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MANAGEMENT II

B.B.A. LL. B. (Hons.) – Semester II

Research Paper: MANAGEMENT II

Topic: An analysis on Piracy in the Digital world and its legal implications

Submitted to: -
Prof. Somnath Roy
Kirit P. Mehta School of Law, NMIMS
(Deemed to be UNIVERSITY)

Submitted by: -
Taneesha Bagherwal
SAP ID: 81022019201
ROLL NO.: E013

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TABLE OF CONTENTS

Sr. No. Contents Page No.


1 Introduction
2 Research Objectives
4 Research questions
5 Research Methodology
6 Definition
7 Types of Piracy

“A person’s possession, be it his work or belongings, is his ultimate brainchild, and the last thing he wants to
happen to it is for it to be stolen and misappropriated by someone else.”

INTRODUCTION

The digital era has unquestionably presented us with numerous advantages that we use on a daily basis.
Human reach can now extend beyond political boundaries thanks to the internet and the capacity to connect
internationally and share information with the press of a button. However, the number and intensity of
socioeconomic and ethical repercussions of information technology misuse has increased exponentially
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over the last few decades. One unpleasant side effect of today's availability of technology is that most of the
material that is shared has been taken illegally by pirates. The term "pirates" in this context does not relate
to men aboard ships who raid other ships for riches while limping on wooden legs and yelling "Arrr!" at the
top of their lungs. Pirates are people who unlawfully share copyrighted information and content, ranging
from computer software to movies. These pirates duplicate, use, and disseminate these items without the
agreement of the authors or copyright holders because they lack authorization or licenses. This is known as
piracy. Consumers who appreciate these stolen goods are frequently ignorant of the harmful consequences. 1

In this article, the word "piracy" refers to the unlawful copying and distribution of proprietary property such
as software, music, and movies. Some unlicensed copies are "bootlegged," meaning they were copied with
the intention of reselling them at a lower price later. Consumers make and distribute illegal copies at no
charge. In a departure from traditional definitions of piracy and counterfeiting, today's "digital piracy" is
primarily concerned with non-physical objects: digital files sold or traded over the Internet. 2

RESEARCH OBJECTIVES

1. To study and understand the meaning and effects of Digital piracy


2. To understand the importance of legal implications of Digital piracy
3. To study the significance of various Acts, Laws and Rules against Piracy
4. To study the scenario of Digital Piracy and laws related to it in India

RESEARCH QUESTIONS

1. What is the meaning of Digital piracy?


2. What are the legal implications of Digital piracy?
3. What various Acts, Laws and Rules against Piracy?
4. How is India dealing with Digital Piracy and what laws are present in the country for the
prevention of the same?

RESEARCH METHODOLOGY

1
STA law firm (2017),"United Arab Emirates: Piracy & Its Legal Consequences”, Mondaq
2
Dana Dahlstrom et al. (2006),"Piracy in the Digital Age”, History of Computing
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Keeping in mind the nature of the topic and the subsequent research questions, the researcher used
both the methods, i.e., method of primary as well as secondary research. As for facts and stats,
various research paper, articles and journals are referred and analyzed for the purpose of research.
On the other hand, researcher has also included study based on personal observations with an
addition of ethnographic research. Hence, this research paper has integrated all the data and
information in a cohesive manner.

MEANING

The term pirate was frequently used in mediaeval times to refer to the act of raiding or looting,
which involves ship-borne robbers attacking residents of another ship or a coastal region with the
primary goal of robbing them of their goods, such as cargo or other valuables. However, in today’s
world piracy is a more relevant and commonly used term, which constitutes theft on copyrighted
and trademarked grounds i.e. unlawfully stealing and infringing someone else’s work and produce
it as one’s own. Because a person illegally distributes a digital file on the internet or locally for
free, he prevents the profit from the purchase of that item from going to the creator, creating an
economic impact comparable to when actual pirates looted cargo, digital piracy can be compared
to physical theft and piracy.3

TYPES OF PIRACY

“Piracy, when elaborated in terms of software, can be classified into 5 types4 , those being –

1. Counterfeiting: It is the illegal acquisition, duplication, and distribution of any copyrighted


material, which directly imitates the copyrighted product. The nature of the distribution of the
said product may be a sale, or not. The most common way of distributing such pirated works is
through compact discs.

