Copyright Infringement

August 21, 2014

U.S. Copyright Office Announces Release of Draft of the Compendium of U.S. Copyright Office Practices, Third Edition

This Tuesday Register of Copyrights Maria A. Pallante (pictured) released a public draft of the

Compendium of U.S. Copyright Office Practices, Third Edition (the “Third Edition”). The first major revision in more than two decades, the draft presents more than 1200 pages of administrative practices and sets the stage for a number of long-term improvements in registration and recordation policy. It will remain in draft form for approximately 120 days pending final review and implementation, taking effect on or around December 15, 2014.

“The new Compendium is an exhaustive undertaking that explains and reconciles the many legal interpretations, regulations, and procedures of the Copyright Office in administering the copyright law,” said Pallante. “At the same time, it provides a necessary and authoritative foundation for ongoing policy and regulatory discussions that are pertinent to the digital era.”

August 11, 2014

Consumers May No Longer Have to Fear Copyright Litigation Resulting from Unlocking Cell Phones

By Overhauser Law Offices, LLC

Washington D.C. – The Leahy-Grassley cell phone unlocking bill has been signed into law.

The House unanimously passed bipartisan legislation recently that would restore the ability of consumers to more easily transfer their cell phones to other wireless carriers, just one week after the Senate approved the same measure. Senate Judiciary Committee Chairman Patrick Leahy (D-Vt.) and Ranking Member Chuck Grassley (R-Iowa) coordinated with House Judiciary Committee Chairman Bob Goodlatte (R-Va.) and Ranking Member John Conyers Jr. (D-Mich.) on the issue. The lawmakers praised Congress’s action to pass the pro-consumer bill, which was signed by President Obama on August 1, 2014.

The legislation approved by the House, which the Senate unanimously approved, reinstates a 2010 rulemaking by the Librarian of Congress so that consumers can transfer, or “unlock,” their cell phones without running afoul of copyright laws. It also directs the Librarian of Congress to consider whether other wireless devices, like tablets, should be eligible for unlocking.

July 9, 2014

Indiana Copyright Litigation: Dallas Buyers Club, LLC Sues 24 Doe Defendants for Copyright Infringement

By Overhauser Law Offices, LLC

Indianapolis, Indiana – A copyright attorney for Dallas Buyers Club, LLC of The Woodlands, Texas sued in the Southern District of Indiana alleging that 24 Doe defendants infringed the copyright of the motion picture “Dallas Buyers Club,” which has been registered with the U.S. Copyright Office.

The movie in question, Dallas Buyers Club, stars Matthew McConaughey as an AIDS patient who smuggled unapproved AIDS-treatment drugs into the United States during the 1980s for his own use and to distribute to others afflicted with AIDS. The movie was nominated for six Academy Awards and won three. Matthew McConaughey and Jared Leto also won Oscars for Best Actor and Best Supporting Actor, respectively, for their performances in the movie.

In this Indiana copyright infringement lawsuit, filed by a copyright lawyer for Dallas Buyers Club, LLC, plaintiff asserts that the copyrighted movie was infringed by 24 as-yet unnamed individuals, who were sued as “Doe” defendants. It alleges that this copyright infringement took place using the “BitTorrent protocol,” which is different from the standard peer-to-peer protocol. Specifically, the BitTorrent protocol enables numerous computers, even those with low bandwidth, to exchange pieces of a computer file among themselves. Each computer that has downloaded a particular piece of a file then becomes a source from which other computers may then download that piece of the file. As a result, the entirety of a computer file may be disseminated across the Internet quickly without having to rely on a central source from which to download.

Plaintiff contends that the 24 defendants acted as part of a “collective enterprise” to infringe its work and that the acts constituting the infringement were “willful, intentional, and in disregard of and with indifference” to plaintiff’s intellectual property rights.

The court is asked to enter judgment for the following monetary and injunctive relief:

• for entry of permanent injunctions providing that each defendant shall be enjoined from directly or indirectly infringing plaintiff’s rights in the movie;
• for judgment that defendants have: a) willfully infringed plaintiff’s rights in its federally registered copyright pursuant to 17 U.S.C. §501; and b) otherwise injured the business reputation and business of plaintiff;
• for actual or statutory damages pursuant to 17 U.S.C. §504 in an amount to be determined at trial;
• for an Order of Impoundment under 17 U.S.C. §§503 and 509(a) impounding all infringing copies of the movie that are in defendants’ possession or under their control; and
• for attorneys’ fees, litigation expenses, including fees and costs of expert witnesses, and other costs of this action.

