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U.s. District Court in south florida hears complaint for copyright infringement. Each of the Defendants copied and distributed most of a website containing 57 movies. Plaintiff alleges each Defendant is liable for: Direct infringement in violation of 17 U.S.c. SSSS 106 and 501.
U.s. District Court in south florida hears complaint for copyright infringement. Each of the Defendants copied and distributed most of a website containing 57 movies. Plaintiff alleges each Defendant is liable for: Direct infringement in violation of 17 U.S.c. SSSS 106 and 501.
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U.s. District Court in south florida hears complaint for copyright infringement. Each of the Defendants copied and distributed most of a website containing 57 movies. Plaintiff alleges each Defendant is liable for: Direct infringement in violation of 17 U.S.c. SSSS 106 and 501.
Авторское право:
Attribution Non-Commercial (BY-NC)
Доступные форматы
Скачайте в формате PDF, TXT или читайте онлайн в Scribd
MALIBU MEDIA, LLC, ) ) Plaintiff, ) Civil Action Case No. ) v. ) ) JOHN DOES 1-7, ) ) Defendants. ) )
COMPLAINT FOR COPYRIGHT INFRINGEMENT AND DEMAND FOR JURY TRIAL
Plaintiff, Malibu Media, LLC (Plaintiff), for its complaint against John Does 1-7 (collectively the Defendants) alleges as follows: Introduction 1. This matter arises under the United States Copyright Act of 1976, as amended, 17 U.S.C. 101 et seq. (the Copyright Act). 2. Each of the Defendants copied and distributed most of a website containing 57 movies. This is known as a siterip. The file containing the subject website is so large that the Defendants computers must have worked collaboratively with each other through the process described below for numerous weeks or months to effectuate a complete download and redistribution of the subject website. 1
3. Throughout this Complaint the word Works refers to 57 movies contained on the subject website. 4. Through this suit, Plaintiff alleges each Defendant is liable for: Direct copyright infringement in violation of 17 U.S.C. 106 and 501; and
1 The hit dates listed in the exhibits are not evidence of when a particular Defendant started the download but are merely evidence of when the investigators server recorded an IP address sending a particular piece of data. Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 1 of 12 www.torrentlitigation.com 2
Contributory copyright infringement. Jurisdiction And Venue 5. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 1331 (federal question); and 28 U.S.C. 1338 (patents, copyrights, trademarks and unfair competition). 6. As set forth on Exhibit A, each of the Defendants acts of copyright infringement occurred using an Internet Protocol address (IP address) traced to a physical address located within this District, and therefore pursuant to Florida Statute 48.193(1)-(2), this Court has personal jurisdiction over each Defendant because each Defendant committed the tortious conduct alleged in this Complaint in the Southern District of Florida, and (a) each Defendant resides in the Southern District of Florida, and/or (b) each Defendant has engaged in continuous and systematic business activity, or has contracted anywhere to supply goods or services in the Southern District of Florida. 7. Venue is proper in this District pursuant to 28 U.S.C. 1391(b) and (c), because: (i) a substantial part of the events or omissions giving rise to the claims occurred in this District; and, (ii) a Defendant resides (and therefore can be found) in this District and all of the Defendants reside in this State; additionally, venue is proper in this District pursuant 28 U.S.C. 1400(a) (venue for copyright cases) because each Defendant or each Defendants agent resides or may be found in this District. Parties 8. Plaintiff is a limited liability company organized and existing under the laws of the State of California and has its principal place of business located at 31356 Broad Beach Road, Malibu, California 90265. 9. Each Doe Defendant is known to Plaintiff only by an IP address. See Exhibit A. Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 2 of 12 www.torrentlitigation.com 3
10. An IP address is a number that is assigned by an Internet Service Provider (an ISP) to devices, such as computers, that are connected to the Internet. 11. The ISP to which each Defendant subscribes can correlate the Defendants IP address to the Defendants true identity. Joinder 12. Pursuant to Fed. R. Civ. P. 20(a)(2), each of the Defendants was properly joined because, as set forth in more detail below, Plaintiff asserts that: (a) each of the Defendants is jointly and severally liable for the infringing activities of each of the other Defendants, and (b) the infringement complained of herein by each of the Defendants was part of a series of transactions, involving the exact same torrent file containing pieces of Plaintiffs copyrighted Works, and was accomplished by the Defendants acting in concert with each other, and (c) there are common questions of law and fact; indeed, the claims against each of the Defendants are identical and each of the Defendants used the BitTorrent protocol to infringe Plaintiffs copyrighted Works. Factual Background I. Plaintiff Owns the Copyright to a Motion Picture 13. Plaintiff has obtained the registration for, or has applied to obtain the registration, for 16 of the 57 movies contained in the siterip with the United States Copyright Office. 14. An internet screen shot from www.copyright.gov of each Registration, along with a copy of any pending application for copyright registration, is attached as Composite Exhibit B. 15. The date on which the United States Copyright Office Registered the works and the date IPP Limited recorded each Defendants infringement is set forth on Exhibit C. Exhibit C demonstrates that each infringement occurred after the registration date.
Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 3 of 12 www.torrentlitigation.com 4
II. Defendants Used BitTorrent To Infringe Plaintiffs Copyright 16. BitTorrent is one of the most common peer-to-peer file sharing protocols (in other words, set of computer rules) used for distributing large amounts of data; indeed, it has been estimated that users using the BitTorrent protocol on the internet account for over a quarter of all internet traffic. The creators and users of BitTorrent developed their own lexicon for use when talking about BitTorrent; a copy of the BitTorrent vocabulary list posted on www.Wikipedia.com is attached as Exhibit D. 17. The BitTorrent protocols popularity stems from its ability to distribute a large file without creating a heavy load on the source computer and network. In short, to reduce the load on the source computer, rather than downloading a file from a single source computer (one computer directly connected to another), the BitTorrent protocol allows users to join a "swarm" of host computers to download and upload from each other simultaneously (one computer connected to numerous computers). A. Each Defendant Installed a BitTorrent Client onto his or her Computer 18. Each Defendant installed a BitTorrent Client onto his or her computer. 19. A BitTorrent Client is a software program that implements the BitTorent protocol. There are numerous such software programs including Torrent and Vuze, both of which can be directly downloaded from the internet. See www.utorrent.com and http://new.vuze-downloads.com/. 20. Once installed on a computer, the BitTorrent Client serves as the users interface during the process of uploading and downloading data using the BitTorrent protocol. B. The Initial Seed, Torrent, Hash and Tracker 21. A BitTorrent user that wants to upload a new file, known as an initial seeder, starts by creating a torrent descriptor file using the Client he or she installed onto his or her Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 4 of 12 www.torrentlitigation.com 5