2. Internet Piracy: Internet piracy is the act of downloading a file from the internet, or by
procuring an online software through a compact disc. Methods of conducting internet piracy

3
Jenkins, J. Philip (2020),” Piracy”, Encyclopedia Britannica
4
Norton LifeLock, “types of piracy", available at https://www.nortonlifelock.com/in/en/legal/anti-piracy/types-piracy/

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are websites offering free downloads of software, auctions selling illegally obtained software
or P2P servers which transfer programs.

3. End-User Piracy: This form of piracy involves the user illegally reproducing software which
he isn’t authorized to do. An example would be a user using one license to the software and
installing it on multiple systems, or upgrading an already pirated software.

4. Client-Server Overuse: In a computer network, when the number of clients exceeded the
number prescribed in the server license, then it is termed as overuse piracy.

5. Hard-Disk Loading: This occurs when a business sells new computers with illegal copies of
software loaded onto the hard disks to make the purchase of the machines more attractive.”

WHY IS IT ILLEGAL ANYWAY?



People may be wondering why piracy is illegal anyway, especially when pirated content is reaching a wider
spectrum of audiences who are otherwise unable to enjoy it, whether the reason is due to the price of the
original material or the overall availability of it. Most pirated products of large companies that receive
profits so massive that a few bucks would not necessarily hurt them or, at least, that is a common belief.
However, what people fail to realize is that, behind these multi-billionaire industries, original authors are
the ones who are getting damaged the most. These authors are usually under a contract or agreement that is
heavily based on the sales of their work, receiving a certain percentage of the profit their work makes. A
publisher, for example, may agree to help in selling the book of an author under the condition that he or she
receive 20 percent and they receive the remaining 80 percent. The fewer purchases of the book, the fewer
profit the publishers are receiving, and the fewer money goes into the pockets of the original writer. Though
the publisher loses the chance of gaining profit, the greater impact is on the author who depends on the sales
of their work. This is just one micro-example of the negative connotation that piracy entails. This makes it
becomes difficult for artists, programmers, and the likes to make a living out of their work if all who
consume it do it through piracy.5”

PIRACY IN INDIA

5
STA law firm (2017),"United Arab Emirates: Piracy & Its Legal Consequences”, Mondaq
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Parallel to the escalation in the use of digital media and expansion of related industries, piracy has increased
rapidly, resulting in a reduction in the fruits of labour for copyright owners. Piracy refers to the
unauthorised copying, distribution and selling of copyrighted works. Before the arrival of online streaming
platforms in India such as Netflix, Amazon Prime, Amazon Music, Wynk etc, unauthorised websites and
torrents were popular among film and TV buffs who had the 'no-cost' alternative for downloading/streaming
such content. When it came to music and sound recordings, downloading music from unauthorised websites
was taken as the normal course of action for a wide range of audiences who were not even aware that such
distribution of music was illegal and unauthorised. 6

Piracy has not only affected the due profits of rightful copyright owners but has given a major blow to the
overall state of the economy, which has seen a loss of jobs and revenue. What makes digital piracy so prone
to risk and difficult to curb is the inability of copyright owners to identify the infringers due to the
omnipresent nature of digital media and the resultant exponential number of pirates. The government of
India (GOI) and various departments thereunder have been mindful of this technological threat, and various
initiatives have been taken at structural and policy levels to combat the same. The continuous and unending
improvements along with the sweeping and far-sighted changes at the legislative and administrative levels
have resulted in strengthening the administration, management and enforcement of intellectual property
rights (IPRs).

India is one of the few countries that has multiple dominant box office film industries, in Bollywood,
Hollywood, and Tollywood. As such, piracy is a much more dominant force considering there is a lot
more material to pirate which the local audience would be interested in. Internet users often use VPNs
to visit torrent sites which host songs, games, movies and the like. Local vendors at technological hubs
often carry compact discs with pirated movies and games, which are sold at cheap prices. Modding
video game hardware to play pirated discs is also a booming industry in India. 7

