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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 1 of 52 Page ID #:5

Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 2 of 52 Page ID #:6



Plaintiff Malibu Media, LLC, sues John Does 1-10, and alleges:

Introduction

1.

This matter arises under the United States Copyright Act of 1976, as

amended, 17 U.S.C. §§ 101 et seq. (the “Copyright Act”).

2.

Each of the Defendants copied and distributed a website containing 22
federally registered copyrighted movies owned by Plaintiff. This is known as a
“siterip.”
3.
• Direct copyright infringement in violation of 17 U.S.C. §§ 106 and 501;

Through this suit, Plaintiff alleges each Defendant is liable for:

and

• Contributory copyright infringement.

Jurisdiction And Venue

4.

This Court has subject matter jurisdiction over this action pursuant to
28 U.S.C. § 1331 (federal question); and 28 U.S.C. § 1338 (patents, copyrights,
trademarks and unfair competition).

5.

As set forth on Exhibit A, each of the Defendants’ acts of copyright
infringement occurred using an Internet Protocol address (“IP address”) traced to a
physical address located within this District, and therefore pursuant to Cal. Civ.
Proc. Code § 410.10, this Court has personal jurisdiction over each Defendant
because each Defendant committed the tortious conduct alleged in this Complaint in
the State of California, and (a) each Defendant resides in the State of California,
and/or (b) each Defendant has engaged in continuous and systematic business
activity in the State of California.

6.

Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) and (c),
because: (i) a substantial part of the events or omissions giving rise to the claims
occurred in this District; and, (ii) a Defendant resides (and therefore can be found)
in this District and all of the Defendants reside in this State; additionally, venue is


1



Complaint



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 3 of 52 Page ID #:7



proper in this District pursuant 28 U.S.C. § 1400(a) (venue for copyright cases)
because each Defendant or each Defendant’s agent resides or may be found in this
District.

Parties

7.

Plaintiff is a limited liability company organized and existing under the
laws of the State of California and has its principal place of business located at
31356 Broad Beach Road, Malibu, CA 90265.

8.

Each Defendant is known to Plaintiff only by an IP address. See

Exhibit A.

9.

An IP address is a number that is assigned by an Internet Service
Provider (an “ISP”) to devices, such as computers, that are connected to the Internet.
10. The ISP to which each Defendant subscribes can correlate the

Defendant’s IP address to the Defendant’s true identity.

Joinder

11. Pursuant to Fed. R. Civ. P. 20(a)(2), each of the Defendants was
properly joined because, as set forth in more detail below, Plaintiff asserts that: (a)
each of the Defendants is jointly and severally liable for the infringing activities of
each of the other Defendants, and (b) the infringement complained of herein by each
of the Defendants was part of a series of transactions, involving the exact same
torrent file containing of Plaintiff’s copyrighted Works, and was accomplished by
the Defendants acting in concert with each other, and (c) there are common
questions of law and fact; indeed, the claims against each of the Defendants are
identical and each of the Defendants used the BitTorrent protocol to infringe
Plaintiff’s copyrighted Works.

Factual Background

Plaintiff Owns The Copyright To The Motion Pictures
12.

Internet screen shots from www.copyright.gov for each of the 22

2

Complaint



I.





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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 4 of 52 Page ID #:8



Registrations is attached as Exhibit B.

13.

Collectively, each of the 22 movies covered by the 22 Registrations are

referred to as the “Works.”

14.

Each of the Works were on a website that was converted into are in a
single torrent file, as evidenced by a single unique Cryptographic Hash Value (the
“Unique Hash Number”).

15.

Each of the Defendants copied and distributed, through the BitTorrent
protocol, the exact same torrent file, as evidenced by a single unique Cryptographic
Hash Value, which contained Plaintiff’s 22 registered works.

16.

The date on which the United States Copyright Office Registered the
works and the date IPP Limited recorded each Defendant’s infringement is set forth
on Exhibit C. Exhibit C demonstrates that each infringement occurred after the
registration date.
II. Defendants Used BitTorrent To Infringe Plaintiff’s Copyright

17.