computer. 22. The Client takes the target computer file, the initial seed, here the subject website containing the copyrighted Works, and divides it into groups of bits known as pieces. 23. The Client then gives each one of the computer files pieces, in this case, pieces of the copyrighted Works, a random and unique alphanumeric identifier known as a hash and records these hash identifiers in the torrent file. 24. When another peer later receives a particular piece, the hash identifier for that piece is compared to the hash identifier recorded in the torrent file for that piece to test that the piece is error-free. In this way, the hash identifier works like an electronic fingerprint to identify the source and origin of the piece and that the piece is authentic and uncorrupted. 25. Torrent files also have an "announce" section, which specifies the URL (Uniform Resource Locator) of a tracker, and an "info" section, containing (suggested) names for the files, their lengths, the piece length used, and the hash identifier for each piece, all of which are used by Clients on peer computers to verify the integrity of the data they receive. 26. The tracker is a computer or set of computers that a torrent file specifies and to which the torrent file provides peers with the URL address(es). 27. The tracker computer or computers direct a peer users computer to other peer users computers that have particular pieces of the file, here the copyrighted Works, on them and facilitates the exchange of data among the computers. 28. Depending on the BitTorrent Client, a tracker can either be a dedicated computer (centralized tracking) or each peer can act as a tracker (decentralized tracking). C. Torrent Sites 29. Torrent sites are websites that index torrent files that are currently being made available for copying and distribution by people using the BitTorrent protocol. There are Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 5 of 12 www.torrentlitigation.com 6
numerous torrent websites, including www.TorrentZap.com, www.Btscene.com, www.ExtraTorrent.com, and www.piratebay.org. 30. Upon information and belief, each Defendant went to a torrent site to upload and download Plaintiffs copyrighted Works. D. Uploading and Downloading Works Through a BitTorrent Swarm 31. Once the initial seeder has created a torrent and uploaded it onto a torrent site then other peers begin to download and upload the computer file to which the torrent is linked (here the copyrighted Works) using the BitTorrent protocol and BitTorrent Client that the peers installed on their computers. 32. The BitTorrent protocol causes the initial seeds computer to send different pieces of the computer file, here the copyrighted Works, to the peers seeking to download the computer file. 33. Once a peer receives a piece of the computer file, here a piece of the Copyrighted Works, it starts transmitting that piece to the other peers. 34. In this way, all of the peers and seeders are working together in what is called a swarm. 35. Here, each Defendant peer member participated in the same swarm and directly interacted and communicated with other members of that swarm through digital handshakes, the passing along of computer instructions, uploading and downloading, and by other types of transmissions. 36. In this way, and by way of example only, one initial seeder can create a torrent that breaks a movie up into hundreds or thousands of pieces saved in the form of a computer file, like the Works here, upload the torrent onto a torrent site, and deliver a different piece of the Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 6 of 12 www.torrentlitigation.com 7
copyrighted work to each of the peers. The recipient peers then automatically begin delivering the piece they just received to the other peers in the same swarm. 37. Once a peer, here a Defendant, has downloaded the full file, the BitTorrent Client reassembles the pieces and the peer is able to view the movie. E. Plaintiffs Computer Investigators Identified Each of the Defendants IP Addresses as Participants in a Swarm That Was Distributing Plaintiffs Copyrighted Works
38. Plaintiff retained IPP, Limited (IPP) to identify the IP addresses that are being used by those people that are using the BitTorrent protocol and the internet to reproduce, distribute, display or perform Plaintiffs copyrighted works. 39. IPP used forensic software named INTERNATIONAL IPTRACKER v1.2.1 and related technology enabling the scanning of peer-to-peer networks for the presence of infringing transactions. 40. IPP extracted the resulting data emanating from the investigation, reviewed the evidence logs, and isolated the transactions and the IP addresses associated therewith for the file identified by the SHA-1 hash value of 121AC0B46088E7C235A23D4379BE65A1840E9B77 (the Unique Hash Number). 41. The IP addresses, Unique Hash Number and hit dates contained on Exhibit A accurately reflect what is contained in the evidence logs, and show: (A) Each Defendant had copied a piece of Plaintiffs copyrighted Works identified by the Unique Hash Number; and (B) Therefore, each Defendant was part of the same series of transactions. 42. Through each of the transactions, each of the Defendants computers used their identified IP addresses to connect to the investigative server from a computer in this District in order to transmit a full copy, or a portion thereof, of a digital media file identified by the Unique Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 7 of 12 www.torrentlitigation.com 8
Hash Number. 43. IPPs agent analyzed each BitTorrent piece distributed by each IP address listed on Exhibit A and verified that re-assemblage of the pieces using a BitTorrent Client results in a fully playable digital motion picture of the Works. 44. IPPs agent viewed the Works side-by-side with the digital media file that correlates to the Unique Hash Number and determined that they were identical, strikingly similar or substantially similar. Miscellaneous 45. All conditions precedent to bringing this action have occurred or been waived. 46. Plaintiff retained counsel to represent it in this matter and is obligated to pay said counsel a reasonable fee for its services. COUNT I Direct Infringement Against Does 1-7
47. The allegations contained in paragraphs 1-46 are hereby re-alleged as if fully set forth herein. 48. Plaintiff is the owner of the copyrights for the Works, each of which contains an original work of authorship. 49. By using the BitTorrent protocol and a BitTorrent Client and the processes described above, each Defendant copied the constituent elements of the Works that are original. 50. Plaintiff did not authorize, permit or consent to Defendants copying of its Works. 51. As a result of the foregoing, each Defendant violated Plaintiffs exclusive right to: (A) Reproduce the Works in copies, in violation of 17 U.S.C. 106(1) and 501; (B) Redistribute copies of the Works to the public by sale or other transfer of ownership, or by rental, lease or lending, in violation of 17 U.S.C. 106(3) and 501; Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 8 of 12 www.torrentlitigation.com 9
(C) Perform the copyrighted Works, in violation of 17 U.S.C. 106(4) and 501, by showing the Works images in any sequence and/or by making the sounds accompanying the Works audible and transmitting said performance of the Works, by means of a device or process, to members of the public capable of receiving the display (as set forth in 17 U.S.C. 101s definitions of perform and publically perform); and (D) Display the copyrighted Works, in violation of 17 U.S.C. 106(5) and 501, by showing individual images of the Works nonsequentially and transmitting said display of the Works by means of a device or process to members of the public capable of receiving the display (as set forth in 17 U.S.C. 101s definition of publically display). 52. Each of the Defendants infringements was committed willfully within the meaning of 17 U.S.C. 504(c)(2). 53. Plaintiff has suffered actual damages that were proximately caused by each of the Defendants including lost sales, price erosion and a diminution of the value of its copyrights. WHEREFORE, Plaintiff respectfully requests that the Court: (A) Permanently enjoin each Defendant and all other persons who are in active concert or participation with each Defendant from continuing to infringe Plaintiffs copyrighted Works; (B) Order that each Defendant delete and permanently remove the torrent file relating to Plaintiffs copyrighted Works from each of the computers under each such Defendants possession, custody or control; (C) Order that each Defendant delete and permanently remove the copy of the Works each Defendant has on the computers under Defendants possession, custody or control; (D) Award Plaintiff the greater of: (i) statutory damages in the amount of $150,000 per Defendant, per registered Work infringed, pursuant to 17 U.S.C. 504-(a) and (c), or (ii) Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 9 of 12 www.torrentlitigation.com 10