The second wave of COVID-19 has accelerated digital piracy in India, which was already on the
rise when the pandemic hit the country last year, making original content creators lose money by
up to five times of what they make through genuine displays, according to a senior official of
consultancy firm EY India. The shift of organized content from theatres to OTT platforms with the
advent of new technologies has also increased digital piracy as these platforms don't come for free.
The second wave has accelerated this problem because more and more people are now looking at
these things sitting at home, and now the technology infrastructure enables you to view anything
and everything from home. The situation was the same then (first wave) and probably worse now
6
Manisha Singh (2020),"India: Combating Copyright Online Piracy in India: Government's Initiatives and Judicial
Enforcement”, Mondaq
7
Paula Boyden (2021),"The Truth About Digital Piracy: Everything You Need to Know”, FraudWatch International
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because people are now used to watching everything on an OTT platform and they would go to
any angle to watch free content. In the new age, some of the methods by which people pillage
video content include - password and credential sharing, sharing files over internet and via social
media, and purchasing illegal streaming boxes.8 To explain why there has been an escalation in
digital piracy - Due to the restrictions to curb the pandemic, theatres and all public places where
people would go out for entertainment are shut. So, the only entertainment they have is the whole
content which is available on their handheld devices, mostly phones.

PUNISHMENT FOR PIRACY

1. Illegal downloading of movies

The Union of India recently issued an amendment to the Cinematograph Act, 1952, in order to
clearly define the punishment which can be faced by pirates who, without the written authorisation
of the copyright owner, use any recording device to make or transmit a copy of a film. It is not
necessary for the film to be fully recorded, or even distributed via the internet. If the perpetrator
attempts to record the movie while inside the theatre, he is guilty under the act. The punishment for
this is generally imprisonment, a fine, or both. This punishment can also extend to those who
download said pirated movies.

2. Charges for Piracy

Since the crime of piracy is not limited to only the movie industry, the punishment specified above
isn’t the only one dealt to pirates. It varies with the industry in which they are committing an act of
piracy. The most notable forms of punishment are covered in the provisions of the Copyright Act,
1957 and Information Technology Act, 2000.9 The punishments specified are as follows-

a) Copyright Act: If a person uses a pirated computer program, or a program that has been
manufactured or acquired through copyright infringement, on any computer device, he
shall be liable for imprisonment no less than 7 days, extending up to 3 years, and a fine no
less than Rs. 50 thousand, which may be extended up to Rs. 3 lakhs.

8
PTI (2021),"As digital piracy rises amid pandemic, original content creators losing money: EY”, The Hindu
9
Mohammed Rafi (2017),"Thanks to censor board move last year, plug on movie leaks", The Indian Express
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b) IT Act: If a person gains access to a computer, a network of computers, or computer


systems, then proceeds to view, copy and extract the data present on the computer, either
through digital means or through a removable storage medium (pen drive or hard disk),
without prior authorization from the owner of the computer, he is liable to pay damages as
compensation which can go up to a sum of Rs. 1 crore. Any person who downloads said
stolen data will also be liable for the same amount.

RULES, LAWS AND ACT AGAINST PIRACY

1. Copyright Act

To handle copyright and copyright infringement related disputes, the Indian Constitution has the
Copyright Act, 1957, which acts as the main statute for all copyright-related laws in India. Under
section 13 of the Act, copyright protection is conferred on literary works, dramatic works, musical
works, artistic works, cinematograph films, and sound recordings.10 The Copyright Act, 1957
handles protection of copyrighted material via classification of the same into two categories of
rights, those being –

 Economic Rights: The scope of this Act falls under originally conceptualized work
including literary works, dramatic works, musical works, artistic works, cinematograph
films, and sound recordings. The owners of these intellectual properties and works are
given exclusive rights which they can exercise when it comes to the reproduction and
distribution of these works, and to have a share in the profit of any sales of the product
made by a licensed third-party.

 Moral Rights: Section 57 of the Act splits moral rights into two basic rights, right of
paternity and right of integrity. The former enables the original creator of the intellectual
property to be able to claim ownership of it and prevent any others from claiming
ownership. The latter enables the creator to restrict any and all ‘distortion, mutilation or
other alterations of his work, or any other action in relation to said work’ which may
damage his reputation.

