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Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 1 of 15
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF GEORGIA
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`Civil Action No.
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`JURY TRIAL DEMANDED
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`COMPLAINT
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`AF HOLDINGS, LLC,
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`Plaintiff,
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`v.
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`RAJESH PATEL,
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`Defendant.
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`Plaintiff AF Holdings, LLC (“Plaintiff”), through its undersigned counsel, hereby files
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`this Complaint requesting damages and injunctive relief, and alleges as follows:
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`NATURE OF THE CASE
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`1.
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`Plaintiff files this action for copyright infringement under the United States
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`Copyright Act and related civil conspiracy, contributory infringement and negligence claims
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`under the common law to combat the willful and intentional infringement of its creative works.
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`Defendant Rajesh Patel (“Defendant”) knowingly and illegally reproduced and distributed
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`Plaintiff’s copyrighted Video by acting in concert with others via the BitTorrent file sharing
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`protocol and, upon information and belief, continues to do the same. In using BitTorrent,
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`Defendant’s infringement actions furthered the efforts of numerous others in infringing on
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`Plaintiff’s copyrighted works. The result: exponential viral infringement. Plaintiff seeks a
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`permanent injunction, statutory or actual damages, award of costs and attorney’s fees, and other
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`relief to curb this behavior.
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`THE PARTIES
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`2.
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`Plaintiff AF Holdings, LLC is a limited liability company organized and existing
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`under the laws of the Federation of St. Kitts and Nevis. Plaintiff is a holder of rights to various
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 2 of 15
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`copyrighted works, and is the exclusive holder of the relevant rights with respect to the
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`copyrighted creative work at issue in this Complaint.
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`3.
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`The copyrighted work at issue in this complaint is one of Plaintiff’s adult
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`entertainment videos, “ Popular Demand” (the “Video”).
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`4.
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`Defendant is an individual who, on information and belief, is over the age of 18,
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`resides in this District, and was the account holder of Internet Protocol (“IP”) address
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`75.89.36.80 at the time of the alleged infringing activity. An IP address is a number assigned to
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`devices, such as computers, that are connected to the Internet. In the course of monitoring
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`Internet-based infringement of its copyrighted content, Plaintiff’s agents observed unlawful
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`reproduction and distribution occurring over IP address 75.89.36.80 via the BitTorrent file
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`transfer protocol.
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`JURISDICTION AND VENUE
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`5.
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`This Court has subject matter jurisdiction over the copyright infringement claim
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`under 17 U.S.C. §§ 101, et seq., (the Copyright Act), 28 U.S.C. § 1331 (actions arising under the
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`laws of the United States), and 28 U.S.C. § 1338(a) (actions arising under an Act of Congress
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`relating to copyrights). This Court has supplemental jurisdiction over the civil conspiracy,
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`contributory infringement and negligence claims under 28 U.S.C. § 1367(a) because they are so
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`related to Plaintiff’s copyright infringement claim, which is within this Court’s original
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`jurisdiction, that the claims form part of the same case and controversy under Article III of the
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`United States Constitution.
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`6.
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`This Court has personal jurisdiction because, upon information and belief,
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`Defendant either resides in or committed copyright infringement in the State of Georgia.
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`7.
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`Venue is properly founded in this judicial district pursuant to 28 U.S.C.
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`§§ 1391(b) and 1400(a) because Defendant resides in this District, may be found in this District,
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 3 of 15
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`or a substantial part of the events giving rise to the claims in this action occurred within this
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`District.
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`BACKGROUND
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`8.
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`BitTorrent is a modern file sharing method (“protocol”) used for distributing data
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`via the Internet.
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`9.
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`Traditional file transfer protocols involve a central server, which distributes data
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`directly to individual users. This method is prone to collapse when large numbers of users
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`request data from the central server, in which case the server can become overburdened and the
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`rate of data transmission can slow considerably or cease altogether. In addition, the reliability of
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`access to the data stored on a server is largely dependent on the server’s ability to continue
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`functioning for prolonged periods of time under high resource demands.
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`10.
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`Standard P2P protocols involve a one-to-one transfer of whole files between a
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`single uploader and single downloader. Although standard P2P protocols solve some of the
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`issues associated with traditional file transfer protocols, these protocols still suffer from such
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`issues as scalability. For example, when a popular file is released (e.g. an illegal copy of the
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`latest blockbuster movie) the initial source of the file performs a one-to-one whole file transfer to
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`a third party, who then performs similar transfers. The one-to-one whole file transfer method can
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`significantly delay the spread of a file across the world because the initial spread is so limited.
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`11.
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`In contrast, the BitTorrent protocol is a decentralized method of distributing data.
