Pablo Star v. Welsh Government - Just Married photo copyright complaint.pdf

77
JS 44C/SDNY REV. 4/2014 CIVIL COVER SHEET The JS-44 civil coversheet and the information contained herein neitherreplace norsupplementthe filing and service of pleadings or other papers as required by law, except as provided by local rules ofcourt. This form, approved by the Judicial Conference ofthe United States inSeptember 1974, is required foruse ofthe Clerk of Courtfor the purposeof initiating the civil docket sheet. DEFENDANTsL O ^ * 11 V„f ' The Welsh Government; Gracenote (d/b/a TribuneMedia Service); Pittsburgh Post-Gazette; E.W. Scripps, Co.; Colorado New Feed; Travel Squire; Richmond Times Dispatch; and Miami Herald Media Co., PLAINTIFFS Pablo Star Ltd. ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER Nelson & McCulloch, 155 East 56th Street, New York, New York 10022 646-704-4900 ATTORNEYS (IF KNOWN) CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OF CAUSE) (DO NOTCITEJURISDICTIONAL STATUTES UNLESS DIVERSITY) Copyright infringement, 17 U.S.C. §§101, etseq. Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? NrJZVesQjudge Previoujltfj&s^igned Ifyes, was this case Vol. Invol. Dismissed. No Yes If yes, give date SCaseNo.. IS THIS AN INTERNATIONAL ARBITRATION CASE? (PLACE AN [x] INONEBOXONLY) TORTS No Yes NATURE OF SUIT ACTIONS UNDER STATUTES F£ffT8 2014 CONTRACT PERSONAL INJURY PERSONAL INJURY [ ] 367 HEALTHCARE/ FORFEITURE/PENALTY BANKRUPTCY OTHERSTATUTES [ ] 375 FALSE CLAIMS [ ] 110 INSURANCE [ ] 310 AIRPLANE PHARMACEUTICAL PERSONAL [ ] 625 DRUG RELATED [ ] 422 APPEAL tJ400 STATE [ ]120 MARINE [ ] 315 AIRPLANE PRODUCT INJURY/PRODUCT LIABILITY SEIZURE OF PROPERTY 28 USC 158 REAPPORTIONMENT [ ] 130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY 21 USC 881 [ ] 423 WITHDRAWAL ( ] 410 ANTITRUST 1 1140 NEGOTIABLE INSTRUMENT [ ] 320 ASSAULT, LIBEL& SLANDER PRODUCT LIABILITY [ ] 368 ASBESTOS PERSONAL [ ] 690 OTHER 28 USC 157 [j 430 BANKS &BANKING [ ] 450 COMMERCE [ ]150 RECOVERY OF [ ] 330 FEDERAL INJURY PRODUCT [ ] 460 DEPORTATION OVERPAYMENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS [ ] 470 RACKETEER INFLU ENFORCEMENT LIABILITY ENCED & CORRUPT OF JUDGMENT [ ] 340 MARINE PERSONAL PROPERTY (XI 820 COPYRIGHTS ORGANIZATION ACT [ 1151 MEDICARE ACT [ ] 345 MARINEPRODUCT [ J 830 PATENT (RICO) [ ] 152 RECOVERY OF LIABILITY [ J 370 OTHER FRAUD [j 840 TRADEMARK [ ]480 CONSUMER CREDIT DEFAULTED [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING [ ] 490 CABLE/SATELLITE TV STUDENT LOANS [ ] 355 MOTOR VEHICLE (EXCL VETERANS) PRODUCT LIABILITY SOCIAL SECURITY [ ] 850 SECURITIES/ [ ]153 RECOVERY OF [ ] 360 OTHER PERSONAL COMMODITIES/ OVERPAYMENT INJURY [ ] 380 OTHER PERSONAL LABOR [ ]861 HIA(1395ff) EXCHANGE OF VETERAN'S [ ] 362 PERSONAL INJURY - PROPERTY DAMAGE [ ] 862 BLACKLUNG (923) BENEFITS MED MALPRACTICE [ ] 385 PROPERTY DAMAGE [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g)) I ]160 STOCKHOLDERS PRODUCT LIABILITY STANDARDS ACT [ ] 864 SSID TITLE XVI SUITS [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g)) [ ] 890 OTHER STATUTORY I ]190 OTHER PRISONER PETITIONS RELATIONS ACTIONS CONTRACT [ ] 463 ALIEN DETAINEE [ ] 740 RAILWAY LABORACT [ ] 891 AGRICULTURAL ACTS I 1195 CONTRACT [ ] 510 MOTIONS TO [] 751 FAMILYMEDICAL FEDERAL TAX SUITS PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE LEAVE ACT (FMLA) LIABILITY 28 USC 2255 [ ] 870 TAXES (U.S Plaintiff or [ ] 893 ENVIRONMENTAL [ ] 196 FRANCHISE CIVIL RIGHTS [ ] 530 HABEASCORPUS [ ] 790 OTHER LABOR Defendant) MATTERS [] 535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY [ ] 895 FREEDOM OF REAL PROPERTY [ ] 440 OTHER CIVILRIGHTS (Non-Prisoner) [ ] 540 MANDAMUS & OTHER [ ] 791 EMPL RET INC SECURITY ACT 26 USC 7609 INFORMATION ACT [ ] 896 ARBITRATION [ ] 899 ADMINISTRATIVE [ ] 441 VOTING IMMIGRATION PROCEDURE ACT/REVIEW OR []210 LAND CONDEMNATION [ ] 442 EMPLOYMENT [ ] 443 HOUSING/ PRISONER CIVIL RIGHTS [ ] 462 NATURALIZATION APPEAL OF AGENCY DECISION [ ]220 FORECLOSURE ACCOMMODATIONS [ ] 550 CIVILRIGHTS APPLICATION [ ] 950 CONSTITUTIONALITY OF [ ]230 RENT LEASE & [ ] 445 AMERICANS WITH [ ] 555 PRISON CONDITION [ ] 465 OTHER IMMIGRATION STATE STATUTES EJECTMENT DISABILITIES - [ ] 560 CIVIL DETAINEE ACTIONS [ ]240 TORTS TO LAND EMPLOYMENT CONDITIONS OF CONFINEMENT [ ]245 TORT PRODUCT LIABILITY [ ] 446 AMERICANS WITH DISABILITIES -OTHEF [ ]290 ALL OTHER REAL PROPERTY [ ] 448 EDUCATION Checkif demanded in complaint: CHECK IF THIS IS ACLASS ACTION UNDER F.R.C.P. 23 DEMAND $_ OTHER Check YES onlyif demanded in complainf JURY DEMAND: HIYES LKlO DC,i YOU CLAJM THIS CASE IS RELATED TOA CIVIL CASE NOW PENDING IN S.D.N.Y.? JUDGE DOCKET NUMBER NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).

Transcript of Pablo Star v. Welsh Government - Just Married photo copyright complaint.pdf

Page 1: Pablo Star v. Welsh Government - Just Married photo copyright complaint.pdf

JS 44C/SDNY

REV. 4/2014

CIVIL COVER SHEET

TheJS-44 civil coversheet and the information contained herein neitherreplacenorsupplementthe filing and serviceofpleadings orother papers as required by law, except as provided by local rules ofcourt. This form, approved by theJudicial Conference ofthe United States inSeptember 1974, is required foruse ofthe Clerk ofCourtfor the purposeofinitiating the civil docket sheet.

DEFENDANTsL O ^ * 11 V„f 'The Welsh Government; Gracenote (d/b/a TribuneMedia Service); PittsburghPost-Gazette; E.W. Scripps, Co.; Colorado New Feed; Travel Squire;Richmond Times Dispatch; and Miami Herald Media Co.,

PLAINTIFFSPablo Star Ltd.

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBERNelson & McCulloch, 155 East 56th Street, New York, New York 10022646-704-4900

ATTORNEYS (IF KNOWN)

CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OFCAUSE)(DO NOTCITEJURISDICTIONAL STATUTES UNLESS DIVERSITY)

Copyright infringement, 17 U.S.C. §§101, etseq.

Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? NrJZVesQjudge Previoujltfj&s^igned

Ifyes, was this case Vol. • Invol. • Dismissed. No • Yes • If yes, give date SCaseNo..

IS THIS AN INTERNATIONAL ARBITRATION CASE?

(PLACE AN [x] INONEBOXONLY)

TORTS

No • Yes •

NATURE OF SUIT

ACTIONS UNDER STATUTES

F£ffT8 2014

CONTRACT PERSONAL INJURY PERSONAL INJURY[ ] 367 HEALTHCARE/

FORFEITURE/PENALTY BANKRUPTCY OTHERSTATUTES

[ ] 375 FALSE CLAIMS[ ] 110 INSURANCE [ ] 310 AIRPLANE PHARMACEUTICAL PERSONAL [ ] 625 DRUG RELATED [ ] 422 APPEAL t J400 STATE[ ]120 MARINE [ ] 315 AIRPLANE PRODUCT INJURY/PRODUCT LIABILITY

SEIZURE OF PROPERTY 28 USC 158 REAPPORTIONMENT

[ ] 130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY 21 USC 881[ ] 423 WITHDRAWAL ( ] 410 ANTITRUST

1 1140 NEGOTIABLE

INSTRUMENT

[ ] 320 ASSAULT, LIBEL&SLANDER

PRODUCT LIABILITY

[ ] 368 ASBESTOS PERSONAL[ ] 690 OTHER

28 USC 157 [ j430 BANKS &BANKING[ ] 450 COMMERCE

[ ]150 RECOVERY OF [ ] 330 FEDERAL INJURY PRODUCT [ ] 460 DEPORTATIONOVERPAYMENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS [ ] 470 RACKETEER INFLUENFORCEMENT LIABILITY ENCED & CORRUPT

OF JUDGMENT [ ] 340 MARINE PERSONAL PROPERTY (XI820 COPYRIGHTS ORGANIZATION ACT

[ 1151 MEDICARE ACT [ ] 345 MARINEPRODUCT [ J 830 PATENT (RICO)

[ ] 152 RECOVERY OF LIABILITY [ J 370 OTHER FRAUD [ j840 TRADEMARK [ ]480 CONSUMER CREDITDEFAULTED [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING [ ] 490 CABLE/SATELLITE TV

STUDENT LOANS [ ] 355 MOTOR VEHICLE(EXCLVETERANS) PRODUCT LIABILITY SOCIAL SECURITY [ ] 850 SECURITIES/

[ ]153 RECOVERY OF [ ] 360 OTHER PERSONAL COMMODITIES/

OVERPAYMENT INJURY [ ] 380 OTHER PERSONAL LABOR [ ]861 HIA(1395ff) EXCHANGE

OF VETERAN'S [ ] 362 PERSONAL INJURY - PROPERTY DAMAGE [ ] 862 BLACKLUNG (923)BENEFITS MED MALPRACTICE [ ] 385 PROPERTY DAMAGE [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g))

I ]160 STOCKHOLDERS PRODUCT LIABILITY STANDARDS ACT [ ] 864 SSID TITLE XVISUITS [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g)) [ ] 890 OTHER STATUTORY

I ]190 OTHER PRISONER PETITIONS RELATIONS ACTIONS

CONTRACT [ ] 463 ALIEN DETAINEE [ ] 740 RAILWAY LABORACT [ ] 891 AGRICULTURALACTS

I 1195 CONTRACT [ ] 510 MOTIONSTO [ ] 751 FAMILYMEDICAL FEDERAL TAX SUITS

PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE LEAVE ACT (FMLA)LIABILITY 28 USC 2255 [ ] 870 TAXES (U.S Plaintiff or [ ] 893 ENVIRONMENTAL

[ ] 196 FRANCHISE CIVIL RIGHTS [ ] 530 HABEASCORPUS [ ] 790 OTHER LABOR Defendant) MATTERS

[ ] 535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY [ ] 895 FREEDOM OF

REAL PROPERTY

[ ] 440 OTHER CIVILRIGHTS(Non-Prisoner)

[ ] 540 MANDAMUS& OTHER [ ] 791 EMPL RET INCSECURITY ACT

26 USC 7609 INFORMATION ACT

[ ] 896 ARBITRATION[ ] 899 ADMINISTRATIVE

[ ] 441 VOTING IMMIGRATION PROCEDURE ACT/REVIEW OR[]210 LAND

CONDEMNATION

[ ] 442 EMPLOYMENT[ ] 443 HOUSING/

PRISONER CIVIL RIGHTS

[ ] 462 NATURALIZATIONAPPEAL OF AGENCY DECISION

[ ]220 FORECLOSURE ACCOMMODATIONS [ ] 550 CIVILRIGHTS APPLICATION [ ] 950 CONSTITUTIONALITY OF[ ]230 RENT LEASE & [ ] 445 AMERICANS WITH [ ] 555 PRISON CONDITION [ ] 465 OTHER IMMIGRATION STATE STATUTES

EJECTMENT DISABILITIES - [ ] 560 CIVIL DETAINEE ACTIONS

[ ]240 TORTS TO LAND EMPLOYMENT CONDITIONS OF CONFINEMENT

[ ]245 TORT PRODUCT

LIABILITY

[ ] 446 AMERICANSWITHDISABILITIES -OTHEF

[ ]290 ALL OTHER

REAL PROPERTY

[ ] 448 EDUCATION

Checkif demanded in complaint:

CHECK IF THIS IS ACLASS ACTIONUNDER F.R.C.P. 23•

DEMAND $_ OTHER

Check YES onlyifdemanded in complainfJURY DEMAND: HIYES LKlO

DC,i YOU CLAJM THIS CASE IS RELATED TOACIVIL CASE NOW PENDING IN S.D.N.Y.?

JUDGE DOCKET NUMBER

NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).

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(PLACEAN x INONEBOXONLY)

D 1 Original LJ 2 Removed from <—' 3 RemandedProceeding state Court from

| J 3. all parties represented "P

| | b. At least oneparty is pro se.

(PLACEAN x INONEBOXONLY) BASIS OF JURISDICTION

• 1US PLAINTIFF • 2 U.S. DEFENDANT \*\ 3 FEDERAL QUESTION Q4 DIVERSITY(U.S. NOT A PARTY)

ORIGIN

| | 4 Reinstated or O 5 Transferred from [~J 6 MultidistrictReopened (Specify District) Litigation

I I 7 Appeal to DistrictJudge fromMagistrate JudgeJudgment

IF DIVERSITY, INDICATECITIZENSHIP BELOW.

