Friday, March 15, 2024

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YouTuber Liable For Bogus DMCA Notice "Awareness Campaign" Targeting Bungie
Andy Maxwell, 15 Mar 11:56 AM

Destiny 2One of the most frustrating aspects of DMCA notices outside the usual complaints aired by rightsholders, is their ability to trigger policies that assume notices are accurate and in some cases, should be blindly obeyed.

Certainly, if the sender of a bogus notice puts in enough effort, the end result can be the removal of whatever material appears in the notice, even when sent to the largest platforms most familiar with fraudulent claims.

In March 2022, someone began sending DMCA notices to YouTube, claiming that the content listed in the notices infringed the rights of videogame developer Bungie. YouTube removed the videos, some of which belonged to high-profile Destiny content creators. Other notices targeted Bungie's own channels, yet fingers of blame soon pointed toward the company itself, compelling Bungie to defend its reputation and clean up the mess.

Impressive Investigation, Culprit Found

During the early days of its investigation, Bungie revealed that the notices sent to YouTube came from a fraudulent Google account; the username was crafted to give the appearance it was sent by a Bungie anti-piracy partner. Bungie also filed a full-blown lawsuit in the United States which is currently in its third year.

The lawsuit alleged that the bogus copyright complaints not only disrupted Bungie's gaming community, it caused "nearly incalculable damage" to Bungie itself. The language deployed in the complaint was unusually aggressive, noting that one of its key aims was to "demonstrate to anyone else stupid enough to volunteer as a Defendant by targeting Bungie's community for similar attack that they will be met by legal process."

tracker-dogsIn June 2022, Bungie filed an amended complaint which demanded $7.65m in damages against a YouTuber called Lord Nazo, aka Nicholas Minor.

Not only had Bungie's investigation tracked down the culprit, the details were laid out in unusual detail in the amended complaint. Bungie methodically followed the online trails, capitalized on the YouTuber's mistakes, and then identified, located and named Minor as their defendant.

Among other things, the investigation showed how persistent email addresses, used across multiple sites, one of which was the victim of a data breach, critically undermined any assumption of anonymity. Bungie was ultimately able to match a confirmed email address with a historic content purchase, made through an account that carried Minor's full name and physical address.

Trigger For the Takedown Campaign

In his deposition, Minor confirmed that the seeds of the campaign were planted when Bungie sent him a takedown notice via YouTube. The video had been hosted on his channel for eight years without issue, so convinced the notice was fraudulent, he sought help from YouTube hoping to get it restored.

When that failed to produce any results, a "confused" and "angry" Minor decided to "raise awareness" of transparency issues in the DMCA takedown process by filing bogus DMCA notices against legitimate videos uploaded by members of Bungie's online community.

Minor reportedly accepts that he "gravely messed up and fully accept[s] that this is [his] fault" but claims he was "oblivious to the reprehensible damages [he] was causing to the community."

Summary Judgment

In December 2023, Bungie filed a motion for summary judgment on the DMCA component of its overall claim. Minor did not oppose the motion but did appear in the case as required, including for his deposition and to provide discovery responses.

"The undisputed record before the Court shows that Minor violated the DMCA by knowingly, intentionally, and materially misrepresenting to YouTube that the takedown notifications were authorized by Bungie and that the material itself was infringing," Senior District Judge Marsha J. Pechman notes in her judgment issued last week.

"Bungie has provided evidence that the materials at issue did not violate its IP Policy, and that the DMCA notices were not properly issued. And, crucially, Minor admits that he had no authority to issue the notices, that he intentionally and knowingly issued the notices, and that he 'gravely messed up.'"

Referencing Section 512 of the DMCA, Judge Pechman notes that the evidence shows that Minor's violations were intentional, and that he lacked a subjective, good faith belief that the targeted material was infringing.

"Bungie has also provided evidence that the fraudulent notices harmed its reputation and caused it to devote significant resources to attempt to remediate the harm. The Court therefore GRANTS summary judgment in Bungie's favor on this claim and GRANTS the Motion," the judgment adds.

Not Over Yet, Possibly Not For a Long Time

The Court notes that the judgment is partial since it does not resolve the question of damages, costs, and attorneys' fees Bungie will likely claim in due course. The amount could be significant and at least in public, Bungie has shown few signs of mercy recently.

Then there are the rest of Bungie's claims in this matter. They include false designation under 15 U.S.C. § 1125(a), copyright infringement under 17 U.S.C. § 501, business defamation, violations of the Washington Consumer Protection Act, and breach of contract.

The order granting partial summary judgment is available here (pdf)

From: TF, for the latest news on copyright battles, piracy and more.

