Disney Enterprises, Inc. et al v. Hotfile Corp. et al

Filing 174

MEMORANDUM of Law re 165 Plaintiff's MOTION FOR ONE ADDITIONAL EXAMINATION DAY FOR RULE 30(b)(6) DEPOSITION OF DEFENDANT HOTFILE CORPORATION Corrected Memorandum of Law 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)

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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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