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Gov.uscourts.mad.150471.1.0

Gov.uscourts.mad.150471.1.0

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Published by J Doe
Gov.uscourts.mad.150471.1.0
Gov.uscourts.mad.150471.1.0

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Categories:Types, Business/Law
Published by: J Doe on Apr 06, 2013
Copyright:Attribution Non-commercial

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07/25/2013

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 1
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MASSACHUSETTS
BREAKING GLASS PICTURES,Plaintiff,v.SWARM SHARING HASH FILE
SHA1:973F491D02C1E0220DBC534D8F8EDC15FC53FAEF;AND DOES 1 through 91
,Defendants.
 CIVIL ACTION NO.:
JURY TRIAL DEMANDEDCOMPLAINT FOR COPYRIGHT INFRINGEMENT
Plaintiff, Breaking Glass Pictures (hereinafter "Plaintiff') files this Complaint againstmultiple unknown Defendants and alleges as follows:
NATURE OF THE CASE
1.
 
Plaintiff is the registered owner of the copyright to a motion picture entitled "6
Degrees of Hell”
(hereinafter the "Motion Picture").
THE MOTION PICTURE IS NOT APORNOGRAPHIC FILM.
A true and correct copy of the Certificate of Registration for theMotion Picture is attached hereto as Exhibit A.
2.
 
Defendants, whose true identities are currently unknown, acted in a collectiveand interdependent manner in the unlawful reproduction and distribution of the Motion Pictureusing the "BitTorrent" file transfer protocol.
3.
 
Each time a Defendant unlawfully distributes a copy of the copyrighted MotionPicture to others over the Internet, particularly via BitTorrent, each recipient can then distributethat unlawful copy of the Motion Picture to others without degradation in sound or picture
Case 1:13-cv-10735-PBS Document 1 Filed 03/29/13 Page 1 of 45
 
 2
quality. Thus, a Defendant's distribution of even a single unlawful copy of the Motion Picturecan result in the nearly instantaneous worldwide distribution of that single copy to a limitlessnumber of people. In this case, each Defendant's copyright infringement built upon the prior infringements, in a cascade of infringement.
4.
 
Plaintiff seeks redress for Defendants' rampant infringement of its exclusive rightsin the Motion Picture, and for injunctive relief to stop Defendants from continuing to infringeupon Plaintiff's copyrighted work.
JURISDICTION AND VENUE
5.
 
This Court has subject matter jurisdiction over Plaintiff's claims for copyrightinfringement and related claims pursuant to 17 U.S.C. §§ 101, et seq., and 28 U.S.C. §§ 1331 and1338(a).
6.
 
Defendants either reside in, solicit, transact, or are doing business within theCommonwealth of Massachusetts; and they have committed unlawful and tortious acts bothwithin and outside the Commonwealth of Massachusetts with the full knowledge that their actswould cause injury in the Commonwealth. As such, Defendants have sufficient contacts with this judicial district to permit the Court's exercise of personal jurisdiction over each.
7.
 
Plaintiff's claims arise out of Defendants' conduct which gives rise to personal jurisdiction over Defendants.
8.
 
Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391(b)(2) and 1400(a).Although the true identities of each and every member of the collective formed by Defendantsare unknown to Plaintiff at this time, on information and belief, each Defendant may be found inthis District and/or a substantial part of the infringing acts complained of herein occurred in thisDistrict, and Defendants can reasonably anticipate being haled into court in this District.
Case 1:13-cv-10735-PBS Document 1 Filed 03/29/13 Page 2 of 45
 
 3
THE PARTIESI. The Plaintiff 
9.
 
Breaking Glass Pictures is limited liability company with a place of businesslocated at 133 N. 4
th
Street, Philadelphia, Pennsylvania 19106.
II. The Defendants
10.
 
The true names and capacities, whether individual, corporate, associate or otherwise, of Doe Defendants 1 through 91 are unknown to Plaintiff, who therefore sues saidDefendants by such fictitious names. Plaintiff knows each Defendant only by the InternetProtocol ("IP")
 
address assigned to the Internet Service Provider ("ISP") account through whicheach Defendant accessed the Internet on the date and at the time at which the infringing activityof each Defendant took place. The IP address used by each Defendant thus far identified,together with the date and time at which his or her infringing activity was observed, is listed below. Plaintiff intends to subpoena the ISPs that issued the IP addresses and/or take other discovery in order to learn the identities of the account holders for the below IP addresses.
11.
 
The Defendants are a group of BitTorrent users or peers, known as a "swarm,"whose computers are collectively interconnected for the purpose of sharing of a particular unique file. The particular file that a BitTorrent swarm is associated with has a unique "hash"(a file identifier generated by an algorithm developed and implemented by the NationalSecurity Agency). The hash in this case is identified as: SHA1:973F491D02C1E0220DBC534D8F8EDC15FC53FAEF (hereinafter the "Shared Hash").
12.
 
Plaintiff is informed and believes, and based thereon alleges, that each Defendantwas and is the agent of the other Defendants, acting within the purpose and scope of said agency.
Case 1:13-cv-10735-PBS Document 1 Filed 03/29/13 Page 3 of 45

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