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

(Place an [X] in one box for Plaintiff and one boxfor Defendant)

PTF DEF

CITIZEN OF THIS STATE [ ] 1 [ ] 1

CITIZEN OF ANOTHER STATE []2 []2

CITIZEN OR SUBJECT OF AFOREIGN COUNTRY

PTF DEF

[ ]3[ ]3

PTF DEF

INCORPORATED and PRINCIPAL PLACE [ ] 5 [ ] 5OF BUSINESS IN ANOTHER STATE

INCORPORATED or PRINCIPAL PLACE [ ] 4 [ ] 4OF BUSINESS IN THIS STATE

FOREIGN NATION []6 []i

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)Pablo Star, Ltd.One Victoria SquareBirmingham, West MidlandsB1 1BD

United Kingdom

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)Welsh Government, Wales International Center, 845 Third Avenue, New York, NY 10022Pittsburgh Post-Gazette, 34 Blvd. of the Allies, Pittsburgh, PA 15222Richmond Times Dispatch, 300 E. Franklin St.; Richmond, VA 23219Miami Hearald Media Co., 3511 NW 91 Ave., Miami, FL 33172Travel Squire, 15 Maiden Lane, Suite 1001, New York, NY, 10038

DEFENDANT(S) ADDRESS UNKNOWNREPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN

RESlBENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

Colorado News feed

Checkone: THIS ACTION SHOULD BE ASSIGNED TO: • WHITE PLAINS [x] MANHATTAN(DO NOTcheck either box ifthis a PRISONER PETITION/PRISONER CIVIL RIGHTSCOMPLAINT.)

DATE SIGNATURE OF ATTORNEY OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT

~T^>.-—~C_<A KS^--— []NO*-*• — ' ' ^-^ [X YES (DATE ADMITTED Mo.RECEIPT # Attorney Bar Code # DN4940

Magistrate Judge is to be designated by the Clerk ofthe Cojjft „ jjjjxje NETBURN

Magistrate Judge

Ruby J. Krajick, Clerk of Court by. Deputy Clerk, DATED.

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

Yr.

is so Designated.

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Danial A. Nelson (DN4940)Kevin P. McCulloch (KM0530)NELSON & McCULLOCH LLP

155 East 56th Street, 3rd FloorNew York, New York 10022

T: (212)355-6050F: (646) 308-1178

Counsel for Plaintiff

15 CV H67

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK -t/:

PABLO STAR LTD.,

Plaintiff,

v.

THE WELSH GOVERNMENT; GRACENOTE(d/b/a TRIBUNE MEDIA SERVICE);PITTSBURGH POST-GAZETTE; E.W. SCRIPPS,CO.; COLORADO NEWS FEED; TRAVELSQUIRE; RICHMOND TIMES DISPATCH; andMIAMI HERALD MEDIA CO.,

Defendants.

Civil Action No.:

COMPLAINT AND

DEMAND FOR A JURY TRIAL

o

Plaintiff Pablo Star Ltd., by and through undersigned counsel, pursuant to Rule 8 of the

Federal Rules of Civil Procedure and the Local Rules of this Court, hereby demands a trial by

jury of all claims and issues so triable and, for its Complaint against Defendants The Welsh

Government; Gracenote (d/b/a Tribune Media Service); the Pittsburgh Post-Gazette; E.W.

Scripps, Co.; Colorado News Feed; Travel Squire; Richmond Times Dispatch; and Miami Herald

Media Co. (together "Defendants") states as follows:

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PLAINTIFF AND ITS COPYRIGHTED WORKS

1. Plaintiff Pablo Star Ltd. ("Plaintiff) is a company organized and registered under

the laws of Ireland and the United Kingdom.

2. Plaintiff is the owner of all American copyrights in and to the photographic works

featuring the iconic poet Dylan Thomas that are the subject of this action for copyright

infringement and related claims against Defendants.

3. Plaintiff owns all American copyrights in the following photo identified as "Just

Married Dylan Thomas" (referred to herein as "Just Married"):

4. Plaintiff owns all American copyrights in the following photo identified as

"Dylan and Caitlin at Penard" (referred to herein as "Penard"):

Both Just Married and Penard were originally created by photographer Vernon

Watkins.

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6. As of August 25, 2011, Pablo Star acquired all rights, title, and interest in the

photographs, including all copyrights therein, by written agreement.

7. Plaintiff has registered its copyrights in both Just Married and Penard with the

United States Copyright Office and was issued certificates of registration for both works.

8. Plaintiff owns exclusive and valid American copyrights in the subject photos.

JURISDICTION AND VENUE

9. This is an action for copyright infringement and related claims brought by

Plaintiff, the registered owner of copyrights in and to the photographic works described herein,

against Defendants for unauthorized uses of those copyrighted photographs.

10. This Court has jurisdiction over the Defendants, either generally and/or for the

specific acts alleged herein.

11. As alleged in more detail herein, the Welsh Government published, displayed,

distributed, and otherwise used unauthorized copies of Plaintiff s copyrighted photographs to in

advertisements, publications, and other promotional materials directed at and specifically

targeted towards New York residents.

12. Upon information and belief, the Welsh Government (the devolved Government

of Wales) operates "Visit Wales" as an administrative division to encourage tourism and

otherwise publicize and promote Wales.

13. The Welsh Government, acting through its Visit Wales division, purposefully

directed advertisements, publications, promotions, solicitations, and other aspect of a tourism

campaign toward residents of the State ofNew York.

14. The Welsh Government maintains offices, employees, and agents in New York

and also conducts substantial ongoing business in the State of New York and this District.

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15. Upon information and belief, the Welsh Government provided unauthorized

copies of Plaintiffs copyrighted works to the other Defendants for purposes of promoting

tourism and Wales' tourism-related interests in New York City.

16. Defendants Gracenote (d/b/a Tribune Media Service) ("Tribune"); E.W. Scripps,

Co. ("Scripps"); the Colorado News Feed; the Pittsburgh Post-Gazette; the Richmond Times

Dispatch; Travel Squire; and Miami Herald Media Co. ("Miami Herald") are collectively

referred to hereinafter as the "Publisher Defendants."

17. Upon information and belief, the Publisher Defendants conduct substantial

ongoing business in New York, including providing ongoing goods and services primarily in the

form of news, entertainment, and other publications, including but not limited to online

publications, to numerous residents of the State of New York and this District.

18. All Defendants conduct substantial business in the State of New York, are subject

to personal jurisdiction in the State of New York, and have infringed Plaintiffs copyrights in the

State of New York and in this District.

19. Upon information and belief, Defendants Tribune; Scripps; and Travel Squire also

maintain employees, agents and/or offices in New York.

20. Upon information and belief, Defendant Travel Squire owns and operates the

website www.travelsquire.eom which is an online digital magazine and travel itinerary planning

service.

21. Upon information and belief, Defendant Colorado News Feed owns and operates

the website www.conewsfeed.com which supplied updated news and information articles online

to viewers and supplies content and articles to subscribers.

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22. Upon information and belief, Defendant Colorado News Feed has subscribers

and customers who reside in New York and Colorado News Feed otherwise provides content and

articles to individuals who reside in New York.

23. Upon information and belief, Defendant Scripps owns and operates the website

www.TCPalm.com which, according to that website, is an "interactive online service" which

provides news, weather, and entertainment stories to visitors.

24. Upon information and belief, Defendant Richmond Times Dispatch owns and

operates the website www.timesdispatch.com which is an online publication that provides news,

weather, and entertainment stories to visitors.

25. Upon information and belief, Defendant Miami Herald owns and operates the

website www.miamiherald.com which is an online publication that provides news, weather, and

entertainment stories to visitors.

26. Upon information and belief, each of the Publisher Defendants obtained

unauthorized copies of Plaintiffs photos from the Welsh Government (or one of its

administrative divisions or websites) that the Publisher Defendants then published and displayed

on the websites that they each respectively own and operate.

27. Jurisdiction for Plaintiffs claims lies with the United States District Court for the

Southern District of New York pursuant to the Copyright Act of 1976, 17 U.S.C. §§ 101, et seq.,

and 28 U.S.C. § 1338(a) (conferring original jurisdiction over claims arising under any act of

Congress relating to copyrights).

28. Venue is proper in this Court under 28 U.S.C. §§ 1391(b) because Defendants

either reside in this District, have infringed Plaintiffs copyrights within this District, and or a

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substantial part of the events or omissions giving rise to Plaintiffs claims occurred in this

District.

29. Venue also is proper in this Court under 28 U.S.C. § 1400(a) since Defendants

reside or may be found in this District.

FACTUAL ALLEGATIONS

30. In March of 2012, Plaintiff discovered that the Welsh Government, acting through

Visit Wales, was using Plaintiffs Just Married photo without permission. Through Visit Wales,

the Plaintiff advised the Welsh Government that it owned copyright in the photo and promptly

demanded in writing that the Welsh Government cease and desist using Plaintiffs Just Married

photo.

31. On or about March 30, 2012, a representative of the Welsh Government

acknowledged Plaintiffs notice of copyright and claimed that the Welsh Government would

comply with Plaintiffs demand that Defendant cease and desist use of the photo.

32. Despite acknowledging Plaintiffs 2012 copyright notice and takedown demand,

the Welsh Government subsequently began new unauthorized uses of Plaintiffs Just Married

photo.

33. Beginning in 2014, the Welsh Government began using unauthorized copies of

Plaintiffs Just Married photo in advertisements, promotions, brochures, and other tourism-

related materials, including materials directed specifically at residents of New York and intended

to lure American tourists to Wales.

34. Attached hereto as Exhibits 1 and 2 are true and correct copies of examples of

publications and tourism materials published by the Welsh Government that feature unauthorized

and infringing copies of Plaintiff s JustMarried photo.

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35. Because information regarding the scope of Defendant's use of Plaintiffs

photographs remains in Defendant's sole possession, the full and complete scope of Defendant's

infringing uses of Plaintiff s Just Marriedwork has not yet been ascertained.

36. In addition to making new unauthorized uses of Plaintiffs Just Married photo,

Defendant also created or acquired an unauthorized derivative copy of Plaintiff s Just Married

photo that it subsequently displayed, published, sold, and otherwise used without permission

from Plaintiff and despite knowing that Plaintiff claimed copyright in the underlying

photographic work.

37. Attached hereto as Exhibit 3 is a true and correct uncropped copy of the

unauthorized derivative work created or acquired by Defendant. Exhibit 3 is a photograph, taken

from Defendant's website, of an old print of Plaintiffs Just Married photo that was being

displayed at the time on the mantle of a fireplace at the Birthplace of Dylan Thomas.

38. Despite previously acknowledging Plaintiffs copyright notice, the Welsh

Government published, displayed, and offered for sale the unauthorized derivative of Plaintiff s

Just Married original work.

39. Attached hereto as Exhibit 4 is a true and correct copy of a screen capture from

the website www.walesonview.com. which is owned and/or operated bythe Welsh Government,

showing the unauthorized derivative copy being offered for sale as image "SVW-C53-1213-

0171.JPG."

40. The Welsh Government also provided this unauthorized derivative copy of

Plaintiffs Just Married photo to the other Publisher Defendants (as well as to other, yet-to-be-

ascertained third parties) to use to promote Wales tourism and the Visit Wales campaign here in

the United States.

Page 10: Pablo Star v. Welsh Government - Just Married photo copyright complaint.pdf

41. The Welsh Government also used Plaintiffs Penard photo as part of its

advertising, tourism, and promotional campaign.

42. Because information regarding the scope of the Publisher Defendants' use of this

unauthorized derivative copy of Plaintiff s photograph remains in the Publisher Defendants' sole

possession, the full and complete scope of Defendants' infringing uses of the unauthorized

derivative has not yet been ascertained.

43. Attached hereto as Exhibits 5-12 are true and correct copies of various

publications and other documents showing that the Publisher Defendants published and

displayed unlicensed copies of Plaintiffs photos or unauthorized derivatives of Plaintiffs

copyrighted work.

44. Because information regarding the scope of Defendant's use of Plaintiffs Penard

photograph remains in Defendant's sole possession, the full and complete scope of Defendant's

infringing uses of Plaintiff s Penard'work has not yet been ascertained.

COUNT I

COPYRIGHT INFRINGEMENT AGAINST ALL DEFENDANTS

45. Plaintiff repeats and re-alleges each allegation set forth in paragraphs above as if

set forth fully herein.

46. Plaintiff is the sole and exclusive owner of the creative visual works identified

herein and that are the subject of this action.

47. Plaintiff registered its copyrights in the images that are the subject of this action

with the U.S. Copyright Office prior to filing this lawsuit and prior to the infringing acts

described and alleged herein.

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48. As alleged herein, Defendants used, published, distributed, displayed, sold, and

otherwise exploited Plaintiffs copyrighted works without a license and without permission.

49. Upon information and belief, the Welsh Government never had permission or a

license to use either theJust Married or Penard photos, particularly to promote tourism or in its

advertising campaigns.

50. In the event that the Welsh Government contends that it did have permission or a

license, Plaintiff alleges that Defendant exceeded the scope of any alleged license.

51. Regardless of whether the Welsh Government ever had any permission to use the

photos—which Plaintiff contends it did not—Plaintiffs March 2012 correspondence provided

sufficient notice to the Welsh Government that any purported license had been rescinded or

revoked and that no additional uses of the photo were permitted.

52. By infringing Plaintiffs copyrights, Defendants misappropriated Plaintiffs

intellectual property for their own profit, causing Plaintiff significant injuries, damages, and

losses in amounts to be determined at trial.

53. Defendants' unauthorized uses of Plaintiffs copyrighted images were knowing

and willful.

54. Plaintiff seeks all damages recoverable under the Copyright Act, including

statutory or actual damages, including each Defendant's profits attributable to the infringing use

of Plaintiffs creative works and the damages suffered as a result of the lack of compensation,

credit, and attribution.

55. Plaintiff also seeks a declaration that the Welsh Government lacks a license to use

Plaintiffs photos identified herein

Page 12: Pablo Star v. Welsh Government - Just Married photo copyright complaint.pdf

56. Plaintiff also seeks a preliminary and permanent injunction against the Welsh

Government precluding any ongoing or future use of Plaintiffs photos, or unauthorized

derivative copies of Plaintiff s original works.

57. Plaintiff also seeks all attorneys' fees and anyothercosts incurred in pursuing and

litigating this matter.

COUNT II

CONTRIBUTORY AND VICARIOUS COPYRIGHT INFRINGEMENTAGAINST THE WELSH GOVERNMENT

58. Plaintiffs repeat and re-allege each allegation set forth above as if set forth fully

herein.

59. Without permission, the Welsh Government provided copies, distributed, or

otherwise allowed access to Plaintiffs copyrighted works to numerous third parties, including

the Publisher Defendants.

60. Through its actions, the Welsh Government materially contributed to, facilitated,

induced, or otherwise is responsible for the directly infringing acts carried out by the other

defendants and yet-to-be-ascertained third parties.

61. The Welsh Government exercised control over the content of its websites and

publications and third party access to the content of those websites and publications, including

copies of Plaintiff s works.

62. The Welsh Government had the ability to prevent the Publisher Defendants and

other third parties from copying Plaintiffs photos or unauthorized derivative copies that were in

the control and possession of the Welsh Government.

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63. When the Publisher Defendants copied, displayed, published, or sold

unauthorized copies of Plaintiffs photos to promote Wales tourism they were acting at the

direction, behest, on behalf of, for, and/or under the control of the Welsh Government.

64. The Welsh Government obtained direct financial benefits from the infringements

of the Publisher Defendants, including the promotion of its tourism business and goals.

