Venice PI LLC (not so “new” copyright troll) filing in select Carl Crowell local counsel courts.

There is a “new” copyright troll filing lawsuits with a fervor across the US named “Venice PI, LLC” (more on the word “new”; more on “across the US”).  The Venice PI lawsuits all claim $150,000 copyright infringement damages for the illegal download of the “Once Upon a Time in Venice” movie starring Bruce Willis.  ISPs are sending notices to their subscribers informing them that a Venice PI subpoena requesting their identity has been provided to them, and that they are under an order signed by a federal judge to comply, unless the subscriber files a “motion to quash” the subpoena.

ISPs sending the subpoena notices to its subscribers informing them about the Once Upon a Time in Venice movie lawsuit include CenturyLink, Comcast Xfinity, Hawaii Telecom, Optimum Online, Verizon Fios, and Time Warner Cable, depending on where you live.

As of this evening, I see lawsuits filed as early as 6/28/2017 and as recent as 7/18/2017. Once Upon a Time in Venice movie lawsuits are being filed in Texas, Indiana, New York, North Carolina, Oregon, and Washington.

…Where have we seen those list of states before?!?

Already, without even looking, I can already see based on where the lawsuits are filed that this is yet one more “common troll” set of lawsuits masterminded by Carl Crowell and his RIGHTS ENFORCEMENT entity. I bet you if I looked up the RIGHTSENFORCEMENT.com website, I’d see the “Once Upon a Time in Venice” movie listed there. Let’s look. …Yup. Bottom right, LSD style.

venice-pi-subpoena-once-upon-a-time-in-venice-movie-lawsuit Venice PI

Personally, for a Once Upon a Time in Venice movie lawsuit, I would prefer something less noisy, but you’re not reading this for my aesthetic preferences.

Point being, we are dealing with Carl Crowell and his local counsel in the various states.  This means that we know not only what the lawsuits will look like (as far as which judge will allow what), but we know the plaintiff attorney who has sent the subpoenas, and their proclivities.  This means that we know which attorneys are squeamish in naming and serving defendants, which are comfortable taking the lawsuit straight into discovery, and which are “quick on the trigger,” (think, the train whistle blows before the train has left the station) meaning, which attorneys will get him or herself into trouble with a judge by not following the rules, and as a result, names and serves every John Doe Defendant.

This historical knowledge of who has done what is one reason to hire an attorney, but knowing which way to approach the lawsuit based on the proclivities of the attorney filing the lawsuit is another reason you hire an attorney.  In short, we all know that the options are FIGHT, NO-SETTLE REPRESENTATION, SETTLE (without describing each option, as I’ve done this before), and we all know that for a defendant who did not do the download, I recommend one set of options, and for someone who did do the download, I recommend another set of options.  Don’t be fooled — it’s not black and white. [SPEAK TO ME if you want my opinion on your particular case.]

Now for those who want to settle, we already have an idea of what Venice PI settlement amounts each attorney will likely ask for (their asking prices), and based on the other lawsuits filed by these attorney, we have a good idea of what settlement amounts Venice PI, LLC will accept, if you decided to settle in the first place.  Again, there is the no settlement representation, where you have me keep an open line of communication with the plaintiff attorney to demonstrate to him/her why you did not do the download, and there is also a “no settlement letter” which I write for innocent clients to stop the troll scheme cold.

In short, there is a lot of repeat here because this lawsuit contains a lot of repeat from what we’ve seen in the past with the ME2 Productions (Mechanic:Resurrection) movie lawsuits, the UN4 Productions (Undisputed 4) movie lawsuits, the Headhunter LLC (A Family Man) movie lawsuits, the WWE Studios (Eliminator) movie lawsuits, the Cook Productions (Mr. Church) movie lawsuits, etc.  Rinse, repeat, rinse repeat.

For those interested in learning more about the Venice PI LLC lawsuits, see the two links below:

Venice Pi (‘Once Upon a Time in Venice’) Movie Lawsuit Page,” written on 7/19/2017, and
All I know about the Venice Pi, LLC (‘Once Upon a Time in Venice’) Movie Lawsuits (FAQ),” written on 7/18/2017.

