TO DEFENDANTS AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on February 25, 2013,
at 1:30p.m., or as soonthereafter as the matter may be heard in Courtroom 840, located at 255 E. TempleStreet, Los Angeles California 90006, before the Honorable Dale S. Fischer,Plaintiffs Sugar Hill Music,
(“Plaintiffs”) will and hereby do move this Court pursuant to Federal Rule of Civil Procedure 65 for a preliminary injunction torestrain Defendants CBS Interactive Inc. and CNET Networks, Inc. (“Defendants”)from:a.
directly or indirectly enabling, facilitating, permitting, assisting,soliciting, encouraging or inducing any public consumer of Defendants indownloading a peer-to-peer (“P2P”) software program based on the bittorrent protocol, including but not limited to uTorrent, Frostwire, Speedlord, FireTorrent,GetTorrent, TorrentRover, MovieTorrent, Vuze, and WireBooster; b.
hosting, linking to or otherwise providing for download any peer-to-peer (“P2P”) software program based on the bittorrent protocol, including but not limited to uTorrent, Frostwire, Speedlord, FireTorrent, GetTorrent,TorrentRover, MovieTorrent, Vuze, and WireBooster; and,c.
encouraging, soliciting or inducing the infringement of copyrighted works, directly or indirectly, through the use of P2P software.Plaintiffs make this motion on the grounds that plaintiffs are likely to succeedon the merits of their inducement claim as Defendants distribute bittorrent software programs capable of widespread copyright infringement while simultaneously
This date was agreed to in advance between counsel to accommodate variousholiday schedules of counsel and clients, and a stipulated briefing schedule willfollow. The later hearing date was agreed to with the understanding that theadditional time from filing to hearing would not be argued as evidence of delay.
Case 2:11-cv-09437-DSF-JC Document 42 Filed 11/09/12 Page 3 of 32 Page ID #:553