65. By copying, distributing, displaying, publishing, and otherwise exploiting

Plaintiffs copyrighted creative works, each of the defendants infringed Plaintiffs copyrights in

the creative works identified herein and caused Plaintiffs significant injuries, damages, and

losses in amounts to be determined at trial.

66. Plaintiff seeks all damages recoverable under the Copyright Act, including

statutory or actual damages, including Defendants' profits attributable to the infringements, and

damages suffered as a result of the lack of compensation, credit, and attribution and from any

diminution in the value of Plaintiffs copyrighted works. Plaintiff also seeks all attorneys' fees

and any other costs incurred in pursuing and litigating this matter.

WHEREFORE, Plaintiff respectfully prays for judgment on its behalf and for the

following relief:

1. A preliminary and permanent injunction against Defendants precluding

Defendants from copying, displaying, distributing, publishing, selling, or in any way using

Plaintiffs works or any publications, advertisements, brochures, or other promotional materials

that include unauthorized uses of Plaintiffs creative works, and requiring Defendants to deliver

to the Court for destruction or other appropriate disposition all relevant materials, including

digital files of Plaintiffs photographs and all copies of the infringing materials described in this

complaint, that are in the control or possession or custodyof Defendants;

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2. All allowable damages under the Copyright Act, including but not limited to,

statutory or actual damages, including damages incurred as a result of Plaintiffs loss of licensing

revenue, Defendants' lack of attribution, and Defendants' profits attributable to infringement;

3. Plaintiffs full costs, including litigation expenses, expert witness fees, interest,

and any other amounts authorized under law, and attorneys' fees incurred in pursuing and

litigating this matter;

4. Any otherreliefauthorized by law, including punitive and/or exemplary damages;

and

5. For such otherand further reliefas the Court deems just and proper.

JURY TRIAL DEMANDED

Dated February 18, 2015New York, New York.

By:

Respectfully submitted,

NELSON & McCULLOCH LLP

4UDanial A. Nelson (DN4940)Kevin P. McCulloch (KM0530)NELSON & McCULLOCH LLP

155 East 56th Street, 3rd FloorNew York, New York 10022

T: (212)355-6050F:(646) [email protected]@nelsonmcculloch.com

Attorneysfor Plaintiff

12

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EXHIBIT 1

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^ WalesCymru

Dylan Thomas Walking Tour of Greenwich Village, New YorkWrittenby PeterThabitJones and Aeronwy Thomas, daughter of Dylan Thomas

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Directions:

O is on the west side of Hudson just south of Grove. Walk north on Hudson and turn right on Grove and walk to Bedford. Turn right on Bedford toBarrow. Q is on the corner of Bedford and Barrow on the north west side of the corner. Turn right on Barrow for ashort way then left on Commerce. Q iswhere Commerce turns the corner. Continue onCommerce back to Bedford. Turn right on Bedford to Carmine. Turn leftonCarmine to 6thAvenue whereCarmine becomes Minetta Lane. Continue east on Minetta Lane toMacDougal. Q is on the south west corner of Minetta Lane and MacDougal. Turn righton MacDougal down to Bleecker. 0 is on the north-west corner of MacDougal and Bleecker. Turn left onto Bleecker and then left onto Thompson. 0 ison the east side ofThompson just below West 3rd. Continue north on Thompson toWashington Square and then turn left towards MacDougal and thenright on MacDougal until you reach Waverley Place. Q is on the north side of Waverley Place close to Washington Square. Continue west on WaverleyPlace until you get to 6th Avenue (Avenue of the Americas). Turn right on 6th Avenue until you reach West 10th. Turn left on West 10th. 0 is a littleway down on the right in Patchin Place and can be viewed from the street on West 10th. Continue west on West 10th and then turn right on GreenwichAvenue until you reach 7th Avenue. 0 is the hospital on the block between 6th and 7th Avenues and 11th and 12th Streets. Turn left on West 11th andgo all theway to Hudson. © is ontheintersection ofHudson and West 11 thonthesouth-west side ofthe intersection.

1

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"At poor peace I singTo you, strangers"

from Prologue

This is a self-guided walking tour of ten placesin Greenwich Village that are connected with theWelsh poet Dylan Thomas, who visited and stayedin New York City while on four reading tours ofNorth America between 1950 and 1953.

The tour is designed to provide you with a strongsense of the real man behind the "brassy orator"with "the lovely gift of the gab," as well asgiving you a feel for Greenwich Villageof the 1950s.

We hope that you will find the walk both pleasurableand informative. Please follow the directions on

this map. The tour will take around 1 hour and 30minutes to 2 hours. Enjoy!

1. CHURCH OF ST. LUKES IN THE FIELD

EPISCOPALEAN CHURCH487 Hudson Street at the corner of Grove Street

"Though lovers be lost love shall not;And death shall have no dominion"

from And death shall have no dominion

Memorial Service

On Friday, 13th November 1953, four days after Dylan Thomas haddied, around four hundred people attended a memorial service for thepoet here in the third oldest church in New York. Hiswife. CaitlinThomas,along with other chief mourners, was at the front of the church.The gathering included poet e.e. cummings and sculptor David Slivka.

It was also the day when a grieving Caitlin accompanied thecoffined bodyof her husband, aboard the SSUnited States,on the longand lonely journey back to Britain.

Dylan was one of the most famous poets in the English-speakingworld; and his popular and electrifying tours had made him a muchloved celebrity in America. While touring, he had found himself inthe company of some of the Twentieth Century's cultural greats,including Charlie Chaplin, Greta Garbo, Marlene Dietrich, MarilynMonroe, Thomas Mann, Henry Miller and Max Ernst.

The sales of his books rivalled those of T.S. Eliot, Ezra Pound,W.H. Auden and John Betjeman. Dylan's Collected Poems, publishedon 10th November 1952. sold 30,000 hardback copies in Britainwithin a couple of years. The Collected Poems went on to be evenmore successful in America.

His early and unexpected death was a great shock on both sidesof the Atlantic. Leading British newspapers, such as the Daily Mailand the Daily Express, acknowledged his genius and his colourfulpoet's lifestyle. The British poet Philip Larkin said. "I can't believethat DT is truly dead.Three people who've altered the face of poetryand the youngest has to die." The other two poets were Auden andEliot. Vernon Watkins, a close friend of Dylan and Larkin, was, in fact,askedto writean obituary before Dylan wasactually dead.

Interestingly, one of the founding wardens of St. Luke's wasClement Clarke Moore, the author of the world-renowned poem'Twas the night before Christmas. He donated the land on whichthe church was built. Dylan Thomas, of course, wrote the verypopular A Child's Christmas in Wales.

2. CHUMLEY'S86 Bedford Street

(between Grove Street and Barrow Street)

"Dressed to die. the sensual strut begun"from Twenty-fouryears

Chumley's is an authentic speakeasy from the Prohibition era. Itspreviousnotoriety is confirmed by the fact that it still has no sign and.as well as its main entrance, it offers a "secret entrance" on 58 Barrow

Street, through the backyard called Pamela's Court. Chumley's is NewYork's second oldest literary bar (the White Horse Tavern is the first).

Its walls are covered with the framed pictures of its clientele oflegendary writers and samples of their book covers. Dylan Thomas isone of many honoured, along with other literary greats such as JohnSteinbeck, Ernest Hemingway and F. Scott Fitzgerald. The poet andplaywright Edna St. Vincent Millay lived upstairs for a while.

Note: Chumley's is closed for renovation as we went to press 6/23/08

3. CHERRY LANE THEATRE38 Commerce Street (on Bedford Street, turn right on BarrowStreet and the theatre will be opposite you on Commerce)

"I, in my intricate image, stride on two levels.Forged in man's minerals, the brassy orator"

from /, in my intricate image

Dylan's ReadingsThe poet and playwright Edna St. Vincent Millay founded Cherry

Lane Theatre, which was originally Cherry Lane Playhouse, in 1924.As New York's oldest off Broadway Theatre, it has been at theforefront of providing innovative theatre for over eighty years.The Downtown Theatre movement.The Living Theatre,establishedbythe actress and political activist Judith Malina, and the Theatre of theAbsurd came out of the Playhouse.

It showcased the early plays of EdwardAlbeeand premiered SamuelBeckett's Waiting for Godot. Its list of renowned performers includesGene Hackman. Bob Dylan and, of course, Dylan Thomas. BarbraStreisand was once an usher there.

In 1952, on his second visit, Dylan did a special reading for theartistic community. Tickets were only $1 a head and Thomas hadpromised to read only his own poems. However, the show was nearlycancelled when he arrived claiming to have lost his copy of his poems.Judith Malina came to the rescue with a replacement that Dylan laterreturned, complete with the hand-written bookmarks he had used forthe performance.

There is also another possible link between Edna St. Vincent Millayand Dylan. Millay, who was born in 1892 and died in 1951, wrote apoem Dirgewithoutmusic. It has the following lines:

"Down, down, down into the darkness of the graveGently they go, the beautiful, the tender, the kind;

Quietly they go. the intelligent, the witty, the brave.I know. ButI do not approve. And I am not resigned."

It brings to mindThomas'sfamous villanelle Do not go gentle intothat good night, which was drafted in March 1951. Millay's poem,infact, appeared inTheNewPocketAnthology ofAmerican Verse, editedby Dylan's American friendOscar Williams, which contained some poemsby Dylan.

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4. MINETTA TAVERN113 MacDougal Street (on the corner of MacDougal Streetand Minetta Lane)

"His drinking was not a means of denying or fleeing life...but of fiercely embracing it."

from Dylan Thomas inAmerica byJohnMalcomBrinnin

The Minetta Tavern, which was a speakeasy during Prohibition,was known as The Black Rabbit until 1929. The Minetta Brook, which

began on 23rd Street on its way to the Hudson, inspired its name.The brook still flows underground.

The old wood panelling and time-honoured candelabra, which arestill part of the attraction for today's customers, appealed to decadesof poets and writers, including Ernest Hemingway, Ezra Pound. EugeneO'Neill, e.e. cummings and DylanThomas.

The black-and-white ink caricature drawings and aged photos,now yellowing, and the murals are testimony to its Bohemian dayswhen celebrities sought out its convivial cosiness.

Dylan became a good friend of Joe Gould, who was known as"Professor Seagull." A Harvard graduate, Gould claimed to understandthe language of sea gulls and wrote several thousand pages of hisimaginary great work.An Oral History of OurTime.

It has been claimed that Reader's Digest originated in thebasement of the property in 1923. More recently the Minetta wasfeatured in the film Jimmy Blue Eyes, which is about the New Yorkmobster Vincent "Jimmy Blue Eyes" Alo (1904-2001).

5. CARPO'S CAFE (SAN REMO CAFE)93 MacDougal Street on the corner of Bleecker Street

"Wewere killed inaction, Manhattan Island, Spring 1952,in a gallant battle against Americangenerosity.

An American called Double Ryeshot Caitlin to Death.I was scalped by a Bourbon."

from a postcardsent by Dylan to Swansea composer Daniel Jones

Favourite Bars/DrinkingAfter the preferred White Horse Tavern, San Remo was one of

Dylan's favourite bars in Manhattan. It was the desired hangout fora host of famous writers, artists, musicians and photographers,including Tennesee Williams. William Burroughs, the Beat poets Allen Ginsberg and Gregory Corso, W.H. Auden, James Baldwin, FrankO'Hara, William Styron, James Agee, Jackson Pollock, Miles Davis, andWeegee. Village character Maxwell Bodenheim was also a regular.Gore Vidalonce tried to pick up Jack Kerouac in the San Remo. It is thesettingof JohnClellon Holmes's 1952 Beatnovel Go, and it alsoappearsas The Masque in Kerouac's 1958 The Subterraneans.

Dylan met Allen Ginsberg in the Cafe. The Beat poet noted thatDylan played on his fame; and an invitation to him to visit Ginsberg'sattic at 206 East 7th Street was turned down after a friend reminded

Dylan that Caitlin was waiting for them. Ginsberg left, sticking histongue out playfully and later regretted that he had not made moreof the encounter.

Note: Carpo's Cafe isno longer open as we went to press 6/23/08

6. THE DOVE (THE GRAND TICINO)228 Thomson Street

(between West 3rd Street and Bleecker Street)"Onceit was the colour of saying

Soaked my table..."from Once it was the colour of saying

Favourite Restaurants

The Grand Ticino. at the time one of the finest Italian restaurants in

Greenwich Village, is where Dylan is said to have experienced his firstmeal in America. John Malcolm Brinnin, the organizer of Dylan's toursof the USA, took him there on his second day in New York, after theyhad been on a whistle-stop sightseeing tour of the city.

Dylan spent time at the Ticino with British poet Ruthven Todd andNew Zealand poet Allen Curnow.The white-table-clothed atmosphereand friendly hospitalityobviouslyappealed to the Welsh poet. Hewroteto his parents about American food. He had sampled milk shakes, friedshrimp and "a T-bone steak the size of a month's ration for an Englishfamily."

Healso liked to eat at a restaurant called the Little Shrimp,which wasattached to the Hotel Chelsea. It was the place where one of the mostsignificant recording deals was struck.

Barbara Cohen (later Holdridge) and Marianne Roney (laterMantell) were two young women, college graduates, who nurturedthe idea that recordings of poetry could sell in sufficient quantities tojustify such a venture. They had decided that Dylan would be the idealcontemporary poet for them to record.

Barbara worked for a small publisher and Marianne worked for arecord company. After several unsuccessful approaches they finallygot him to meet them at the Little Shrimp and he agreed to theirrequest. "As far as Dylan was concerned," said Mrs. Mantell later,"we were justtwo younggirls withan ideaand some money."

On 22nd February 1952, Dylan arrived for the recording atSteinway Hall on 57th Street. He had a sheaf of poems, but theengineer told him that they would only fill one side of a long-playing record. Dylanfound a copy of Harper's Bazaar, which containedA Child's Christmas in Wales, a story he had put togetherfrom two earlier writings. The finished recordingwas released on 2ndApril and sold modestly at first.

The record of Dylan Thomas was the launch of Caedmon, acompany formed by the two enterprising women and poweredby their own money. It became one of the leading spoken-wordrecording labels and is now part of HarperCollins. It was also thebeginning of the spoken-word recording industry. Since Dylan's firstrecording many great and famous literary figures have committedtheir voicesto Caedmonvinyl, including T.S. Eliot, JamesJoyce. ErnestHemingway and William Faulkner, and actors such as Charlton Hestonand Sir John Gielgud. The company eventually made the two womenvery wealthy.

Onthe 50th anniversary of Dylan's death, Caedmon released DylanThomas: The Caedmon Collection, which contained some previouslyunavailable recordings.

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7. WASHINGTON SQUARE HOTEL (HOTEL EARLE)103 Waverly Place (on the corner of MacDougal Street)

"A haven cosy as toast, cool as an icebox..."from A visit to America

Dylan's Hotels in New YorkOn the first tour John Malcolm Brinnin booked Dylan into the

Beekman Hotel, on the corner of First Avenue and 49th Street,in a room at least twenty floors up. Dylan had wanted to stay in anapartment in New York, rather than a hotel, and he did not like theBeekman. As it was. the hotel management soon asked him to leavebecause of his partying and excessive demands on room service.

