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`KELLY KLAUS (SBN 161091)
`Kelly.Klaus@mto.com
`ROSE LEDA EHLER (SBN 296523)
`Rose.Ehler@mto.com
`SHANNON GALVIN AMINIRAD (SBN 324780)
`Shannon.Aminirad@mto.com
`MUNGER, TOLLES & OLSON LLP
`350 South Grand Avenue, Fiftieth Floor
`Los Angeles, California 90071
`Telephone: (213) 683-9100
`Facsimile:
`(213) 687-3702
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`
`Attorneys for Plaintiffs
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`
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`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`WESTERN DIVISION
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` Case No. 2:21-cv-09317
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`COMPLAINT FOR
`COPYRIGHT INFRINGEMENT
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`DEMAND FOR JURY TRIAL
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`PARAMOUNT PICTURES
`CORPORATION; UNIVERSAL CITY
`STUDIOS PRODUCTIONS LLLP;
`UNIVERSAL CONTENT
`PRODUCTIONS LLC; UNIVERSAL
`TELEVISION LLC; WARNER BROS.
`ENTERTAINMENT INC.,
`COLUMBIA PICTURES
`INDUSTRIES, INC.; DISNEY
`ENTERPRISES, INC.; NETFLIX
`STUDIOS, LLC; NETFLIX US, LLC;
`and NETFLIX WORLDWIDE
`ENTERTAINMENT, LLC, 
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`vs.
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`DOES 1-10 d/b/a PRIMEWIRE,
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`Defendants.
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`Plaintiffs,
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`Plaintiffs bring this Complaint for copyright infringement under the
`Copyright Act (17 U.S.C. § 101 et seq.) against Does 1–10, the individuals (who
`have taken steps to hide their identities) who own and operate the websites
`www.primewire.li, www.primewire.ag, and www.primewire.vc (together with other
`websites owned and operated by Defendants1 the “PrimeWire Websites”) and
`related technology and internet protocol addresses presented to the public as
`“PrimeWire” (collectively, “Defendants”). This Court has subject matter
`jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338(a), and 17 U.S.C. § 501(b).
`Plaintiffs allege, on personal knowledge as to themselves and information and belief
`as to others, as follows:
`
`INTRODUCTION
`1.
`Defendants own, operate, and profit from PrimeWire, an illegal
`enterprise devoted to mass online copyright piracy. PrimeWire provides users with
`unauthorized on-demand access to infringing streams of the world’s most popular
`movies and TV shows, including those protected by copyrights that Plaintiffs or
`their affiliates own or exclusively control (the “Copyrighted Works”). Defendants
`fuel the illicit market for pirated content by connecting users to high-quality streams
`of pirated copies of everything from classics to popular new releases, including
`those just released in theaters such as Columbia Picture’s Ghostbusters: Afterlife
`(released November 19, 2021) and Disney’s Encanto (released November 24, 2021).
`2.
`The infringing nature of Defendants’ service is obvious from even a
`cursory review of the PrimeWire Websites. Starting with the very first screen, users
`are presented with an array of copyrighted movies and TV shows available
`
`1 For example, Defendants recently registered and launched vendtxt.com, which is a
`“mirror” website for PrimeWire. Operators of pirate websites like PrimeWire
`frequently create “mirror” websites to move their illicit operations to another online
`location in response to successful anti-piracy actions. Vendtxt.com is hosted at IP
`address 31.10.5.190. From the user’s perspective, vendtxt.com appears to be
`identical to the other PrimeWire Websites.
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`unlawfully for on-demand, free-to-the-user streaming. Defendants curate titles into
`categories that make clear users can immediately access popular content, including
`“Featured Movies,” “New Movies,” and “Latest TV Shows to Air.” Defendants
`admit that watching movies and TV shows through PrimeWire is “risky”—in other
`words, Defendants are providing an illegal service—and Defendants “strongly urge”
`their users “to use a VPN [a virtual private network] to make themselves anonymous
`while streaming films and TV shows online.”
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`3.