Practice Tip: Defendants who fail to appear run a significant risk of having a default judgment entered against them. There is a significant disparity in the dollar amount awarded in default judgments against defendants in copyright infringement cases involving BitTorrent. In two separate cases, Judge William T. Lawrence ordered defendants who failed to appear to pay $20,000 for the copyright infringement that was deemed to have been admitted by the defendants’ failure to defend against the allegations. See here and here. However, in a similar case, Judge Jane Magnus-Stinson ordered an entry of default judgment against a defendant for $151,425, the full amount requested.

Overhauser Law Offices, the publisher of this website, has represented several hundred persons and businesses regarding copyright infringement and similar matters.

June 23, 2014

Indiana Copyright Law: Three Default Judgments of $2,500 Ordered for Copyright Infringement

By Overhauser Law Offices, LLC

Indianapolis, Indiana – In Bell v. Glacier International, District Judge Tanya Walton Pratt (pictured) of the Southern District of Indiana granted default judgments against three defendants, DiamondIndyLimo.com, Lon Dunn and Glacier International. In the three nearly identical opinions, the three defendants were each ordered to pay statutory damages of $2,500 for infringing a copyrighted photograph.

In January 2013, Indiana copyright attorney and professional photographer Richard N. Bell, acting as his own copyright lawyer, sued alleging copyright infringement under the Copyright Act and conversion under Indiana statutory law as a result of the allegedly unauthorized use of a photograph he had taken. This photograph had been registered with the United States Copyright Office.

In this lawsuit, Bell sued forty-eight Defendants: Jerry Gordon; Demand Media, Inc.; Bryce Welker; Royal Corniche Travel Ltd.; VRBO.com, Inc.; Experience Credit Unions, LLC; Jaclothing.com; Glacier International; ABNHotels.com; 1&1 Internet, Inc.; Conde Nast Digital; Flixter, Inc.; Financing-USA.com; SodaHead, Inc.; NuMedia Marketing, Inc.; Jynell Berkshire; Tzvetelin Petrov; Los Pentecostales del Area de la Bahia; 10Best, Inc.; Keyes Outdoor Advertising; Zoom Communications Inc.; Christine Nevogt; Zarzar, Inc.; Hydro-Gear; Tam T. Dang; Lon Dunn; William McLaws, Trustee; Natl-electronic Residential Payment History Recording Agency; CVI; Constant Contact, Inc.; Charles Lantz; Schumacher Cargo Logistics; Eventbrite, Inc.; Celebrity Entertainment Corp.; Association of Equipment Manufacturers; Yardi Systems Inc.; DiamondIndyLimo.com; Marcelo Santos; National Rural Recruitment & Retention Network; Anbritt Stengele; Pinnacle Sports Equipment, Inc.; Marygrove College; RunAnyCity.com; Buzzle.com, Inc.; Charles Onuska; University of Indianapolis; and PersephoneMagazine.com.

Bell alleged that each Defendant, independent of each other Defendant, “created a website to promote and advertise its own business” and placed Bell’s copyrighted photo on each of the Defendants’ respective websites. In addition to asserting copyright infringement, Bell also alleged criminal misconduct under Indiana statutory law. Bell requested an injunction and a declaratory judgment. He also asked the court for damages for copyright infringement under the Copyright Act as well as treble damages under an Indiana criminal statute prohibiting conversion.

In September 2013, the court entered default judgments against each of the three Defendants. Last week, the court issued three new opinions addressing the damages to be assessed against those Defendants.

The court first discussed the issue of damages for copyright infringement. Under 17 U.S.C. § 504(c)(1), statutory damages, in lieu of actual damages and profits, may be awarded “in a sum not less than $750 or more than $30,000” for each finding of infringement. A determination of willful copyright infringement permits the court in its discretion to increase the award of statutory damages up to $150,000 per infringement.

In determining the appropriate measure of statutory damages, the court considers factors including: (1) the infringer’s state of mind; (2) the expenses saved, and profits earned, by the infringer; (3) the revenue lost by the copyright holder; (4) the deterrent effect on the infringer and third parties; (5) the infringer’s cooperation in providing evidence concerning the value of the infringing material; and (6) the conduct and attitude of the parties.