He was booked here into the Hotel Earle, which was a cheaper

place than the Beekman and also close to his favourite bars andrestaurants in Greenwich Village. In the 1950s the Earle was asomewhat well-worn hotel. The atmosphere and the attitude of themanagement and staff was easy-going. Dylan wrote a letter to hisparents in May 1950 in which he described the Earle as "rightin Washington Square, a beautiful Square, which is right in the middleof Greenwich Village, the artists' quarter of New York."

Dylan and his wife Caitlin, on the second tour in 1952, spent acouple of nights at the Hotel Earle before moving in to the HotelChelsea, where they had a one-room kitchenette apartment.

The Hotel Chelsea is situated on West 23rd Street, between

Seventh and Eighth Avenues. Constructed in 1883. it becameDylan's "home" on his American tours. Other famous literary figureshave stayed there, including 0. Henry, Thomas Wolfe and ArthurMiller. Some famous people who lived there for a while include SarahBernhardt, Jackson Pollack and the Welsh musician John Cale along withhis then wife Betsey Johnson.

It was at the Chelsea that Dylan worked on the final version of UnderMilk Wood prior to its New York premiere. It was also from there thathe was taken, unconscious, to St. Vincent's Hospital, where he died afterfailing to come out of a coma. A plaque on the Hotel Chelsea reads:"Dylan Thomas lived and wrote at the Chelsea Hotel and from here hesailed out to die."

8. E.E. CUMMINGSS APARTMENT4 Patchin Place (off West 10th Street

between 6th Avenue and Greenwich Avenue)

"Time passes. Listen.Time passes"from Under Milk Wood

Dylan's FriendshipsThe American poet e.e. cummings (Edward Estlin Cummings)

lived here, with his third wife Marion Morehouse, a photographerand fashion model, from 1923 until his death in 1962. Dylan reallyadmired cummings and. on the first tour of New York, he made aspecial request to Brinnin to arrange a meeting with him. Brinnin,who was present when Dylan and e.e. met, wrote in Dylan Thomas inAmerica: "...itseemed to me that some of their judgements showed theacerb, profound and confident insights of artists who in their work havedefined a world within the world..."

Cummings, in fact, had been in the audience at Dylan's first readingat the Kaufmann Auditorium of the 92nd Street Y on February 23rd1950, where Dylan delivered a spellbinding performance to anaudience of more than a thousand people. The overwhelmed andappreciative audience refused to let him leave the stage. According toMarion Morehouse, cummings was so moved he walked the streets forhours afterwards.

The following week or so Marion Morehouse invited Dylan here toPatchin Place to take his photograph. Dylan had had a few drinks andattempted a playful seduction. She described him as "Groucho Marxon a bad day."

After Dylan's death a committee was formed by his Americanpublisher James Laughlin to organise support for Caitlin and herfamily. Cummings was part of this committee, and an amount of$20,000 was raised.

There is another connection between Patchin Place and Dylan.The writer Djuna Barnes lived in 5 Patchin Place from the 1940sonwards. She was an obsessive recluse. According to ConstantineFitzgibbon, Dylan's first biographer, Barnes, along with James Joyce,influenced Dylan's early prose writing. It has been noted byothers that Dylan particularly liked her novel Nightwood. which waspublished in 1936.

Dylan made some very good friendships in New York, in particularwith David Slivka, a sculptor, and his wife Rose, an art critic.Rose, infact,became Caitlin's closest friend in America. Rose said of Caitlin, "She

was the artist's wife, and that can be a terrible place to be." The Slivkaslived in Greenwich Village. David was born on the same day and yearas Dylan. 27th October 1914, and it was he and Rosewho looked afterCaitlinwhen Dylan was in a coma and after he died.

It was David who made Dylan's death mask. The original mask is inan upstairs bedroom of the Boat House in Laugharne, Wales. The maskused to belong to Richard Burton and ElizabethTaylor until it was soldafter Burton's death. The last bust cast from the mask is in the DylanThomas Centre in Swansea, Wales. David and Rose later divorced, but

David, aged ninety-four years, stillworks and liveswith his partner, Joan,in New York.

Other New York friends included poet and anthologist OscarWilliams and his wife Gene Derwood, also a poet, New Zealand poetAllen Curnow and poet Jean Garrigue. Jean once held a party for Dylanwhere he met a very young Andy Warhol. Poet John Berryman andBritish poet Ruthven Todd were also friends; and both kept a vigilat St.Vincent's when Dylan was hospitalized. Berryman was in Dylan's roomwhen he died. It was he who rushed up to John Malcolm Brinnin andsaid. "He's dead! He's dead! Where were you?"

9. ST. VINCENTS HOSPITAL11th Street at 7th Avenue

"And my shining men no more aloneAs I sail out to die"

from Poem on his birthday

Dylan's Death.St. Vincent's Hospital is straight up 11th Street from the White

Horse Tavern. Dylan's favourite New York bar. Roman Catholics ran thehospital, when Dr. Milton Feltenstein, Liz Reitell's doctor, ordered anambulance to take an unconscious Dylan there.

The myth is that Dylan died as a result of a drinking bout in the WhiteHorse Tavern, when he declared to Liz Reitell back at the Hotel Chelsea

"I've had eighteen straight whiskies. I think that's a record." The truthis more complex.

When he arrived in New York on Monday. 19th October 1953, forhis fourth tour, he was already desperately ill. Yet he still seemed tohave no desire to curtail his drinking or smoking. There is evidence thathe was becoming increasingly dependent on medication. He was alsosuffering blackouts, and his behaviour, at times, was erratic.

On Tuesday, 3rd November, he started weeping in his bedroom atthe Chelsea. He told Liz Reitell that he wanted to die and "go to thegarden of Eden." At two o'clock in the morning he told her he had to

continued on pg 5

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have a drink and left for the White Horse. He returned to the Chelsea

and boasted about the whiskies.

He slept until the middle of the morning of 4th November.He went with Liz Reitell to the White Horse, where he had twoglasses of beer. On returning to the Chelsea he became so unwell thatDr. Feltenstein was called three times. Feltenstein's fourth summoning

to the Chelsea on Thursday, 5th November, resulted in Dylan's beingrushed to St. Vincent's where he was admitted at two minutes before

two a.m.

Caitlin arrivedat Idlewild Airporton Sunday morning,where she wasmet by David and Rose Slivka. When she saw Brinnin she asked. "Well,isthe bloody man dead or alive?" She broke down when she saw Dylanand was taken by the Slivkas to their apartment on Washington Street,in order to calm herself and rest. When she returned to St. Vincent's

she dismayed the nurses by smoking near the oxygen tent and almostthreatening Dylan's breathing in a lovingembrace.

Her deep despair turned to violence and she started to abuse andattack Brinnin and hospital nuns and nurses. She was placed in astrait-jacket and taken to the Rivercrest Mental Institution in Astoria,Long Island. She later wrote, "I was possessed of ten thousandravaging demons. Mymadness:an untutored broken heart."

Dylan died at lunchtime on 9th November 1953,while a nursewasgiving him a bed bath. Poet John Berryman was the onlyother personpresent. To this day there is a controversy over what actually causedDylan's death. While his lifestyle of smoking and excessive drinkingcontributed to his bad health, it has been suggested that he sufferedfrom undiagnosed diabetes. However, it ismedical negligence that mostexperts now claim was the real cause. Four days prior to Dylan's deathDr. Feltenstein had given Dylan a high dose of morphine as a sedative.

The post-mortem stated pneumonia as the primarysource of death,with pressureon the brainand a fatty liver as contributing factors.

"And death shall have no dominion.

Dead men naked they shall be one'from And death shall have no dominion

aftersleeping until midday, returned with Liz Reitell to his beloved "TheHorse" for a couple of beers, his final drinks there.Theyreturned to theHotel Chelsea to the last pages of his incredible story.

"Andfreely he goes lostIn the unknown, famous light of great

And fabulous, dear God

Dark is a way and light is a place'from Poem on his birthday

Dylan Thomas is often thought of as the "first rock 'n' roll poet":he spent months away from home touring America, attracted hugeaudiences at his readings, and often got accosted when he appearedin public. He was also the subject of a lot of gossip, rumour, andlegend, just like rock starsand celebrities are today.

In spite of the rumours and gossip and the tragic narrative of hisshort life, he was a great and original poet, a master craftsman whodid, indeed, "labour by singing light" to leave to the world a wonderfulcollection of poems and prose inspired by Wales.

"I build my bellowing arkTo the best of my love..."

from Prologue

This is the end of the tour, and we suggest you go inside the WhiteHorse Tavern to see the room dedicated to Dylan and the paintings,posters and other memorabiliaon the walls. Please raise a glass to oneof Wales's most famous sons and one of the world's most famous

English-language poets.

END OF TOUR #•Wales

Jf Cymru

^f Please take care oftheenvironment and recycle this copy after use.

10. WHITE HORSE TAVERN567 Hudson Street at West 11th Street

"And Thou, I know, wilt be the first

To see our best side, not our worst"

from Under Milk Wood

Dylan lovingly called it "The Horse." One of New York's oldest bars,dating back to 1880. the White Horse's "British pub atmosphere"made him feel very much at home. He would have seen the mastsand funnels of ships in the Hudson River teasing the sky at the endsof streets, possibly reminding him of Swansea's dockside area. He andfellow writers would also have chatted and sat with the seamen and

dockworkers who frequented the White Horse.In Dylan's day an elderly German gentleman and his wife ran the

Tavern. Many other writers, literary figures, and artists have alsoenjoyed a drink there, including Norman Mailer, James Baldwin, JackKerouac. the Clancy Brothers, Bob Dylan and Jim Morrison. It is DylanThomas, though, who is most associated with the bar.

It is now famously linked to Dylan's death. At two a.m. onWednesday, 4th November, he inexplicably left Liz Reitell at the HotelChelsea and disappeared for around two hours. When he returned toher he made the claim that he had downed eighteen straight whiskies.However, when friends later questioned the proprietor, he said itwas more likelythat Dylan had had six whiskies.

Even after the now legendary episode of the whiskies, Dylan.

Dylan Thomas Background InformationFurther background information to the tour that includes thefollowing information can be e-mailed to you on request [email protected]

• Dylan's Life• Dylan's Visits to New York• Bibliography

®Visit WalesCroeso Cymru

Dylan Thomas in Wales:Every lover of Dylan Thomas and his work should visit Walesand the places most associated with him, such as Swansea,Laugharne and New Quay. Please visit www.travelwales.org/dylanfor more information.

The Dylan Thomas Prize for young writers:The Dylan Thomas Prize of $120.000 isawarded to thebest published writer in English under the age of 30from anywhere in the world. For further informationvisit http://www.thedylanthomasprize.com

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WalesCymru

James Agee: (1909-1955) an American novelist, screenwriter, journalist,poet, and a distinguished film critic.

Edward Albee: (1928-) an Americanplaywright. He isprobably best knownfor writing Who's Afraid of Virginia Woolfl

W.H. Auden: (1907-1973) a prolific English poet who eventually claimedAmerican citizenship. He was a Chancellor of The Academy of AmericanPoets from 1954 to 1973.

James Baldwin: (1924-1987) an African-American novelist, writer.playwright, and civil rights activist.

Djuna Barnes: (1892-1982) an American writer. She was a leadingindividual in bohemian Greenwich Village and later in Paris in the 1920sand 1930s. Dylan Thomas described Barnes' novel Nightwood as "one ofthe three great prose booksever written by a woman."

Samuel Beckett: (1906-1989) an Irish writer, dramatist and poet.His works are bleak and minimalist. He was awarded the Nobel Prize in

Literature in 1969.

Sarah Bernhardt: (1844-1923) a French stage actress, who has beenreferred to as "the most famous actress in the history of the world."Bernhardt made her fame on the stages of Europe in the 1870s. andwas soon in demand in Europe and the United States. She developeda reputation as a serious dramatic actress, earning the nickname "TheDivine Sarah."

John Berryman: (1914-1972) an American poet. He is regarded asone of the creators of the Confessional school of poetry. He committed

suicide in 1972.

John Betjeman: (1906-1984) an English poet writer and a populartelevision personality on British television. He was a founding memberof The Victorian Society, Britain, in 1958, and he championed thepreservation of oldbuildings that werethreatened bydemolition.

Maxwell Bodenheim: (1892-1954) an American poet and novelistwho was known as the "King of GreenwichVillage Bohemians."

John Malcolm Brinnin: (1916-1999) an American poet and literarycritic. He wrote academic works on T. S. Eliot. Gertrude Stein, Truman

Capote, and William Carlos Williams, as well as his well-known DylanThomas in America.

William Burroughs: (1914-1997) an American novelist, painter,essayist and performer, Asignificant memberof the BeatMovement.

Richard Burton: (1925-1984) a Welsh theatre and film actor. In1954, he made his most famous radio role, as the narrator in the originalproduction of Dylan Thomas's Under Milk Wood. He repeated the role inthe film version of Dylan's play twenty years later.

John Cale: (1942-) a Welsh musician, composer, singer-songwriter andrecord producer. Heis best knownfor hisworkin rockmusic, particularly asa founding member of The VelvetUnderground, although he has worked ina variety of styles over the years.

Charlie Chaplin: (1889-1977) an Academy Award-winning comedyactor. He became one of the most famous actors of all time, as well as

an outstanding director,duringthe early-to mid-Hollywood cinema period.Hisfamous character "The Tramp" personifies the silent-film age.

A Child's Christmas in Wales: was published in 1955. It is a nostalgicand veryeffective sketch of a traditional Christmas. Dylan Thomas createdit from a piece that was originallywritten for radio.

Barbara Cohen (Holdridge) and Marianne Roney (Mantell): BarbaraHoldridge has described the Dylan Thomas recording as a momentousexperience. "We had no idea of the power and beauty of this voice.We justexpected a poet with a poet's voice, but this was a full orchestral voice."Caedmon is named after the first English poet to write in English ratherthan Latin.

Appendix (in alphabetical order): J^ Gregory Corso: (1930-2001) an American poet, who was the youngestof the inner circle of the Beat Generation. He was born at St. Vincent'sHospital, where DylanThomas died.

e.e. cummings: (Edward Estlin Cummings, 1894-1962)an American poet,painter, essayist, and playwright.

Allen Curno:(1911-2001) a New Zealand poet and journalist.

Miles Davis: (1926 1991) an American jazz trumpeter, bandleader.and composer.

Gene Derwood: (1909-1954) an American poet, painter and wife ofthe poet and anthologist Oscar Williams. She did a few paintings anddrawings of Dylan, photographs of which are now housed at HarvardUniversity Library.

Marlene Dietrich: (1901 1992) a German-bornAmerican actress and singer.

Dylan: the name comes from the Mabinogion. the Welsh medieval proseromances. Dylan in the text is a sea-son of the waves.