`PrimeWire provides its users a too-good-to-be-true offering. Users
`need only make a few clicks to start receiving illicit, on-demand streams of titles
`without any payment by the user or PrimeWire to the rights’ holders. The
`PrimeWire service is free to the user. PrimeWire makes money by selling
`advertising on the site or by getting users to click on sponsored links. PrimeWire
`includes titles that lawfully may be viewed only through licensed distribution
`channels and that often are in exclusive distribution “windows,” including motion
`pictures in their initial theatrical release or available for streaming only through
`legitimate streaming services. To take just a few examples, PrimeWire users can
`use the site to stream Disney’s Cruella (2021), Universal’s Dear Evan Hansen
`(2021), and Paramount’s Clifford the Big Red Dog (2021), all of which were first
`released in theaters and for authorized on-demand streaming at the same time
`PrimeWire also made them available to its users.
`4.
`The scale of Defendants’ infringement is breathtaking. Defendants
`have drawn approximately 20 million monthly visits to the PrimeWire Websites in
`the United States, a number that has been growing. PrimeWire’s total monthly
`visits far exceed the number of visits to the websites of many lawful businesses,
`such as apnews.com, overstock.com, or delta.com. Over half of global traffic comes
`from users in the United States. Unsurprisingly, PrimeWire is one of the most
`popular websites for finding pirated content in the United States.
`5.
`Defendants operate an infringing enterprise for a simple reason: to
`make money. Defendants sell space on the site to third-party advertisers.
`Defendants also generate revenue by including sponsored links on the PrimeWire
`Websites. Defendants’ business model uses the lure of unrestricted on-demand
`access to copyrighted content to generate substantial ill-gotten profits.
`6.
`Defendants know what they are doing is illegal. Just as they exhort
`users to hide their identities by using VPNs to access the PrimeWire Websites,
`Defendants go to great lengths to cloak themselves in anonymity. Defendants use
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`made-up names to communicate with users and provide false identifying
`information to domain name registrars and other service providers.
`7.
`The harms that Defendants are causing to Plaintiffs are significant,
`irreparable, and growing. Plaintiffs and/or their affiliates have invested and
`continue to invest substantial resources and effort each year to develop, produce,
`and distribute their Copyrighted Works. Plaintiffs themselves, or through their
`affiliates, recoup their investments and invest in new movies and TV shows by
`licensing their content through lawful channels, including services engaged in
`authorized streaming. Defendants’ infringing service undermines the market for
`licensed distribution and usurps Plaintiffs’ exclusive rights under copyright.
`8.
`Defendants have increasingly focused their unlawful activities on the
`United States as court orders in other countries have reduced the reach of the
`PrimeWire Websites in those jurisdictions. As PrimeWire grows in popularity in
`the United States, so does the harm to Plaintiffs. Plaintiffs bring this action to stop
`Defendants’ ongoing copyright infringement and to secure damages on account of
`Defendants’ blatantly unlawful conduct.
`THE PARTIES
`9.
`Plaintiff Paramount Pictures Corporation (“Paramount”) is a
`corporation duly incorporated under the laws of the State of Delaware with its
`principal place of business in Los Angeles, California. Paramount owns or controls
`copyrights or exclusive rights in content that it or its affiliates produce or distribute.
`10. Plaintiff Universal City Studios Productions LLLP is a limited liability
`limited partnership duly organized under the laws of the State of Delaware with its
`principal place of business in Universal City, California.
`11. Plaintiff Universal Content Productions LLC (formerly known as
`Universal Cable Productions LLC and Universal Network Television, LLC) is a
`limited liability company duly organized under the laws of the State of Delaware
`with its principal place of business in Universal City, California.
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`12. Plaintiff Universal Television LLC is a limited liability company duly
`organized under the laws of the State of New York with its principal place of
`business in Universal City, California.
`13. Plaintiffs Universal City Studios Productions LLLP, Universal Content
`Productions LLC, and Universal Television LLC are referred to individually and
`collectively as “Universal.” Universal owns or controls copyrights or exclusive
`rights in content that it or its affiliates produce or distribute.
`14. Plaintiff Warner Bros. Entertainment Inc. (“Warner Bros.”) is a
`corporation duly incorporated under the laws of the State of Delaware with its
`principal place of business in Burbank, California. Warner Bros. owns or controls
`copyrights or exclusive rights in content that it or its affiliates produce or distribute.
`15. Plaintiff Columbia Pictures Industries, Inc. (“Columbia Pictures”) is a
`corporation duly incorporated under the laws of the State of Delaware with its
`principal place of business in Culver City, California. Columbia owns or controls
`copyrights or exclusive rights in content that it or its affiliates produce or distribute.
