Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
171
MEMORANDUM of Law re 165 Plaintiff's MOTION FOR ONE ADDITIONAL EXAMINATION DAY FOR RULE 30(b)(6) DEPOSITION OF DEFENDANT HOTFILE CORPORATION of Defendants Hotfile Corporation and Anton Titov In Opposition to Plaintiffs' Motion to Depose Anton Titov Individually and as Hotfile's Rule 30(b)(6) Witness For Over Four Days and Defendants' Cross-Motion for Protective Order Limiting the Depositions of Hotfile Witnesses Including Mr. Titov by Hotfile Corp., Anton Titov. (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit B)(Munn, Janet)
EXHIBIT 8
MOTION PICTURE
COITION OF AMEM
FOR IMMEDIATE RELEASE
February 8, 2011
MOTION PICTURE STUDIOS FILE LAWSUIT AGAINST
HOTFILE.COM
Los Angeles — The Motion Picture Association of America, Inc. (IVIPAA) on behalf of several of its
member studios today filed a lawsuit against the operators of the download hub service Hotfile
(www.hotfile.com) for copyright infringement. Hotfile facilitates the theft of copyrighted motion
picture and television properties on a staggering scale and profits handsomely from encouraging and
providing the means for massive copyright infringement.
"In less than two years Hotfile has become one of the 100 most trafficked sites in the world. That is
a direct result of the massive digital theft that Hotfile promotes. Everyday Hotfile is responsible for
the theft of thousands of MPAA member companies' movies and TV shows - including movies still
playing in theaters - many of which are stolen repeatedly, thousands of times a day, every single
day," said Daniel Mandil, General Counsel & Chief Content Protection Officer for the MPAA. "The
theft taking place on Hotfile is unmistakable. Their files are indeed 'hot,' as in 'stolen.' It's wrong
and it must stop."
Sometimes referred to as cyberlockers, download hubs like Hotfile bear no resemblance to
legitimate online locker services. In fact, Hotfile openly discourages use of its system for personal
storage. Hotfile's business model encourages and incentivizes users to upload files containing illegal
copies of motion pictures and TV shows to its servers and to third-party sites, so unlimited users can
download the stolen content — in many cases tens of thousands of times. Hotfile profits from this
theft by charging a monthly fee to users who download content from its servers. Hotfile also
operates an incentive scheme that rewards users for uploading the most popular files - which are
almost exclusively copyrighted works. Hotfile profits richly while paying nothing to the studios for
their stolen content.
Hotfile is operated by Anton Titov, a foreign national residing in Florida. The studios are suing
Hotfile and Titov for direct infringement for unlawfully distributing copyrighted works, inducement
of infringement, contributory infringement and vicarious infringement, for actively promoting,
enabling and profiting from their users' copyright infringement. A civil lawsuit has been filed in U.S.
District Court in the Southern District of Florida for damages and injunctive relief for violations
under the United States Copyright Act of 1976.
"Digital theft is not just a Hollywood problem. It's an American problem," Mandil said. "More
than 2.4 million hardworking, middle-class Americans spanning all 50 states rely on the motion
picture and television industry for their livelihoods. For all these workers and their families, digital
theft means declining incomes, lost jobs and reduced health and retirement benefits."
A copy of the Hotfile complaint can be found here.
About the MPAA The Motion Picture Association of America, Inc. (VIP A) serves as the voice and advocate of
the American motion picture, home video and television industries from its offices in Los Angeles and Washington,
D.C. Its members include: Walt Disney Studios Motion Pictures; Paramount Pictures Corporation; Sad! Pictures
Entertainment Inc.; Twentieth Centmy Fox Film Corporation; Universal 0'0 Studios T .T.TP; and Warner Bros.
Entertainment
###
For more information, contact:
MPAA Los Angeles
Elizabeth Kaltman
(818) 995-6600
Elizabeth kaltman@mpaa.org
IvIPAA Washington, D.C.
Howard Gantman
(202) 293-1966
Howard gantman@,mpaa.org
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