Plaintiffs actual damages and any additional profits of the Defendant pursuant to 17 U.S.C. 504-(a)-(b); (E) Award Plaintiff its reasonable attorneys fees and costs pursuant to 17 U.S.C. 505; and (F) Grant Plaintiff any other and further relief this Court deems just and proper. COUNT II Contributory Infringement Against Does 1-7
54. The allegations contained in paragraphs 1-46 are hereby re-alleged as if fully set forth herein. 55. Plaintiff is the owner of the copyrights for the Works, each of which contains an original work of authorship. 56. By using the BitTorrent protocol and a BitTorrent Client and the processes described above, each Defendant copied the constituent elements of each of the Works that are original. 57. By participating in the BitTorrent swarm with the other Defendants, each Defendant induced, caused or materially contributed to the infringing conduct of each other Defendant. 58. Plaintiff did not authorize, permit or consent to Defendants inducing, causing or materially contributing to the infringing conduct of each other Defendant. 59. Each Defendant knew or should have known that other BitTorrent users, here the other Defendants, would become members of a swarm with Defendant. 60. Each Defendant knew or should have known that other BitTorrent users in a swarm with it, here the other Defendants, were directly infringing Plaintiffs copyrighted Works by copying constituent elements of the Works that are original. Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 10 of 12 www.torrentlitigation.com 11
61. Indeed, each Defendant directly participated in and therefore materially contributed to each other Defendants infringing activities. 62. Each of the Defendants contributory infringements were committed willfully within the meaning of 17 U.S.C. 504(c)(2). 63. Plaintiff has suffered actual damages that were proximately caused by each of the Defendants including lost sales, price erosion, and a diminution of the value of its copyright. WHEREFORE, Plaintiff respectfully requests that the Court: (A) Permanently enjoin each Defendant and all other persons who are in active concert or participation with each Defendant from continuing to infringe Plaintiffs copyrighted Works; (B) Order that each Defendant delete and permanently remove the torrent file relating to Plaintiffs copyrighted Works from each of the computers under each such Defendants possession, custody or control; (C) Order that each Defendant delete and permanently remove the copy of the Works each Defendant has on the computers under Defendants possession, custody or control; (D) Find that each Defendant is jointly and severally liable for the direct infringement of each other Defendant; (E) Award Plaintiff the greater of: (i) statutory damages in the amount of $150,000 per Defendant, per registered Work infringed, pursuant to 17 U.S.C. 504-(a) and (c), or (ii) Plaintiffs actual damages and any additional profits of the Defendant pursuant to 17 U.S.C. 504-(a)-(b); (F) Award Plaintiff its reasonable attorneys fees and costs pursuant to 17 U.S.C. 505; and (G) Grant Plaintiff any other and further relief this Court deems just and proper. Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 11 of 12 www.torrentlitigation.com 12
DEMAND FOR A JURY TRIAL Plaintiff hereby demands a trial by jury on all issues so triable. Respectfully submitted,
By: /s/ M. Keith Lipscomb M. Keith Lipscomb (429554) klipsomb@lebfirm.com LIPSCOMB EISENBERG & BAKER, PL 2 South Biscayne Blvd. Penthouse 3800 Miami, FL 33131 Telephone: (786) 431-2228 Facsimile: (786) 431-2229 Attorneys for Plaintiff
Case 2:12-cv-14171-KMM Document 1 Entered on FLSD Docket 05/11/2012 Page 12 of 12 www.torrentlitigation.com JS 44 (Rev. 2108) CIVIL COVER SHEET The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the fi li ng and service of pleadings or other papers as required by law except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is reqUired for the usc of the Clerk of Court for the purpose ofmit iating the civil docket sheet. (SEE INSTRUCTI ONS ON TilE REVERSE OF THE FORM.) NOTICE: Attorn eys MlJST I ndicate All Re-filed C ases Below. I. (a) PLA I NTIFFS MALIDU MEDIA, LLC DEFENDANTS JOHN DOES 1-7 (b) County of Residence of First Listed Plaintiff Los Angeles County (EXCEPT IN U.S. PLAINTIFF CASES) County of Residence of Fi rst Listed Defendant Martin County (I N U.S. PLAI NTIFF CASES ONLY) {c) Attorney's (Fi rm Address, a nd Telephone Number) NOTE: IN LAND CONDEMNATION CASES. USE THE LOCATION OF THE TRACT LAND INVOLVED. Lipscomb, Eisenberg & Baker, PL, 2 S. Biscayne Boulevard, Penthouse 3800, Miami, FL 33 13 1, (786) 431-2228 Allomeys (lrKnown) (d) Check County Where Action Arose- 0 MIAMI DADE 0 MONROE 0 BROWARD 0 PALM DEACH ./J MARTrN 0 ST. LUCIE 0 INDIAN RIVER 0 OKEECHOBEE HIGHLANDS II. BASIS OF J URISDI CTION (Pioccanxin OncDoxOnly) Ill. CITIZENSHIP OF PRI NCIPAL PARTIEScrlaccon -x" in OncBoxrorPtaintirr .;o I U.S. Government 0 J Federal Ques tion Plainti ff ( U.S. Government Nol l\ Pnrty) 0 2 U.S. Government 0 4 Divers by Dcfcndent (Indicate Citizens hip of Pa rties in Item fll ) A IV N TURE OF SUI T (Place an -x" in One Box Only) CONTRACT TORTS 0 I I 0 Insurance PERSONAL INJURY PERSONAL INJURY 0 120 Marine 0 3 10Airplllne 0 J62 Personal Injury 0 130 Miller Act 0 3 15 Airplane Product Med. Malpnet iee 0 140 Negotiable Instrument Liabi lity 0 36S Pcn:onal Injury 0 ISO Recovery of Overpayment 0 }20 ASSI UII , Libel & Product Liabilily & Enforcement of J udgment Slander 0 368 Asbes tos Person! 0 IS I Medicare Act 0 330 Federa l Employers' Injury Product 0 I !52 Recovery of Linbility Liability St udcn1 Loans 0 340 Muinc PERSONAL PROPEitTY (E,.cl. Veterans) 0 }45 M u inc Produce 0 370 Other Fnud 0 I Recovery of liability 0 371 Trulh in Lcndina ofVeter11n's Benefits 0 3SO Mo1or Vehicle 0 380 Other Personal 0 160 Stockholders' Suits 0 MotorVchiclc Propert y Oanucc 0 190 Other Cont rnct Proll uct 0 J8S Properly Da mage 0 19!5 Controcr Product Linbilit y 0 360 Other Personal Product Linbilll y 0 196 Franchise ln ury REAL PROPERTY CIVIl. RI GHTS PRISONER PETITIONS 0 210 Land Condemnation 0 44 1 Votinc 0 510 Motions to Vocate 0 220 Foreclosure .:J 442 Employment Sentence 0 230 Rent Letse &. Ejectment 0 443 II outi ng/ I Iabus Cor pus: 0 240 Tort s 10 La nd Acconmodut ions 0 General 0 Tort Product Linbilit y 0 444 Welfare 0 S3S Death Pc1wl1y 0 290 All Other Rcal l,rope rt y O 445 Amcr. w/Oisabilitics Employment o 540 Mandamus&.. Other 0 446 Amer. w/ Diubilitics Other o $SO Civil Righ11 0 440 Other Civil Rights 0 S5!5 Prison Condilion (For Oivcrsi1y Ca.scs Only) PTF Ci tize n of This State 0 Ci tizen of Another State 0 Citizen or Subject of a 0 FORFEIT REIPF.NALTY 0 6 10 Agriculture 0 0 620 Other Food & Drug 0 0 62S Drua Rchucd Seizure or Properly 21 USC 881 0 630 Liquor Laws 0 640 R.R. & Truck Jil 0 650 Air line Rccs. 0 0 660 Occupuliono.l 0 Safctylll cnllh 0 690 Other ROR 0 7 10 Fair l t bor Slilndards 0 Act 0 0 720 Labor/ M gm1. Relations 0 0 730 LnboriM umt.Rcport lnu 0 &. Disclosure Act 0 0 740 Railwoy l t bor Act 0 790 Other Lt bor Litigation 0 0 791 Em pl. Ret. Inc. Seeurit Act 0 1M 0 462 Nnturalizntion AJ>rllicat lon 0 463 ll abeu Corpus -Alien Detainee 0 46S Other lmmigntion Actions and One Box for Ocfendanr) DEF PTF DEF 0 I lncorpor.:tt ed or Jlrine:ipal Place 0 0 4 of Ousincss In This