`16. Plaintiff Disney Enterprises, Inc. (“Disney”) is a corporation duly
`incorporated under the laws of the State of Delaware with its principal place of
`business in Burbank, California. Disney owns or controls copyrights or exclusive
`rights in content that it or its affiliates produce or distribute.
`17. Plaintiff Netflix Studios, LLC is a limited liability company duly
`incorporated under the laws of the State of Delaware with its principal place of
`business in Los Gatos, California.
`18. Plaintiff Netflix US, LLC is a limited liability company duly
`incorporated under the laws of the State of Delaware with its principal place of
`business in Los Angeles, California.
`19. Plaintiff Netflix Worldwide Entertainment, LLC is a limited liability
`company duly incorporated under the laws of the State of Delaware with its
`principal place of business in Los Angeles, California.
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`20. Plaintiffs Netflix Studios, LLC, Netflix US, LLC, and Netflix
`Worldwide Entertainment, LLC are referred to individually and collectively as
`“Netflix.” Netflix owns or controls copyrights or exclusive rights in content that it
`or its affiliates produce or distribute.
`21. Plaintiffs have obtained Certificates of Copyright Registration for their
`Copyrighted Works. Exhibit A contains a representative list of movie and
`television program titles (along with their registration numbers, the corresponding
`entity that owns the copyright, the copyright registration number and date), the
`copyrights to which Defendants have infringed and continue to infringe. The titles
`included on Exhibit A are only a sample of a much larger number (certainly in the
`thousands) of Copyrighted Works infringed through the PrimeWire Websites.
`22. PrimeWire operates in the United States through primewire.li,
`primewire.ag, and primewire.vc. PrimeWire’s IP address is 185.100.87.10. That IP
`address traces to a hosting provider, FlokiNET, which lists PrimeWire’s physical
`address as Beau Vallon, Seychelles. Plaintiffs are informed and believe that
`Defendants can be contacted through admin@primewire.li (listed as the contact
`address for PrimeWire on its Websites) and admin@primewire.agmailto: (which
`sends emails regarding PrimeWire account creation).
`23. Defendants Does 1–10 are the individuals and/or entities who control
`and profit from www.primewire.li, www.primewire.ag, and www.primewire.vc, and
`who own, rent, lease or otherwise control PrimeWire’s technology and infrastructure
`and enter into contracts with PrimeWire’s service providers, including domain name
`registrars, hosting providers, proxy services, and advertising networks.
`24. Plaintiffs have exercised and will continue to exercise due diligence to
`determine Doe Defendants’ true names, locations, and personal contact information.
`Plaintiffs will amend this complaint to allege Doe Defendants’ true names,
`locations, and personal contact information if and when Plaintiffs ascertain that
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`information. In the meantime, Plaintiffs are informed and believe that Defendants
`can be contacted and served with process through email.
`JURISDICTION AND VENUE
`25. This Court has subject matter jurisdiction over this Complaint pursuant
`to 28 U.S.C. §§ 1331, 1338(a), and 17 U.S.C. § 50l(b).
`26. This Court has personal jurisdiction over Defendants pursuant to
`Federal Rule of Civil Procedure 4(k)(1)(A) and 4(k)(2).
`27. Defendants operate an interactive website for the primary purpose of
`facilitating and profiting from copyright infringement. Defendants thereby injure
`Plaintiffs in this District, where each Plaintiff maintains headquarters or offices and
`conducts a significant amount of its production and distribution operations.
`28. Defendants transact substantial business in the United States related to
`their infringing operations, including through agreements with Cloudflare (a U.S.-
`based website security company) and social media platforms such as Twitter (a
`U.S.-based social networking company) and YouTube (a U.S.-based online video
`sharing company). Defendants use Cloudflare’s proxy service to run its business
`anonymously, and Defendants use Cloudflare’s content delivery network (“CDN”)
`service to ensure its websites are fast and provide reliable services to users in the
`United States. Cloudflare records indicate that the PrimeWire accounts were
`accessed by a potential Doe Defendant from an IP address associated with a Texas
`internet service provider. Defendants advertise and market their service to a United
`States audience through promotions on social media platforms based in California,
`including Twitter and YouTube.
`29. Defendants intentionally target users in the United States. The
`PrimeWire Websites are offered in English and moderators respond to questions
`posed by PrimeWire users in English. Defendants invoke United States law,
`specifically the Digital Millennium Copyright Act (“DMCA”), and instruct
`PrimeWire users to use a VPN to avoid “the government and the NSA [National
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`Security Agency].” Defendants’ users sign up for accounts with PrimeWire and
`agree to legal terms, including that their name, contact information, and country of
`residence may be used for advertising and other purposes by PrimeWire.
