors, though there may well be a reasonable explanation. We just need to have it.
Additionally, E****** is not V*******. There is no documentation from V******* confirming the rights of the Concept Productions to act for V******* and Internet reviews that there are no actual checks made of the validity of such claims in your process. We requested this on 26 September and feel certain you would have definitive proof (by way of signature) of her empowering Concept Productions to act on her behalf, that predates that request.
The letter is further addressed by:
[Image]
Which we understand is the third rebrand of Copy Track. This again is an example of a degree of obfuscation frequently used by illegitimate actors. Again, your actions may be completely legitimate, but in the online world, you would surely expect us to make appropriate checks before passing information over.
Now on to your claim itself, which is in two parts:
1. €374.50 for a one year licence. This is for an image that if we needed to buy is available for £1.90 (Adobe Stock subscription) for a lifetime licence. Alternatively, it is available as a free download as part of a trial on other sites. Were we to be in need of an ongoing licence, the cost is next to nothing or we could just use a different image. Therefore, this seems to be a somewhat exaggerated and excessive claim.
2. As for the €350 claim for past use, were this to apply, damages are limited to the lost licencing fee which is defined as what the infringer would have paid for a license to use the image (£1.90) or the actual damages suffered by the copyright owner, including lost profits (£1.90 less the adobe stock or similar fee) and harm to the work's value (£0). Your claim, were it valid, is therefore highly excessive.
So, we reiterate, please provide the factual evidence requested rather than internally produced documents by 14 October and we will gladly provide the additional information we have as we will continue to vigorously defend our position.
CT:
Dear Sir or Madam,
As the domain owner, you are responsible for the content posted on your platform. We have discovered the usage of copyrighted materials, likely resulting in significant damages to our client.
If you possess a valid license or authorization for the materials, kindly provide proof of permission, such as an invoice from the Agency or written permission indicating the image's authorized use.
If you are unable to provide the required proof, we insist on immediate compensation to our client. Payment can be securely processed using your unique Case ID through this link:
https://portal.copytrack.com/.
We hope for an amicable resolution. However, non-cooperation may necessitate involving our partner lawyers, leading to higher settlement costs. Our goal is to achieve fairness while protecting our client's rights and interests.
For any clarifications or payment discussions, please contact me within this email conversation.
US:
We continue to be amicable and very much hope you can provide the evidence we have asked for in our e-mail of 9th October 2025. If you possess a valid authorization from the artist, kindly provide proof of permission as we have requested several times, without success. That should be simple, otherwise you/Concept Productions are just making a claim for which you have yet to show validity. Once we have that we will of course continue assist as you request. Until then the threat of legal action, which we will defend vigorously.
However, being as damages are limited to the loss by the artist, your continued use of the words “significant damages” is at best an exaggeration.
As such, we would also like an explanation how one man can have two different jobs, one for a company that no longer exists, and why signing for such is above board and constitutes “the proof” you claim it to be..
CT:
Thank you for your message However, as I mentioned before we can not close the case without a proof of valid license.
Please be reminded that if you do not wish to cooperate we will be forced to hand this case over to our partners, and they will take further actions. It will also lead to higher settlement costs.
US:
We do wish to cooperate and we believe have done so, apart from asking for reasonable evidence. We will continue to cooperate when you send us proof that Concept Productions have a signed contract with the artist, that can be verified. We cannot send you the details you request without such proof, particularly given the ambiguity presented by an individual claiming two jobs, one for a company that has not existed for several years. We trust you will now cooperate.
Can we remind you that damages are limited to the loss for the artist, which by our records amounts to £1.90, especially as we have continued to try to work with you, while you have continually failed to send the proof from the artist requested. We will continue to work with you, but feel that if you had such proof, you could have supplied it by now and will do so by return. Internal documents produced after the event do not contribute proof and we will vigorously hold and defend that position.
CT (my highlights):
As outlined in our previous communication, our client holds rights to the image in question. We have provided evidence.
Thus, any usage of their images without explicit authorization is a violation of their copyright.
We must insist on compensation for the past unauthorized usage. Should you be unable to provide evidence of a valid license or written permission to use these images, we will have no choice but to escalate it to our partner lawyers for further action.
Thank you for your attention to this matter.
Please let me know if you would require more information in this case, or a draft of the settlement agreement so we can close this case promptly.
US:
You have continued to state that your client (Concept Productions) holds the right to that image but yet not provided the proof we have asked for. Please confirm whether they hold the Intellectual Property rights of V********’s image and provide a signed document from V*********, rather than the internally signed claim produced after our request.