Bob Dylan: (born Robert Allen Zimmerman in 1941) an American singer-songwriter, author, musician, poet, and artist, who hasbeen a major figurein popular music for five decades. His songs of anti-war andthe civil rightsmovements in the 1960s inspired a generation of young people.

T.S. Eliot: (1888-1965) a poet, dramatist, and literary critic. He receivedthe Nobel Prize in Literature in 1948. His The Wasteland (1922) has had aprofound impact on modern poetry.

Max Ernst: (1891-1976) a German painter and sculptor. A foremostfigure inthe movements of Dadaism and Surrealism,

William Faulkner: (1897-1962) an American author. He received theNobel Prize in Literature in 1949.

Dr. Milton Feltenstein: Among the personal items returned to Walesafter Dylan's death was a prescription from Feltenstein. The doctor diedin 1974.

F. Scott Fitzgerald: (1896 1940) an American writer of novels andshort stories. His works, such as The Great Gatsby, capture the Jazz Age

(1920s).

Constantine Fitzgibbon: (1919-1983) a notable historian and novelist.Afriend of Dylan's, he wrote The Life of Dylan Thomas (1965) and editedSelected Letters of Dylan Thomas (1966).

Jean Garrique: (1914-1972) an American poet.

Sir John Gielgud: (1904-2000) an English theatre and film actor.He is recognisedfor hiswonderful Shakespearean work.

O. Henry: (William Sydney Porter 1862-1910)a famous American shortstorywriter. His hundreds of shortstories are well-known for theirsenseofhumour and surprise endings.

Charlton Heston: (1923 2008) an American actor of film, theatre andtelevision. His notable films include Ben-Hur and Planet of the Apes.

Hotel Chelsea: a famous residence for writers, artists and musicians.

It was the first building to be listed by New York City as a culturalpreservation site and historic building. It is mentioned in a song calledSara by Bob Dylan, which states "Staying upfor days in the Chelsea Hotel,writing Sad-Eyed Lady of the Lowlands for you."

Greta Garbo: (1905-1990) a legendary. Swedish-born actress duringHollywood's silent film period and part of its Golden Age.

Allen Ginsberg: (1926-1997) an American Beatpoet. Heisbest known forthe poem Howl(1956), which celebrates hisfriends of the Beat Generation.

Joe Gould: (1889-1957) a Greenwich Village eccentric. He worked for awhile as a reporter for the New York Evening Mail.

Gene Hackman: (1930) a very popular Academy Award-winningAmerican actor.

Harper's Bazaar: a renownedAmerican fashion magazine, which wasfirstpublished in 1867.

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Ernest Hemingway: (1899-1961) a great American novelist, short-story writer, and journalist. He was awarded the Nobel Prize in Literaturein 1954.

John Clellon Holmes: (1926-1988) an American writer, poet and professor.

Betsey Johnson: (1942-) an American fashion designer best known forherfeminineand whimsical designs.Shealso isknown for doinga cartwheelat the end of her fashion shows. In 1968 she married Velvet Underground'sJohn Calefrom Wales. They divorced later in the year.

Daniel Jones: (1912-1993) a Welsh composer of classical music.He wrote a book, My FriendDylan Thomas, in 1977.

James Joyce: (1882-1941) an Irish writerwho was a major influence on20th century literature. Ulysses (1922) is regarded as his masterpiece.

Jack Kerouac: (1922-1969) an American novelist, writer, poet andartist from Massachusetts. His most popular books are On the Road.TheDharma Bums. BigSur. and Visions of Cody. Hewas a major influenceon many writers, and even pop stars, such as The Beatles.

Philip Larkin: (1922-1985) an English poet, novelist and jazz critic. Hiscarefully crafted and often pessimistic poetry influenced a generation ofBritish poets.

James Laughlin: (1914-1997) an American poet and literary bookpublisher who founded New Directions, publisher of Dylan Thomas'sworks in America. He was awarded the1992 Distinguished Contribution toAmerican Letters Award from the National Book Awards Program.

Norman Mailer: (1923-2007) an American novelist, journalist, playwri

and screenwriter. He received the Pulitzer Prize twice.

?ht.

Judith Malina: (1926) an American theatre actor and director.

Thomas Mann: (1875-1955) a major German novelist and short story writer.

Marlais: the name comes from Dylan's father's uncle William Thomas, aclergyman and poet. He wrote in the Welsh language and took the bardicname of Gwilym Maries, after a river called the Marlais. Nancy, Dylan'ssister, who was eight years older, was given the middle name Maries, theversion used by the great-uncle.

Edna St. Vincent Millay: (1892-1950) an American poet and playwrightand the first woman to receive the Pulitzer Prize for Poetry. Her middlename actually comes from St. Vincent's Hospital in New York, where heruncle, close to death, was saved (before she was born).

Arthur Miller: (1915-2005) one of America's greatest playwrights. His dramatic works include The Crucible (1953) and Death of a Salesman (1949).

Henry Miller: (1891-1980) an American writer and painter. Hisnovels Tropicof Cancer (1834) and Tropicof Capricorn (1939) are goodexamples of his highly individual style.

Marilyn Monroe: (1926-1962) an American actress, singer, and model.She was a sex symbol and remains a cultural icon.

Clement Clarke Moore: (1779-1863) the author of A Visit from St.Nicholas, which is known today as Twas the Night Before Christmas.He was a professor of Oriental and Greek literature at Columbia College.

Marion Morehouse: (1906-1969) an American model and photograher.There is a belief that she was never legally married to the poete.e. cummings, because his divorce of his previous wife was carried out inMexico and not recognised in the United States.

Jim Morrison: (1943-1971) an American singer, poet, songwriter.He was the lead singer and lyricist of The Doors.

Frank O'Hara: (1926-1966) an American poet who, along with JohnAshberry, was a chief member of what was known as the New York Schoolof poetry.

Jackson Pollock: (1912-1956) an influential American painter and amajor force in the abstract expressionist movement.

Ezra Pound: (1885-1972) an American poet and critic. Poundinfluenced the careers of many writers, including W. B. Yeats. T S. Eliot,Robert Frost, and D.H. Lawrence.

Liz Reitell: (1921-2001) the Assistant Director of the world premiere ofUnderMilk Wood,which featured Dylanas First Voice.They embarked onan affair, despite initially being uneasy in each other's company.

David Slivka: a sculptor with an international reputation. Born in Chicago,Illinois, he studied for four years at the California School of Fine Art. Helater settled in New York and was connected with The New York School, an

informal group of American poets, painters, dancers, and musicians activein the 1950s and 1960s in New York City.

Rose Slivka: (1919-2004) the editor-in-chief and a writer for themagazine Craft Horizons from 1959 to 1979. A distinguished art critic,she married and later divorced the sculptor David Slivka. She wrotepoetry and her work is profiled in Issue 4 of The Seventh Quarry SwanseaPoetry Magazine, a publication withan international perspective, edited bySwansea poet Peter Thabit Jones and NewYork poet Vince Clemente.

John Steinbeck: (1902-1968) one of the most celebrated and mostwidely read American writers of the 20th century. He was awarded theNobel Prize in Literature in 1962.

Barbra Streisand: (born April 24, 1942) an American singer, film andtheatre actress. She has been awarded an Emmy, a Grammy, an Oscar anda Tony award.

William Styron: (1925-2006) a prominent American novelistand essayist.

Swansea: a city and county in Wales. It has the second largestpopulation for a city in Wales. Cardiff, the capital, has the largest.Swansea expanded during the eighteenth and nineteenth centuries, whenit became a hub for heavy industry. It was granted city status in 1969.

Elizabeth Taylor: (1932) an American (British-born) actress who wonthe Academy Award twice. She marriedand divorced Richard Burtontwice.

Caitlin Thomas: (1913-1994) was born in Hammersmith. London. Herparents' maiden name was Macnamaraand they were Protestant Irish fromCounty Clare. Ireland. Her father wrote poetry and published a book ofpoems, Marionettes, four years before she was bom. She was a passionateand professional dancer as a young woman. She was introduced to Dylanin 1936 and they married at the register office in Penzance, Cornwall, on11th July 1937.

Ruthven Todd: (1914-1978) a Scottish poet and novelist.

Under Milk Wood: a play for voices that has the sound-texturing of anextended poem. DylanThomas worked on it for eight years. It has beenadapted for stage, screen, opera and album. Dylan himself wassound-recorded at a performance at the 92nd Street Yin Manhattan.

Gore Vidal: (1925) an American author of novels, screenplays, andessays. He has been a passionate critic of American politics.

Andy Warhol: (1928 1987) a controversial American artist and a majorcontributor to the movement known as Pop Art. He is now mostly knownfor his paintings of American icons, such as Marilyn Monroe and ElizabethTaylor.

Vernon Watkins: (1906-1967) a Swansea poet who was a very closefriend of Dylan. He was godfather to Dylan's and Caitlin's son Llewelyn.His book Letters to Vernon Watkins.published in 1957, is a real insight intoDylan as a friend and as a fellow poet and craftsman.

Weegee: (1899 1968) a photographer.Weegee was the pen-name ofArthur Fellig. He specialised in blackand white street photography.

Oscar Williams: (1900-1964) an American anthologist and poet.

Tennessee Williams: (1911-1983) a major American playwright. He wasawarded the Pulitzer Prize for Drama for A Streetcar Named Desire in 1948

and for Cat on a Hot Tin Roof'm 1955.

Thomas Wolfe: (1900-1938) a significant American novelist. His worksexplore American culture.

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EXHIBIT 2

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Wales.com - The Welsh in America

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lliih Cvmratg Francis Qeutseh iipaAol $ >

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Discovering the Welsh in Americano©™*Welsh in America - booklets and exhibition.

The Welsh Government has researched and produced an exhibition and a booklet outlining the history of the Welsh inAmerican up to the present day and outlining the important contribution that the Welsh have made to life in America. ThePDF for the booklet is below and copies for distribution free-of-charge can be ordered from the Welsh Government in NewYork.

tm Document Download: Welsh in Amtrlea 2010J- Size: [7.07 MB] File Type: [.pelf]

The exhibition 'Welsh in America' can be loaned free-of-charge from the Welsh Government in New York. Details can befound under Ixhibitions on this website.

mt Document Download: Wilsh Guidt te Niw York City)- Size: [473 KB] File Type: [.pdf]

Welsh Guide to New York City

Take a tour of New York City from a Welsh perspective with our downloadablePDF guide (473 KB). You'll learn how the Welsh have influenced the city andsome connections with some of our most famous exports.

Debunking myths about Dylan Thomas in an official walking tour of New York's historic Greenwich Village.

Dylan 81 Caithn:Copynght JeffTowns

Dylan Thomas was greeted like a rock star when he crossed America to give his legendary readings to huge audiences. InGreenwich Village, he was able to enjoy literary and musical pursuits in more relaxed and less public way. The architectureand atmosphere appealed to him. He wrote to his parents saying that he found Washington Square Park, ' very beautiful.'

St tuke in the Fields inspired Dylan's "Child's Christmas in Wales,"he went to visit his pal ee cummings in Patchin Place,and ate his first meal in America (which he said was as big as a month's ration for a British family).

The two hour tour was created in association with Aeronnwy Thomas, Dylan's daughter who was able to 'trial' the tour justbefore she died. The tour guide is Ianto Roberts whose voice has an uncanny similarity to Dylan's. He weaves tales aboutthe extrovert bohemian artists of 1950's Greenwich Village in with stories about Thomas' life and death in New York.

This is the Official Dylan Thomas Walking Tour of New York,a collaboration of the Welsh Government in New York and the

http://www.wales.com/en/content/cms/English/USA/The_Welsh_in_America/The_Welsh_in_America.aspx[ll/7/2014 3:40:23 PM]

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family of Dylan Thomas.

The first tour is Sunday March 6th 2011 at 11am. $25.00 per ticket. And every Sunday after that. Bookings and furtherinformation www,N@wYerkfsunTeurs,ceffi/dylan=thema§ rr

The Dvlan Thomas Walking Tour of Greenwich Village was developed by the Welsh Assembly Government in New York inassociation with Aeronwy Thomas, Peter Thabit Jones, Jane O'Brien, John Pierce Jones, Huw Chiswell, Todd tefkovic andothers. The Welsh Government would like to thank all those involved for their assistance with the project and we wish NewYork Fun Tours the very best of success with the new commercial venture

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http://www.wales.com/en/content/cms/English/USAAfie_Welsh_in_America/The_Welsh_in_America.aspx[ll/7/2014 3:40:23 PM]

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EXHIBIT 4

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For reference only. All images © Crown copyright (Visit Wales).

SVW-C53-1213-0176.JPG

Bedroom

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0169.JPG

Bedroom

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0157. JPG

Kitchen

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0174.JPG

Landing

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0167.JPG

Bedroom

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0153.JPG

Piano and books on shelves

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0171.JPG

Photograph of Dylan Thomas and his wife Caitlin

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0160.JPG

Kitchen

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

SVW-C53-1213-0150.JPG

Books on shelves

5 Cwmdonkin Drive

Birthplace of Dylan Thomas

Swansea

All unauthorised extraction or use of images is strictly prohibited

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7/11/2014 This is the year to hike the Dylan Thomas trail | TMS Specialty Products

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THIS IS THE YEAR TO HIKE THE DYLAN THOMASTRAIL

Dylan Thomas and his

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EXHIBIT 6

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Obltuiritt ivente Jebs Real Mite

y*tJlittf fotrgb Jwh^twttrpott-grattt.coM

74°?.day *B(Ma»i

A fitting year to hike Dylan Thomas trailApril 13. 2014 12:00 AM

mrnm11 ea

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4fcPrint N^Kmitil H§ Stead Later

Dylan Thomas and his wife, Caitlin.

By Roger Rapoport / McClatchy-Tribune News Service

LAUGHARNE, Wales —In his short life, Dylan Thomas became one of the world's firstmultimedia superstars through his spellbinding poetry, stage readings and dramatic writing for

the stage, screen, radio and television.

Just 39 when he died in November 1953, Thomas also was an inspiration for a generation of

younger artists, ineluding Bob Dylan and John Lennon. Followinghis passing, countless girls were

named in honor of his widow, Caitlin. His poetry, stories such as "A Child's Christmas in Wales"

and the play "Under Milk Wood" remain central to the Welsh literary canon.

This year, the centenary of his birth, offers a perfect opportunity to take a hike along the Dylan

Thomas trail. There is no better place to start this Welsh eoastal journey than Browns Hotel, the

Laugharne public house where he did some of his best work.

You never know who might join you for the Dylan Thomas 100 Festival. As I was leaving Browns,

the owner suggested delaying my departure and joining the small crowd gathered outside. An

hour later Prince Charles and the Duchess of Windsor greeted our group and made an

unannounced visit to this literary shrine, just a short walk from the idyllicboathouse where

Thomas lived with Caitlin and their children.