The court declined to find the copyright infringement to be willful, in part because Bell requested statutory damages well under $30,000.00 per instance of infringement. Instead, the court found that $2,500 per Defendant was an appropriate measure of damages. An injunction was also granted, as it would serve the public interest by protecting copyrighted material and encouraging compliance with federal law. The injunction will be lifted upon payment of the award of statutory damages.

A claim of conversion under Indiana state law, and treble damages awarded pursuant to such a claim, was denied as preempted by the Copyright Act. Indiana code § 35-43-4-3(a) provides that a “person who knowingly or intentionally exerts unauthorized control over property of another person commits criminal conversion.” However, section 310 of the Copyright Act preempts “all legal or equitable rights that are the equivalent to any of the exclusive rights within the general scope of copyright” and that “no person is entitled to any such right or equivalent right in any such work under the common law or statutes of any State.” The court held that the photograph in question was clearly under the scope of the Copyright Act and that Bell had not sufficiently alleged a right apart from the Act. Thus, no damages were available under Bell’s state law conversion claim.

Practice Tip:

Deciding to simply ignore a complaint, as these defendants apparently did, can be a costly error. Failing to present the defendants’ versions of the facts and arguments results in the court considering only the plaintiff’s side of the story. Here, because the defendants chose to leave the complaint unanswered, the well-pled allegations of the plaintiff relating to liability were taken as true.

After the entry of default judgment, the court then conducted an inquiry to ascertain the amount of damages. Again, in such circumstances, it serves a defendant well to plead his case – to present the court with reasons that the plaintiff should not get 100% of what he requests.

Under 17 U.S.C. § 504(c)(1), a copyright owner may elect actual or statutory damages. Statutory damages range from a sum of not less than $750 to not more than $30,000. The determination of the exact amount is left to the discretion of the court. In this case, Richard Bell asked the court for no less than $5,000. In some cases, courts in determining damages in cases of default judgment have granted the entire amount. In this case, the court took the additional step of considering the cost to purchase Plaintiff Bell’s picture – $200 – and incorporated that into its determination of the proper amount of damages to be awarded.

June 16, 2014

Appeals Court Disallows Mass Joinder in Copyright Infringement Litigation

By Overhauser Law Offices, LLC

Washington, D.C. – The United States Court of Appeals for the District of Columbia handed copyright trolls a major defeat recently by removing one of their most powerful tactics: the ability to sue large groups of John Doe defendants together with minimal evidence.

The case, AF Holdings v. Does 1-1058, is one of the few mass copyright cases to reach an appellate court, and the first to look into fundamental procedural problems that have tilted the playing field firmly against the Doe Defendants. With this decision on the books, it appears likely that even more federal trial courts will disallow cookie-cutter lawsuits seeking cash payouts from dozens or even hundreds of Internet subscribers.

The appeal was brought by several internet service providers (Verizon, Comcast, AT&T and affiliates) with amicus support from copyright attorneys for the Electronic Frontier Foundation (“EFF”), the ACLU, the ACLU of the Nation’s Capital, Public Citizen, and Public Knowledge.

June 11, 2014

Indiana Copyright Litigation: Malibu Media Sues Nine Additional “John Does” Asserting Copyright Infringement

By Overhauser Law Offices, LLC

Indianapolis, Indiana – Nine copyright infringement lawsuits have been filed in the Southern District of Indiana on behalf of Malibu Media, LLC of Los Angeles, California. The lawsuits assert that nine separate unidentified defendants, each identified with only “John Doe” and an internet protocol address, infringed Malibu Media’s copyrighted works.

Frequent copyright litigator Paul Nicoletti has filed another set of copyright infringement complaints in Indiana federal court. The complaints, filed on behalf of adult-content purveyor Malibu Media, assert infringement of the company’s intellectual property. In this latest round, Malibu Media submitted nine new and nearly identical lawsuits for adjudication in the Southern District of Indiana against nine anonymous John Doe defendants. The defendants allegedly used the BitTorrent file-sharing protocol to illegally download, copy and distribute elements of various works of Malibu Media’s copyrighted material. As with all of Malibu Media’s complaints, the copyrights-in-suit cover pornographic videos.

Malibu Media seeks a permanent injunction barring the defendants from engaging in infringing activities; an order by the court that infringing materials be removed from all computers of each defendant; a separate award of statutory damages for each work found to have been infringed and reasonable attorneys’ fees and costs.

