Documents

Selected public records and redacted materials referenced throughout this archive.

This page is curated for relevance, not volume. It gathers a small set of records that define the present dispute: the federal docket, the filing concerning the website, an excerpt of the amended pleading, and an excerpt of the defendant’s principal motion. The docket reflects that the case was filed on November 5, 2025, that the First Amended Complaint was filed on November 20, 2025, that a notice regarding an undertaking concerning beggars.ai was filed on November 21, 2025, and that the case later moved into fuller motion practice through February 2026.

Federal docket / current posture

A short public record of Hemerlein v. Beggars Group Limited, No. 2:25-cv-04132-MTL. It shows the filing of the complaint, the early TRO proceedings, the filing of the First Amended Complaint, the notice regarding the undertaking concerning beggars.ai, the amended motion to dismiss, and the later briefing sequence through February 25, 2026.

Undertaking regarding Beggars.ai

A redacted copy of the undertaking filed in the federal action as part of the record concerning beggars.ai and compliance with the Court’s November 12, 2025 order. The docket reflects that this notice and its attached fully executed undertaking were filed on November 21, 2025.

First Amended Complaint

A redacted excerpt of the amended pleading setting out the core public theory of the site: that beggars.ai is used for commentary, criticism, and discussion of Defendant’s conduct, contracts, and industry practices; that Namecheap suspended implementation of the WIPO decision; and that Plaintiff seeks a declaration that the domain should remain registered to Plaintiff and not be transferred.

Defendant’s corrected motion to dismiss and motion to strike (Doc. 27)

A redacted excerpt of Beggars’ principal merits filing. It states Beggars’ position that the contract-related claims belong in the U.K. under the forum-selection clause, that Beggars was not a party to the recording agreement, that the claims are time-barred, and that the amended complaint should be struck for failure to comply with local formatting rules.

Additional filings :

Request for Judicial Notice (Doc. 38)

A filing presenting public-record materials relevant to the motion to dismiss and the broader record concerning Beggars, 4AD, and the dispute.

Reply in support of Request for Judicial Notice (Doc. 42)

A later filing completing the RJN briefing and clarifying why those public materials matter.

Why these documents?

Together, these records show the shape of the live dispute: a pending federal action, a website-centered domain fight, Plaintiff’s claim that beggars.ai is protected commentary and criticism, and Defendant’s effort to narrow or dismiss the case.

Current note :

This page will remain selective. Additional records may be added as appropriate while the dispute remains live. These are redacted public filings and related records posted for documentary and archival purposes. Allegations and arguments remain subject to dispute and adjudication

Independent artist-run archive and commentary site.
Not affiliated with Beggars Group Limited or any of its labels.
Where issues remain contested, they are identified as disputed.