Something of a workaholic who rewrote his poems hundreds

of times in the small writing shed above his residence,

Thomas aiso was the life of the party on his legendary- tours

at home and across America. A series of multimedia

Laugharne weekends this summer are offered as "less a

Dylan Thomas festival than the kind of festival Dylan would

have liked to go to," according to the Dylan Thomas

Centennial program published by the sponsors of the Dylan

Thomas 100 program.

Easily combinable with hiking tours along the Wales Coast

Path is a pilgrimage to bucolic Carmarthenshire, which

inspired Thomas' famed poem "Fern Hill." It's also easy to

reach New Quay, the Ceredigion fishing village that became

the wellspring for the fictional village of Llareggub and his

poem "Quite Early One Morning."

If you go

The Welsh like to joke about the fact thatit costs $10 in bridge tolls to enter theirland, but there's no charge to leave.Well worth the tariff, a visit to DylanThomas Centennial (www.dt100.info)begins with a trip to Swansea (threehours west of London) and the DylanThomas Centre. Although centennialevents are being staged in many Welshand UKvenues, this is a great place tostart your journey, you can pick up mapsand a picturesque set of walkingguides.www.swafieeaisyuK/aylanthsmgs.

Literature Wales is sponsoring

a wide range of special events

ineluding kayaking trips, pony

trap rides and behind the

scenes tours. For more details

visit dylanthomas.com/2014-

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Although Thomas is celebrated for his own work, his readings

ofShakespeare and the great British poets were oftenstanding-room-only events attracting the likes of T.S. Eliot,

CharlieChaplin,Arthur Millerand William Faulkner. Hisout-of-town tryouts included a solo performance of "Under Milk

Wood" at the Salad Bowl cafe on Tenbv's north cliff.

centenary or vLsitwales.com.

To hear Prince Charles reading

Thomas' "Fern Hill"go to

This reading, his last UK performance before his fatal journey to America, is just one more

landmark on the Thomas trail, which also includes the Dylan Thomas Centre in Swansea, his

hometown.

The hub of the Dylan Thomas 100 Festival Program, this collection is a literary landmark that

offers a chance to see the writer's notebooks, hear readings of his poetry and join events featuring

some of Wales' best known writers. Because Thomas was a close friend of leading novelists,

playwrights and poets on both sides of the Atlantic, the museum provides a panoramic view of the

mid-20th-centuiy literary canon.

"One of the mast beguiling things about Dylan's social character," wrote his friend, agent and

biographer John Malcolm Brinnin, "was the spell-like illusion of intimacy he would cast upon

anyone who came near. Everyone, it seemed, could command his intimate attention."

This intimacy, which extends to today's audiences, goes far beyond readings of his poetry at

funerals everywhere. Perhaps the most intriguing aspect of a Dvlan Thomas walking tour is the

relationship between his work and village life. As often as he visited world capitals tor his

legendary command performances and partying, Thomas traveled under a cloud of nostalgia for

his native land.

To see why, visit Swansea's Cwmdonkin Park, where Thomas -- as he described it in his radio

broadcast, "Reminiscences of Childhood" — "endured with pleasure, the first agonies of

unrequited love, the first slow boiling in the belly of a bad poem and the struggling and raven-

locked self-dramatization of what, at that time, seemed incurable adolescence."

Although the Dylan Thomas trail is only a small portion of the 870-mile-long Wales Coast Path, it

provides an intimate look at the literary life of an inspiring writer. His early departure from his

celebrated literary life remains the central mystery of life. Walking the Welsh paths he loved

makes one consider the great poems he might have written into his 40s and beyond.

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EXHIBIT 7

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Page 46: Pablo Star v. Welsh Government - Just Married photo copyright complaint.pdf

EXHIBIT 8

Page 47: Pablo Star v. Welsh Government - Just Married photo copyright complaint.pdf

8/27/2014 SWANSEA, Wales:Celebrating a poet: 100years after the birthofDylan Thomas- Travel- MiamiHerald.com

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Miami Herald > Lifestyle > Travel

Posted on Saturday, 05.03.14 A A tttiait pfirtt comment reprlrrts

Celebrating a poet: 100 years after the birth ofDylan Thomas GUB

DYLAN THOMAS CENTENARY

Information: www.vis itwaies .com,

EVENTS

Here are some highlights of the celebration. Aful!schedule of Dylan Thomas Centennial events is atwww.dytanthomaslG0.org.

• Bangor University in North Wales will stage 'My Friend: Dylan Thomas," a festival presenting musical responses: to Thomas' work, including new commissions: Oct. 25-

30.

• Swansea Festival of Music and the Arts in October will

' present the first Welsh performance of JohnCorregliano's "Dylan Thomas Trilogy''

• The National Library of Wales, Aberystwyth, will open itsrecentlycompiied archive of Thomas material in a newexhibit June 28-Dec. 20. Thomas's father, D.J,, studied atAberystwyth University and was the onlystudent in hisyear to obtain a first-class honors degree in Englishliterature. Dylan visited the town in 1934,

• Director Michael Bogdanovwill launch a new productionof "AChild's Christmas in Wales,' atthe Swansea Grand

; Theatre in earlyNovember, followed bya tour acrossWales. "One Christmas was so much like another, in

: thoseyears around the sea-town corner that I can neverremember whether it snowed for six days and six nightswhen I was twelve or whether it snowed for twelve daysand twelve nights when I was six.' Thomas wrote.

WHERETO STAY

• Fain/hill, ReynoJdston, Gower: 011-44-01792 380139;, www.fairyhill.net. Acontemporarycountryhouse hotel,, with renowned restaurantand wine cellar. Double rooms

' with breakfast, from S319 per night.

Morgans Hotel. Swansea; 011-44-01792 484848;www.morganshotel.co.uk. In Swansea's historic MaritimeQuarter, this grade IE listed building is five minutes' walkfrom the city center. Free Wi-Fi. Double rooms, withbreakfast, from S109.

: Swansea Marriott Maritime Quarter Swansea: 011-44-

01792 642020: www.marriott.com/hatelsfact-

sheet/travel/swsdt-swansea-marriott-hote!/. In the

bustling Maritime Quarter on Swansea Bay, near the citycenter and markets. Double rooms from S200.

Tides Reach, Mumbles, 011-44-01792 404877;www.tidesreachguesthouse.com. Built in 1855. Tides

BY BETSA MARSH

TRAVEL ARTS SYNDICATE

SWANSEA. Wales - Fueled by the invincibilityofyouth, Dylan Thomas Was only 19 when heproclaimed "And death shall have no dominion."

Although he was destined to live only two more

decades, his poem became a personal manifesto.

This year, a century after his birth, death will haveno dominion over one of the 20th century's most

celebrated writers.

Thomas' native Swansea, Wales, is epicenter ofDylan Thomas 100 celebrations that Will run morethan a year. Festivals, exhibits and performances

will radiate out from his "ugly, lovely town" toreverberate throughout Wales.

Thomas was a prodigy, writing two-thirds of his

work before age 23 from his birthplace at 5

Cwmdonkin Drive. Swansea. In addition to poems,

he wrote film scripts, plays and stories, performing

his work on the radio and on stage during tours of

the United States.

He s a YouTube favorite, reading his poetry in

what he called his "breathless boom boom boom."

Some consider Thomas the first modern

multimedia star — he's said to be the most-quoted

author after Shakespeare.

It was on Thomas' fourth American tour in 1953

that, after a drinking bout, he proclaimed in thewee hours of Nov. 4, 'I've had 18 straight

whiskies. I believe that's the record." He collapsed

and died five days later of a "massive insult to thebrain.'

The arc of that short life began in the front room

of the family home in Swansea on Oct. 27, 1914.

The house was lovingly restored to August 1914.

wheri Dylan s parents, D.J. and Florrie Thomas,moved in.

The house and its contents advance along a

timeline. "Bits of chrome are coming in, a directresult of World War I,' said Anne Haden, who puther own money and energy into the restoration.

"In 1922, the crystal radio Will come in, and radiowas very important to Dylan."

Prepare to climb up Cwmdonkin Drive to the

Edwardian house. "You've got to be a Sherpa,"Thomas said, to live here.

Visitors can explore the two-story house with a

free audio tour and even stay overnight in Dylan'sbirthplace room — the front bedroom.

When he started writing at 4, Dylan loved to sneakinto his sister Nancy s room to compose. "Iwanted

to write poetry in the beginning because I had

fallen in love with words ..." he wrote in his Poetic

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8/27/2014 SWANSEA, Wales: Celebrating a poet: 100 years after thebirth ofDylan Thomas - Travel - MiamiHerald.comSelect a Stale• Reach is an elegant guest house on the site of a previous

Victorian bath house. Double rooms, with breakfast, from

S117,

WHERETO EAT

The Grape & Olive Meridian Tower, Trawler Roau' Swansea; 011-44-01792 462617;: http://swansea.grapeandolive.co.uk/.On the top floorof; the tallest building in Wales, the Grape &Olive has views

across Swansea Bayand Mumbles. ModernMediterranean cuisine. Entrees from S15-S37.

La Parilla, J Shed, Kings Road Swansea. 011-44-01792464530; http:ZiWww.lapaiTilla.co.uk/. Contemporarymenu.

; Closed Mondays. Entrees from $18-$35.

Verdis Cafe Knab Rock. Mumbles: 011-44-01792i 369135; www.verdis-cafe.co.uk. Family-run cafe, ice

cream pador and licensed restaurant wilh an authenticItalian menu. On the sea front in the Wctonan fishingvillageof Mumbles. Pizzas and pastas from S10.

The Kin Reynoldston. Cower; 011 -44-01792 390775;www.kmgarthurhotel.co.uk. The pub has its original stone

: work, reclaimed timbers and open log fires in the winter.. The Gower Room has a nautical theme with local maps,original artifacts and photographs of Gower's nauticalhistory. Serving Felinfoet the national ale of Wales.Dinner entrees from S11-$26.

Manifesto. "I cared for fhe colors the words cast

on my eyes."

Thomas never liked his own room, a tiny

renovated bedroom ... hardly any light, book-knife. No red cushion. No cushion at all. Hard

chair. Smelly. Painful. Hot water pipes very near.Gurgle all the time. Nearly go mad. Niceviewofwall through window."

In his parents' bedroom at the back of the house,guests stilllook out to the town "crawling,sprawling by a long and splendid curvingshore" ofSwansea Bay.

In October, the Dylan Birthplace will sponsor TheDylanathon,a photo-marathon celebrating the lifeand work of Dylan Thomas. Themes from hiswriting willprovide the cues.

IndowntownSwansea May31-Aug. 31, the DylanThomas Centre on Somerset Place will display his

notebooks, which are returning to Swansea for fhefirst time. The center has an extensive permanent

Dylan Thomas exhibition, from his "too happychildhood" to his death in New York.

The exhibit opens with a tweed suit Thomas borrowed froman American painter, Jorge Fick, whenthewriterran out of clean clothes in NewYork. Fick was storing his clothes at the Chelsea Hotel,whereThomas collapsed, and this Is the suit he was wearingwhen he was taken to fhe hospital. Noone knowsifthe ink stain in the right trouser pocket was from Dylan's pen.

For such a multimedia star, there are no moving images Of Thomas, just a silent newsreel of his funeralprocession in Laugharne. Buthis recordings continueto be money-spinnersfor his estate.

The Thomas Centre will be the headquarters for the special 2014 Dylan Thomas Festival, lasting fromhis birthday Oct. 17 to Nov.9, the anniversary of his death.

Nearby, the Swansea City Centre Trail traces Thomas' life along the old landmarksand pubs he knew.One of the stops is The Uplands Hotel, nowthe Uplands Tavern, where he first tasted beet: "Itslive Whitelather, its brass-bright depths, the sudden world through the wet brown walls of the glass, the tilted rushto the lips."

The tour also pops into Swansea's AdelphiTavern on Wind Street, where Thomas drank as a cubreporter. Heleftschoolat 16, with no credentials, and became a reporterforthe SouthWalesEveningPost. Itwas the only regular Job he ever held.

Thomas wrote and scrambled for money throughout his 20s, often heading lo Oxford and London. On atrip to the capital In 1936. he met bohemian dancer Caitlin Macnamara In a pub. They married in 1937,and a year later moved to Laugharne. about 30 milesnorthwest of Swansea, to make a home forfheirchildren, Aeronwy, Llewellyn and Colm.

Laugharne, on a nook of the RiverTaf, is an ancient, oliffside settlement with a 13th-century fortress, fthas a venerable literary past, too. Feminist philosopher MaryWollstonecraft lived in Laugharne, and herdaughter Mary Shelley, author of Frankehstein. often visited. Novelist Kingsley Amis wrote during staysin the town, and Margaret Atwood set a short story in Laugharne.

Thomas called it simply "the strangest town in Wales."

The family moved around a bit in the villageof 400, alwayscoveting the Boathouse perched on rocks onthe "heron prlested" Taf Estuary. The waves sometimes swept into the lower rooms, and there was norunning wateror heat. Buta patron bought the house for the Thomases, and they lived there for the lastfour years of his life, from 1949 to 1953.

Step inside and you'llhear Thomas, maybe his broadcast of Qt//feEarly One Morning. Muchof thefurniture is original, and the tiny rooms have a lived-in feel.

Just 50 yards away, Thomas took an old garage as his Writing Shed. Here, on stilts above the cliffs, hepracticed his "sullencraft,"writing Under Milk Wood, Do NotGo Gentle Into Thai GoodNight and Poemon His Btihday.

Signposts make iteasy to follow the two-mile walk which is the setting for Poem Ih October. Thomas' strollaround Laugharne on his 30th birthday. Ifyou walk it on your birthday, withID, several local businesseswill give you freebles.

As Thomas' fellow Welshman and friend Richard Burton wrote in his diaries, I remember that Dylan

Thomas was almost embarrassingly sentimental about his birthday as indeed he shows in Poem InOctober."

Most of Thomas' ramblings ended at Browns Hotel in Laugharne, where he would commandeer the baywindow to drink pints of Buckley's, write, read the papers and chat with the locals.

The town hosts the Laugharne Weekend each April, but this year, the festival has Branded into

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8/27/2014 SWANSEA, Wales:Celebrating a poet: 100years afterthe birthof Dylan Thomas- Travel- MiamiHerald.com

September. The council also will move a temporary writing shed throughout Carmarthenshire, toencourage writers inspired by Thomas.

Some pilgrims may Want to pay respects to Dylan and Caitlin Inthe churchyard of St. Martin's Church.Theirgrave is marked by a simple white cross, with offeringsat its feet. On a recent day. people feltmoved to leave sea shells, dollar bills and a liquor bottle for husband and wife.

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EXHIBIT 9

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8/27/2014 This is the year to hite the Dylan Thomas trail - Richmond Times-Dispatch: Travel News, Guides, Photos &Gadgets

TimesDispatchP I'll, .•!.,) u'l„H« !li»U..|li,

NfWS iUSINISS OPINION SPORTS ENTERTAINMENT/UFE VIDEO WIATHIR OBITUARIES CONTISTS CLASSIFIEDS JOBS REALFSTATE AUIQS FIND LOCAL ALL ACCESS

«H Richmond, VA 77° F

Travel News, Guides, Photos & Gadgets

This is the year to hike the DylanThomas trail

Posted Saturday August 9 2014 10 30 pm

BY ROGER RAPOPORT McClatchy-Tribune

LAUGHARNE, Wales — In his short life,

Dylan Thomas became one ofthe world's

first multimedia superstars through his

spellbinding poetry, stage readings, and

dramatic writing for the stage, screen, radio

and television.