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`Instead of relying on a central server to distribute data directly to individual users, the BitTorrent
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`protocol allows individual users to distribute data among themselves. Further, the BitTorrent
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`protocol involves breaking a single large file into many small pieces, which can be transferred
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`much more quickly than a single large file and in turn redistributed much more quickly than a
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`single large file. Moreover, each peer can download missing pieces of the file from multiple
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 4 of 15
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`sources—often simultaneously—which causes transfers to be fast and reliable. After
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`downloading a piece, a peer automatically becomes a source for the piece. This distribution
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`method contrasts sharply with a one-to-one whole file transfer method.
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`12.
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`In BitTorrent vernacular, individual downloaders/distributors of a particular file
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`are called peers. The group of peers involved in downloading/distributing a particular file is
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`called a swarm. A server which stores a list of peers in a swarm is called a tracker. A computer
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`program that implements the BitTorrent protocol is called a BitTorrent client. Each swarm is
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`unique to a particular file.
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`13.
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`The BitTorrent protocol operates as follows. First, a user locates a small “torrent”
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`file. This file contains information about the files to be shared and about the tracker, the
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`computer that coordinates the file distribution. Second, the user loads the torrent file into a
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`BitTorrent client, which automatically attempts to connect to the tracker listed in the torrent file.
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`Third, the tracker responds with a list of peers and the BitTorrent client connects to those peers
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`to begin downloading data from and distributing data to the other peers in the swarm. When the
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`download is complete, the BitTorrent client continues distributing data to other peers in the
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`swarm until the user manually disconnects from the swarm or the BitTorrent client otherwise
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`does the same.
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`14.
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`The degree of anonymity provided by the BitTorrent protocol is extremely low.
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`Because the protocol is based on peers connecting to one another, a peer must broadcast
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`identifying information (i.e. an IP address) before it can receive data. Nevertheless, the actual
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`names of peers in a swarm are unknown, as the users are allowed to download and distribute
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`under the cover of their IP addresses.
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 5 of 15
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`15.
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`The BitTorrent protocol is an extremely popular method for transferring data. The
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`size of swarms for popular files can reach into the tens of thousands of unique peers. A swarm
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`will commonly have peers from many, if not every, state in the United States and several
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`countries around the world. And every peer in the swarm participates in distributing the file to
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`dozens, hundreds, or even thousands of other peers.
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`16.
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`The BitTorrent protocol is also an extremely popular method for unlawfully
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`copying, reproducing, and distributing files in violation of the copyright laws of the United
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`States. A broad range of copyrighted albums, audiovisual files, photographs, software, and other
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`forms of media are available for illegal reproduction and distribution via the BitTorrent protocol.
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`17.
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`Efforts at combating BitTorrent-based copyright infringement have been stymied
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`by BitTorrent’s decentralized nature. Because there are no central servers to enjoin from
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`unlawfully distributing copyrighted content, there is no primary target on which to focus anti-
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`piracy efforts. Indeed, the same decentralization that makes the BitTorrent protocol an extremely
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`robust and efficient means of transferring enormous quantities of data also acts to insulate it from
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`anti-piracy measures. This lawsuit is Plaintiff’s only practical means of combating BitTorrent-
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`based infringement of the Video.
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`ALLEGATIONS COMMON TO ALL COUNTS
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`18.
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`Plaintiff is the exclusive rights holder with respect to BitTorrent-based
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`reproduction and distribution of the Video.
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`19.
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`The Video is currently registered in the United States Copyright Office
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`(Copyright No. PA0001754383). (See Exhibit A to Complaint.) On December 20, 2011, Plaintiff
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`received the rights to this Video pursuant to an assignment agreement, a true and correct copy of
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`which is attached hereto as Exhibit B. (See Exhibit B to Complaint.)
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 6 of 15
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`20.
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` The torrent file used to access the copyrighted material was named in a manner
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`that would have provided an ordinary individual with notice that the Video was protected by the
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`copyright laws of the United States.
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`21.
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`Plaintiff employs proprietary peer-to-peer network forensic software to perform
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`exhaustive real time monitoring of the BitTorrent-based swarm involved in distributing the
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`Video. This software is effective in capturing data about the activity of peers in a swarm and
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`their infringing conduct.
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`22.
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`Defendant, using IP address 75.89.36.80, without Plaintiff’s authorization or
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`license, intentionally downloaded a torrent file particular to Plaintiff’s Video, purposefully
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`loaded that torrent file into his BitTorrent client, entered a BitTorrent swarm particular to
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`Plaintiff’s Video, and reproduced and distributed the Video to numerous third parties.
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`23.