Practice Tip: Defendants who fail to appear run a significant risk of having a default judgment entered against them. There is a significant disparity in the dollar amount awarded in default judgments against defendants in copyright infringement cases involving BitTorrent. In two separate cases, Judge William T. Lawrence ordered defendants who failed to appear to pay $20,000 for the copyright infringement that was deemed to have been admitted by the defendants’ failure to defend against the allegations. See here and here. However, in a similar case, Judge Jane Magnus-Stinson ordered an entry of default judgment against a defendant for $151,425, the full amount requested.

Overhauser Law Offices, the publisher of this website, has represented several hundred persons and businesses regarding copyright infringement and similar matters.

May 27, 2014

Indiana Copyright Litigation: Fourteen New Lawsuits Asserting Copyright Infringement Filed by Malibu Media

By Overhauser Law Offices, LLC

Indianapolis, Indiana – An intellectual property attorney has filed fourteen new copyright suits in the Southern District of Indiana on behalf of Malibu Media, LLC of Los Angeles, California alleging that 14 separate unidentified defendants, listed as “John Doe” defendants, infringed Malibu Media’s copyrighted works.

In this latest batch of lawsuits filed by copyright lawyer Paul Nicoletti, the 14 defendants, all sued under the name “John Doe” until they can be identified pursuant to a court subpoena and named, are listed as “persistent online infringer[s]” of Malibu Media’s copyrighted works. The nearly identical copyright infringement lawsuits contend that the defendants used the BitTorrent file-sharing protocol to illegally download, copy and distribute elements of various works of Malibu Media’s copyrighted material.

The defendants accused of infringing the fewest copyrighted works are accused of infringing 16 of Malibu Media’s copyrights. Malibu Media contends that two defendants, however, have infringed more than 40 of its copyrighted works.

Malibu Media seeks a permanent injunction barring the defendants from engaging in infringing activities; an order by the court to remove infringing materials from all computers of each defendant; an award of statutory damages for each infringed work and reasonable attorneys’ fees and costs.

Practice Tip #1:

Copyright trolling, also known as “porn trolling” when the plaintiff owns copyrights to pornographic material, has changed in the years since the practice began. Most early lawsuits were filed against tens, hundreds or even in excess of a thousand anonymous defendants. When judges such as District Judge Otis Wright made it clear that this misjoinder would not be permitted, porn trolls began filing multiple lawsuits claiming copyright infringement against single defendants.

Porn trolls also responded to this change in the judicial landscape by adding a new exhibit, “Exhibit C,” with each filing. Exhibit B to each complaint was a legally relevant listing of the Malibu Media copyrights that were allegedly infringed. However, Exhibit C listed other pornographic material – material not owned by Malibu Media – allegedly downloaded by the internet protocol address of the accused.

While the titles of Malibu Media’s copyrighted works are often fairly innocuous – “Almost Famous,” “Blonde Ambition” and “LA Plans” are among their works – the titles listed in Exhibit C were decidedly not. In response these and other Malibu Media copyright litigation tactics, one federal judge, District Judge William Conley, said, “[t]hese Internet copyright infringement cases … give off an air of extortion.” He sanctioned Malibu Media’s counsel under Rule 11 and ordered a fine of $2,200.

Practice Tip #2: Mass misjoinder in copyright cases has also been flagged as impermissible in other, non-pornography, cases that assert copyright infringement against multiple defendants. In one recent Indiana copyright lawsuit, Magistrate Judge Denise K. LaRue, writing for the Southern District of Indiana, severed all but one defendant from the copyright infringement complaint of Richard Bell, an Indiana copyright attorney. The court also ordered Bell to pay separate filing fees for each new cause of action.

May 23, 2014

Indiana Copyright Law: Court Orders Severance of Misjoined Copyright Infringement Complaint

By Overhauser Law Offices, LLC

Indianapolis, Indiana – Magistrate Judge Denise K. LaRue, writing for the Southern District of Indiana, directed the Clerk of the Court to sever all but one defendant from the copyright infringement complaint of Richard Bell, an Indiana copyright attorney. Bell was also ordered by the court to pay separate filing fees for each new cause of action.

Bell is a copyright lawyer and a professional photographer. He contends that he is the owner of two copyrighted photographs of Indianapolis taken in March 2000. The photos have been registered with the U.S. Copyright Office.