`Defendants then engage advertisers and sponsors based on their United States
`audience. Defendants earn revenue through advertisers and sponsors who pay
`Defendants for access to Defendants’ United States users.
`30. Over half of Defendants’ worldwide traffic comes from U.S. users, a
`percentage that Defendants have sought to increase over time. PrimeWire provides
`unauthorized access to an enormous quantity of popular copyrighted content created
`by the entertainment industry (predominantly based in California, United States),
`including content that characterizes certain lifestyles of California residents, such as
`Million Dollar Listing Los Angeles, The Real Housewives of Beverly Hills, and
`Selling Sunset.
`31. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(6),
`1400(a).
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`BACKGROUND FACTS
`Plaintiffs and Their Copyrighted Works
`32. Plaintiffs and/or their affiliates produce and distribute a significant
`portion of the world’s most sought-after, critically acclaimed, and award-winning
`movies and television programs. Plaintiffs’ ability to invest in new Copyrighted
`Works depends upon protection and enforcement of their rights under copyright law.
`33. Plaintiffs own or hold the exclusive U.S. rights to, among other things,
`reproduce, distribute, display, and publicly perform (including by means of
`streaming over the Internet) the Copyrighted Works.
`34. Plaintiffs themselves, or through their affiliates, authorize the
`legitimate distribution and public performance of the Copyrighted Works in various
`formats and through multiple distribution channels, including, by way of example:
`(a) through authorized, licensed cable and direct-to-home satellite services
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`(including basic, premium, and “pay-per-view”); (b) through authorized, licensed
`Internet video-on-demand (“VOD”) services, including Apple TV+, Amazon Prime
`Video, Disney+, Google Play, HBO Max, Hulu, Netflix, Paramount+, and Peacock;
`(c) through authorized, licensed Internet or over-the-top streaming services,
`including those offered by Hulu Live TV, Fubo TV, Sling TV, and YouTube TV;
`(d) for private home viewing on DVD, Blu-ray, and UHD discs; (e) for exhibition in
`theaters; and (f) for broadcast television.
`35. Plaintiffs have not authorized Defendants to stream any of the
`Copyrighted Works or to exercise any of Plaintiffs’ other exclusive rights under the
`Copyright Act, 17 U.S.C. § 106.
`Defendants’ Infringement of Plaintiffs’ Copyrighted Works
`36. PrimeWire provides users with unauthorized VOD access to an
`enormous quantity of Plaintiffs’ Copyrighted Works. The Copyrighted Works are
`streamed to users through embedded streaming via the PrimeWire Websites or
`through third-party websites and repositories to which Defendants curate links.
`Defendants encourage and induce the supply and consumption of infringing content
`through the PrimeWire service. Defendants use the Copyrighted Works as the bait
`to lure the largest possible audience, so that Defendants will profit from
`advertisements shown to their users. By their conduct, Defendants intentionally
`induce and knowingly contribute to the unauthorized reproductions, public
`performances, and display of the Copyrighted Works on a massive scale.
`PrimeWire Is Devoted to the Mass Infringement of Copyrighted Works
`37. The infringing nature of the PrimeWire service is blatant and obvious.
`PrimeWire’s landing page prominently features copies of the cover art to
`Copyrighted Works available for free, on-demand streaming. Such cover art
`frequently contains still images from the underlying motion picture or TV show.
`Defendants have designed the entirety of the service to make it easy for users to find
`nearly any Copyrighted Work, including Plaintiffs’ most popular titles.
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`38. For example, if a user types “Wonder Woman” into the search box,
`PrimeWire returns a webpage with information (which PrimeWire appropriates
`from the IMDb.com and m.media-amazon.com website for movies and from
`TVMaze.com for television shows) about the movie, followed by multiple links for
`users to click to illegally stream the movie through the PrimeWire platform. The
`screenshot below shows only the first several links, but this particular search
`produced 20 active links to copies of Wonder Woman (2017) for streaming:
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`39. By simply clicking on one of the “Version” links, an embedded media
`player opens on the PrimeWire Website and the user can watch the movie through
`the media player (or in full screen), without leaving that Website:
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`40. A PrimeWire user can also choose to watch a title through a third-party
`website by clicking the “Direct” icon, represented by a box and arrow diagonally
`upward and shown in the lower left-hand corner of the above screenshot. Doing so
`will open a window for streaming directly from the linked website:
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`41. Defendants curate title listings into various categories that make plain
`the service’s infringing nature. “Featured Movies,” for example, includes popular
`recent releases, like Warner Bros.’s The Suicide Squad (2021) and Space Jam: A
`New Legacy (2021) and Disney’s Jungle Cruise (2021).