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`Plaintiff’s investigators detected Defendant’s illegal download on
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`December 4, 2011 at 21:39:23 UTC. However, this is a simply a snapshot observation of when
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`the IP address was observed in the BitTorrent swarm; the conduct itself took place before and
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`after this date and time.
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`24.
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`Defendant was part of a group of BitTorrent users or peers in a single swarm—a
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`process generally described above—whose computers were collectively interconnected for the
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`sharing of a particular unique file. The particular file a BitTorrent swarm is associated with has a
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`unique file “hash”—i.e. a unique file identifier generated by an algorithm (hereinafter “Hash
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`Tag.”)—and common to all of the participants in the swarm.
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`COUNT I – COPYRIGHT INFRINGEMENT – REPRODUCTION
`(17 U.S.C. § 106(1))
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`25.
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`the preceding paragraphs as if fully set forth fully herein.
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 7 of 15
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`26.
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`Plaintiff is the copyright owner of the Video.
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`27.
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`28.
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`Defendant, without authorization, unlawfully obtained a copy of the Video.
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`Normally, Plaintiff offers the Video for purchase. Defendant, however, did not
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`purchase the Video and/or obtain the Video legally.
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`29.
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`Defendant used IP address 75.89.36.80 to access the Video on the Internet, and
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`download the unique file containing the Video onto a hard drive through the unique swarm
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`associated with the unique Hash Tag using the BitTorrent protocol.
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`30.
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`31.
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`Defendant’s actions constituted copyright infringement of Plaintiff’s Video.
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`Defendant knew or had constructive knowledge that his acts constituted copyright
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`infringement of Plaintiff’s Video.
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`32.
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`Defendant’s conduct was willful within the meaning of the Copyright Act:
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`intentional, and with indifference to the Plaintiff’s rights.
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`33.
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`Defendant’s conduct infringed upon Plaintiff’s exclusive rights of reproduction of
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`the Video that are protected under the Copyright Act.
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`34.
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`Plaintiff has been damaged by Defendant’s conduct, including, but not limited to,
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`economic and reputation losses. Plaintiff continues to be damaged by such conduct, and has no
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`adequate remedy at law to compensate the Plaintiff for all of the possible damages stemming
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`from Defendant’s conduct.
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`35.
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`As Defendant’s infringement was intentional and willful, the Plaintiff is entitled
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`to an award of actual damages and/or statutory damages (pursuant to 17 U.S.C. § 504(c)) at its
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`own election, exemplary damages, attorneys’ fees (pursuant to 17 U.S.C. § 505), injunctive relief
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`(pursuant to 17 U.S.C. §§ 502, 503) and the costs of the suit.
`
`///
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 8 of 15
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`COUNT II – COPYRIGHT INFRINGEMENT – DISTRIBUTION
`(17 U.S.C. § 106(3))
`
`Plaintiff hereby incorporates by reference each and every allegation contained in
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`36.
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`the preceding paragraphs as if set forth fully herein.
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`37.
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`Plaintiff holds the exclusive rights under the Copyright Act to distribute the
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`Video.
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`38.
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`Defendant has used, and continues to use, the BitTorrent file transfer protocol to
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`unlawfully distribute the Video to other individuals over the Internet by publishing the Video to
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`hundreds of thousands of BitTorrent users from a computer owned or controlled by Defendant,
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`which, in essence, served as a distribution server for the Video. In doing so, Defendant violated
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`Plaintiff’s exclusive rights to distribute the Video.
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`39.
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`Defendant was not given any permission to conduct such reproduction, and
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`Plaintiff never consented to such.
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`40.
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`Defendant’s actions constitute infringement of Plaintiff’s copyrights and
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`exclusive rights under the Copyright Act.
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`41.
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`Defendant knew or had constructive knowledge that his acts constituted copyright
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`infringement of Plaintiff’s Video.
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`42.
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`Defendant’s conduct was willful within the meaning of the Copyright Act:
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`intentional, and with indifference to the Plaintiff’s rights.
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`43.
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`Plaintiff has been damaged by Defendant’s conduct, including but not limited to
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`economic and reputation losses. Plaintiff continues to be damaged by such conduct, and has no
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`adequate remedy at law to compensate the Plaintiff for all of the possible damages stemming
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`from the Defendant’s conduct.
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 9 of 15
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`44.
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`As Defendant’s infringement was intentional and willful, the Plaintiff is entitled
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`to an award of actual damages and/or statutory damages (pursuant to 17 U.S.C. § 504(c)) at its
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`own election, exemplary damages, attorneys’ fees (pursuant to 17 U.S.C. § 505), injunctive relief
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`(pursuant to 17 U.S.C. §§ 502, 503) and the costs of the suit.