Just 39 when he died in November 1953,

Thomas also was an inspiration for a

generation of younger artists, including BobDylan and John Lennon. Following his

passing, countless girls were named in

honor of his widow, Caitlin. His poetry,

stories like "A Child's Christmas in Wales"

and play "Under MilkWood" remain central

to the Welsh literary canon.

This year, the centenary of his birth, offers a

perfect opportunity to take a hike along the

Dylan Thomas trail. There is no better place

to start this Welsh coastal journey than

Browns Hotel, the Laugharne public house

where he did some of his best work.

Dylan Thomas and his wife. Caitlin. (Visit Wales/TvlCT;

Something of a workaholic who rewrote his poems hundreds of times inthe small writingshed above his residence, Thomas also was the life ofthe party on his legendary tours at

home and across America. A series of multimedia Laugharne weekends this summer are

offered as "less a DylanThomas festival than the kind of festival Dylanwould have liked togo to," according to the DylanThomas Centennial program published by the sponsors ofthe DylanThomas 100 program.

If you go

The Welsh like tojoke about the factthatitcosts $10 in bridge tolls to enter theirland,butthere'sno charge to leave. Wellworth the tariff, a visitto Dylan Thomas Centennial(wm.dt100.infb) begins with a trip to Swansea (threehours westof London)and theDylan Thomas Centre. mW£mmm.J2SVMkj/SL)tJMl!i3m$$/

ooo®o©

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8/27/2014 This is the year to hike the Dylan Thomastrail - Richmond Times-Dispatch: Travel News,Guides, Photos &Gadgets

Literature Wales is sponsoring a widerange of special events including kayaking trips, ENTERTAINMENT-LIFE VIDEOS

pony trap rides and behind-the-scenes tours. For more details, visit

Although Thomas is celebrated for his ownwork, his readings of Shakespeare and thegreat Britishpoets were often standing-room-only events attracting the likes of T.S. Eliot,

Charlie Chaplin, Arthur Millerand William Faulkner.

The hub ofthe DylanThomas 100 Festival Program, the Dylan Thomas Centre in

Swansea, his hometown, is a literary landmark that offers a chance to see the writer's

notebooks, hear readings of his own poetry and join events featuring some of Wales' best

known writers. Because Thomas was a close friend of leading novelists, playwrights and

poets on both sides ofthe Atlantic, the museum provides a panoramic view ofthe mid-

20th century literary canon.

"One ofthe most beguiling things about Dylan's social character," wrote his friend, agent

and biographer John Malcolm Brinnin,"was the spell-like illusionof intimacy he would cast

upon anyone who came near."

This intimacy, which extends to today's audiences, goes far beyond readings of his poetry

at funerals everywhere. Perhaps the most intriguing aspect of a Dylan Thomas walking

tour is the relationship between his work and village life.As often as he visited world

capitals for his legendary performances and partying, Thomas traveled under a cloud of

nostalgia for his native land.

To see why, visit Swansea's Cwmdonkin Park, where Thomas — as he described in his

radio broadcast, "Reminiscences of Childhood" — "endured with pleasure, the first

agonies of unrequited love, the first slow boiling in the belly of a bad poem and the

struggling and raven-locked self-dramatization of what, at that time, seemed incurable

adolescence."

Although the Dylan Thomas trail is only a small portion ofthe 870-mile-long Wales Coast

Path, it provides an intimate look at the literary life of an inspiring writer. His early

departure from his celebrated literary life remains the central mystery of life.Walking the

Welsh paths he loved makes one consider the great poems he might have written into his

40s and beyond.

SfTweet 0 g+1 n \9inU\ I

is*. >

Posted inTravelon Saturday.August 9 2014 10:30pm.

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WORLD MEDIA PRIVACY POLICY

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How does the Web site use the information it gathers?

Information collectedon the Web site, including traffic patterns and user behavior is used primarily for the following purposes

Internal research. The Website is continuouslyassessing howvisitors use the site. This data assists us in making decisions about how to improve the site and to betterserve our users. Research data are aggregated and do not include data about specific individuals.We may share aggregated research (but not individual user information)with our advertisers or business partners. Additionally, the Web site mayuse yourinformation tocontactyouto ask foryourparticipation in a focus group, survey, or some othertype of research effort.

Tocustomize your experience on the Web site.As the Web site improves its service, itmayoffer users moreopportunities tocustomize contentand otheraspects ofthe site.Information provided byyou maybe used to assist in the customization process, ifyou elect to participate in these features.Totailor advertising efforts. Most ofthe information and services available toyou at the Web site are free In ordertocontinue providing services free ofcharge the Web sitesells advertising. Advertisers prefer totargettheir communication toward audienceswhoare most likely to be interested intheirproducts. Theinformation gathered on theWeb sitehelpsus advise advertisers ingeneral terms aboutcertain aspects ofsitevisitors (e.g. how visitors use thesite general demographic attributes ofvisitors, usagepatterns on various parts ofoursite,etc). This information helps both advertisers and theWeb sitemakebetterdecisionsaboutwheretoplace advertising. This informationmayaisobeused to send targeted marketing such as emails, to users that we think wouldbe interested in such marketing Visitors who choose to conductfinancialtransactions with advertisers on the Web site mayalso provide specific data tothose advertisers during theprocess oftheir transactions. Additionally, anyinformation providedduring the purchase on the Web site ofproducts or serviceswill result inthe collection ofcertain information requiredto completethe transaction.Touse third party serviceproviders. Weprovide some services and products through third parties.These third partyserviceproviders mayperform functions on our behalf, likesending outand distributing promotional emails. Wemayshare yourpersonallyidentifiable information with such serviceproviders as necessary toallow those serviceproviders to fulfill orders, send mail oremail, administer contests orsweepstakes,remove repetitive information on customer lists,analyze data,provide marketingassistance, provide search results and links, process credit cardpayments, operatethe Web site, troubleshoot, orprovide customerservice. We mayalso collect personalinformation from individuals and companies with whom wehave business relationships ("Affiliates") andmayshare your information with service providers to accomplish ouradministrative tasks. Forexample, whenyou ordera service, the third party payment processorwe use releases your credit cardinformation tothe card-issuing banktoconfirm payment for theservice. The use ofyour personally identifiable information bythese third parties is governed bythe privacy policies ofthese third parties andis notsubject to ourcontrol.

Morespecifically, here is how the Web site may use information you provide

E-mail addresses, if you supply the Web sitewith your e-mail address,either byregistering onthesite, by communicating with us via e-mail, or signing upfor promotionaloffers oremails we may. from time to time, sendyou information that we believe would beof interest to you via e-mail. This information maybe from the Web site orsentby usonbehalf ofoneofour quality advertisers. Note: If wesendyou e-mail onbehalf ofanother company, your personally identifiable information is notdisclosed tothat companyunlessyou purchase a product orservice from thatcompany inwhich case itmayneed your information tofulfill your purchase. Rather thecompany provides us with theinformation itwantstosend, andwe prepareand send thee-mail directly toyou. We mayuse a third party service provider to manage orsend emails on ourbehalf, butthatthird party is only authorized to use your information as necessarytosend ouremail toyou arid itis notauthorized to sellor transfer your information.Postal addresses.If you supply theWeb sitewith your postal address, we may sendyou periodic mailings with information onnew products, coming events, surveys orotherresearch materials, or other information we think might be of interest to you.Telephone numbers. If you provide your telephone number orcell phone number, the Web sitemay call ortext you regarding orders you have placed online totell you aboutnew products, services, orcoming events, ortooffer other information that may interest you. Additionally, theWeb siteoroneofits agents maycall you for research purposes.Saletransaction information. From time totime, we provide offers from ouradvertisers who as part oftheir offer request information oncustomers who purchased their offermorder toallow theadvertiser tofulfill the purchase. In those cases we sharesomeofyour personally identifiable information with that advertiser. Sharing this Informationmay allow that advertiser to market directly toyou should itchoose to doso.However, we will only sharepersonally identifiable information with anadvertiser if you provide usthat information and enter intoa transaction withthat advertiser on or throughour Website Weare not responsible or liablefor the actions ofsuch advertiser.Business transfer. We may alsoshareyour information in the case our business is sold ortransferred. If this occurs, thesuccessorcompany would acquire the informationwe mainiain, including personaliyidentifiable information.

Except as necessary to process your requests or orders placed with advertisers or merchants featured on the Web site, or as otherwisedescribed above,WORLD MEDIAdoes not rent, sell barter orgive away any lists containing Personal Information for use by any outside company. WORLD MEDIA alsorespects the privacy of data onyourpersonalcomputer and does notaccess, read,upload orstore datacontained inorderived from your private files without your authorization.

Facebook Connect

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Our Web site may allow users to access Facebook Connect to interact with friends and to share on Facebook through Wall and friends' News Feeds. Ifyou are logged into our

Web site and Facebook, when you click on "Connect with Facebook' your profiles will merge il the em ail addresses match. If the email addresses don't match, we ask you if

you want to merge them and you must enter your Web site password to validate that they control that account, it you are already logged into our Web site but not logged into

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the Web site to access your information and you are agreeing to the Facebook Terms of Use in your use of our Web site. Similar access to your information may occur if the

Web site allows users to access other social applications similar to Facebook.

Conversely, if you are not currently registered as an the Web site user and you click on "Sign in Using Facebook." you will first be asked to enter your Facebook credentials and

then be given the option to register and join the Web site. Once you register on our Web site and Connect with Facebook. you will be able to automatically post recent activity

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News Right

This Web site uses services provided by News Right. LLC- News Right is based m the United States and collects content usage information and may use cookies and/or clear

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*:•• ..'••• •• • . ' • for further information.

Links

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indicate a special relationship or partnership with WORLD MEDIA(such as co-branded pages or "powered by'or'in cooperation with''relationships). WORLD MEDlAdoes not

disclose personaliyidentifiable information or unique identifiers to those responsible for the linked sites. The linked sites however, may collect personal information from you

that is not subject to WORLD MEDIA'S control. To ensure protection of your privacy, always review the privacy policy ot the sites you may visit by linking from the WORLD MEDIA

site.

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You mayopt out of any or all contacts from the Web site at anytime. A!) e-mails sent to you from the Web site will allow you to opt out of any further e-mail from us. You maye-

mail us at >• =.'•"•• :';,.. :: . .to opt out of our email programs. Youmay also write or call us at the following address and phone number to notifyus

regarding use ot your information: 333 Franklin Street. Richmond VA23219; phone. 804.649.6588.

When you register on the Web site, you will be given the opportunity to opt out of further communication from us.

You may accept certain kinds of contact and decline others. For example, you may choose to accept e-mails, but not postal mail or telephone calls,

if.at anytime in the future, the Web site decides to use information provided byyou hi a way not described here, we willcontact you beforehand to explain the use ofthe

information and give you the opportunity to decline that use,

Children's Privacy

The following additional terms, conditions and notices apply fa use of the Web site by children under the age of 13 years whenever VA/ORLD MEDIA becomes aware that a user

is in that age range:

Users under 13 years of age may not submit or post informationon the Web site withoutthe consent of the users parent or legal guardian. Prior to collecting any personalinformationabout a child under 13. WORLD MEDIA makes reasonable effortsto obtain consent from the child s parent after informingthe parent about the types of informationWORLD MEDIA will collect, how it will be used, and under what circumstances it will be disclosed,

Although WORLD MEDIA will applythese children's terms and conditionswhenever it. becomes aware that a user who submits Personal Information is less than 13 years old.no method is foolproof. WORLD IvEDIAstronglyencourages parents and guardians to supervise their children's online activitiesand consider using parental control toolsavailablefrom online services and software manufacturers to help provide a child-friendly online environment. These tools also can preventchildrenfrom disclosing onlinetheir name, address, and other personal information without parental permission."Personal information" collected from children mayinclude any of the informationdefined above as Personal Information" with respect to general users ofthe Web site andmaybe used by WORLD MEDlAforthe same purposes. Except as necessary to process a child's requests or orders placed with advertisers or merchants featured on theWeb site, WORLD MEDlAdoesnot rent, sell, barter or give away any lists containing a child's Personal Information for use by any outside company.Ifa childenters a game, contest or other activity sponsored by WORLD MEDIA on the Web site, the child maybe required byWORLD MEDIA to provide the minimum Personalinformation reasonably necessary for the ehifd to participate in such activity.Achild's parent or legal guardian may request WORLD MEDIA to provide a description ofthe Persona! Information that WORLD MEDIAhas collected from the child, as well asinstruct WORLD MEDIA to cease further use, maintenance and collection of Personal Information from the child.

Ifa childvoluntarily discloses his or her name, e-mail address or other personally-identifying information on chat areas, bulletinboards or other forums or publicpostingareas, such disclosures mayresult in unsolicited messages from other parties.

Cancellation & Refund Policies

Asubscription to any of our products can be cancelled at anytime. Subscriber refunds will be issued within two weeks of cancellation for the entire credit balance on the

accountatthe time of cancellation. Refunds willbe issued per the original method of payment.

Advertiserrefunds will be granted upon cancellation of an entire run schedule ifnotice of cancellation is received from the advertiser priorto the beginning ofthe run schedule.

Refunds will be issued per the original method of payment and will be processed within 10 business days otthe request.

General

These Termsand Conditions constitute the entireagreement and understandingbetweenyou and WORLD MEDIA with respect to use ofthe Web site, superseding allprioror

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8/27/2014 Terms and Conditions | BH Media Groupcontemporaneous communications and/or proposals. WORLD MEDIAreserves the right to make changes to these Terms and Conditions rmmediatelybyposting thechanged Terms and Conditions in this location. By continuing to use the Web site, you are agreeing to all changes made by WORLD MEDIA Aprinted version ofthese Termsand Conditions shall beadmissible in judicial oradministrative proceedings based upon orrelating to useofthe Web site to the sameextent and subject to the sameconditions as otherbusiness documents and records originally generatedand maintained inprinted form.

The Web site iscontrolled and operated by WORLD MEDIAftom its principal office in the Commonwealth ol Virginia. USA. WORLD MEr.DIAmakes no representation thatmaterials ontheWeb siteareappropriate oravailable for use inother locations. Those who choosetoaccess theWeb site from other locations doso ontheir own initiativeand areresponsible for compliance with local laws, ifandtothe extent local laws areapplicable. The Web siteis notintended tosubject WORLD MEDIA tothe laws orjurisdiction ofany state, country or territory other than the State/Commonwealth ofVirginia and the United States ofAmerica.