St i le 0 Incorporated and Principe I Place ofDus iecss In Another State 0 0 ' 0 Foreign Nuion 0 0 6 OTHF. A 422 Appcal28 USC 1$8 0 400 State R eapportionmcnt 423 W ithdraw11 0 4 10 Antitrust 28 usc 1$7 0 430 Banks and Oanking 0 4SO Commerce PROPER rY RIGUTS 0 460 Deportation 820 Copyrights 0 470 Racketeer Influenced and 830 Pat ent Corrupt Orgonizations 840 Tr-.dcnuuk 0 480 Consumer Credi t 0 490 Coblc/SII TV 0 810 Selective Service SOCIAL Sr. URITY 0 8SO Securilies/Commoditiesl 861 utA (IJ9srn Exchange 862 Block Lung (92J) 0 87S C us tomer C hallenge 86J DIWC/DIWW (403( 8 )) 12 usc J4 10 864 SSID Til le XVI 0 890 Ot her Statut ory Actions 86$ RSI (40S(g)) 0 89 1 Agriculturo l Acts FEDERAL TAX SUITS 0 892 Cconon, ic Stabilization Acl 870 Taxes (U.S. Plainti ff 0 893 Environmental Matters or Defend :ant) 0 894 Energy A llocttion Act 871 IRS-Third Parly 0 89S Freedom of Information Act 26 usc 7609 0 900 Appcnl of Fcc Under Equal Access 10 J ustice 0 9!50 ConUilulionality of State St atutes V. ORIG IN .fJ I Ori ginal Proceedi ng ( Place :1n x in One Uox Only) 0 2 Removed from 0 3 State Court Re-fi lcd 0 (see VI below) 4 Reinstated or 0 Reopened Transferred from 5 another district (specify) 0 6 Mult idi stri ct Litigation 0 7 Appeal to Distri ct Judge from Magistrate Jud mcnt V I. R ELA TED/ RE-FILED CASE(S). (Sec instrucl ions second page): n) Re-tiled Case 0 YES ,jlJ NO JUDGE b) Related Cases 0 YES DOCKET NUMBER Cite the U.S. Civil Statute under which you arc fil ing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversi ty): VII. CAUSE OF ACTI ON 17 U.S.C. 101 -Copyright Infringement VIII. R EQUESTED I N COMP LAINT: LENGTil OF TRIAL via _L_ days est imated (for both sides to try entire case) 0 CIIECK IF THIS IS A CLASS ACTION DEMANDS UNDER F.R.C.P. 23 ,000. ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE CHECK YES only if demanded in complaint: JURY DEMAND: Yes 0 No DATE 5- FOR OFFICE USE ONLY AMOUNT RECEIPT M IFP Case 2:12-cv-14171-KMM Document 1-1 Entered on FLSD Docket 05/11/2012 Page 1 of 1 www.torrentlitigation.com EXHIBIT A SFL10 SHA-1 Hash: 121AC0B46088E7C235A23D4379BE65A1840E9B77 Title X-Art Siterip #1 Rights Owner: Malibu Media
Case 2:12-cv-14171-KMM Document 1-2 Entered on FLSD Docket 05/11/2012 Page 1 of 1 www.torrentlitigation.com /9/12 Public Catalog WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be avail abl e between 6 :30am and 8 :30am U.S. East ern Time on Sunday, April 8 due to routine syst em maintenance. We apologi ze for any Inconveni ence to our user s. Help Search History Titles Start ovor Copyright Catalog (1978 to present) Search Request: Left Anchored Title = carlie beautifi.tl blowjob Search Results: Displaying I of 1 entries prevlous II Carlie Beautijill Blowjob. Type of Work: Motion Picture Registration Number I Date: PA0001762079 / 2011- ll -21 Application Title: Car lie Beautiful Blowjob . Title: Car lie Beautiful Blowjob . Description: Electronic file (eService) Copyright Claimant: Malibu Media LLC. Address: 3 1356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date of Publication: 20 l 0-03-26 Nation of First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names : Malibu Media LLC j II I Save, Print a nd Email I Select Download Fonmt Full Record G I Format for Print/Save J l --- IP nt Pr vn Email l EXHIBIT B - ocatalog.loc.gov/cgi-bin/Pwebrecon.cgl? Sea rch_Arg,carlle+beautiful+blowjob&Search_ Code=T ALL& . .. 11 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 1 of 17 www.torrentlitigation.com /9/12 Public Catalog WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be availabl e between 6 :30am and 8 :30am U.S. Eastern Time on Sunday, Apr il 8 due to routine system maintenance. We apologize for any inconvenience to our users. Help Search History Titles Start Over Copytight Catalog (1978 to present) Search Request: Left Anchored Title = carlie big toy orgasm Search Resultc;;: Displaying 1 of 1 ennies pn1vfous II next )>I Carlie Big Toy Orgasm. Type of Work: Motion Picture Registration Number I Date: PA0001776839 I 2012-02-21 Application Title: Carlie Big Toy Orgasm Title: Car lie Big Toy Orgasm Description: Electronic file (eService) Copyright Oai.mant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date ofPublication: 2010-03-22 Nation of First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire 1notion pictw"e. Names: Malibu Medi-:1. LLC previous II next I Save, Print and Email (lleln I Select Download Format Full Record B ( Format for Print/Save J IF n tPI' vn11 r J Emaill ocatalog .loc.gov/cgi-bin/Pwebrecon .cgi?Search_Arg=carlie+big+toy+orgasm&Search _Code= T ALL&PI . .. 1/ Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 2 of 17 www.torrentlitigation.com /9/ 12 Public Catalog WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be available between 6: 30am and 8:30am U.S. Eastern Time on Sunday, April 8 due to routine system maintenance. We apologize for any inconvenienc e to our users. Help Search History Titles Start ovar Copyright Catalog (1978 to present) Search Request: Left Anchored Title = cartie leila strawberries and wine Search Results: DLc;playing I of 1 entries Carlie Leilc1 Strawberries and Wine. Type of Work: Motion Picture Registration Number I Date: PA0001762081 I 2011-11-18 Application Title: Carlie Leila Strawbenies and Wine . Title: Carlie Leila Strawbenies and Wine. Desctiption: Electronic file (eService) Copyright Claimant: Malibu Media LLC. Address: 3 1356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 201 0 Date of Publication: 20 I 0-05-07 Nation of First Publication: United States Authorship on Application: Malmu Media ILC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media LLC I Save, Print and Email I Select Download Fonnat Full Record B I Format for PrinVSave I lEntei:...vnur address d Emaill ocatalog.loc.gov/cgl-bln/Pwebrecon.cgi?Search_Arg=carlie+leil;a+strawberries+and+wine&Search_C ... 1/ Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 3 of 17 www.torrentlitigation.com /9/12 Public Catalog WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be available between 6:30am and 8: 30am U.S. Eastern Time on Sunday, April 8 due to routine system mai ntenance. We apol ogize for any inconvenience to our users. Help Search History Titles Start Ovar Copytight Catalog (1978 to present) Search Request: Left Anchored Title= daddy's office Search Result::;: Displaying I of l entries Type of Work: Motion Picture Labeled VIew Daddy's Office. Registration Number I Date: PAOOOI776838 / 2012-02-21 Application Title: Daddy' s Office. Title: Daddy' s Office. Description: Electronic file (eServicc) Copy1ight Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date of Publication: 20 I 0-1 1- I 2 Nadon of First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media LLC previous II next I Save, Print and Email (Belu Paee) I Select Download Fonnat Full Record GJ [ Format for J IP ntPr 'I.(Q.UJ:..eJDail address:_ d Email l .. . 11 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 4 of 17 www.torrentlitigation.com 5/7/12 WebVoyage Record View 1 . . Public Catalog Copyright Catalog (1978 to present) Search Request Left Anchored Name = mabbu media Search Results: Displaying 36 of73 entries Just tlte Two of Us. Type of Work: Motion Picture Registration Number I Date: PA0001781672 I 2012-03-18 Application Title: Just the Two ofUs. Title: Just the Two ofUs. Description: Electronic file (eService) . .. Copyright Claimant: Mabbu Media ILC. Address: 31356 Broad Beach Rd, Malibu, CA., 90265. Date of Creation: 2011 Date ofPublication: 2011-11-18 Nation of First Publication: United States Authorship on Application: Mabbu Media ILC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media LLC I Save, Print and Email (Help I Select DowoJoad F onnat Full Record c::J I Fonnat for J IEnter your email address: ( Emaii JI Help Search Hio.;tmy Titlt:s Start Over Contact Us I Request Copies I Get a Search E'\lin1ate I Frequently Asked Qut!slions (F AQs) about Copyright I Office Home Page I Library of Congress Home Page cocatalog.loc.gov/cgi-bln/Pwebrecon.cgi?V 1 =36&1l=26,36&Search_Arg=mallbu media&Search_ Code= ... 