In April, Bell filed another copyright infringement lawsuit in the Southern District of Indiana alleging copyright infringement of his photos by numerous Defendants. The Defendants were: Diversified Vehicle Services of Marion County, Indiana; Cameron Taylor and Taylor Computer Solutions of Indianapolis, Indiana; Rhonda Williams of Indianapolis, Indiana; Forensic Solutions, Inc. of Waterford, New York; Heath Garrett of Nashville, Tennessee; CREstacom, Inc. of Fishers, Indiana; American Traveler Service Corp LLC, location unknown; Mike Cowper of Martinsville, Indiana; Kimberly Hinds of Indianapolis, Indiana; Rensselaer Polytechnic Institute of Troy, New York; EasyStreet Realty of Indianapolis, Indiana; Drohan Management of Reston, Virginia; Metal Markets of Indianapolis, Indiana; Mattison Corporation of Indianapolis, Indiana; Industrial Heating Equipment Association of Taylor Mill, Kentucky; Junk Dawgs of Indianapolis, Indiana and WRTV of Indianapolis, Indiana. Bell is both the copyright lawyer and Plaintiff in this lawsuit.

In this earlier complaint, Bell alleged that each Defendant, independent of each other Defendant, “created their individual website to promote and market their business” and placed the Plaintiff’s copyrighted photo on each of the Defendants’ respective websites. Claiming copyright infringement, unfair competition and theft, Bell asked the court for, inter alia, the maximum allowable statutory damages for each copyright violation.

The court ordered Bell to show cause why all defendants but one should not be severed for misjoinder. Bell argued that the rules regarding joinder should be given a broad scope so that multiple lawsuits could be avoided.

The court was not persuaded. In addressing Bell’s contention that joinder of the unrelated Defendants was proper, it was Bell’s own language, and the factual underpinnings of that language, to which the court pointed in denying joinder. The court noted that Bell’s “complaint alleges that ‘[e]ach defendant, independently of each other, created or had created a website to promote and advertise the business of each Defendant,’ and that Plaintiff discovered that ‘the website [of] each of these Defendants contained [one of the photographs].'” The court also noted that “[e]xcept for defendants Cameron Taylor and Taylor Computer Solutions, the Complaint contains no allegation that any defendant acted in concert with another defendant in appropriating Plaintiff’s photographs and it does not allege any transaction, occurrence, or series of transactions or occurrences in which two or more defendants participated.” (Citations omitted.)

The court then reviewed the requirements of Federal Rule of Civil Procedure 20(a)(2)(A) that a Plaintiff’s claims against defendants joined in the same action must respect or arise out of the same occurrence or the same series of occurrences. While Bell had alleged copyright infringement of the same copyrighted material against all Defendants, the court held this to be insufficient. Similarly, while the same types of questions of fact would arise against each Defendant – “e.g., how did the defendant find Plaintiff’s photograph, what did the defendant know about the photograph’s copyright status, did the defendant make commercial use of the photograph, and did the defendant pay for the use of the photograph” – those similar questions of fact provided no logical relationship among the Defendants that would support joinder.

Instead, the court found that each Defendant was accused of independently committing separate and distinct acts of copyright infringement that happened to involve the same photograph.

The court then directed the Clerk of the Court to sever all defendants other than Diversified Vehicle Services from the complaint as it had been filed and to open separate causes for each of the severed defendants, with the exception of defendants Cameron Taylor and Taylor Computer Solutions, which the court directed to be joined in one cause. WRTV was dropped, as Bell indicated that it had been included as a defendant inadvertently.

The court also ordered Bell to pay the $400 filing fee for each of the 15 severed causes of action no later than June 2, 2014.

Practice Tip #1: There has been a growing trend of attempting to monetize copyright infringement. In this particular case, the docket for the initial complaint showed Bell’s demand to be $5,000,000 for the alleged infringing activities. In ruling that “unrelated claims against unrelated defendants belong in different suits, in part to ensure that plaintiffs pay the required filing fees” and subsequently ordering the Plaintiff to pay a separate filing fee for each of the Defendants, Magistrate Judge LaRue has employed one approach that may be useful in combatting such copyright trolling.

Practice Tip #2: Under 17 U.S.C. § 504(c)(1), a copyright owner may elect actual or statutory damages. Statutory damages range from a sum of not less than $750 to not more than $30,000 per infringed work.

Practice Tip #3: The claims of this case appear calculated to trigger the “advertising injury” clause of many general business liability insurance policies. If a defendant has applicable business insurance, this may allow Bell to negotiate quicker settlements. Overhauser Law Offices, publisher of this Site, counsels clients on insurance coverage for insurance claims.