BitTorrent is one of the most common peer-to-peer file sharing
protocols (in other words, set of computer rules) used for distributing large amounts
of data.

18. The BitTorrent protocol’s popularity stems from its ability to distribute
a large file without creating a heavy load on the source computer and network. In
short, to reduce the load on the source computer, rather than downloading a file
from a single source computer (one computer directly connected to another), the
BitTorrent protocol allows users to join a "swarm" of host computers to download
and upload from each other simultaneously (one computer connected to numerous
computers).

A. Each Defendant Installed a BitTorrent Client onto his or her

Computer

19. Each Defendant used a BitTorrent Client to commit the infringement





3

Complaint



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 5 of 52 Page ID #:9



alleged herein.

20. A BitTorrent “Client” is a software program that implements the
BitTorent protocol. There are numerous such software programs including µTorrent
and Vuze, both of which can be directly downloaded from the internet. See
www.utorrent.com and http://new.vuze-downloads.com/.

21. Once installed on a computer, the BitTorrent “Client” serves as the
user’s interface during the process of uploading and downloading data using the
BitTorrent protocol.

The Initial Seed, Torrent, Hash and Tracker

B.
22. A BitTorrent user that wants to upload a new file, known as an “initial
seeder,” starts by creating a “torrent” descriptor file using the Client he or she
installed onto his or her computer.

23. The Client takes the target computer file, the “initial seed,” here the
subject website containing the copyrighted Works, and divides it into groups of bits
known as “pieces.”

24. The Client then gives each one of the computer file’s pieces, in this
case, pieces of the copyrighted Works, a random and unique alphanumeric identifier
known as a “hash” and records these hash identifiers in the torrent file.

25. When another peer later receives a particular piece, the hash identifier
for that piece is compared to the hash identifier recorded in the torrent file for that
piece to test that the piece is error-free. In this way, the hash identifier works like an
electronic fingerprint to identify the source and origin of the piece and that the piece
is authentic and uncorrupted.

26. Torrent files also have an "announce" section, which specifies the URL
(Uniform Resource Locator) of a “tracker,” and an "info" section, containing
(suggested) names for the files, their lengths, the piece length used, and the hash
identifier for each piece, all of which are used by Clients on peer computers to


4

Complaint





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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 6 of 52 Page ID #:10



verify the integrity of the data they receive.

27. The “tracker” is a computer or set of computers that a torrent file

specifies and to which the torrent file provides peers with the URL address(es).

28. The tracker computer or computers direct a peer user’s computer to
other peer user’s computers that have particular pieces of the file, here the
copyrighted Works, on them and facilitates the exchange of data among the
computers.

29. Depending on the BitTorrent Client, a tracker can either be a dedicated
computer (centralized tracking) or each peer can act as a tracker (decentralized
tracking).
C.
30.

Torrent Sites
“Torrent sites” are websites that index torrent files that are currently
being made available for copying and distribution by people using the BitTorrent
protocol. There are numerous torrent websites, including www.TorrentZap.com,
www.Btscene.com, and www.ExtraTorrent.com.

31. Upon information and belief, each Defendant went to a torrent site to

upload and download Plaintiff’s copyrighted Works.

D. Uploading and Downloading Works Through a BitTorrent Swarm
32. Once the initial seeder has created a torrent and uploaded it onto a
torrent site then other peers begin to download and upload the computer file to
which the torrent is linked (here the copyrighted Works) using the BitTorrent
protocol and BitTorrent Client that the peers installed on their computers.

33. The BitTorrent protocol causes the initial seed’s computer to send
different pieces of the computer file, here the copyrighted Works, to the peers
seeking to download the computer file.

34. Once a peer receives a piece of the computer file, here a piece of the

Copyrighted Works, it starts transmitting that piece to the other peers.


5

Complaint





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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 7 of 52 Page ID #:11



35.

In this way, all of the peers and seeders are working together in what is

called a “swarm.”

