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Scientology-Anwlte an WikiLeaks

To: Legal@sunshinepress.org
Subject: Unauthorized Use of Copyrighted Materials
From: ampaquette@aol.com
Date: Thu, 27 Mar 2008 07:40:22 +0000 (GMT)
Dear Legal:

Our office represents Religious Technology Center ("RTC"), the owner of


the confidential Advanced Technology of the Scientology religion and
the holder of exclusive rights under the copyrights applicable to the
Advanced Technology materials. The Advanced Technology materials are
unpublished, copyrighted works. RTC's works include, among others,
the individual works comprising levels known as "NOTs," "OT II," and
"OT III." These works are registered with the United States Copyright
Office under registration numbers TXu 257 326 and 257 527, TXu 303 388,
and TXu 290 496.

Someone has placed RTC's Advanced Technology works on Wikileaks.org's


website without the authorization of our client. These infringements
can be found under the following URLs:

http://wikileaks.org/wiki/Church_of_Scientology_collected_Operating_Thetan_
documents

http://wikileaks.org/leak/scientology-ot-levels.pdf

Please be advised that your customer's action in this regard violates


United States copyright law. Accordingly, we ask for your help in
removing these works immediately from your service.

Under the U.S. Copyright Act, 17 U.S.C. 106, it is unlawful to


reproduce or distribute someone else's copyrighted work without that
person's authorization. See, BMG Music v. Gonzalez, 430 F.3d 888
(7th Cir. 2005) (acknowledging that posting copyright materials on
the Internet constitutes copyright infringement citing In re Aimster
Copyright Litigation, 334 F.3d 643, 645 (7th Cir. 2003).

Indeed, courts have entered numerous permanent injunctions and awarded


statutory damages and attorneys' fees regarding infringement of these
and similar works. For instance, a jury in the United States District
Court in San Jose, California awarded RTC $75,000 in statutory damages,
and statutory attorney's fees and a permanent injunction were imposed
against a Mr. Henson for posting one of the NOTs works on the Internet.
A Virginia United States District Court granted RTC judgment for damages,
costs, and a permanent injunction related to similar wholesale copyright
infringement, in addition to permanent injunctions that were entered in
another three copyright cases related to similar infringements in the
United States.

Likewise, a Swedish court enjoined a defendant who engaged in


infringements of these same Advanced Technology works, in addition to
finding that his actions in placing those works on the Internet violated
our client's rights under Swedish copyright law. RTC v. Panoussis,
Judgment of the Stockholm District, Division 7, case T-7-886-96. He was
also fined for his illegal actions and ordered to pay litigation costs.
The decision by Stockholm District Court was upheld on appeal.

We also ask that you preserve any and all documents pertaining to this
matter and this customer, including, but not limited to, logs, data
entry sheets, applications -- electronic or otherwise, registrations
forms, billings statements or invoices, computer print-outs, disks,
hard drives, etc.

I have a good faith belief, and in fact know for certain, that posting
copies of these works through your system was not authorized by my client,
any agent of my client, or the law.

I declare under penalty of perjury that this information is accurate


and that I am authorized to act on behalf of RTC in this matter.

I appreciate your prompt attention to this matter.

Sincerely,
Ava Paquette
Moxon & Kobrin
3055 Wilshire Boulevard
Suite 900
Los Angeles, California 90010
Tel: (213) 487-4468
Fax: (213) 487-5385