Practice Tip #4: These latest causes of actions represent the most recent of three ongoing cases filed by Bell asserting infringement of his photos. We have blogged about his copyright infringement litigation before. See here. The Indiana Lawyer also wrote recently about Bell’s copyright litigation. That article includes an interview with Paul B. Overhauser, Managing Partner of Overhauser Law Offices.

May 22, 2014

Indiana Copyright Lawsuit – Malibu Media Alleges Infringement of Thirty Copyrighted Works

By Overhauser Law Offices, LLC

Indianapolis, Indiana – A copyright attorney for Malibu Media, LLC d/b/a X-Art.com of Los Angeles, California has sued alleging that an unidentified Indiana resident, “John Doe,” engaged in BitTorrent transactions associated with 241 files owned by Malibu Media between October 6, 2013 and May 2, 2014. Malibu Media asserts that these alleged acts of copyright infringement took place in the Southern District of Indiana.

The “John Doe” defendant in this copyright infringement lawsuit allegedly used the BitTorrent file-sharing protocol to illegally download, copy and distribute elements of various works of Malibu Media’s copyrighted material. Malibu Media has also claimed that the defendant is a “persistent online infringer.” It claims that “John Doe” has infringed 30 separate copyrighted works owned by Malibu Media. Of these 30 works, 27 have been registered by the U.S. Copyright Office. Three registrations remain pending.

Malibu Media seeks a permanent injunction against infringing activities; an order by the court to remove infringing materials from all computers of the defendant; an award of statutory damages pursuant to 17 U.S.C. § 504(a) and (c) and reasonable attorneys’ fees and costs.

Practice Tip #1: In its complaint, filed by a copyright lawyer, Malibu Media alleges that the infringing transfer and copying of this copyrighted work was accomplished by the Defendant using BitTorrent, a peer-to-peer file-sharing protocol. Plaintiff states that the BitTorrent protocol makes even small computers with low bandwidth capable of participating in large data transfers for copying large files such as movies.

Practice Tip #2: Under 17 U.S.C. § 504(c)(1), a copyright owner may elect actual or statutory damages. Statutory damages range from a sum not less than $750 to not more than $30,000 per infringed work. The determination of the exact amount is left to the discretion of the court. The docket report shows that, in this case, Malibu Media is demanding $150,000.

May 19, 2014

Indiana Copyright Litigation – Another John Doe Sued by Malibu Media on Allegations of Copyright Infringement

By Overhauser Law Offices, LLC

Indianapolis, Indiana – A copyright attorney for Malibu Media, LLC d/b/a X-Art.com of Los Angeles, California has sued alleging that an unidentified Indiana resident, “John Doe,” infringed numerous of its copyrighted works in the Southern District of Indiana between July 2012 and May 2014.

The “John Doe” defendant in this copyright infringement lawsuit allegedly used the BitTorrent file-sharing protocol to illegally download, copy and distribute elements of various works of Malibu Media’s copyrighted material. Malibu Media has also claimed that the defendant is a “persistent online infringer.” It claims that “John Doe” has infringed 43 separate copyrighted works owned by Malibu Media. Of these 43 works, 42 have been registered by the U.S. Copyright Office. One registration remains pending.

Malibu Media seeks a permanent injunction against infringing activities; an order by the court to remove infringing materials from all computers of the defendant; an award of statutory damages pursuant to 17 U.S.C. § 504(a) and (c) and reasonable attorneys’ fees and costs.

Practice Tip #1: The BitTorrent protocol is a decentralized method that allows users to distribute data via the Internet, and has become an extremely popular method for unlawful copying, reproducing and distributing files in violation of the copyright laws. While the copyright infringements committed with BitTorrent once consisted mostly of music copyright violations, the adult entertainment industry has increasingly been filing suit against infringers who have used BitTorrent-based technology.

Practice Tip #2: Malibu Media, LLC is represented by Paul Nicoletti, one of the country’s most notorious “copyright troll” attorneys. In addition to filing suits on behalf of Malibu Media, LLC, he has also sued hundreds of defendants on behalf of copyright trolls Patrick Collins, Inc. and TCYK, LLC. (Search for these company names on this site to find articles about those other suits, or visit http://fightcopyrighttrolls.com/or www.dietrolldie.com.)

Practice Tip #3: Overhauser Law Offices, the publisher of this website, has represented several hundred persons and businesses regarding copyright infringement and similar matters.