36. Here, each Defendant peer member participated in the same swarm and
directly interacted and communicated with other members of that swarm through
digital handshakes, the passing along of computer instructions, uploading and
downloading, and by other types of transmissions.

37.

In this way, and by way of example only, one initial seeder can create a
torrent that breaks a movie up into hundreds or thousands of pieces saved in the
form of a computer file, like the Works here, upload the torrent onto a torrent site,
and deliver a different piece of the copyrighted work to each of the peers. The
recipient peers then automatically begin delivering the piece they just received to the
other peers in the same swarm.

38. Once a peer, here a Defendant, has downloaded the full file, the

E.

BitTorrent Client reassembles the pieces and the peer is able to view the movie.
Identified Each of

the
Plaintiff’s Computer
Defendants’ IP Addresses as Participants in a Swarm That Was
Distributing Plaintiff’s Copyrighted Works

Investigators


38. Plaintiff retained IPP, Limited (“IPP”) to identify the IP addresses that
are being used by those people that are using the BitTorrent protocol and the internet
to reproduce, distribute, display or perform Plaintiffs’ copyrighted Works.

39.

IPP used forensic software named INTERNATIONAL IPTRACKER
v1.2.1 and related technology enabling the scanning of peer-to-peer networks for the
presence of infringing transactions.

40.

IPP extracted the resulting data emanating from the investigation,
reviewed the evidence logs, and isolated the transactions and the IP addresses
associated therewith for the file identified by the SHA-1 hash value of
07465D809433A7FA20611BDDF4F0C6C36D448FB2
“Unique Hash


(the

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Complaint





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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 8 of 52 Page ID #:12



Number”).

41. The IP addresses, Unique Hash Number and hit dates contained on

Exhibit A accurately reflect what is contained in the evidence logs, and show:

(A) Each Defendant had copied a piece of Plaintiff’s copyrighted Works

identified by the Unique Hash Number; and

(B) Therefore, each Defendant was part of the same series of transactions.
42. Through each of the transactions, each of the Defendant’s computers
used their identified IP addresses to connect to the investigative server from a
computer in this District in order to transmit a full copy, or a portion thereof, of a
digital media file identified by the Unique Hash Number.

43.

IPP’s agent analyzed each BitTorrent “piece” distributed by each IP
address listed on Exhibit A and verified that re-assemblage of the pieces using a
BitTorrent Client results in a fully playable digital motion picture of the Works.

44.

IPP’s agent viewed the Works side-by-side with the digital media file
that correlates to the Unique Hash Number and determined that they were identical,
strikingly similar or substantially similar.

45. All conditions precedent to bringing this action have occurred or been

Miscellaneous

waived.

46. Plaintiff retained counsel to represent it in this matter and is obligated

to pay said counsel a reasonable fee for its services.

COUNT I

Contributory Infringement Against Does 1-10

47. The allegations contained in paragraphs 1-46 are hereby re-alleged as if

fully set forth herein.

48. Plaintiff is the owner of the copyrights for the Works, each of which

contains an original work of authorship.


7

Complaint





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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 9 of 52 Page ID #:13



49. By using the BitTorrent protocol and a BitTorrent Client and the
processes described above, each Defendant copied the constituent elements of the
Works that are original.

50. Plaintiff did not authorize, permit or consent to Defendants’ copying of

its Works.

51. As a result of the foregoing, each Defendant violated Plaintiff’s

exclusive right to:

(A) Reproduce the Works in copies, in violation of 17 U.S.C. §§ 106(1) and

501;

(B) Redistribute copies of the Works to the public by sale or other transfer
of ownership, or by rental, lease or lending, in violation of 17 U.S.C. §§ 106(3) and
501;

(C)

Perform the copyrighted Works, in violation of 17 U.S.C. §§ 106(4)
and 501, by showing the Works’ images in any sequence and/or by making the
sounds accompanying the Works audible and transmitting said performance of the
Works, by means of a device or process, to members of the public capable of
receiving the display (as set forth in 17 U.S.C. § 101’s definitions of “perform” and
“publically” perform); and

(D)

Display the copyrighted Works, in violation of 17 U.S.C. §§ 106(5)
and 501, by showing individual images of the Works nonsequentially and
transmitting said display of the Works by means of a device or process to members
of the public capable of receiving the display (as set forth in 17 U.S.C. § 101’s
definition of “publically” display).