1/1 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 5 of 17 www.torrentlitigation.com /9/12 WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be availabl e between 6:30am and 8:30am U.S. Eastern Time on Sunday, April 8 due to routine system maintenance. We apologize for any inconvenience to our users. Help Search History Titles Start Ovor Public Catalog Copyright Catalog (1978 to present) Search Request: Le'ft: Anchored Title = jennifer naughty angel Search Results: Displaying 1 of 1 entJies II next Jennifer Naug hty Angel. Type of Work: Motion Picture Registration Number I Date: PAOOO 1776809 I 2012-02-21 Application Title : Jennifer Naughty Angel Title: Jennifer Naughty Angel. Description: Electronic file (eService) Copyight Claimant: Malibu Media LLC Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date of Publication: 201 0-1 1-05 Nation of First Publication: United States Authorship on Application: Mahbu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. AuthorsJ,jp: entire rnotion pictttre. Names: Malibu Media LLC II next I Save, Print and Email (!Ie)R I Select Download Fom1at Full Record G I Format for PrinUSave j PntF'r v..o.w:...emaiJ d_ Email 1 ocatalog.loc.gov/cgi-bln/Pwebrecon.cgi?Search_Arg=jennif'er-tnaughty1"angei&Search_Code=TALL& . . 1/ Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 6 of 17 www.torrentlitigation.com /9112 Web Voyage Record View 1 Oll\cc Public Catalog The U.S. Copyright Office Catal og will not be availabl e between 6:30am and 8:30am U.S. Eastern Time on Sunday, April 8 due to routine system maintenance. We apol ogize f or a ny Inconvenience to our users. Help Search History Titles Start Over Copyright Catalog (I 978 to present) Search Request: ldt Anchored Title = kat translucence Search Results: Displaying I of I entries previous II next ' labeledVIeW Kat Translucence. Type of Work: Motion Picture Registration Number/ Date: PA0001 762073 / 201 1-11- 19 Application Title: Kat Transhtcence. Title: Kat Translucence. Description: Electronic file (eService) Copyright Clai ma nt: Malibu Media LLC. Address: 3 1356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2009 Date of Publication: 2009- 11 -20 Nation of First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media LLC previous II next )>I I Save, Print and Email Page) I Select Download Format Full Record G [ Fonnat for PrintJSa'IA:! I lEotcLvnuLermlil addr:ess.:_ d Email L ocataiog.loc.govlcgi-blniPwebrecon.cgi?Search_Arg=kat+translucence&Search_Code=TALL&PID=L .. 1/ Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 7 of 17 www.torrentlitigation.com 19112 Public Catalog WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be available between 6:30am and 8:30am u.s. Eas tern Time on Sunday, Apri l 8 due to routine system maintenance. We apol ogize for any inconvenience to our users. Hel p Search History Titles Start Over Cop )'light Catalog ( 1978 to present) Search Request: Lett Anchored Title = katka cum like crazy Search Results: Displaying 1 of 1 entries previoul l next La.,_led VIew Katka Cum Like Crazy. Type of Work: Motion Picture Registration Number I Date: PA0001762074 / 201 l- 11 -21 Application Tille: Kalka Cum Like Crazy. Title: Katka Cum Like Crazy. Description: Electronic file (eService) Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 20 I 0 Date of Publication: 2010-07-07 Nation of .First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media LLC II next J>l I Save, Print and Email I Select Download F onnat Full Record G I Format for Print/Sa\e J IFntPr vour eu:Jail address.:_ J Email1 ocalalog.loc.gov/cgl-bln/Pwebrecon.cgi?Search _Arg=kal ka+cu m+like+crazy&Search _ Code=T ALL&PI .. . ,, Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 8 of 17 www.torrentlitigation.com /9/12 Public Catalog WebVoyage Record View 1 The U. S. Copyright Office Catal og wi ll not be available between 6 :30am and 8 :30am u.s. Eastern Time on Sunday, April 8 due to routine system maintenance. We apol ogize for any inconvenience to our user s . Help Search History Titles Start ovar Cop)'light Catalog ( 1978 to present) Search Request: Left Anchored Tille = kalka sweet surprise Search Results: Displaying l of 1 cnbies J<{ previous II LabeledVJ.w Kafka Sweet Surprise. Type of Work: Motion Picture Registration Number I Date: PA0001762075 I 201 J-11 -18 Application Title: Kat.ka Sweet Surprise. Title: Katka Sweet Surprise. Description: Electronic file (eService) Copytight Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date of Publication: 2010-08-04 Nation ofFlrst Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media LLC II I Save, Print and Email (Hdp I Select Download F onmt Full Record G I Format for Print/Save J IJ::ntPr """r J Email l ocatalog.loc.gov/cgl-bin/Pwebrecon .cgi?Search _Arg=katka+sweet+surprise&Search_ Code=T ALL&PI ... ,, Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 9 of 17 www.torrentlitigation.com /9/12 Public Catalog WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be avai l abl e between 6:30am and 8: 30am U.S. Eastern Time on Sunday, April 8 due to routine system maintenance. We apologize for any Inconvenience to our user s. Help Search History Titles Start Over Copyright Catalog ( 1978 to present) Search Request: Le1t Anchored Title = kristen gid next door Search Results: Displaying 1 of t entiies I;({ prvvious II next ~ ~ Labeled VIew Kristen Girl Next Doo,., Type of Work: Motion Picture Registration Number I Date : PA0001762076 /2011-J 1- 18 Application Title: Kristen Girl Next Door. Title: Kristen Girl N e>.1 Door. Description: Electronic tile (eService) Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 20 I 0 Date of Publication: 20 I 0-08-25 Nation of First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media lLC I Save, Print and Email (Help Page) I Select Download Fonmt Full Record E) [ Format for Print/Sa-.e J lr.ntPr vom email add.r:ess J Emaill ocatalog.loc.gov/ogi-bin/Pwebrecon.cgi?Search_Arg=kristen+girl- next+door&Search_Code=TALL&PI ... 11 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 10 of 17 www.torrentlitigation.com /9/12 - WebVoyage Record VIew 1 Copyright Office The u.s. Copyright Office Catalog will not be availabl e between 6:30am and 8:30am u.s. Eastern Time on Sunday, April 8 due to routine sy stem maintenance. We apologize for any inconveni ence to our users. Help Search History Titles Start Over Public Catalog Cop)'light Catalog ( 1978 to present) Search Request: Left Anchored Title = leila sex on the beach Search Results: Displaying 1 of I entries pre\'louaj l next )>j Labeled VIew Leila Sex On The Beach. Type ofWork: Motion Picture Registration Number/ Date: PA0001762083 /2011-11-21 Application Title: Leila Sex On The Beach. Title: Leila Sex On 1l1e Beach. Description: Electronic file (eService) Copyright Claimant: Malibu Media LLC. Address: 3 I 356 Broad Beach Rd., Malibu, CA, 90265, United States. Date of Creation: 20 I 0 Date ofPubl.ication: 201 0-12-22 Nation of First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names : Malibu Media LLC previous II next
