Four models sue Worcester's Badoux Club over Facebook ads using their images

The complaint

Gibson v. JS Media Corporation d/b/a Badoux Club & Hookah Lounge, No. 4:26-cv-40251 (D. Mass.), is a 22-page complaint filed November 9, 2026, with a jury demand. The plaintiffs are Cielo Jean "CJ" Gibson of Los Angeles County, California, Claudia Sampedro of Miami-Dade County, Florida, Jessica Burciaga of Fulton County, Georgia, and Ursula Mayes of Orange County, California, whom the complaint describes as well-known professional models who earn their living by modeling and licensing their images. The defendant is JS Media Corporation, a Massachusetts corporation of Worcester, Massachusetts, which the complaint alleges, on information and belief, operates the Badoux Club & Hookah Lounge nightclub in Worcester.

What the models allege

The complaint alleges, on information and belief, that each plaintiff appears in a photo, attached as Exhibits A through D, that the club posted on its Facebook page to promote the club, and that each image was intentionally altered to make it appear that the model worked at, endorsed, or was affiliated with the club. It alleges that none of the plaintiffs ever worked for or endorsed the club, that none was asked for permission or paid, and that some images came from the models' own social media pages. It describes the club's business in general terms as a nightclub selling alcohol and food, and alleges that the false association harmed the models' reputations and deprived them of licensing fees that, according to the complaint, are usually negotiated for limited usage and terms.

The claims

The First Cause of Action alleges false association under Section 43(a)(1)(A) of the Lanham Act, 15 U.S.C. § 1125(a)(1)(A). The other nine causes of action allege Massachusetts common law right of privacy, unauthorized use of name, portrait, or picture under M.G.L. c. 214 § 3A, common law right of publicity, unfair trade practices under M.G.L. c. 93A § 11, defamation, negligence and respondeat superior, conversion, unjust enrichment, and quantum meruit.

Relief

The plaintiffs ask for actual damages, a permanent injunction against using their images to promote the club, punitive damages and treble damages under 15 U.S.C. § 1117, and attorneys' fees and costs under the same section. The First Cause of Action also asks for lost profits, disgorgement of the defendant's profits, and interest.

Docket

The complaint is the only entry on the docket, entered November 9, 2026, with exhibits, a civil cover sheet, and a category form.