The legal complaint cited the last verse, saying the line about "killing dogs" was likely to incite violence.
The complaint cites numerous transactions, however, and prosecutors could broaden the charges later.
The complaint filed on Friday cited interviews with several former Interboro employees.
The complaint cites the experience of a number of Stratton customers.
The complaint cited more than 200 reports from members of the public who were identifiable on images hosted by the service.
Such a complaint, if issued, would cite the Tour's conflicting event regulations and television releases as being unduly restrictive.
To support those accusations, the complaint cites a 1985 police strategy intended to end drug dealing at nearly 70 street intersections in minority neighborhoods.
The complaint also cites a 1988 police search for a man who was sexually assaulting women in the downtown area.
The earlier recall produced more than 14,000 complaints to regulators, but those complaints cited just 41 deaths.
The complaint also cites similar ads on television and radio.