I Select Download Format Full Record G I Format for Print/Sa-.e J \Enter your ern:lil address: ( Emait// ocatalog.loc.gov/cgl-bln/Pwebrecon.cgi?Search_Arg=lella+sex+on+the+beach&Search_Code=TALL& ... 1/ Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 11 of 17 www.torrentlitigation.com ./9/12 Web Voyage Record VIew 1 copyright office The u.s. Copyright Offi ce Catal og wi ll not be avail abl e between 6:30am and 8:30am u.s . East ern Time on Sunday, April 8 due to routi ne system maintenance. We apol ogize for any inconvenience to our user s. Help Search History Titl es Start Over Public Catalog Copyright Catalog (1978 to present) Search Request: Left Anchored Title = megan morning bath Search Results: Displaying 1 of 1 entiies previous II next Lllbeladvt.w Megan Monring Btzth. Type of Work: Motion Picture R egistration N umber I Date: PAOOOJ 762077 I 2011-11-18 Application Title: Megan MomingBath Title: Megan Morning Bath. Description: Electronic file (eService) Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date of Publication: 201 0-02-12 Nation of First Publication: United States Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Malibu Media Ll.C I<( previous II next , I I Save, Print and Email I Select Download Fonnat Full Record EJ I Format for Print/Save I J Email 1 ocatalog.loc.gov/cgl-bin/Pwebrecon.cgi ?Search_Arg=megan+moming+balh&Search_Code=TALL&PI . .. 11 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 12 of 17 www.torrentlitigation.com /9/12 Public Catalog WebVoyage Record View 1 The U.S. Copyright Office Catalog wi ll not be availabl e between 6: 30am and 8:30am u.s. Eastern Time on Sunday, April 8 due to r o utine syst e m maintenance. We apologi ze for a ny inconveni ence to our users. Help Search History Titles Start Over Copyright Catalog (1978 to present) Search Request: Left Anchored Title = mina's fantasy Search Results: Displaying I of2 entties Labeled Vlllw Mi11a's Ftmtmy. Type of Work: Motion Picture Registration Numher I Date: PA0001 76207R / 2011-11-23 Application Title: Mim1' s Fantasy. Title: Mina' s Fantasy. Description: Electronic file (eService) Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date of Publication: 20 I 0-06-25 Nation of First Publication: United States Authorship on Application: Mahbu Media LLC, employer for hire; Domicile: United States; Citizen'ihip: United States. Aulhorship: entire molion pi<.:ture. Names : Malibu Media LLC I Save, Print and Email (Help Page) I Select Download F01mat Full Record EJ [ Format for Print/Save I Entegaur email address J Emalll ocatalog.loc.gov/cgi-bln/Pwebrecon.cgl?v1 =1 &ti=1, 1 &Search_Arg=mina%27s fantasy&Search_ Code .. . 11 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 13 of 17 www.torrentlitigation.com *-APPLICATION-* Title---------------------------- Title of Work: The Girl in My Shower Completion/Publication --------------------- Year of Completion: 2009 Dnte of 1st Publication: October 23, 2009 Nation of 1st Publication: United States Author Author: Malibu Media LLC Author Cl'eated: entire motion picture Work made for hire: Yes Citizen of: United States Domiciled in: United States Copyright claimant Copyright Claimant : Malibu Media LLC 31356 Broad Beach Rd, Malibu. CA, 90265 Certification Name: Emilie Kennedy D11tc: March 30, 20 12 J>age 1 of 1 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 14 of 17 www.torrentlitigation.com Registrat ion #: Service Request#: 1-745923182 Priority: Routine Correspondent AJ>plicntion Dute: March 30,2012 08:46:22 PM Organization Name: Lipscomb, Eisenberg & Baker Name: F.mi )ie Kennedy Mail Certificate Email: copyl'ight@lebfitm.com Address: 2 South Biscayne Blvd. Penthouse 3800 Miami, FL 33 13 1 Malibu Media LLC Brigham Field 31356 Broad Heach Rd Malibu, CA 90265 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 15 of 17 www.torrentlitigation.com /9/12 Public Catalog WebVoyage Record View 1 The U. S. Copyright Office Catalog will not be availabl e between 6 :30am and 8 :30am U.S. Eastern Time on Sunday, April 8 due to routine s y stem mai ntenance. We apologize for any inconv eni ence to o ur users. Help Search . History Titles Start over Copyright Catalog (1978 to present) Search Request: Left Anchored Title = tiffitny teenagers in love Search Results: Displaying 1 ofl entries II next )>I Labeled View Tiffany Teenagers /11 Love. Type of Work: Motion Picture Registration Number I Date: PAOOO 1762019 / 2011-11-20 Application Title: Tiffimy Teenagers In Love. TitJc: Ti:ffitny Teenagers In Love. Description: Elecoonic "file (eService) Copytight Claimant: Malibu Media LLC. Address: 3 1356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 20 I 0 Date of Publication: 20 I 0- 12-29 Nation of First Publication: United States Authorship on Application: Maltbu Media LLC, employer for hire; Domicile: United States; Citizenshlp: United States. Authorship: entire motion pjcture. Names: MalibuMediaLLC previoua II I Save, Print and Email (Bd p f aee) I Select Download Fonnat Full Record EJ I Fonnat for PrinVSave ) P ntPr "mo.- Pon"'il <>rlrloess:.... d Email L ocala log .loc.gov/cgi-bin/Pwebrecon.cgi?Search_i\rg=tiffany+teenagers+in+love&Search._ Code= TAL .. 11 Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 16 of 17 www.torrentlitigation.com /9/12 WebVoyage Record View 1 The U.S. Copyright Office Catalog will not be available between 6 :30am and 8:30am U.S. Eastern Time on Sunday, April 8 due to routine system maintenance. We apologize for any inconvenience to our users. Help Search History Titles Start Over Public Catalog Copyright CataJog ( 1978 to present) Search Request: Le'ft Anchored Title = tori the endless orgasm Search Results: Displaying I of I entries next )>j Labeled View J Tori The Endless O,.gasm. Type of Work: Motion Picture Registration Number I Date: PA000l762082 I 2011-11-18 Application Title: Tori The Endless Orgasm Title: Tori The Endless Orgasm. Des cription: Electronic file ( eService) Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265. Date of Creation: 2010 Date of Publication: 20 I 0-10-20 Nation of First Publication: United Slates Authorship on Application: Malibu Media LLC, employer fi)r hire; Domicile: United States; Citizenship: United States. Authorship: entire motion picture. Names: Media LLC previoua II next I Save, Print and Email (ll.elp I Select Download Fomlat Full Record G I Format for Print/Save J Eol:e.Lvour email address J Email 1 ocatalog.loc.gov/cgibln/Pwebrecon.ogi?Search_Arg=tori+lhe+endless+orgasm&Search_Code=TALL ... 1/ Case 2:12-cv-14171-KMM Document 1-3 Entered on FLSD Docket 05/11/2012 Page 17 of 17 www.torrentlitigation.com
EXHIBIT C SFL10
Doe #1
Title Date First Pub Regis Date Infringement Date Carlie Beautiful Blowjob 03/26/2010 11/21/2011 04/15/2012 07:49:29 Carlie Big Toy Orgasm 03/22/2010 02/21/2012 04/15/2012 07:49:29 Carlie Leila Strawberries and Wine 05/07/2010 11/18/2011 04/15/2012 07:49:29 Daddy's Office 11/12/2010 02/21/2012 04/15/2012 07:49:29 Jennifer Naughty Angel 11/05/2010 02/21/2012 04/15/2012 07:49:29 Just the Two of Us 11/18/2011 03/18/2012 04/15/2012 07:49:29 Kat Translucence 11/20/2009 11/19/2011 04/15/2012 07:49:29 Katka Cum Like Crazy 07/07/2010 11/21/2011 04/15/2012 07:49:29 Katka Sweet Surprise 08/04/2010 11/18/2011 04/15/2012 07:49:29 Kristen Girl Next Door 08/25/2010 11/18/2011 04/15/2012 07:49:29 Leila Sex on the Beach 12/22/2010 11/21/2011 04/15/2012 07:49:29 Megan Morning Bath 02/12/2010 11/18/2011 04/15/2012 07:49:29 Mina's Fantasy 06/25/2010 11/23/2011 04/15/2012 07:49:29 The Girl in My Shower 10/23/2009 03/30/2012 04/15/2012 07:49:29 Tiffany Teenagers in Love 12/29/2010 11/20/2011 04/15/2012 07:49:29 Tori The Endless Orgasm 10/20/2010 11/18/2011 04/15/2012 07:49:29
Total Statutory Copyright Infringements for Doe #1: 16
Case 2:12-cv-14171-KMM Document 1-4 Entered on FLSD Docket 05/11/2012 Page 1 of 7 www.torrentlitigation.com
EXHIBIT C SFL10 Doe #2
Title Date First Pub Regis Date Infringement Date Carlie Beautiful Blowjob 03/26/2010 11/21/2011 03/11/2012 10:57:20 Carlie Big Toy Orgasm 03/22/2010 02/21/2012 03/11/2012 10:57:20 Carlie Leila Strawberries and Wine 05/07/2010 11/18/2011 03/11/2012 10:57:20 Daddy's Office 11/12/2010 02/21/2012 03/11/2012 10:57:20 Jennifer Naughty Angel 11/05/2010 02/21/2012 03/11/2012 10:57:20 Kat Translucence 11/20/2009 11/19/2011 03/11/2012 10:57:20 Katka Cum Like Crazy 07/07/2010 11/21/2011 03/11/2012 10:57:20 Katka Sweet Surprise 08/04/2010 11/18/2011 03/11/2012 10:57:20 Kristen Girl Next Door 08/25/2010 11/18/2011 03/11/2012 10:57:20 Leila Sex on the Beach 12/22/2010 11/21/2011 03/11/2012 10:57:20 Megan Morning Bath 02/12/2010 11/18/2011 03/11/2012 10:57:20 Mina's Fantasy 06/25/2010 11/23/2011 03/11/2012 10:57:20 Tiffany Teenagers in Love 12/29/2010 11/20/2011 03/11/2012 10:57:20 Tori The Endless Orgasm 10/20/2010 11/18/2011 03/11/2012 10:57:20
Total Statutory Copyright Infringements for Doe #2: 14
Case 2:12-cv-14171-KMM Document 1-4 Entered on FLSD Docket 05/11/2012 Page 2 of 7 www.torrentlitigation.com
EXHIBIT C SFL10 Doe #3