52. Each of the Defendants’ infringements was committed “willfully”

within the meaning of 17 U.S.C. § 504(c)(2).

53. Plaintiff has suffered actual damages that were proximately caused by
each of the Defendants including lost sales, price erosion and a diminution of the


8

Complaint





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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 10 of 52 Page ID #:14



value of its copyrights.

COUNT II

Contributory Infringement Against Does 1-10

54. The allegations contained in paragraphs 1-46 are hereby re-alleged as if

fully set forth herein.

55. Plaintiff is the owner of the copyrights for the Works, each of which

contains an original work of authorship.

56. By using the BitTorrent protocol and a BitTorrent Client and the
processes described above, each Defendant copied the constituent elements of each
of the Works that are original.

57. By participating in the BitTorrent swarm with the other Defendants,
each Defendant induced, caused or materially contributed to the infringing conduct
of each other Defendant.

58. Plaintiff did not authorize, permit or consent to Defendants’ inducing,
causing or materially contributing to the infringing conduct of each other Defendant.
59. Each Defendant knew or should have known that other BitTorrent
users, here the other Defendants, would become members of a swarm with
Defendant.

60. Each Defendant knew or should have known that other BitTorrent users
in a swarm with it, here the other Defendants, were directly infringing Plaintiff’s
copyrighted Works by copying constituent elements of the Works that are original.

61.

Indeed, each Defendant directly participated in and therefore materially

contributed to each other Defendant’s infringing activities.

62. Each of the Defendants’ contributory infringements were committed

“willfully” within the meaning of 17 U.S.C. § 504(c)(2).

63. Plaintiff has suffered actual damages that were proximately caused by
each of the Defendants including lost sales, price erosion, and a diminution of the


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Complaint





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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 11 of 52 Page ID #:15



value of its copyright.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court:

(A) Permanently enjoin each Defendant and all other persons who are in
active concert or participation with each Defendant from continuing to infringe
Plaintiff’s copyrighted Works;

(B) Order that each Defendant delete and permanently remove the torrent
file relating to Plaintiff’s copyrighted Works from each of the computers under each
such Defendant’s possession, custody or control;

(C) Order that each Defendant delete and permanently remove the copy of
the Works each Defendant has on the computers under Defendant’s possession,
custody or control;

(D) Find that each Defendant is jointly and severally liable for the direct

infringement of each other Defendant;

(E) Award Plaintiff the greater of: (i) statutory damages in the amount of
$150,000 per Defendant, per registered Work infringed, pursuant to 17 U.S.C. §
504-(a) and (c), or (ii) Plaintiff’s actual damages and any additional profits of the
Defendant pursuant to 17 U.S.C. § 504-(a)-(b);

(F) Award Plaintiff its reasonable attorneys’ fees and costs pursuant to 17

U.S.C. § 505; and

(G) Grant Plaintiff any other and further relief this Court deems just and

proper.









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Complaint



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 12 of 52 Page ID #:16



DEMAND FOR A JURY TRIAL

Plaintiff hereby demands a trial by jury on all triable issues.


KUSHNER LAW GROUP

DATED: May 23, 2012






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By:



Leemore L. Kushner
Attorneys for Plaintiff Malibu Media, LLC

11

Complaint



Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 13 of 52 Page ID #:17

!!!!!!!!!!!!!!!!!!!!!!!!!!!