10
Legal Service India, “Copyright Law in India", available at https://www.legalserviceindia.com/article/l195-Copyright-Law-in-
India.html
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2. IT Act

While the Copyright Act acts as a general supervisor to monitor acts of piracy and punish the
perpetrators accordingly, the Information Technology Act’s scope of piracy only extends to the
unauthorized use of computers or a network of computers. Any data then copied or reproduced
from that system onto an external storage device counts as an act of piracy. The punishment for
piracy, when governed under the Information Technology Act, is direct payment of damages,
which may amount to compensation up to Rs. 1 crore. The determination of how much the pirate
will have to compensate is quantified through these factors –

 The amount of gain or unfair advantage, wherever quantifiable, made as the result of the
default
 The amount of loss caused to any person as a result of the default
 The repetitive nature of the default.
 Internet Service Providers, however, are exempted from the provisions of this Act, if they
can prove that they had no existing knowledge of the act of piracy committed.

3. Trademark Act

A trademark is the primary identification mark of intellectual property and is represented by the
universal symbol (TM or ®), used by a particular organization, which signifies that the intellectual
property is unique and under their sole ownership. Trademarks can either be registered or
unregistered, although being registered offers many more legal remedies. The owner of a
registered trademark can file a suit to protect the intellectual property registered under it from any
infringement or unauthorized use of the trademark. They can file an action of infringement which
is a statutory relief, which can either be an injunction to prevent unauthorized use of the trademark
or enable the claim of damages by the injured party. In the case of an unregistered trademark, the
owner can file a suit under the action of passing off for the same remedies as an action of
infringement, except the benefits are limited to only the geographical area in which the owner
operates.

PREVENTION OF PIRACY

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While the legal consequences associated serve to act as an effective deterrent against piracy, they
are not nearly enough to act as a solid preventive measure, considering actual prosecutions against
digital pirates are few and far in between. This is because most intellectual property owners tend to
just get a cease-and-desist(termination) order against sites which host pirated content, which are
just orders to take down the download links for the content.11

Therefore, there are, while loosely-defined, some effective ways to prevent piracy, i.e. deter users
themselves from seeking out and downloading pirated content. These are as follows –

1. Price Regulation: By offering digital goods and services at a lower, realistic price,
producers can hope to at least lessen the number of users pirating their content by a wide
margin. It won’t stop piracy completely but reducing the incentive for people to make use
of pirated content will certainly prevent piracy to a large extent.

2. Barriers to Entry: This is a mode of prevention that rests more within the jurisdiction of
the government. Most governments instruct and encourage ISPs to restrict entry into sites
which host pirated content, mostly by blocking the sites on their servers. Directly barring
users from accessing these sites helps reduce the pirate users by a large amount, as most
don’t have the technical know-how i.e., how to use VPNs which is required to circumvent
the sites being blocked.

3. User Confrontation: A lot of TV and streaming services often use a combination of both
the above-listed methods, but with some real-time interaction with the users. Pirate users
often get real-time messages which notify them that the producer is aware of them using
pirated content. Game developers often use this to troll pirate gamers in hilarious, game-
breaking ways.

4. Cooperation between industries: The above-listed methods to prevent piracy, while


working great on their own, often fail and fizzle out when there is one bad link in the chain.
That one bad link can be a producer who is lenient with his content being pirated or doesn’t
know about the extent of piracy. That is why, all of the above methods, if executed
systematically and efficiently by all relevant producers at once, can be one of the biggest
deterrents to pirates.
11
Ben Falk (2019),"Why movie piracy is much more dangerous than you think”, yahoo movies
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GOVERNMENT INITIATIVES

1. National Intellectual Property Rights Policy, 2016

India's march towards robust protection and enforcement of IPRs started with the introduction of the
National IPR Policy (“the Policy”) in 2016, which brought radical and profound changes to the table. The
GOI adopted the Policy with a view to promoting creativity and innovation, as well as recognising the value
of IPR in economic development. The Policy lays down the road map for India in its quest to increase
creativity and stimulate innovation by establishing an ecosystem which is conducive to these aims in terms
of IP awareness, creation, commercialisation and enforcement.

Objective 1 of the Policy is aimed at creating awareness of the economic, social and cultural benefits of
IPRs. The steps to be taken in furtherance of this objective include the introduction of IPR studies in school
curriculum. School children, especially teenagers, constitute a major section of consumers of pirated
content, be it for films or unauthorized downloads of music. Introducing IPR studies in their curriculum
would teach them the significance of IP rights and how infringement of the same results in injury not only
to the owner of the rights, but also has a significant impact on the economy of the country. More
specifically, IPR studies would at least clarify the distinction between legal and illegal channels of
distribution to a large section of society which may be unknowingly promoting piracy.