Cox Requests Rehearing of Piracy Case That 'Threatens to Throw Countless People Offline'
Ernesto Van der Sar, 15 Mar 12:08 AM

cautionInternet provider Cox Communications has been on the sharp end of several piracy lawsuits in recent years.

The biggest hit came four years ago when the Internet provider lost its legal battle against a group of major record labels, including Sony and Universal.

A Virginia jury held Cox liable for pirating subscribers because it failed to terminate accounts after repeated accusations, and ordered the company to pay $1 billion in damages to the labels. This landmark ruling was appealed, leading to a mixed outcome last month.

Appeals Court Issues Mixed Order

After taking a fresh look at the case, the Fourth Circuit Court of Appeals ruled partly in favor of Cox. The Court concluded that Cox is not vicariously liable for piracy carried out by subscribers, as it didn't directly profit from their activity.

The Court did not reverse the lower court's contributory copyright infringement finding, however. According to the Court of Appeals, there was sufficient evidence to show that Cox 'knew' piracy would likely occur if it continued to provide its Internet services to particular subscribers.

While the ruling is a mixed bag, it also meant that the $1 billion damages award could not stand. Instead, the Court ruled that a new trial should determine the scale of the damages.

Rehearing en Banc

Neither party was pleased with the ruling and both Cox and the labels requested a rehearing en banc, essentially calling for a do-over.

The labels, for example, would like the $1 billion in damages to remain unchanged, arguing that Cox waived a potential challenge of it earlier. In addition, the music companies argue that the Court's decision conflicts with appeal court precedents.

Cox also calls for a rehearing. The Internet provider argues that this case isn't merely about nuances of copyright law and associated liability, it's much bigger than that. According to the ISP, the Internet connectivity of countless people is at stake.

'Disconnecting Schools and Nanny Cams'

In its petition, the provider argues that the current precedent results in a highly restrictive regime where Internet providers may find themselves forced to disconnect 'innocent' people because someone allegedly used their connection to pirate content.

"If an ISP receives more than one accusation that some anonymous person used a specified internet connection to download infringing songs, it can avoid liability only by swiftly throwing every person in that home or business off the internet, disconnecting the guilty and innocent alike from their schools, their livelihoods, their nanny cams, their news, and everything else they do online," Cox warns.

"If instead the ISP continues to provide the connection, a jury can find it engaged in 'culpable conduct' akin to aiding-and-abetting a crime."

most severe

The ISP argues that the liability finding is at odds with a recent Supreme Court decision which concluded that a service is not necessarily liable for 'merely' providing a service that's used for illegal activity. The Court of Appeal didn't consider this in its latest ruling, but should do so, Cox notes.

A rehearing is also warranted because a party shouldn't necessarily be held liable for willful secondary infringement, as is the case here. This conflicts with earlier precedent, the ISP argues.

"[W]illfulness requires the defendant's awareness that its own conduct violates the law, as the Eighth Circuit has squarely held in a secondary infringement case like this one," Cox writes in its petition.

'Draconian Regime'

These two earlier conclusions of the court created "the most draconian approach in the country," Cox argues, stressing that a rehearing should be granted to address them.

The matter ultimately boils down to an interpretation of the law, which can get quite technical. However, Cox also highlights the potential consequences, stressing that these issues are "extraordinarily important." Not just for Cox, but for millions of Internet subscribers at risk of disconnection.

"The issues presented here are deeply important, not only to copyright defendants like Cox, but to millions of people who depend on internet access every day," Cox writes.

"[T]he legal regime the panel decision and BMG enact requires an ISP to cut the cord on subscribers after receiving just a handful of notices alleging that some anonymous person has used the subscribers' connection to infringe."

The current precedent requires ISPs to disconnect subscribers based on repeated third-party claims. If they don't, they subject themselves to liability, as the previous $1 billion verdict showed.

'Hobson's Choice'

Cox suggests that this looming punishment is disproportionate. Not only in terms of the financial consequences for Internet providers but also because the public's Internet connectivity will be put at risk based on unadjudicated piracy claims from rightsholders.

"Without meaningful limits on secondary liability, ISPs face powerful incentives to swiftly terminate the internet connections of innumerable businesses and households, their monthly subscription fees a pittance compared to the threat of $150,000 in damages for every downloaded song.

"The full Court should grant rehearing and reject a Hobson's choice that threatens to throw countless ordinary people offline in service of the music industry's bottom line," Cox concludes.

The ISP's position is supported by several amici including the American Library Association, Public Knowledge, the Electronic Frontier Foundation, and fellow Internet provider Frontier Communications, which has filed supporting briefs.

A copy of Cox's petition for a rehearing en banc is available here (pdf) and the record labels' petition can be found here (pdf). Frontier's proposed amicus curiae brief can be found here (pdf) and the brief of the other supporters is available here

From: TF, for the latest news on copyright battles, piracy and more.

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