Title Date First Pub Regis Date Infringement Date Carlie Beautiful Blowjob 03/26/2010 11/21/2011 04/11/2012 15:38:34 Carlie Big Toy Orgasm 03/22/2010 02/21/2012 04/11/2012 15:38:34 Carlie Leila Strawberries and Wine 05/07/2010 11/18/2011 04/11/2012 15:38:34 Daddy's Office 11/12/2010 02/21/2012 04/11/2012 15:38:34 Jennifer Naughty Angel 11/05/2010 02/21/2012 04/11/2012 15:38:34 Just the Two of Us 11/18/2011 03/18/2012 04/11/2012 15:38:34 Kat Translucence 11/20/2009 11/19/2011 04/11/2012 15:38:34 Katka Cum Like Crazy 07/07/2010 11/21/2011 04/11/2012 15:38:34 Katka Sweet Surprise 08/04/2010 11/18/2011 04/11/2012 15:38:34 Kristen Girl Next Door 08/25/2010 11/18/2011 04/11/2012 15:38:34 Leila Sex on the Beach 12/22/2010 11/21/2011 04/11/2012 15:38:34 Megan Morning Bath 02/12/2010 11/18/2011 04/11/2012 15:38:34 Mina's Fantasy 06/25/2010 11/23/2011 04/11/2012 15:38:34 The Girl in My Shower 10/23/2009 03/30/2012 04/11/2012 15:38:34 Tiffany Teenagers in Love 12/29/2010 11/20/2011 04/11/2012 15:38:34 Tori The Endless Orgasm 10/20/2010 11/18/2011 04/11/2012 15:38:34
Total Statutory Copyright Infringements for Doe #3: 16
Case 2:12-cv-14171-KMM Document 1-4 Entered on FLSD Docket 05/11/2012 Page 3 of 7 www.torrentlitigation.com
EXHIBIT C SFL10 Doe #4
Title Date First Pub Regis Date Infringement Date Carlie Beautiful Blowjob 03/26/2010 11/21/2011 02/21/2012 10:21:18 Carlie Big Toy Orgasm 03/22/2010 02/21/2012 02/21/2012 10:21:18 Carlie Leila Strawberries and Wine 05/07/2010 11/18/2011 02/21/2012 10:21:18 Daddy's Office 11/12/2010 02/21/2012 02/21/2012 10:21:18 Jennifer Naughty Angel 11/05/2010 02/21/2012 02/21/2012 10:21:18 Kat Translucence 11/20/2009 11/19/2011 02/21/2012 10:21:18 Katka Cum Like Crazy 07/07/2010 11/21/2011 02/21/2012 10:21:18 Katka Sweet Surprise 08/04/2010 11/18/2011 02/21/2012 10:21:18 Kristen Girl Next Door 08/25/2010 11/18/2011 02/21/2012 10:21:18 Leila Sex on the Beach 12/22/2010 11/21/2011 02/21/2012 10:21:18 Megan Morning Bath 02/12/2010 11/18/2011 02/21/2012 10:21:18 Mina's Fantasy 06/25/2010 11/23/2011 02/21/2012 10:21:18 Tiffany Teenagers in Love 12/29/2010 11/20/2011 02/21/2012 10:21:18 Tori The Endless Orgasm 10/20/2010 11/18/2011 02/21/2012 10:21:18
Total Statutory Copyright Infringements for Doe #4: 14
Case 2:12-cv-14171-KMM Document 1-4 Entered on FLSD Docket 05/11/2012 Page 4 of 7 www.torrentlitigation.com
EXHIBIT C SFL10 Doe #5
Title Date First Pub Regis Date Infringement Date Carlie Beautiful Blowjob 03/26/2010 11/21/2011 04/29/2012 08:28:28 Carlie Big Toy Orgasm 03/22/2010 02/21/2012 04/29/2012 08:28:28 Carlie Leila Strawberries and Wine 05/07/2010 11/18/2011 04/29/2012 08:28:28 Daddy's Office 11/12/2010 02/21/2012 04/29/2012 08:28:28 Jennifer Naughty Angel 11/05/2010 02/21/2012 04/29/2012 08:28:28 Just the Two of Us 11/18/2011 03/18/2012 04/29/2012 08:28:28 Kat Translucence 11/20/2009 11/19/2011 04/29/2012 08:28:28 Katka Cum Like Crazy 07/07/2010 11/21/2011 04/29/2012 08:28:28 Katka Sweet Surprise 08/04/2010 11/18/2011 04/29/2012 08:28:28 Kristen Girl Next Door 08/25/2010 11/18/2011 04/29/2012 08:28:28 Leila Sex on the Beach 12/22/2010 11/21/2011 04/29/2012 08:28:28 Megan Morning Bath 02/12/2010 11/18/2011 04/29/2012 08:28:28 Mina's Fantasy 06/25/2010 11/23/2011 04/29/2012 08:28:28 The Girl in My Shower 10/23/2009 03/30/2012 04/29/2012 08:28:28 Tiffany Teenagers in Love 12/29/2010 11/20/2011 04/29/2012 08:28:28 Tori The Endless Orgasm 10/20/2010 11/18/2011 04/29/2012 08:28:28
Total Statutory Copyright Infringements for Doe #5: 16
Case 2:12-cv-14171-KMM Document 1-4 Entered on FLSD Docket 05/11/2012 Page 5 of 7 www.torrentlitigation.com
EXHIBIT C SFL10 Doe #6
Title Date First Pub Regis Date Infringement Date Carlie Beautiful Blowjob 03/26/2010 11/21/2011 04/29/2012 02:47:32 Carlie Big Toy Orgasm 03/22/2010 02/21/2012 04/29/2012 02:47:32 Carlie Leila Strawberries and Wine 05/07/2010 11/18/2011 04/29/2012 02:47:32 Daddy's Office 11/12/2010 02/21/2012 04/29/2012 02:47:32 Jennifer Naughty Angel 11/05/2010 02/21/2012 04/29/2012 02:47:32 Just the Two of Us 11/18/2011 03/18/2012 04/29/2012 02:47:32 Kat Translucence 11/20/2009 11/19/2011 04/29/2012 02:47:32 Katka Cum Like Crazy 07/07/2010 11/21/2011 04/29/2012 02:47:32 Katka Sweet Surprise 08/04/2010 11/18/2011 04/29/2012 02:47:32 Kristen Girl Next Door 08/25/2010 11/18/2011 04/29/2012 02:47:32 Leila Sex on the Beach 12/22/2010 11/21/2011 04/29/2012 02:47:32 Megan Morning Bath 02/12/2010 11/18/2011 04/29/2012 02:47:32 Mina's Fantasy 06/25/2010 11/23/2011 04/29/2012 02:47:32 The Girl in My Shower 10/23/2009 03/30/2012 04/29/2012 02:47:32 Tiffany Teenagers in Love 12/29/2010 11/20/2011 04/29/2012 02:47:32 Tori The Endless Orgasm 10/20/2010 11/18/2011 04/29/2012 02:47:32
Total Statutory Copyright Infringements for Doe #6: 16
Case 2:12-cv-14171-KMM Document 1-4 Entered on FLSD Docket 05/11/2012 Page 6 of 7 www.torrentlitigation.com
EXHIBIT C SFL10 Doe #7
Title Date First Pub Regis Date Infringement Date Carlie Beautiful Blowjob 03/26/2010 11/21/2011 04/18/2012 00:26:09 Carlie Big Toy Orgasm 03/22/2010 02/21/2012 04/18/2012 00:26:09 Carlie Leila Strawberries and Wine 05/07/2010 11/18/2011 04/18/2012 00:26:09 Daddy's Office 11/12/2010 02/21/2012 04/18/2012 00:26:09 Jennifer Naughty Angel 11/05/2010 02/21/2012 04/18/2012 00:26:09 Just the Two of Us 11/18/2011 03/18/2012 04/18/2012 00:26:09 Kat Translucence 11/20/2009 11/19/2011 04/18/2012 00:26:09 Katka Cum Like Crazy 07/07/2010 11/21/2011 04/18/2012 00:26:09 Katka Sweet Surprise 08/04/2010 11/18/2011 04/18/2012 00:26:09 Kristen Girl Next Door 08/25/2010 11/18/2011 04/18/2012 00:26:09 Leila Sex on the Beach 12/22/2010 11/21/2011 04/18/2012 00:26:09 Megan Morning Bath 02/12/2010 11/18/2011 04/18/2012 00:26:09 Mina's Fantasy 06/25/2010 11/23/2011 04/18/2012 00:26:09 The Girl in My Shower 10/23/2009 03/30/2012 04/18/2012 00:26:09 Tiffany Teenagers in Love 12/29/2010 11/20/2011 04/18/2012 00:26:09 Tori The Endless Orgasm 10/20/2010 11/18/2011 04/18/2012 00:26:09
Total Statutory Copyright Infringements for Doe #7: 16
Case 2:12-cv-14171-KMM Document 1-4 Entered on FLSD Docket 05/11/2012 Page 7 of 7 www.torrentlitigation.com BitTorrent vocabulary- Wikipedia, the free encyclopedia Page 1 of5 BitTorrent vocabulary From Wlkipedia, the free encyclopedia from Terminology ofBitTorrent) This list explains terms used when discussing BitTorrent clients, and in particular the BitTo:rrent protocol tlsed by these clieirts. Common BitTorrent terms . . . Announce Same as scrape it (see below), but a client also announces that it wants to join the swarm and that the server should add it i9 the list of peers in
' . {Also known as distn.Ou.ted copies.) The number full copies of the file available to the client. .Each seed adds 1.0 to this as they have one complete copy of the file. A connected peer With a fraction of the file available adds that fraction tO the availability, if nc other peer has this part of the file. Example: a peer with 653% of the file downloaded increases the availability by 0.653. However, if two peers both have the same portion of the file downloaded- say 50% - and there is only one seeder, the availability is 1.5. Choked Descnl>es a peer to whom the client refuses tO send file pieces. A chokes another client in several situations: The second client is a seed, in it does want any pieces {i.e., it is completely uninterested) . \ i I f I The client is already uploading a:t its full capacity {it has reached the value of max_ uploads) ' The second client has been blacklisted for being abusive or is using a blacklisted BitTorrent client. Client ' . . . :- ; The program that enables p2p file sharing via the Bit Torrent protoc<?L Exam.]