Contacting Us

It you have any questions about this privacy statement the practices ofthe WORLD MEDIAsite. oryour dealings with WORLD MEDIA you may contact usat:

WORLD MEDIA ENTERPRISES INC.

fax:804-819-7498

Contact us via ' ->

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EXHIBIT 10

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8/9/2014 Exploring Dylan Thomas' Wales

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Photo: Crown copyright (2013) Visit Wales

In Swansea's renovated Maritime Quarter, steps from theharbor, book a room at stately Morgans Hotel. The PortAuthority's former brick andlimestone headquarters nowfeatures luxurious rooms with polished woodwork and highceilings, an elegant dining room anda spacious column-linedbar.

Around the cornerat The Dylan Thomas Centre, a permanentexhibit displays the poet's manuscripts, photos and othermemorabilia, including the borrowed, ink-stained suit he woreon hisfetal lecture tour in New York in1953. The center'sbookstore stocks copies ofThomas works and CD's, plusexcellent guidebooks like The Dylan Thomas Trail, a four partseries, and Dylan Thomas: Swansea, Gower and laugharnebyJamesA. Davies (University ofWales Press, 2000).

TheCentre isalso the siteoftheannual, two week DylanThomas Festival, October 27-November 9. ReflectingThomas' reputation as both a distinguished man ofletters anda beer swilling roustabout, the festival is similarlyeclectic.Onenight I hear Gillian Clarke, the distinguished white-

maned National Poet ofWales, reading from her newly pennedstory inspired by Thomas' "A Child's Christmas in Wales."Another night, the Bluestocking Lounge stages an uproariousburlesque showalternating bawdy striptease acts withsnatches of poetry.

It's a short walk to the waterside where, in Dylan ThomasSquare, a bronzestatue ofthe seated poet overlooks a yachtfilled marina. Here, too, is the Dylan Thomas Theatre, oncethe Swansea Little Theatre,where the poet performed as ateenager. Rising above, it all is the contemporaryMeridianTower, where the Grape &Olive restaurant serves upWelshspecialties like fish pie, and cawl, a hearty lamb stew. Samplethe country's finest ales anddrink infabulous 360degreeviews ofthe "harp shaped hills"and "water lidded lands"thatinspired Thomas.

In the hilltop enclave ofThe Uplands isthe Dylan ThomasBirthplace, a stucco andbrick Edwardian style"villa." Fromthesecond floor guest room, where thepoet was born, enjoysplendid views ofSwansea Bay. In the downstairs parlour,'with itsbrick fireplace guarded bywhite ceramic poodles, ashiny brass gramophone and flowered sofa,"the unclessnoozed" in Thomas' famous reminiscence in, "A Child'sChristmas in Wales." You can rent the entire four bedroomhouse fora day or longer. Or just ring up homeowner GeoffHaden and pop in for a tour.

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i copyright (201 3) V isit Wales

Steps away is Cwmdonkin Park, which Thomas fondly recalledas "a world within the world of the sea town." Guarded byenormous yew trees like a sacred Druidic site, the rollinggreens are dotted with huge oaks. The cast iron fountain thatThomas and his playmates drank from is still there. Beside agentle rill, shaded by weeping willows, a memorial boulder isinscribed with the final verse of "Fern Hill."

In The Uplands, the poet's upwardly mobile father soughtmiddle class respectability. But, down near the waterfront,Thomas came of age. Steps from Morgans Hotel, Dylanworked at the South WalesEvening Post for a year as a cubreporter before devoting himself entirely to poetry. Thenewspaper offices have moved but around the corner, theQueens Hotel, a pub Thomas and fellow reporters frequented,remains. Since Dylan's day, when the "shillingwomen" wrotethe price of their favors on the soles of their shoes, much haschanged. But the longburnished woodbar remains and Gary,the proprietor, plans to class up the joint by decorating thewalls with Dylan Thomas verses.

Facing Morgans, Wind Street, once choekablock with winemerchants, is now lined with several blocks of pubs. On aSaturday night, the No Sign Wine Bar, another Thomaswatering hole, is a people watcher's paradise packed withyoung men in tee shirts and black leather jackets and youngwomen tarted up in skintight mini-dresses and spandex.

Mumbles—or as purists put it, The Mumbles—is about fivemileswest ofSwansea. Facing the bay, the town's singlemainstreet is lined with inns, restaurants and pubs, includingTheAntelope, another Dylan Thomas haunt. Mumbles is thegateway to the Gower Peninsula, chosen as the U.K.'s first"Area of Outstanding Natural Beauty" in 1956. It's rimmedwith more than a dozenbays and another dozensandybeaches. Asa boy, Thomas camped here with his family. Asateenager, he romanced localgirls on the golden sands ofLangland and Caswell Bays, and climbed the limestone cliffs atRhossili. Today, visitors surf, ride horses, kayak andmountain bike here. They also hike the 35 mile GowerWay,which crosses the peninsula, or the 39 mile Gower leg ofthe870 mile. Wales Coastal Path, the first trail to encircle anentire country.

An hour west of Swansea lies the village of Laugharne—pronounced "larn"—where Thomas spent the last four yearsof his life. He delighted in the "legendary lazy little blackmagicalbedlam by the sea" whose splendor also captivatedSamuel Coleridge and Man- Wollstonecraft, feminist author ofA Vindication ofthe Rights of Women and mother ofFrankenstein author Mary Shelley.

Smack in the middle of town at Browns Hotel, Thomas heldcourt daily, while seated in a bay window,sipping ale andplaying cards. The 14 spacious upstairs rooms have all beenrecently renovated as have those at another Thomas haunt,The New Three Mariners Inn.

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Photo: The Robert Titley Consultancy

Thomas rented lime green Pelican House across the street forhis elderly parents. In 1951,inspired by his dyingfather,Thomas wrote the poem, "Do Not Go Gentle Into That GoodNight," urging him to "Rage,rage against the dyingofthelight." Two years later, Dylan's own body lay in state herebefore being buried under a simple white cross in nearby St.Martin's Churchyard.

Photo: The Robert Titley Consultancy

Also acrossfromthe hotel, CorranBooks Ispresidedover bythe leonine George Tremlett, whowrote a 1991 Dylan Thomasbiography and co-wrote a 1986 autobiography by CaitlinMacnamara, Dylan's golden haired wife and muse. In the tell-all book,whichdetails the couple's enduring love as wellastheir frequent infidelities and drunken brawls, Caitlin recalledspending the happiest years of their marriage at Sea View, ayellow and white house around the corner.

It's a short walkto the RiverTaf Estuary, guarded by12"'century Laugharne Castle. In adjacent Castle House,novelist Richard Hughes wrote his 1929bestsellerAHighWind inJamaica. In the house's gazebo, Thomas later wrotehisshort story collection, Portrait ofthe Artist as a YoungTk>y. Here the two writers and their wives often entertainedguests like Welsh painter AugustusJohn, who,years earlier,seduced a teenaged Caitlin to pose for a portrait.

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8/9/2014 Exploring Dylan Thomas' Wales

Photo: Clown copyright C2013) Visit Wales

Just beyond Castle House in his whitewashed Writing Shed,Thomas wrote his famous play for voices, Under Milk Wood,while contemplating cattle across the estuary on Sir John'sHill. BobStevens, a gentleman farmer who keeps cattle there,has laid out a two mile hilltop trail that's modeled after the30"' birthday walk Thomas recounted in "Poem in October."From the hillyou can see clear across the estuaiy's opalescentblue waters rimmed, as Thomas put it, with "mussel pooledand heron priested" shores.

Photo: Crown copyright (2013) Visit

Wales

Steps away on a cliffjust above the estuary Is The DylanThomas Boathouse, the "seashaken house" where the poetlivedwith his wife, three children and dog Mably. Visitthesmall parlor with its coal fireplace and humble 1940'sfurniture and watchfilms about Dylan Thomas in an upstairsbedroom. Have tea and a slice of currant-filled Welsh cake onthe slate terrace. Then hie back to Browns, as DylanThomaswouldhave done, to gossipwith the locals, whiledowning acouple pints of ale with the same "brass bright depths" and"live white lather" that inspired the poet.

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Photo: Crown copyright (2013) Visit Wa

The area code for Wales is 44.

Where to Stay, Eat & Drink:

Pare Thistle Hotel - Steps from Cardiff Castle, find well-appointed rooms, and a popular restaurant. The Social forwell-wrought Welsh comfort food. Park Place, CardiffCFto 3UI), (0871) 376 9011. wyw^justle._cpm

Morgans Hotel - Luxuriate in elegant rooms, and enjoy aspacious bar and an excellent restaurant. Adelaide St..Swansea SAi 1RR, (01792) 48 48 48.

Queens Hotel - Patronized by young Dylan, the pub is stillgoing strong. Gloucester Place. Swansea SA 1 iTY, (01792)521 531.

No Sign Wine Bar - Swansea's oldest pub Is a no-nonsenseplace for partying and people-watching. 56 Wind St.,Swansea SAi lEG. (01792) 465 300.

Grape & Olive - Welsh lamb, seafood and ales pluspanoramic views. Meridian Tower, Trawler Rd., SwanseaSAi iJW, (01792) 462 617.

Browns Hotel - Book a stylish room, then lift a few pintswith the locals. KingStreet, Laugharne SA33 4RY, (01994)427 688. ww.brov^_-hgXel.co.uk

The New Three Mariners Inn - Along with six refurbishedrooms come bountiful breakfasts with sublime Welshbacon. Victoria St., Laugharne SA33 4SA, (01994) 427426.

What to See and D<>:

Dylan Thomas 100 Festival - Celebrating the poet's 1oolhbirthday in 2014 with scores of events in Wales, Londonand New York, wvyv.dylanthomasioo.org

"Dylan Country" Tours - Swansea and Laugharne walkingtours are offered by lively AnneHaden (vww.anmefroinwatesxom). Van tours of SouthWales ai 1. pi <«\ ided by Mike Davies of Dragon Tours(www\dragon-tours.com). In 2014, Literature Wales(tvww.literaturewales.org) offers 17 unique day ando\ ermght torn s, 111c hiding bus. boat, carnage andhorseback tides.

The Dvlan Thomas Centre - Home ofthe annual DylanThomas Festival, it has an excellent permanent exhibit andbookstore. Somerset PI. Swansea SAi 1RR. (01792) 463980. wyyyy.dylanthomas.com

DylanThomas Birthplace - The Edwardian-style "villa" iscrammed with period furniture and memorabilia. 5

http://tra\elsq uire.com/exploring-dylan-thomas-wal es/

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Hip-hop, DylanThomas and Wales : BlackHistory Month : BlogSeries : News and Features

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Hip-hop, Dylan Thomas and Wales

Discovering Black History in Walestorn one of America * most celebrated writers. Kevin Powell a» he celebrate*the birthdayof Martin Luther King Jr. and HackHistory Month by discovering

the tlnkt between American black historyand Wales Mritf

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Hip-hop, Dylan Thomas and Wales

By Kevin Powell

I have been in love with and a participant in hip-hop culture since I was 13. Coming of age in the New York City metro area, the birthplaceof hip-hop, is the reason why, no question. Working-class Black and Latino youth created this music, this energy, and we really had no ideahow much it would affect the entire planet.

Early on I tagged graffiti with magic markers wherever I could, and danced to hip-hop at every kind ofparty imaginable. Somewhere between my college years and the mass explosion of hip-hop in the early1990s I started writing poetry and joined the hip-hop-inspired spoken word movement happening in NewYork. Then when music legend Quincy Jones launched Vibe magazine, to document hip-hop from allangles, I was very fortunate to get on board as one of the staff writers. I interviewed major rap stars ofthe era, including the late Tupac Shakur on several occasions. Years after I would produce the very firstexhibit on hip-hop culture in America, via the Rock and Roll Hall of Fame.

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v/wi*Beyond all of this I have lectured about hip-hop culture, and the differences between the culture and whatI call "the hip-hop industry," across the United States and globally. I have been blown away time againhow hip-hop is the dominant youth culture on the planet. Even in Wales, the United Kingdom, where Irecently spent significant time there is no greater evidence of this than a local organization based inCardiff, the Welsh capital, called Grassroots Cardiff: http://www.grassrootscardiff.com/ «P

I was invited to Grassroots to speak to its youth, who range in age from 16-25 and are all working-class, just asthe famous Welsh coal miners of generations past. Where those miners formed all-male choirs to give voice to theirpassions today the Welsh young people of today have hip-hop. Grassroots Cardiff is a combination multimedia space,self-help center, and safe space for these young people. Three of them performed raps for their peers and myselfand I felt as if I were back somewhere in the U.S.: they wore the "uniforms" of American hip-hop, the baseballcaps, the tee shirts or hoodies, the work boots or sneakers (what they call "daps") in Wales; they had themannerisms of hip-hop down as if they had created it in Wales, not Black and Latino youth in New York City; andthey rapped about their Wales, about their hopes, fears, sorrows, and dreams.

This was hip-hop at its finally, fully loaded from Wales. I took to a microphone to speak with these youth anddiscussed my main reason for being in Wales: the nation's greatest writer ever, Dylan Thomas. Some youth knew ofDylan Thomas and some did not. It did not matter. I shared with them Thomas' short 39-year life and his greatimpact, from his roots in Wales, on African American writers like myself. The Grassroots young people were verysurprised, and I can see a feel of pride swell in the room. For here they were, Welsh young people inspired by anAfrican American art form called hip-hop, yet I, a Black man from America, was telling them that an artist from Wales had affected megreatly.

This is one of the great wonders of Wales, especially given that it has had multi-ethnic communities forcenturies, including the first such neighborhood of its kind, Tiger Bay, right here in Cardiff. So there is anopenness and a crossing of many cultural boundaries here in Wales passed from generation to generation,from African American artist and humanitarian Paul Robeson working with Welsh coal miners in the 1920sand 1930s, to African American me, writer, activist, hip-hop historian, bonding with these Welsh hip-hoppers in the 21st century.

Part of the bond, for sure, is the mutual love and appreciation of music that the Welsh and BlackAmericans share. Coal miners came together to form all-male singing choirs as a way to expressthemselves freely, in their own language, on their own terms. Similarly hip-hop is a mostly all-malecreated art form, created by working-class people just as those Welsh coal miners were, as a way tospeak for themselves, to make something magical seemingly from nothing. I highly recommend to anyAfrican American who visits Wales to not only tour the coal mines, and to spend some time listening toone of the all-male choirs that still exist, but to also stop by places like Grassroots Cardiff.

http://wvvw.americas.visirwales.eom/news-and-features/blog/black-histoi7-month/black-history-month-6tll/7/2014 4:24:12PM]

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Hip-hop, Dylan Thomas and Wales : BlackHistory Month : Blog Series : News and Features

I was able to visit each of these things and it all deepened not only my appreciation for the people and culture of Wales, but also for myown roots as an African American, and how much my culture means to the world.

Biography

Kevin Powell is one of America's most celebrated writers and leaders. He is the author or editor of 11 books, a noted public speaker wholectures globally, a long-time community organizer and humanitarian, and the president and co-founder of BK Nation, a new American nonprofit organization. He can be emailed at [email protected]. Or follow him on Twitter @kevin_powell

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