 The complaint stated that over 150,000 unauthorized clips of Viacom's programming, such as "SpongeBob SquarePants" and "The Daily Show", had been made available on YouTube, and that these clips had collectively been viewed 1.5 billion times.Viacom claimed that YouTube had infringed on its copyrights by performing, displaying, and reproducing Viacom's copyrighted works.Furthermore, the complaint contended that the defendants "engage in, promote and induce" the infringement, and that they had deliberately built up a library of infringing works in order to increase the site's traffic (and advertising revenue).