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`Likewise, the category “New Movies” features those that are new to the market and
`new to the PrimeWire service like Columbia Pictures’ Venom: Let There Be
`Carnage (2021).
`42. Defendants denote the quality of the linked content with symbols that
`indicate the quality of the source copy for the stream.
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`The symbols themselves make clear that the underlying copy has been made
`illegally. A DVD icon indicates “High Quality.” The icon reflects that the copy
`available for streaming was ripped from a DVD, Blu-ray disc, or legitimate
`streaming service, thereby providing a perfect digital copy of the movie or TV
`show. A “TS” icon indicates “Medium Quality.” TS is an abbreviation of “HDTS,”
`an acronym referring to a bootleg recording of a film made from within the theater,
`sometimes from the projection booth, by a high quality camera with a direct
`connection to the sound source. A camera icon indicates “low quality.” The icon
`reflects that the copy was made using a camcorder or another type of camera that
`recorded a performance of the movie or TV show on a theater or television screen.
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`43. Defendants ask users to “vote” on the quality of the links on a scale of
`one to five stars. Defendants curate the presentation of links based on these ratings,
`so as to ensure that the highest-ranked results will be the highest-quality streams.
`The image below shows several links for Universal’s Minions (2015), each with
`hundreds of votes and a rating of one to five stars:
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`44. Through these and other actions, Defendants cultivate loyalty to and
`awareness of PrimeWire as a high quality, reliable source for illegal streaming.
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`COMPLAINT
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`Case No. 2:21-cv-09317
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`Case 2:21-cv-09317-RAO Document 1 Filed 12/01/21 Page 17 of 28 Page ID #:17
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`Defendants Induce the Infringement of Copyrighted Works Because Their Business
`Depends on Infringement
`45. The popularity and profitability of Defendants’ site depends on high-
`volume infringing conduct. Maintaining an evergreen collection of links to
`infringing copies is critical to keeping existing users and getting new ones, all of
`which is critical to Defendants’ scheme to profit (through advertising and
`sponsored-link revenue) from high-volume infringing traffic to the site.
`46. Defendants encourage and rely on users to upload links to infringing
`content, including through an API (https://www.primewire.li/api). This process
`sustains and grows Defendants’ infringing service. Defendants have stated on
`Internet forums that they “are looking for linkers,” and have invited prospective
`users to “register for a new account” with PrimeWire “and start linking right away.”
`In the same posting, Defendants have admitted that user-submitted “links will go
`through a moderation process,” meaning Defendants or their agents check the
`submitted links and indisputably know their users are linking to infringing copies of
`Copyrighted Works.
`47. Once users start using PrimeWire, Defendants continue to urge them to
`post links to infringing content. Defendants tell users which “approved” sites they
`can use as sources for infringing streams, and Defendants emphasize sites that pay
`users for uploading infringing content. Defendants also implement a point system to
`reward users who contribute to the pirate enterprise. Users are awarded 30 points
`for each new link. Users with the highest monthly point totals are featured on
`PrimeWire’s “Top Users” page. Those at the top of the list have seeded
`Defendants’ service with tens of thousands of links.
`48. Defendants likewise reward users with points for reporting “broken”
`links, i.e., links that do not take users to the content they request. Getting rid of
`broken links furthers Defendants’ goal of ensuring users receive high-quality
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`COMPLAINT
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`Case No. 2:21-cv-09317
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`Case 2:21-cv-09317-RAO Document 1 Filed 12/01/21 Page 18 of 28 Page ID #:18
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`infringing streams and thus continue to use the service and promote its infringing
`use to others.
`49. Defendants also curate and encourage users to curate content into
`collections that other users will find desirable. Defendants have implemented and
`maintain a “Playlist” feature, which invites users to submit links to groups of movies
`that organize and recommend movies and TV shows to stream. For example,
`Defendants promote a curated “Disney” Playlist, which features Moana (2016) and
`Cars (2006), among many other popular Copyrighted Works.