Objective 3 of the Policy called for suitable amendments in The Cinematographs Act, 1952 for the inclusion
of penal provisions for illegal duplication of films. Objective 6 of the Policy underlined the need for public
awareness and stringent enforcement mechanisms to combat offline and online piracy. A few important
steps identified under the objective to tackle the issue of piracy are set out below.

 Enhanced coordination between the various agencies and providing direction and guidance on
strengthening enforcement measures; coordination and sharing of intelligence and best practices at
the national and international level; studying the extent of IP violations in various sectors;
examining the implications of jurisdictional difficulties among enforcement authorities; and
introducing appropriate technology-based solutions for curbing digital piracy.

 Initiating fact-finding studies in collaboration with stakeholders to assess the extent of piracy and
the reasons behind it as well as measures to combat it.

In this regard, the Policy specifies that the definition of “pirated copyright goods” as provided in Article 51
of the TRIPS Agreement shall serve as the guiding principle: goods which are copies made without the
consent of the right holder or person duly authorised by the right holder in the country of production and
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which are made directly or indirectly from an article where the making of that copy would have constituted
an infringement of a copyright or a related right under the law of the country of importation.

2. The Cell for IPR Promotion and Management (CIPAM)

The National IPR Policy has also led to the establishment of the Cell for IPR Promotion and Management
(CIPAM) under the aegis of the Department of Industrial Policy and Promotion, Ministry of Commerce and
Industry, GOI. It is a national focal point for the WIPO Technology and Innovation Support Centre
programme and has taken profound initiatives for promoting awareness and strengthening the enforcement
of IP rights.

CIPAM, in cooperation with the Film and Television Producers Guild of India and Viacom18, has launched
a campaign against piracy through a series of videos including animation videos on anti-piracy. A number
of top celebrities have been involved in giving anti-piracy messages in these videos to strengthen the impact
on the audience. These videos are shown before the screening of films in various cinemas across the
country, including PVR cinemas, which is the largest cinema chain in India. CIPAM's collaboration with
National Internet Exchange of India and Maharashtra Cyber Digital Crime Unit (MCDCU) has resulted in
the suspension of over 300 infringing websites, having over 186 million hits per month have been
suspended.

CIPAM has also cleverly devised its activities around children and educational institutes to foster awareness
about IP rights from an early age. Nickelodeon videos have also been created to appeal to children and
explain to them about IPRs in a simple manner. A series of anti-piracy videos with cartoon characters have
been aired with the message: "Say No to Piracy". India has also found its first IPR mascot "IP Nani"
(“Nani” means maternal grandmother in Hindi), which has been created to raise awareness about the
importance of IPRs, especially among children, in an interesting manner. A number of animated videos
explaining the importance of IP rights have been produced in collaboration with the European Union
Intellectual Property Office (EUIPO). Content on IP rights is being included in the curriculum for high
school students, and colourful posters, brochures, and presentations have been created for students to teach
them about IP rights. The said material is available in multiple languages and can be downloaded from
CIPAM's official website.

CIPAM's IP awareness programmes, which started in 2017 in collaboration with the International
Trademark Association (INTA), have reached over 100 schools. Any teacher or educational institute
interested in organising an IP awareness campaign in their school can write to CIPAM. An annual IP
competition called IPRISM has launched to engage college and university students in its anti-piracy
campaign. This competition provides students with a national platform to showcase their talent, such as by
making a film or comic book on topics related to IP. More than 100 IPR Cells have been established at

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various colleges and universities across India, and IPR awareness programmes have been conducted in over
10,000 academic institutions reaching over 200,000 students; 100,000 college students and faculty
members, and over 2,700 rural students were reached through satellite communications.

One of the major objectives of the National IPR Policy is the effective enforcement of IP rights, which is
only possible through capacity building of enforcement agencies, including judiciary, police and customs.
CIPAM, in association with the Federation of Indian Chambers of Commerce and Industry (FICCI), has
created an IPR Enforcement Toolkit for Police to aid police officials in dealing with IP crimes, in particular,
trademark counterfeiting and copyright piracy. The toolkit provides: (i) information on legal provisions
relevant to IPR crime, (ii) a checklist for registering a complaint, (iii) a checklist for search and seizure, and
(iv)proposed guidelines for search and seizure in case of IP crimes. The toolkit has been disseminated to all
state police departments and major industry associations across the country. In order to strengthen the
enforcement mechanism, CIPAM has devised a capacity building campaign for enforcement agencies by
organising training programmes. The training programmes for police officials are aimed at sensitising the
police about their powers and duties while handling IP cases. The participants are generally in-service and
probation police officers. These training programmes have been designed to give an overview of all
domains of IP and to ensure that police officials get a broad insight into varied related topics. Expert
academics, lawyers and industry experts are invited to conduct the training programmes.