?les of clients include p.Torrentand Vuze. Downloader A downloader is any peer that does not have the entire file and is downloading the :file. This used in Bram Cohen's Python implementation, lacks the negative cOnnotation attn"buted to leech. Brani prefers downloader to leech because BitTorrent's tit-for-tat ensures downloa4ers also wload and thus do not unfairly qriaiify as leeches. EXHIBITD _of_BitTorrent .:JlUI-4-Ull \. Case 2:12-cv-14171-KMM Document 1-5 Entered on FLSD Docket 05/11/2012 Page 1 of 5 www.torrentlitigation.com BitT orrent vocabulary - Wikipedia, the free encyclopedia Page2of5 EndGame Bitto:rrent has a couple of download strategies for .initializing a download, downloading normally among the middle of the torrent ai:l.d downloading the last few pieces {see below) of atorrent. Typically, the last download pieces arrive more slowly $an the others since the faster and more easily accessible pieces should have already been obtained, so toprevent ~ t h e BitT arrent client attempts to get the last missing pieces from all of its peers. Upon receiving a piece, a cancel request command is sent to other peers. Fake A fake torrent is a torrent that does not contain what is specified in its name ordescripti.on(i.e. a torrent is said. to contain a video, but it contains only a-snapshot of a moment in the video, or in some cases a virus). Hash [: [: l j i The hash is a string of alphanumeric characters in the .torrent file t h a ~ the client uses to verify the data that is being transferred. It contains information like the file list, sizes, p i ~ etc. Every piece received is first checked against the hash. If it fails verification, the data is discarded and .. requested again. The 'Hash FSils' field in the torrent's General tab shows the number of "these hash fails. . Hash checks greatly reduce the chance that invalid data is incorrectly identified as valid by the BitTorrent client, but it is still possible fur invalid data to have the same hash value as the valid data and be treated as such. Ibis is known as a hash collision. Health is shown in a bar or in% usnally next to the torrents name and size, on the site where the . t-orrent file is hosted. It shows if all pieces of the torrent are, available tO download (i.e. 50% means that only half of the torrent is available). Index An index is a list of .torrent files (usually including descriptions and other information) managed by a website and available for searches. An index website can also be a tracker. Interested Describes a downloader who wishes to obtain pieces of a file the client has. For example, the uploading client would flag a downloading client as mterested' if that client did not possess a piece that it did, and wished to obtain it. Leech .. A leech is a term with. two meanings. Usually it is used to refer a peer who has a negative effect on the swarm by having a very poor share ratio (downloading much more than they upload). Most leeches are users on asymmetric internet connections and d? not leave their BitTorrent client open httn:/fetiwikinedia.orWwildJTemrinoloJzy of BitTorrent 3/6/2011 Case 2:12-cv-14171-KMM Document 1-5 Entered on FLSD Docket 05/11/2012 Page 2 of 5 www.torrentlitigation.com BitTorreni vocabulary - Wikipedia, the free encyclopedia Page 3 of5 to seed the file after their download has completed. However, some leeches intentionally avoid uploading by using modified clients or excessively limiting their upload speed. The often used second meaning of leech is synonymous With dawnloader (see above): used simply to de$crlbe a peer or any client iha.t does not have 100% of the data. This alternative meaning was mainly introduced by most BitTorrent tracker sites. Lurker p2p A lurker is a user that only downloads files frOm the group but does not add new content. It does not necessarily mean that the lurker will not seed. Not to be confused with a.leecher. Stands for rrpeerto peer", which is ttie technology used for file sharing among computer users over the.lnternet In a p2p network, each node (or computer on the network) acts as both a client and a server. In other words, each computer is capable of both sending and receiving data. Peer - A peer is one instance of a BitTorrent client a computer futemet to which other clients connect and transfer data- Usually a peer does not have the complete file, but only parts of it. However, in the colloquial definition, "peern can be used to refer to any participant in. the swarm (m this case, ifs synonymous with "client"). Piece This refers to the torrented files being divided up into equal specifk sized pieces (e.g. 512Kb, 1Mb). The pieces are distnouted in a random fashion among peers in order to optin:iize trading efficiency. Ratio credit -A ratia eredit, also known as upload credit or ratio is a currency system used on a number of private trackers to provide an incentive for higher upload/download ratios among member file-sharers_ In such a those users who have greater amounts bard drive space (particularly seedbOies) Qr idle computer uptime are at a greater advantage to accumulate ratio credits versus who are :in any one or more oftli.e same resources. : : Scrape This is when a client sends a request to the tracking server for information about the statistics of 1he torrent, such as with whom to share the file and how well those other users are sharini Seeder A seeder is a peer that has an entire copy of the torrent and offers it for upload. The more seeders there are, the better the chances of getting a higher download speed. If the seeder seeds the whole copy of the download, they should get faster downloads. htto://en.wilipediaorWwilcifferminology _of_BitTorrent 3/6/20-11 I I I Case 2:12-cv-14171-KMM Document 1-5 Entered on FLSD Docket 05/11/2012 Page 3 of 5 www.torrentlitigation.com BitTor:rent vocabulary - Wikipedia, the free encyclopedia Page4of5 Share ratio A user's share ratio for any lndividual totrent is a number determined by dividing the amount of data that user has uploaded by the amount of data they have downloaded. Final share ratios over 1 carry a positive connotation in the BitTorrent comm:unizy, because they indjcate that the user has sent more data to other users than they received. Likewise, share ratios -qnder 1 negative connotation. Snubbed An uploading client is flagged as snubbedif1he downloading client has not received any data :from it in over 60 seconds. Super-seeding When a file is new, time can be wasted because the seeding client might send the same file piece to many while other pieces not yet been downloaded at all Some like ABC, Vuze, BitTornado, TorrentStonn, and have a "super-seed" mode, where they 1cy to only nd out pieces that have never been out making _ 1he initial propagation of the :file much faster. However the super-seeding-becomes substantially less effective and may even reduce performance compared 1D the normal model in cases where some peers have poor or limited connectivity. This mode is generally used only for a . new torrent, or one which must be re-seeded because no other seeds are available. Swarm Main article: segmented downloading Together, all peers (mcludil,lg seeders) sharing a torrent are called a swarm. For example, six. ordinary peers and two seeders make a swarm of eight Torrent A rorrent can mean either a . torrent metadata file or ail files descnDed by it, depending on context. nie torrent file contains metadata about all the files it makes downloadable, including their names and sizes and checksums of all pieces in the torrent. It also contains the addreS$. of a tracker that coordinates communication between the peers :in the swarm. .... - ':: Tracker A tracker is a server that keeps track of which seeds and peers are in the swarm.. Clients report information to the tracker periodically and in exchange, receive infoimation about other clients tO which they can connect The tracker is not directly involved in the data transfer and does not have a cOpy of the file. See also Retrieved from "http :lien. wi:J4pedia.org!wiki!BitTorrent _ vocabulary 11 . Categories: BitTorrent I Lexis. htto:llen.wil<i.Pedia.Qrg!wj.kVfenninology_of_BitTorrent 3/6/2011 Case 2:12-cv-14171-KMM Document 1-5 Entered on FLSD Docket 05/11/2012 Page 4 of 5 www.torrentlitigation.com BitTorrent vocabulary- Wikipedia, the free encyclopedia . PageS of5 This page was last modified on 22 February 2011 at 15:22. Text is available the Creative Commons Attribution-ShareAlike License; additional terms inay apply. See Tenns ofUse for details. Wlkipedia is a registered trademark of the Wlkimedia Foundation, Inc., a non-profit
. . . :- : of BitTorrent '3/6/2011 I. Case 2:12-cv-14171-KMM Document 1-5 Entered on FLSD Docket 05/11/2012 Page 5 of 5 www.torrentlitigation.com