As for your insistence on compensation for past use, this is limited to the rights owner being put in the in the position they would have been, had the infringement not occurred. Therefore, your claim for €350 is totally exaggerated even if it was to be valid.
You then ask if we require “require more information in this case”. We have asked for you to provided signed documentation from V******** which you have not yet done, just the internally produced documentation from Concept Productions.
We remain eager to conduct discussions amicably and help resolve the case, we are just waiting for one piece of evidence, that you surely collected prior to engaging in the reverse search? Once you have provided such a document we will gladly move forward.
CT:
Thank you for your message.
Unfortunately, we are not able to close a case without one of the following conditions being fulfilled:
1. A proof of valid license.
2. The compensation to our client is paid.
If you do not have a license, and you understand that not settling with us will consequently lead to court and you would like to have a chance to settle with us, please also go onto the link
https://portal.copytrack.com/ by entering your case is and choose ‘NO’ for having the license question then proceed further with the steps.
US:
We continue to be helpful and you continue not to supply the one document we've asked for. We are unable to close our side until you do, but are starting to think that perhaps you don't have the document requested and that your claim is nothing but specious, particularly as the damages you are claiming are hugely excessive and exaggerated.
You have offered to assist if we need more information, we have repeatedly asked for the same one document of proof. When supplied we will be able to proceed to assist you.
As for your ongoing threat of court action, which we will vigorously defend, the IPEC small claims will look at our very reasonable request for the document we have asked for and how we have continued to offer to cooperate and are unlikely to be sympathetic to your case. Provide the proof requested and we can look to close the case.
Failure to provide implies you don't have the rights you claim
CT:
Our position on this matter remains the same.
US:
I don’t think we ever asked you to change your position merely to submit proof, which despite being asked several times that you have proof dated before you contacted us, that V********* had engaged Concept Productions. We would suggest that if this documentation exists it would be a simple process to forward a copy. The greater the prevarication, the more we are likely to be suspicious of the approach. I am sure that as an organisation “policing” the internet you would totally support our request for confirmation. We’d also like an explanation as to how E******* D******* can represent a company on the 19th of September 2025 that ceased to exist when it was acquired by Adobe Stock, several years ago.
As we have stated all along, we will gladly help you get to the bottom of your claim once you provide the evidence we have asked for. To that extent nor has our position not changed either, we remain entirely willing to help and will defend this entirely reasonable position vigorously
CT:
I hope this email finds you well.
As outlined in our previous communication, our client holds rights to the image in question. We have provided evidence.
Thus, any usage of their images without explicit authorization is a violation of their copyright.
We must insist on compensation for the past unauthorized usage. Should you be unable to provide evidence of a valid license or written permission to use these images, we will have no choice but to escalate it to our partner lawyers for further action.
Thank you for your attention to this matter. Please let me know if you would require more information in this case, or a draft of the settlement agreement so we can close this case promptly.
US:
As ever we stand by to assist when we have proof that you client hold the rights rather than merely your client’s assertion. By proof we would expect this to be the artist’s signature (and not just the assertion you claim is proof from your client’s employee) and an explanation of how that employee can be both an employee of your client while holding a position of a company that ceased trading on 5 November 2019, a claim which on the surface seems somewhat impossible.
As for compensation costs for past usage of 350.00 €. You state “We calculate these fees based on our client's license history, as well as the duration of use and type of rights infringement“. Given the current licence fee for said image starts at £1.90 it’s a curious calculation that arrives at €350! In any case, compensation doesn’t quite work like that in the IPEC small claims track. In this case compensation is limited to the artist bringing a case and being put in the in the position they would have been, had the infringement not occurred - if indeed there was an infringement. Therefore, your claim for €350 is totally exaggerated even if it was to be valid.
We reiterate that we are more than willing to work with you to resolve the issue you raise once we have proof of the validity of your claim, bearing in mind the date of the alleged unlicenced use and the date you claim to have acquired the rights. This should be a document that predates your initial contact and before the date of the alleged unlicenced use as your client doesn’t even claim to have the rights at that time. We too would like to expedite closure, so feel that if you are not able to provide such evidence by the end of the month then it seems reasonable that you don’t have such evidence. I would suggest that any further correspondence from you other providing the proof we as asking very politely for, would be nugatory as we cannot proceed without such unequivocal proof. Indeed, one might consider any missive going forward that does not provide such proof are vexatious and we will defend our position most vigorously.