CIPAM has also been working in conjunction with WIPO and National Judicial Academy, India (NJA) to
organise training and awareness programmes on IPRs for high court and district court judges.

3. Maharashtra Cyber Digital Crime Unit (MCDCU)

The Maharashtra Cyber Digital Crime Unit (MCDCU) is a collaboration between the cyber police and
industry players like the Motion Picture Association of America, Indian Motion Pictures Producers'
Association, the Producers Guild, and the Indian Music Industry (IMA). Established in August 2017 and
headed by Special Inspector General of Police Brijesh Singh, MCDCU has been leading the way in the fight
against piracy with the skilful execution of serious actions against piracy, resulting in the permanent shut
down of over 200 top piracy websites with 172 million hits monthly. This effort has been praised by WIPO,
and MCDCU has been emerging as one of the strongest units across the world. The US Chamber of
Commerce recently honoured MCDCU with the 2019 Global Intellectual Property Champion Award.

FINDINGS

1. Anti-Piracy Laws Have No Effect

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It may seem like these anti-piracy laws are ineffective on the surface, but you will say otherwise if
you really look at it closely. However, a research states that there is increased consumer awareness
of anti-piracy laws that caused online sales, specifically on iTunes, to increase.

2. There’s No Tracking When There’s No Seeding

Seeding is when pirates continue to share a completed file, in which the status of the torrent will
change from “Downloading” to “Seeding” after it’s completed. Some users believe that stopping
the file before it starts to seed will prevent anti-piracy companies from tracking them down. The
truth is, you are already on their radar the moment you download that file.

3. Everything Can Be Pirated

It’s easy to think that everything can be pirated; perhaps, that’s possible. However, pirates are
picky as well, and they have limited storage capabilities. Also, not everyone is willing to download
shows and movies that will leave untouched for many years to come.

4. VPN Can Stop Traces

You can get online privacy with a VPN, but only to a certain degree. In short, it’s not foolproof.
Even the best VPN services can’t guarantee total anonymity when piracy is in the mix.

5. Piracy Is Due to Tight Budgets

Most people don’t jump into pirated digital files because of their tight budgets. In fact, the more
people earn, the more they are likely to succumb to this illegal act. You will also be surprised to
know that there are many pirates who pay for content compared to general consumers.

6. Old People Don’t Pirate

There is no age restriction when it comes to piracy. So, if you think old people don’t do this, think
again.

7. Having Original Copies Is a Pass to Pirate


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There is really no legal way to pirate. So, it doesn’t matter if you purchased the complete
collection of a show. Anyone who participates in piracy is an offender.

8. It Doesn’t Affect Sales

This is one of the biggest issues creative industries have today. Some believe that people who
pirate wouldn’t purchase the content they copied to begin with, which means that they wouldn’t
exactly impact the sales. However, according to economist Michael Smith, when NBC took down
Hulu shows, piracy shot up, and no one purchased an original copy of the shows that were
removed.

9. You Can’t Beat Free Content

If that’s the case, then why do we have growing content makers? That is because piracy can’t take
paid content out of the picture. Even if some people prefer to pay nothing, there are still many
people who do to ensure the quality and reliability of the content.

Digital piracy is highly illegal, yet it remains a controversial topic where you can expect things to
escalate quickly. Still, it’s important you stray away from digital piracy and only honor reliable
and quality content, even if you have to pay for it.

CONCLUSION

To conclude, this study deals with Digital piracy or piracy in the digital world. This paper revolves
around the issue of Piracy, people struggling with it, punishment for this offense as well as how to
prevent it. The author has mentioned in detail the meaning of piracy and why is it illegal. The
research paper further consists of types of piracy and certain Acts, Rules and Laws related to the
same. Also, the GoI took some initiatives to prevent piracy and in order to punish the offenders of
the same. Hence, the author has done the research in a systematic and very cohesive manner.

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