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`COUNT III – CONTRIBUTORY INFRINGEMENT
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`45.
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`the preceding paragraphs as if set forth fully herein.
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`46. When users in this unique swarm all possess the same infringing work with the
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`same exact hash value, it is because each infringer possesses an exact digital copy, containing the
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`exact bits and pieces unique to that specific file of Plaintiff’s original copyrighted work. They
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`only way this happens in a BitTorrent swarm is through the sharing of these bits and pieces of
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`each same unique file, with the same unique hash value, between the users in the swarm. In
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`essence, although hundreds of users may be uploading the copyrighted work, a single user will
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`receive only the exact parts of a singular upload through that exact swarm, not a compilation of
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`available pieces from various uploads.
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`47.
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`48.
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`Defendant published the Hash Tag to the BitTorrent network.
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`Defendant downloaded, uploaded and distributed the Video to other BitTorrent
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`users through use of the hash-specified protocol in the unique swarm.
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`49.
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`As each of the thousands of people who illegally downloaded the movie accessed
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`this illegal publication, they derived portions of their illegal replication of the file from multiple
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`persons, including, but not limited to, Defendant.
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 10 of 15
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`50.
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`Defendant knew of the infringement, was conscious of his own infringement, and
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`Defendant was fully conscious that his actions resulted in multiple other persons derivatively
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`downloading the file containing Plaintiff’s Video.
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`51.
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`The infringement by the other BitTorrent users could not have occurred without
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`Defendant’s participation in uploading Plaintiff’s copyrighted works. As such, Defendant’s
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`participation in the infringing activities of others is substantial and contributed, for profit, to the
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`infringing activity of thousands of other peers over the Internet across the world.
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`52.
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`Defendant profited from this contributory infringement by way of being granted
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`access to a greater library of other infringing works, some of which belonged to Plaintiff and
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`some of which belonged to other copyright owners.
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`COUNT IV – CIVIL CONSPIRACY
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`53.
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`the preceding paragraphs as if set forth fully herein.
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`54.
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`In using the peer-to-peer BitTorrent file distribution method, Defendant engaged
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`in a concerted action with other unnamed individuals to reproduce and distribute Plaintiff’s
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`Video by exchanging pieces of the Video file in the torrent swarm.
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`55.
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`Defendant and his co-conspirators downloaded a torrent file, opened it using a
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`BitTorrent client, and then entered a torrent swarm comprised of other individuals distributing
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`and reproducing Plaintiff’s Video. In participating in said conspiratorial network, Defendant
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`agreed with others to engage in a concerted tortious action in the network to reproduce and
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`distribute Plaintiff’s Video.
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 11 of 15
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`56.
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`Participants in the torrent swarm have conspired to provide other individuals with
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`pieces of the Video in exchange for receiving other pieces of the same Video to eventually obtain
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`a complete copy of the file.
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`57.
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`In furtherance of this civil conspiracy, Defendant committed overt tortious and
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`unlawful acts by using BitTorrent software to download the Video from and distribute it to
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`others, and were willful participants in this joint activity.
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`58.
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`As a proximate result of this conspiracy, Plaintiff has been damaged, as is more
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`fully alleged above.
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`COUNT V – NEGLIGENCE
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`59.
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`the preceding paragraphs as if set forth fully herein.
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`60.
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`In the alternative, Defendant was negligent and/or reckless in allowing a third-
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`party to commit the allegations of infringement, contributory infringement, and civil conspiracy
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`described above through his Internet connection.
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`61.
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`Defendant accessed, or controlled access to, the Internet connection used in
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`performing the unauthorized copying and sharing of Plaintiff’s Video, proximately causing
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`financial harm to Plaintiff.
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`62.
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`Defendant had a duty to secure his Internet connection. Defendant breached that
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`duty by failing to secure his Internet connection.
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`63.
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`Reasonable Internet users take steps to secure their Internet access accounts
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`preventing the use of such accounts for an illegal purpose. Defendant’s failure to secure his
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`Internet access account, thereby allowing for its illegal use, constitutes a breach of the ordinary
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`care that a reasonable Internet account holder would do under like circumstances.
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 12 of 15
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`64.
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`In the alternative, Defendant secured his connection, but knowingly permitted an
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`unknown third party to use his Internet connection to infringe on Plaintiff’s Video. Defendant
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`knew, or should have known, that this unidentified individual used Defendant’s Internet
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`connection for the aforementioned illegal activities. Defendant declined to monitor the
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`unidentified third-party infringer’s use of his computer Internet connection, demonstrating
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`further negligence.
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`65.