CT:
Our client has suffered damages due to your unauthorized use of their copyrighted material. By law, you are required to pay the photographer damages for previous use of the image.
Copytrack represents the copyright owner of this image .Our client, the photographer, holds the exclusive rights to this image, and as the copyright owner, they are entitled to seek damages for the unauthorized use of their work. Regarding the sum of 350 euros, this amount represents Copytrack's standard fee for the unauthorized use of copyrighted material. We have now requested the necessary documents from our client and will get back to you as soon as we receive them.
[My comment - note the use of the photographer holding teh rights and not Concept Productions
Thank you for this and confirming that you currently don’t have the documentation from the artist. I think you will agree were we quite right to question the paper trail, but we had hoped you already had this so we could have concluded the issue in October. It is curious that you were making a claim without the necessary paperwork, so as we suspected merely on the assertation of E***** D*******. We look forward to examining what you provide going forward.
It still remains, therefore, just an assertion that you client has suffered. And to be specific your client hasn’t suffered “damages”, but if your assertion is to be believed, “loss or injury”. The remedy for this is “damages” and in the IEPC small claims division, damages are limited to returning the injured party to the state they would have been in if the injury or loss hadn’t occurred (if it did) unless it has been wilful or caused ill-repute (or similar) or we had been deliberately uncooperative – none of these reasons seem remotely likely. I would contend and vigorously defend the position that since you first contacted us, we have been nothing but co-operative, we just been asking for the clarification you finally offered to procure today. Yet even today you haven’t provided the information, implying you don’t have it. May I also remind you the cost of a licence for the said image, (and therefore the amount of “damages” to return the artist to the position they would have been had the loss or injury not occurred), is £1.90.
Regarding the sum of 350 euros representing “Copytrack's standard fee for the unauthorized use of copyrighted material”. It would be interesting to see how that fee is made up, not least your currently unsubstantiated claim has put us to considerable work responding to a plethora of emails where you didn’t answer our very reasonable questions about proof from the artist, meaning we have been incurring costs that we would not have done had you actually had the proof and explanations we very reasonably asked for as we continue to co-operate.
Even now you haven’t answered our request for clarification as to how a member of staff from Concept Productions was simultaneously a member of staff from a for a company that ceased trading 6 years ago tomorrow. Whilst I am sure this is merely an oversight, many might see the inability to respond as a sign that it cannot, in fact, be explained and further raise the suspicion of your claim. To that extent we will need an explanation for how someone signs a claim on behalf of a company that has ceased to exist.
CT (no longer an individual but the legal department!:
Thank you for your message.
As we are interested in solving this matter amicably with you, our client is willing to offer you a settlement payment of 200 EUR to cover the compensation costs for your copyright infringement. This is the maximum we can offer.
The reduced compensation costs can be paid securely at
https://portal.copytrack.com/ by entering your case ID NNNNNN. Once you have made the payment, we can close your copyright infringement case.
Copytrack GmbH has officially been renamed to RD Legal GmbH. We kindly ask you to use the new company name, especially for all future bank transfers.
US
Dear Legal Department.
Thank you for your offer, it would certainly be worth considering if we had infringed copyright but first, let’s examine your email and the claims made within it, as we wouldn’t want to dismiss your kind offer.
Firstly, it seems A******* has had no joy in trying to pressure us, so passes it to the “Legal Department”, presumably as that sounds more threatening. But as you cannot produce the documentation we have very reasonably asked for from the start, you reduce your claim hoping you won’t need to answer our legitimate clarifications. However, that reduced claim is now for compensation, which is limited at the IPEC to restoring the artist to the position they would have been in had the “infringement” (if indeed there was one) not occurred – approximately £1.90 (about €2.16).
But you have yet to prove Concept Productions (your client) or CopyTrack have the rights to pursue such an unproven claim. As you cannot provide proof that the right was passed to them by the artist prior to your initial approach almost two months ago – we have to assume you don’t have it as in your last email you admitted to having to go and get it. Nor have you explained how a known Concept Productions employee was simultaneously a Product manager for a business that ceased trading over six years ago. On this our very reasonable position has not changed, we will gladly help as and when you provide the proof we have asked for.
