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Complaint
David E. KendallRobert J. ShaughnessyLaura H. Parsky, State Bar No. 178984WILLIAMS & CONNOLLY LLP725 Twelfth Street, N.W.Washington, DC 20005Telephone: (202) 434-5000Telecopy: (202) 434-5029JAN B. NORMAN, State Bar No.11711715503 Ventura BoulevardEncino, California 91436-3103Telephone: (818) 995-6600, x250Telecopy: (818) 382-1797
 Attorneys for Plaintiffs
UNITED STATES DISTRICT COURTFOR THE CENTRAL DISTRICT OF CALIFORNIAWESTERN DIVISION
METRO-GOLDWYN-MAYER STUDIOS INC., COLUMBIAPICTURES INDUSTRIES, INC.,DISNEY ENTERPRISES, INC., NEWLINE CINEMA CORPORATION,PARAMOUNT PICTURESCORPORATION, TIME WARNER ENTERTAINMENT COMPANY,L.P., TWENTIETH CENTURY FOXFILM CORPORATION, UNIVERSALCITY STUDIOS, INC., ARISTARECORDS, INC., ATLANTICRECORDING CORPORATION,ATLANTIC RHINO VENTURESINC. d/b/a RHINO ENTERTAIN-MENT COMPANY, BAD BOYRECORDS, CAPITOL RECORDS,INC., ELEKTRA ENTERTAINMENTGROUP INC., HOLLYWOODRECORDS, INC., INTERSCOPERECORDS, LAFACE RECORDS,LONDON-SIRE RECORDS INC.,MOTOWN RECORD COMPANY,L.P., THE RCA RECORDS LABEL, aunit of BMG MUSIC d/b/a BMGENTERTAINMENT, SONY MUSICENTERTAINMENT INC., UMGRECORDINGS, INC., VIRGINRECORDS AMERICA, INC., WALTDISNEY RECORDS, WARNER Case No.
 
COMPLAINT FOR DAMAGES ANDINJUNCTIVE RELIEF FOR COPYRIGHT INFRINGEMENT
 
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Complaint
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BROS. RECORDS INC., WEAINTERNATIONAL INC., WEALATINA INC., and ZOMBARECORDING CORPORATION,Plaintiffs,v.GROKSTER, LTD.,MUSICCITY.COM, INC.,MUSICCITY NETWORKS, INC., andCONSUMER EMPOWERMENT BV,Defendants.Plaintiffs, through undersigned counsel, allege as follows based on personal knowledge as to allegations concerning themselves and on informationand belief as to all other allegations:
NATURE OF THE ACTION
1.
 
Plaintiffs, who are owners of copyrights in motion pictures andsound recordings, bring this action to stop Defendants from continuing toencourage, enable, and profit from the massive infringements of Plaintiffs’copyrighted works on the Internet. Dubbed the “next Napster” by the press,Defendants have developed and control a network largely dedicated to the repeatedand exploitative unauthorized distribution and reproduction of Plaintiffs’ protectedworks. Defendants provide Internet users with a fully integrated infrastructure thatconnects them to millions of infringing digital files. Defendants have created a 21stcentury piratical bazaar where the unlawful exchange of protected materials takes place across the vast expanses of the Internet, and where the materials beingexchanged include first-run movies currently playing in theaters and hit songs fromvirtually every major recording artist. The sheer magnitude of this haven for piracyis overwhelming and undeniable. Defendants themselves cannot disclaimknowledge of the massive infringements facilitated by their network. Indeed, in aneffort to create a protected zone for piracy, Defendants have encrypted the
 
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Complaint
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electronic communication within the network and boast of the anonymity it provides to users. The ease of use of Defendants’ network and the massive piracy itfacilitates have rapidly advanced its popularity with potential users. Defendantshave sought to turn their growing user base into profit through advertising andinvestment dollars. In short, Defendants are building a business based on the dailymassive infringement that they enable and encourage. Defendants’ conduct hascaused and continues to cause Plaintiffs grave and irreparable harm.
JURISDICTION AND VENUE
2.
 
This is an action for copyright infringement and arises under theCopyright Act, 17 U.S.C. § 101,
et seq
., based on acts of copyright infringementcommitted in the United States. This Court has exclusive jurisdiction of this actionunder 28 U.S.C. § 1338(a).3.
 
Venue is proper in this District pursuant to 28 U.S.C.§§ 1391(b)-(c) and 1400(a) because this is a judicial District in which a substantial part of the events giving rise to the claims occurred, and/or this is a judicial Districtin which Defendants reside or may be found.
THE PARTIES
4.
 
Plaintiff Metro-Goldwyn-Mayer Studios Inc. is a Delawarecorporation, with its principal place of business in California.5.
 
Plaintiff Columbia Pictures Industries, Inc. is a Delawarecorporation, with its principal place of business in California.6.
 
Plaintiff Disney Enterprises, Inc. is a Delaware corporation, withits principal place of business in California.7.
 
Plaintiff New Line Cinema Corporation is a Delawarecorporation that is qualified to transact business in California.8.
 
Plaintiff Paramount Pictures Corporation is a Delawarecorporation, with its principal place of business in California.
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