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`In the alternative, Defendant knew of, and allowed for, the unidentified third party
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`infringer’s use of his Internet connection for illegal purposes and thus was complicit in the
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`unidentified third party’s actions.
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`66.
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`Upon information and belief, Defendant’s failure to secure his Internet access
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`account directly allowed for the copying and sharing of Plaintiff’s Video over the BitTorrent
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`protocol through Defendant’s Internet connection, and interfered with Plaintiff’s exclusive rights
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`in the copyrighted work.
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`67.
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`Upon information and belief, Defendant knew, or should have known of, the
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`unidentified third party’s infringing actions, and, despite this, Defendant directly, or indirectly,
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`allowed for the copying and sharing of Plaintiff’s Video over the BitTorrent protocol through
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`Defendant’s Internet connection, and interfered with Plaintiff’s exclusive rights in the
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`copyrighted Video.
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`68.
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`By virtue of his unsecured access, Defendant negligently allowed the use of his
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`Internet access account to perform the above-described copying and sharing of Plaintiff’s
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`copyrighted Video.
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`69.
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`Had Defendant taken reasonable care in securing access to this Internet
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`connection, or monitoring the unidentified third-party individual’s use of his Internet connection,
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 13 of 15
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`such infringements as those described above would not have occurred by the use of Defendant’s
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`Internet access account.
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`70.
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`Defendant’s negligent actions allowed numerous others to unlawfully copy and
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`share Plaintiff’s copyrighted Video, proximately causing financial harm to Plaintiff and
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`unlawfully interfering with Plaintiff’s exclusive rights in the Video.
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`JURY DEMAND
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`71.
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`Plaintiff hereby demands a jury trial in this case.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff respectfully requests Judgment and relief as follows:
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`1)
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`Judgment against Defendant that he has: a) willfully infringed Plaintiff’s rights in
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`federally registered copyrights pursuant to 17 U.S.C. § 501; and b) otherwise injured the
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`business reputation and business of Plaintiff by Defendant’s acts and conduct set forth in this
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`Complaint;
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`2)
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`Judgment in favor of the Plaintiff against Defendant for actual damages or
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`statutory damages pursuant to 17 U.S.C. § 504, at the election of Plaintiff, in an amount to be
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`ascertained at trial;
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`3)
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`Order of impoundment under 17 U.S.C. §§ 503 & 509(a) impounding all
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`infringing copies of Plaintiff’s audiovisual works, photographs or other materials, which are in
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`Defendant’s possession or under his control;
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`4)
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`As to Count III, that the Court order the Defendant jointly and severally liable to
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`Plaintiff in the full amount of the Judgment along with the damages associated with the
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`infringing activities of his co-conspirators;
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`5)
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`As to Count IV, an order that Defendant is liable to the Plaintiff in the full amount
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`of Judgment on the basis of a common law claim for contributory infringement of copyright; for
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 14 of 15
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`an award of compensatory damages in favor of the Plaintiff and against Defendant in an amount
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`to be determined at trial;
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`6)
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`On Count IV, in the alternative, an order that Defendant is jointly and severally
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`liable to the Plaintiff in the full amount of Judgment on the basis of Defendant’s negligence in
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`allowing an unidentified third party access his Internet account and, through it, violate Plaintiff’s
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`copyrighted works; for an award of compensatory damages in favor of the Plaintiff and against
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`Defendant, jointly and severally, in an amount to be determined at trial;
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`7)
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`Judgment in favor of Plaintiff against the Defendant awarding the Plaintiff
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`attorneys’ fees, litigation expenses (including fees and costs of expert witnesses), and other costs
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`of this action; and
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`8)
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`Judgment in favor of the Plaintiff against the Defendant, awarding Plaintiff
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`declaratory and injunctive or other equitable relief as may be just and warranted under the
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`circumstances.
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`Respectfully submitted,
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`AF Holdings, LLC,
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`DATED: November 2, 2012
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`By:
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`/s/ Jacques Nazaire
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`Jacques Nazaire, Esq. (Bar No. 142388)
`Of Counsel to Prenda Law Inc.
`125 Town Park Drive, Suite 300
`Kennesaw, Georgia 30144
`Telephone: (415) 325-5900
`Email: blgibbs@wefightpiracy.com
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`Attorney for Plaintiff
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`

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`Case 2:12-cv-00262-WCO Document 1 Filed 11/02/12 Page 15 of 15
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`DEMAND FOR A JURY TRIAL
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`Plaintiff hereby demands a jury trial as provided by FRCP 38(a).
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`By:
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`/s/ Jacques Nazaire
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`Jacques Nazaire, Esq.
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`Attorney for Plaintiff
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