EXHIBIT A

Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 14 of 52 Page ID #:18

SHA-1 Hash:
 
 07465D809433A7FA20611BDDF4F0C6C36D448FB2






Title
Rights Owner: Malibu Media

X-Art Siterip #51

DOE#
 

IP
 

174.67.224.25
 

72.194.66.183
 

208.127.187.237
 

208.127.6.204
 

68.183.143.21
 

24.24.231.232
 

24.43.25.98
 

75.85.119.61
 

76.175.47.108
 

98.151.11.121
 

1
 

2
 

3
 

4
 

5
 

6
 

7
 

8
 

9
 

10
 



Hit
 date
 
(UTC)
 
5/18/2012
 

6:52
  Mission
 Viejo
 

City
 

State
 

ISP
 

Network
 

3/31/2012
 

3:10
  Lake
 Forest
 

5/17/2012
 

3:18
  Los
 Angeles
 

5/13/2012
 

5:42
  Encino
 

5/18/2012
 

2:29
  Los
 Angeles
 

4/22/2012
 

2:11
  El
 Segundo
 

5/15/2012
 
19:28
 
4/16/2012
 
3:00
 
5/16/2012
 

North
 
Hollywood
 
North
 
Hollywood
 

21:14
  Murrieta
 

5/17/2012
 
2:29
 

North
 
Hollywood
 

CA
 

CA
 

CA
 

CA
 

CA
 

CA
 

CA
 

CA
 

CA
 

CA
 

Cox
 Communications
 

BitTorrent
 

Cox
 Communications
 

BitTorrent
 

DSL
 Extreme
 

DSL
 Extreme
 

DSL
 Extreme
 

Road
 Runner
 

Road
 Runner
 

Road
 Runner
 

Road
 Runner
 

Road
 Runner
 

BitTorrent
 

BitTorrent
 

BitTorrent
 

BitTorrent
 

BitTorrent
 

BitTorrent
 

BitTorrent
 

BitTorrent
 

Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 15 of 52 Page ID #:19

!!!!!!!!!!!!!!!!!!!!!!!!!!!

EXHIBIT B

Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 16 of 52 Page ID #:20

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = carlie beautiful blow
Search Results: Displaying 1 of 1 entries



Carlie Beautiful Blowjob .

Type of Work: Motion Picture

Registration Number / Date: PA0001762079 / 2011-11-21

Application Title: Carlie Beautiful Blowjob .
Title: Carlie Beautiful Blowjob .
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-03-26
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 17 of 52 Page ID #:21

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = carlie big toy orgasm
Search Results: Displaying 1 of 1 entries



Carlie Big Toy Orgasm.

Type of Work: Motion Picture

Registration Number / Date: PA0001776839 / 2012-02-21

Application Title: Carlie Big Toy Orgasm.
Title: Carlie Big Toy Orgasm.
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-03-22
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 18 of 52 Page ID #:22

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = carlie leila strawberries
Search Results: Displaying 1 of 1 entries



Carlie Leila Strawberries and Wine .

Type of Work: Motion Picture

Registration Number / Date: PA0001762081 / 2011-11-18

Application Title: Carlie Leila Strawberries and Wine .
Title: Carlie Leila Strawberries and Wine .

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-05-07
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = daddy's office
Search Results: Displaying 1 of 1 entries



Daddy's Office.

Type of Work: Motion Picture

Registration Number / Date: PA0001776838 / 2012-02-21

Application Title: Daddy’s Office.
Title: Daddy’s Office.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-11-12
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = deep inside caprice
Search Results: Displaying 1 of 1 entries



Deep Inside Caprice.

Type of Work: Motion Picture

Registration Number / Date: PA0001776837 / 2012-02-21

Application Title: Deep Inside Caprice.
Title: Deep Inside Caprice.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-04-13
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 21 of 52 Page ID #:25

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = faye prelude to an orgy
Search Results: Displaying 1 of 1 entries



Faye Prelude to an Orgy.

Type of Work: Motion Picture

Registration Number / Date: PA0001776836 / 2012-02-21

Application Title: Faye Prelude to an Orgy.
Title: Faye Prelude to an Orgy.
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-02-11
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 22 of 52 Page ID #:26

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = hayden pink and tight
Search Results: Displaying 1 of 1 entries



Hayden Pink and Tight.