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`50. Defendants use metadata—key words that search engines use to rank
`search results—to maximize PrimeWire’s visibility and priority in Internet search
`results for infringing websites. The metadata for the PrimeWire Websites include
`such terms as “letmewatchthis” and “theater releases.”
`51. Defendants also provide information that facilitates easy streaming.
`Defendants maintain a “How do I watch movies? Quick guide here …” that walks
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`COMPLAINT
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`Case No. 2:21-cv-09317
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`Case 2:21-cv-09317-RAO Document 1 Filed 12/01/21 Page 19 of 28 Page ID #:19
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`users, step-by-step, through the process for watching videos through PrimeWire.
`Defendants also host and moderate a forum for users to discuss movies and sources
`for infringing content.
`52. Through these and other acts, Defendants promote (a) the unauthorized
`copying and uploading of movies and TV shows so PrimeWire has a perennial
`source of links to infringing content; and (b) the unauthorized streaming of content,
`so that users will return again and again to PrimeWire and promote the use of the
`service to others looking for unlicensed and free content.
`Defendants Profit from Their Infringing Conduct Through Referral Links and by
`Displaying Ads on the Sites
`53. Defendants induce and facilitate infringing conduct through PrimeWire
`to make money from the illegal exploitation of copyrighted content.
`54. Defendants are paid when their users click on a link to another website
`or service that pays Defendants a referral fee. For example, Defendants prominently
`feature advertisements and links for the ExpressVPN service on the PrimeWire
`Websites. When a PrimeWire user clicks through to ExpressVPN and signs up for
`its VPN services, ExpressVPN pays Defendants a referral fee. PrimeWire has a
`similar “sponsored” relationship with the “Unlimited Streaming”
`(unltdentertainment.co) website, which appears to be a scheme to obtain users’
`credit card information rather than a legitimate streaming service.
`55. Defendants also sell advertising on the PrimeWire website.
`Advertisements “pop up” as users navigate through the site and are required to be
`viewed by users before the stream of the movie or TV show starts. Advertisements
`focus on products like VPN services, which Defendants describe as “Support[ing]
`the Site.” While PrimeWire describes its site as “family friendly,” the site is replete
`with ads containing sexually explicit material. These explicit ads are visible to all
`users, regardless of age, as PrimeWire does not utilize any age-gating protections to
`ensure that ads of a mature nature are displayed only to adults.
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`COMPLAINT
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`Case 2:21-cv-09317-RAO Document 1 Filed 12/01/21 Page 20 of 28 Page ID #:20
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`56. Defendants use third-party advertising networks, which have changed
`over time, but currently include Clickadu, to place advertisements on the PrimeWire
`website. The ad networks link advertisers to the PrimeWire service. The
`advertisers pay the networks, and the networks then credit PrimeWire with a share
`of that revenue when users open the ads on the PrimeWire site. These advertisers
`are indifferent to whether the advertisements are legitimate or fraudulent and
`numerous comments on the site note the risk of malware to users who click on the
`wrong link.
`57. For these reasons, among others, high-volume use of PrimeWire as a
`source for illegal streaming translates into significant amounts of ill-gotten profits
`flowing into Defendants’ pockets.
`Defendants Know They Are Engaged in Illegal Conduct
`58. Defendants know they are engaged in mass copyright infringement.
`Defendants go to great lengths to hide their identities. Defendants use aliases on
`their forum. Moderators are known as “Dev_Team,” “Silverrain,” “Fugitive,” and
`“drodman250,” each of whom uses a stock image profile picture and fake location,
`such as “Fugitive” who claims to be from “Valyria, Earth” (a Game of Thrones
`reference):
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`COMPLAINT
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`Case 2:21-cv-09317-RAO Document 1 Filed 12/01/21 Page 21 of 28 Page ID #:21
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`59. Defendants provide false information in registering their domains, so
`the WHOIS information cannot be used to identify them or their location.
`60. Defendants likewise encourage their users to take steps to remain
`anonymous, further betraying Defendants’ knowledge that they are facilitating
`unlawful activity. At the moment users access the site, Defendants encourage them
`to buy a VPN from ExpressVPN so users will avoid being identified or having
`streams blocked.
`61. Over the past several years, Defendants have grown their presence in
`the United States substantially. In less than three years, Defendants’ U.S. user base
`has grown from less than 1 million monthly visits to approximately 20 million
`monthly visits.
`62. Defendants openly mock th

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