Further, your previous emails explained that the €350 fee was, and I quote, “Copytrack's standard fee for the unauthorized use of copyrighted material”. Yet you now claim your client, (Concept Productions), is willing to reduce the payment for an as yet unproven claim of an unproven right. So, on the one hand in your previous emails you claim a few euros for the licence that you have yet to prove was held by Concept Productions plus €350 for CopyTrack’s standard fee – yet somehow or other it seems Concept Productions (who claim but have yet to prove they hold the rights) have increased their demand from a few euros to €200 and CopyTrack have reduced their standard fee to zero. To that extent we are totally confused, as it seems you may be, as your claims and rationale change regularly. However, on the basis that you say your client has reduced their claim we therefore accept the reduction of CopyTrack’s claim to zero! Thank you.
That leaves the unproven claim for the as yet unproven lack of licence. I can assure you there is a valid licence for the image, the artist has most definitely been compensated, as we agree they should be, for the full amount of the licence. When you can both explain how someone can sign a document this year as an employee of a company that ceased trading 6 years ago, explaining how this legal and show proof that the artist passed the right on to your client, we will gladly share the details of the licence.
In the meantime, as you are a legal organisation focused on policing aspects of the internet, I am sure you will agree we are right to seeking clarification in a world where one needs to be increasingly careful of giving away information to anyone who makes, as yet, unsubstantiated claims.
As an aside, you state in your email that you have legally changed your name to RD Legal GmbH, yet sign the same email as the “Legal Department, COPYTRACK”. Again, I hope you can see why we continue to need the very reasonable and completely consistent clarification we ask for as we continue to be as cooperative as we can be; we just need you to confirm the details we have asked for.
CT:
Thank you for your message
However, as I mentioned before we can not lower the compensation in this case more.
Please be reminded that discounted offer will expire within the next 7 days, and then we will be forced to hand this case over to our partners, and they will take further actions. It will also lead to higher settlement costs, since the discounted offer will expire
US:
Dear legal department,
Throughout we have been consistently offering to resolve this issue once you provide the evidence we need. Namely, proof the artist signed over the rights to the image to Concept Productions and an explanation of how E****** D****** signed a legal document as the product manager for a company that ceased trading 6 years ago whilst also signing as an employee of concept productions.
In a previous response, you even said you were going to ask the artist for such proof, which you have yet to produce. However, you have never addressed the latter. As we have said all along, without such proof, we cannot proceed. It is our conclusion that after two months of not providing them, you do not have them, else you would be willing to share them.
You then stated that of the amount you originally claimed, €350 was Copy Track's standard fee, yet then went on to state that your client, Concept Productions, was prepared to reduce the claim to €200. We now need an explanation as to how your client can reduce your standard fee.
We have never asked for a reduction, but accepted CopyTrack's offer to reduce their fee to zero whilst expressing surprise that the Concept Productions was increasing their demands from a few euros to €200, for a licence that can be purchased for £1.90. We have merely pointed out that compensation due at the IPEC would only cover returning the artist to the position they would have been in if a breach hadn't occurred, if indeed it had. We also assert that there is a fully paid-up licence for this image, so the artist is fully remunerated.
Overall, it strikes us that despite our unwavering offer to help resolve your query, you:
1. Don't read the replies we send
2. If you do, you don't understand them, which we find curious, or
3. You ignore what we say and stick to your script.
Whilst we yet again offer to assist, we need:
1. Proof (not just assertions) that the artist signed over rights to your client Concept Productions.
2. An explanation of how E***** D***** was able to sign a legal declaration as the product manager for a company that ceased trading 6 years ago in a way that no offence was committed at the time of that signature
3. An understanding of how your client, Concept Productions was able to offer a reduction to your standard fees, when their claim is for the licence.
Provide these and we will gladly assist further. Without such evidence and explanation from you, we may have to conclude any other response is somewhat vexatious and you are conducting something of a fishing expedition, bordering on bullying, as many internet forums discussing Copy Track suggest.
To be clear, we have always offered to assist, and continue to do so. It seems you are unable to offer the additional documentation we seek to clarify your many inconsistencies in order to be able to help. To that extent, we will continue to vigorously defend our position but we do need the information requested to move forward.
CT:
Thank you for your message.
We have received the payment and the case is closed.
Thank you for your kind cooperation
For the avoidance of doubt, WE did not pay!!! Dare I suggest they ended up deciding they were on a hiding to nothing
I am tempted to go back to them and ask who paid (no one) and submit an invoice for the vexatious communications as they clearly didn't have the documents we asked for, they created another and got a guy to sign what appears to be a fraudulent claim, namely being a product manager for an extinct company. Nor did they have an explanation for their client reducing the CT fee!