Type of Work: Motion Picture

Registration Number / Date: PA0001776805 / 2012-02-21

Application Title: Hayden Pink and Tight.
Title: Hayden Pink and Tight.
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-04-04
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 23 of 52 Page ID #:27

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = just the two of us
Search Results: Displaying 24 of 222 entries



Just the Two of Us.

Type of Work: Motion Picture

Registration Number / Date: PA0001781672 / 2012-03-18

Application Title: Just the Two of Us.
Title: Just the Two of Us.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-11-18
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 24 of 52 Page ID #:28

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = katka cum like
Search Results: Displaying 1 of 1 entries



Katka Cum Like Crazy.

Type of Work: Motion Picture

Registration Number / Date: PA0001762074 / 2011-11-21

Application Title: Katka Cum Like Crazy.
Title: Katka Cum Like Crazy.
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-07-07
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 25 of 52 Page ID #:29

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = katka sweet surprise
Search Results: Displaying 1 of 1 entries



Katka Sweet Surprise.

Type of Work: Motion Picture

Registration Number / Date: PA0001762075 / 2011-11-18

Application Title: Katka Sweet Surprise.
Title: Katka Sweet Surprise.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-08-04
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 26 of 52 Page ID #:30

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = kristen girl
Search Results: Displaying 1 of 1 entries



Kristen Girl Next Door.

Type of Work: Motion Picture

Registration Number / Date: PA0001762076 / 2011-11-18

Application Title: Kristen Girl Next Door.
Title: Kristen Girl Next Door.
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-08-25
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 27 of 52 Page ID #:31

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = leila faye awesome threesome
Search Results: Displaying 1 of 1 entries



Leila Faye Awesome Threesome.

Type of Work: Motion Picture

Registration Number / Date: PA0001776804 / 2012-02-21

Application Title: Leila Faye Awesome Threesome.
Title: Leila Faye Awesome Threesome.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-02-02
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 28 of 52 Page ID #:32

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = leila naked in the hot
Search Results: Displaying 1 of 1 entries



Leila Naked in the Hot Sun.

Type of Work: Motion Picture

Registration Number / Date: PA0001776803 / 2012-02-21
Application Title: Leila Naked in the Hot Sun.
Title: Leila Naked in the Hot Sun.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-03-25
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 29 of 52 Page ID #:33

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = leila sex on the
Search Results: Displaying 1 of 1 entries



Leila Sex On The Beach.

Type of Work: Motion Picture

Registration Number / Date: PA0001762083 / 2011-11-21

Application Title: Leila Sex On The Beach.
Title: Leila Sex On The Beach.
Description: Electronic file (eService)

States.
Date of Creation: 2010

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd., Malibu, CA, 90265, United

Date of Publication: 2010-12-22
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 30 of 52 Page ID #:34

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = megan morning bath
Search Results: Displaying 1 of 1 entries



Megan Morning Bath.

Type of Work: Motion Picture

Registration Number / Date: PA0001762077 / 2011-11-18

Application Title: Megan Morning Bath.
Title: Megan Morning Bath.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-02-12
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 31 of 52 Page ID #:35

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = Mina's Fanta
Search Results: Displaying 1 of 2 entries



Mina's Fantasy.

Type of Work: Motion Picture

Registration Number / Date: PA0001762078 / 2011-11-23

Application Title: Mina’s Fantasy.
Title: Mina’s Fantasy.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-06-25
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 32 of 52 Page ID #:36

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = Tatiana the Voyeur
Search Results: Displaying 1 of 1 entries



Tatiana the Voyeur.

Type of Work: Motion Picture

Registration Number / Date: PA0001776808 / 2012-02-21

Application Title: Tatiana the Voyeur.
Title: Tatiana the Voyeur.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-03-23
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 33 of 52 Page ID #:37

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = art of anal sex
Search Results: Displaying 1 of 1 entries



The Art of Anal Sex.

