DeCSS Letter from the MPAA

From: mpaa23@pacbell.net
Subject: Unauthorized Distribution of DeCSS (Reference#: 77715)

MOTION PICTURE ASSOCIATION OF AMERICA, INC.
15503 VENTURA BOULEVARD
ENCINO, CALIFORNIA 91436

UNITED STATES
Anti-Piracy Operations
PHONE: (818) 728 - 8127
Email: MPAA23@pacbell.net

Wednesday, March 21, 2001

Via Fax/Email

RE: Illegal Provision of DeCSS/Circumvention Device
Site/URL: http://www.csd.net/~cgadd/ [with unknown IP address]
Reference#: 77715

T*>

Dear support@csd.net :

The Motion Picture Association (MPA) represents the following motion picture production and distribution companies:

Columbia Pictures Industries, Inc.
Disney Enterprises, Inc.
Metro-Goldwyn-Mayer Studios Inc.
tro-Goldwyn-Mayer Studios Inc.
Paramount Pictures Corporation
TriStar Pictures, Inc.
Twentieth Century Fox Film Corporation
United Artists Pictures, Inc.
United Artists Corporation
Universal City Studios, Inc.
Warner Bros., a Division of Time Warner Entertainment Company, L.P.

We have received information that the above referenced Internet site is providing a circumvention device commonly known as DeCSS. DeCSS is a software utility that decrypts or unscrambles the contents of DVDs (consisting of copyrighted motion pictures) or otherwise circumvents the protection afforded by the Contents Scramble System (CSS) and permits the copying of the DVD contents and/or any portion thereof. As such, DeCSS is an unlawful circumvention device within the meaning of the Digital Millennium Copyright Act, Title 17 United States Code Section 1201(a)(2)(3). Providing or offering DeCSS to the public on your system or network violates the provisions of Section 1201(a)(2) which prohibit the “manufacturing, importing or offering to the public, providing, or otherwise trafficking” in an unlawful circumvention device. (Title 17 United States Code Section 1201 et seq. hereafter is referred to as the “DMCA”).

On August 17, 2000, a federal district court in the Southern District of New York confirmed that offering, providing, or trafficking in DeCSS, or any other device designed to circumvent CSS, violates the DMCA. The district court granted a permanent injunction against (1) posting on any Internet site, or in any other way manufacturing, importing or offering to the public, providing, or otherwise trafficking in DeCSS or any other technology primarily designed to circumvent CSS, and (2) linking any Internet web site, either directly or through a series of links, to any other Internet web site containing DeCSS.

The district court’s ruling makes clear that by providing DeCSS, the above referenced Internet site violates the DMCA. This conduct may also violate the laws of other countries, international law, and/or treaty obligations.

We therefore demand that you take appropriate steps to cause the immediate removal of DeCSS from the above identified Internet site, along with such other actions as may be necessary or appropriate to suspend this illegal activity. Failure to comply with this measure will subject you to liability as described above.

We also request that you:

1. maintain and take whatever steps are necessary to prevent the destruction of all records, including electronic records, in your possession or control related to this Internet site, account holder or subscriber, and

2. provide appropriate notice to the subscriber or account holder responsible for the presence of DeCSS on your system or network, advising him/her of the contents of this notice and directing that person to contact the undersigned immediately at the email address provided above.

By copy of this letter, the owner of the above referenced Internet site and/or email account is hereby directed to cease and desist from the conduct complained of herein.

On behalf of the respective owners of the exclusive rights to the copyrighted material at issue in this notice, we hereby state, pursuant to the DMCA that we have a good faith belief that the acts complained of are not authorized by the copyright owners, their respective agents, or the law.

Also pursuant to DMCA, we hereby state, under penalty of perjury under the law of California and under the laws of the United States, that the information in this notification is accurate and that we are authorized to act on behalf of the owners of the exclusive rights being infringed as set forth in this notification.

Please contact us at the above listed address or by replying to this email if you should have any questions.

Thank you for your cooperation in this matter. Your prompt response is requested.

Respectfully,

Hemanshu Nigam
Director
Worldwide Internet EnforcementFrom: mpaa23@pacbell.net

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