Indiana Intellectual Property Law News
Photographer Morgan Howarth has filed a federal lawsuit in Indiana against Angie’s List Inc., doing business as Angi, alleging copyright infringement. The complaint accuses Angi of copying and distributing one of Howarth’s registered photographs without permission to promote its home services business online. The case centers on a single copyrighted image titled “1881_Nash_Glickman_Bath_Shower_2_f.jpg,” created in 2015 and registered in early 2016.
Howarth, a Washington, D.C.-based photographer with over 25 years of experience, claims the image was used without a license on Angi’s Home Advisor website. According to the suit, he discovered the unauthorized use in June 2024 and attempted to resolve the issue with Angi later that year, but those efforts were unsuccessful.
The complaint, however, contains several noticeable errors, suggesting it may have been compiled using a copy-and-paste approach—likely due to the high volume of similar lawsuits Howarth has filed. Over the past 21 years, he has initiated 133 federal cases, nearly all involving copyright infringement. This places him among a small group of photographers who regularly go to court to protect their creative work.
One glaring mistake appears in paragraph 22 of the complaint, where the placeholder text “Error! Reference source not found.” remains instead of a proper citation. This type of error typically occurs when content is copied from another document without properly updating the references, indicating a lack of thorough review before filing.
Another issue arises from a misstatement about Angi’s corporate status. The complaint identifies Angie’s List Inc. as an Indiana corporation, yet official business records show no such company exists in Indiana. In reality, Angi is incorporated in Delaware, though it maintains a substantial operational presence in Indiana. While this error might seem minor, it could lead to confusion about the proper legal entity being sued and raise questions about the court’s jurisdiction.
This marks the third time we’ve closely examined lawsuits filed by Howarth in Indiana, and a pattern is emerging. (Blog 1: Howarth v. My Sauna World LLC, Blog 2: Howarth v. Premier Aquascapes) He adopts a highly aggressive legal strategy, often targeting companies that use his architectural or interior design photographs without permission. However, with so many lawsuits filed, recurring errors suggest not every complaint receives the level of care and precision it should.
The case against Angi is expected to follow a familiar path: disputes over authorization, potential damages, and whether Howarth’s lengthy litigation history influences the court’s view of his claims. Regardless of the outcome, the lawsuit underscores ongoing tensions between content creators and commercial platforms over the digital use of creative work.
The case has been assigned to Judge Sarah Evans Barker and Magistrate Judge Mario Garcia in the U.S. District Court of Southern Indiana Case No. 1:25-cv-00969.