Type of Work: Motion Picture

Registration Number / Date: PA0001776834 / 2012-02-21

Application Title: The Art of Anal Sex.
Title: The Art of Anal Sex.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-04-25
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 34 of 52 Page ID #:38

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = ultimate blowjob
Search Results: Displaying 1 of 1 entries



The Ultimate Blowjob.

Type of Work: Motion Picture

Registration Number / Date: PA0001776806 / 2012-02-21

Application Title: The Ultimate Blowjob.
Title: The Ultimate Blowjob.
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-04-22
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 35 of 52 Page ID #:39

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = tiffany sex with a supermodel
Search Results: Displaying 1 of 1 entries



Tiffany Sex with a Supermodel.

Type of Work: Motion Picture

Registration Number / Date: PA0001762022 / 2011-11-21

Application Title: Tiffany Sex with a Supermodel.
Title: Tiffany Sex with a Supermodel.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2011

Date of Publication: 2011-02-23
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 36 of 52 Page ID #:40

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = tiffany teenagers in love
Search Results: Displaying 1 of 1 entries



Tiffany Teenagers In Love.

Type of Work: Motion Picture

Registration Number / Date: PA0001762019 / 2011-11-20
Application Title: Tiffany Teenagers In Love.
Title: Tiffany Teenagers In Love.

Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-12-29
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 37 of 52 Page ID #:41

Public Catalog
Copyright Catalog (1978 to present)
Search Request: Left Anchored Title = tori the endless
Search Results: Displaying 1 of 1 entries



Tori The Endless Orgasm.

Type of Work: Motion Picture

Registration Number / Date: PA0001762082 / 2011-11-18

Application Title: Tori The Endless Orgasm.
Title: Tori The Endless Orgasm.
Description: Electronic file (eService)

Copyright Claimant: Malibu Media LLC. Address: 31356 Broad Beach Rd, Malibu, CA, 90265.

Date of Creation: 2010

Date of Publication: 2010-10-20
Nation of First Publication: United States
Authorship on Application: Malibu Media LLC, employer for hire; Domicile: United States; Citizenship: United

States. Authorship: entire motion picture.

Names: Malibu Media LLC



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Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 38 of 52 Page ID #:42

!!!!!!!!!!!!!!!!!!!!!!!!!!!

EXHIBIT C

Case 2:12-cv-04650-GAF-FMO Document 1 Filed 05/29/12 Page 39 of 52 Page ID #:43



Doe #1


Title
Carlie Beautiful Blowjob
Carlie Big Toy Orgasm
Carlie Leila Strawberries and Wine
Daddy's Office
Deep Inside Caprice
Faye Prelude to an Orgy
Hayden Pink and Tight
Just the Two of Us
Katka Cum Like Crazy
Katka Sweet Surprise
Kristen Girl Next Door
Leila Faye Awesome Threesome
Leila Naked in the Hot Sun
Leila Sex on the Beach
Megan Morning Bath
Mina's Fantasy
Tatiana The Voyeur
The Art of Anal Sex
The Ultimate Blowjob
Tiffany Sex with a Supermodel
Tiffany Teenagers in Love
Tori The Endless Orgasm

Total Statutory Copyright Infringements for Doe #1: 22


Date First Pub Regis Date Hit Date
03/26/2010
03/22/2010
05/07/2010
11/12/2010
04/13/2011
02/11/2011
04/04/2011
11/18/2011
07/07/2010
08/04/2010
08/25/2010
02/02/2011
03/25/2011
12/22/2010
02/12/2010
06/25/2010
03/23/2011
04/25/2011
04/22/2011
02/23/2011
12/29/2010
10/20/2010

11/21/2011 05/18/2012 06:52:25
02/21/2012 05/18/2012 06:52:25
11/18/2011 05/18/2012 06:52:25
02/21/2012 05/18/2012 06:52:25
02/21/2012 05/18/2012 06:52:25
02/21/2012 05/18/2012 06:52:25
02/21/2012 05/