Video Stream DMCA (Copyright) Complaint to Google

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Dear Sir/Madam:

We write to inform you of a violation of the Google AdSense Program Policies, which also severely affect our rights. According to the AdSense Program Policies, "Sites displaying Google ads may not include:... Any other content that is illegal, promotes illegal activity, or infringes on the legal rights of others."

MLB Advanced Media, L.P., ("MLBAM") is the exclusive licensee of the MLB Entities with respect to uses via the Internet and other interactive media of their game and exhibition telecasts and excerpts thereof (collectively, "MLB Telecasts"). MLBAM has received information that a Google AdSense partner, www.rojadirecta.es (the "Website"), is still distributing and displaying, without authorization, copyrighted works of MLBAM, the Office of the Commissioner of Baseball, and/or certain Major League Baseball Clubs (collectively, the "MLB Entities") despite our notifying you of this violation on April 5, 2011. (See Exhibit A attached hereto for an example.) <b>The Website streams live copyrighted MLB Telecasts when games are occurring.</b> The unauthorized distribution of such copyrighted works is an infringement of the applicable MLB Entity's copyrights in them, in violation of the U.S. Copyright Act and other applicable law.

The copyright owner of the MLB game telecasts are the applicable MLB Entities. I have a good faith belief that this use is not authorized by the copyright owner, its agent or the law. The information in this notice is accurate, and I hereby certify under penalty of perjury that I am authorized to act on behalf of the MLB Entities, the owner(s) of the copyrights in the works identified above. I have a good faith belief that none of the materials or activities listed above have been authorized by the MLB Entities, their agents, or the law.

I may be contacted at

[redacted]
Legal Coordinator
MLB Advanced Media, L.P.
[redacted]
New York, NY 10011
Tel: [redacted]
E-mail: [redacted]@mlb.com

We appreciate your cooperation in this matter. Please advise us regarding what actions you take. This letter does not purport to be a complete statement of the applicable facts or law and is submitted without prejudice.

Very truly yours
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[redacted]
Legal Coordinator