MPAA sends payment intermediary request to disable user for copyright infringement a

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Dear Stripe:

We represent each of the major motion picture studios in the United States, specifically,
Paramount Pictures Corporation, Sony Pictures Entertainment Inc., Twentieth Century Fox Film
Corporation, Universal City Studios LLC, Universal City Studios Productions LLLP, Warner
Bros. Entertainment Inc., Walt Disney Studios Motion Pictures, and their respective affiliates
(collectively, the “MPAA Member Studios”), which own or control exclusive rights under
copyright in and to a vast number of motion pictures and television shows. By this letter, we are
reaching out to seek your assistance in mitigating the copyright infringement of motion pictures
and television shows being committed by the website Glumbouploads.com (“client website”),
which uses your payment processing services. The client website is violating both copyright law
and your Acceptable Use Policy (“AUP”), which expressly prohibit use of your facilities for
copyright infringement.
More specifically, the client website is violating the MPAA Member Studios’ copyrights, and
your AUP, by providing unauthorized access to infringing copies of motion pictures or television
programs, either by enabling streaming of the work (unlawful public performance) or
downloading of the work (unlawful distribution and reproduction). See Metro-Goldwyn-Mayer
Studios Inc. v. Grokster, Ltd., 545 U.S. 912 (2005); Arista Records LLC v. Usenet.com, Inc., 633
F. Supp. 2d 124, 155 (S.D.N.Y. 2009) (defendants liable for direct and contributory copyright
infringement where defendants operated computers that stored and distributed infringing
content); Playboy Enters, Inc. v. Webbworld, Inc., 991 F. Supp. 543 (N.D. Tex. 1997), aff’d, 168
F.3d 486, 551-553 (5th Cir. 1999) (unpublished) (same); Columbia Pictures Indus., Inc. v. Fung,
No. 06-5578, 2009 U.S. Dist. Lexis 122661, at *56 (C.D. Cal. Dec. 21, 2009) (defendants liable
for inducement of infringement where they operated a website that provided access to copies of
plaintiffs’ works); Warner Bros. Entm’t Inc. v. Free-tv-video-online.info, Case No. CV 08-8484
(C.D. Cal. Feb. 1, 2010) (court granted summary judgment against the owner of an Internet
website who knowingly provided links to infringing works). As an example, the client website is
presently indexing, transmitting, streaming, publicly performing and otherwise providing
unauthorized access to infringing copies of motion pictures or television programs owned or
controlled by the MPAA Member Studios.
We have attempted to contact the individual operating this client website to demand that they
cease engaging in infringing activity, and in spite of our notices the client website continues to
unabashedly infringe the MPAA Member Studios’ copyrighted works.
Exhibit A hereto contains a non-exhaustive sampling of the infringing works found on the client
website. Exhibit A, therefore, is provided as a representative sample of the infringements being
committed by the client website and to demonstrate the readily apparent nature of the
infringements occurring thereon. Having been informed, through the representative list, of the
nature and scope of infringements occurring on the client website, we hope that you will act
appropriately under your AUP to address the infringement occurring on the client website.
We are providing this notice based on our good faith belief that the use of motion pictures and
television programs owned by the MPAA Member Studios in the manner occurring on the client
website is not authorized by the copyright owners, their agents, or the law. The information in
this notification is accurate and, under penalty of perjury, we are authorized to act on behalf of
the MPAA Member Studios, which own or control exclusive rights under copyright that are
being infringed in the manner described herein. This letter is without prejudice to the rights and
remedies of the MPAA Member Studios, all of which are expressly reserved.
If you have any questions, please contact me by telephone at 818-935-5869, or via email at
[redacted]@copyright.org.
Very truly yours,
[redacted]
Attachment


EXHIBIT A

Tron Uprising
Walt Disney
http://glumbouploads.net/e5znt0dqe1os
Touch
Fox
http://glumbouploads.net/0irlizecx8b3
Snow White and The Huntsman
Universal
http://glumbouploads.net/35olkp6wndnh
American Pie 3
Universal
http://glumbouploads.net/35olkp6wndnh
Iron Man
Paramount Pictures
http://glumbouploads.net/h46jthxldg01
Madagasar 3
Dreamworks/Walt Disney
http://glumbouploads.net/kcwsa16jm2qr
American Pie
Universal
http://glumbouploads.net/fkn1n4q2e1rb