RECENT CASE HISTORY OF THE VENICE PI SUBPOENA CASES:

VENICE PI ISP subpoenas ordered in the Texas Southern District Court
Venice PI, LLC v. Does 1-16 (Case No. 4:17-cv-02203)

VENICE PI ISP subpoenas ordered in the various North Carolina District Courts

Venice PI subpoena cases in the North Carolina Eastern District Court:
Venice PI, LLC v. Does 1-12 (Case No. 5:17-cv-00337, Case No.5:17-cv-00333)
… v. Does 1-11 (Case No. 5:17-cv-00334)
… v. Doe 1 et al (Case No. 5:17-cv-00340, Case No. 5:17-cv-00339, Case No. 4:17-cv-00089)

Venice PI subpoena cases in the North Carolina Middle District Court:
… v. DOES 1-11 (Case No. 1:17-cv-00611)
… v. DOES 1-18 (Case No. 1:17-cv-00610)

Venice PI subpoena cases in the North Carolina Western District Court:
… v. Does 1-10 (Case No. 3:17-cv-00409, Case No. 1:17-cv-00170)

VENICE PI ISP subpoena ordered in the New York District Courts
Venice PI, LLC v. Doe et al (Case No. 1:17-cv-04076, 1:17-cv-04249, 1:17-cv-04904)

VENICE PI ISP subpoenas ordered in the Oregon District Court
… v. Doe-73.96.114.240 (Case No. 3:17-cv-01002)
… v. Doe-71.59.242.118 (Case No. 3:17-cv-01001)

VENICE PI ISP subpoenas ordered in the Indiana Northern & Southern District Courts
… v. Doe 1 et al (Case No. 2:17-cv-00284, Case No. 2:17-cv-00285, Case No. 1:17-cv-02274, Case No. 1:17-cv-02328)

VENICE PI ISP subpoenas ordered in the Colorado District Court
… v. Doe 1 et al (Case No. 1:17-cv-01664)

VENICE PI ISP subpoenas ordered in the Hawaii District Court
… v. Doe 1; et al. (Case No. 1:17-cv-00335)

VENICE PI ISP subpoenas ordered in the Washington Western District Court
Venice PI LLC v. Doe 1 et al (Case No. 2:17-cv-01076, Case No. 2:17-cv-01075, Case No. 2:17-cv-01074, Case No. 2:17-cv-00988, Case No. 2:17-cv-00990, Case No. 2:17-cv-00991)

[CONTACT AN ATTORNEY: If you have a question for an attorney about the Venice PI subpoena-based cases and options on how to proceed (even specifically for your case), you can e-mail us at info[at]cashmanlawfirm.com, you can set up a free and confidential phone consultation to speak to us about your Venice PI subpoena, or you can call us at 713-364-3476 (this is our Cashman Law Firm, PLLC’s number].

 

RIGHTSENFORCEMENT – New Movie Titles (July 2017 Update)

RIGHTS ENFORCEMENT still obtaining new movie company copyrights to “enforce.”

Yesterday, while researching the new Headhunter, LLC North Carolina bittorrent-based copyright infringement cases, I checked back on Carl Crowell’s  RIGHTSENFORCEMENT.com website to look to see whether “A Family Man (2016)” belonged to Crowell’s “common troll” entity, and I was surprised to see that  a whole slew of new movies are now listed on their “client” list.

To learn more about RIGHTS ENFORCEMENT and everything I know about them to date, click here.

New RIGHTSENFORCEMENT.com Movies

NOTE: The last time I wrote about RIGHTS ENFORCEMENT and Carl Crowell’s new production company clients was in the “RIGHTSENFORCEMENT, New Movie Lawsuits” Article, written on 4/28/2017.

Here is a list of the new movies I’ve “spied” on their website:

july-rightsenforcement-new-movie-copyright-trolls-1

  • This Beautiful Fantastic
  • Black Butterfly
  • Rupture
  • In Dubious Battle
  • HopeLost
  • Beyond the Sun
  • Arctic Justice (Thunder Squad)
  • All Road Lead to Rome

july-rightsenforcement-new-movie-copyright-trolls-2

july-rightsenforcement-new-movie-copyright-trolls-3

july-rightsenforcement-new-movie-copyright-trolls-4

  • Playing it Cool
  • The Company You Keep
  • The Destination
  • Secret Scripture
  • Once Upon a Time in Venice,

…AND OTHER MOVIE TITLES I HAVE ALREADY WRITTEN ABOUT.

What does this mean to an internet user who has downloaded or streamed this movie using bittorrent, Popcorntime, and/or some other “free” streaming service?

What this means is that they are hard at work contacting production companies / copyright holders for newer movies (a.k.a., “floppers) which have not done so well in the theaters.  They convince these companies to license the rights to “enforce” that movie company’s copyrights (think, sue in a “copyright troll” lawsuit looking for settlements).  Then they have their local counsel file “John Doe” lawsuits in select federal courts (where the judges are friendly to them, or where the lawsuits are otherwise profitable).

What will happen to me if I have been caught downloading one of these films?

Honestly, at the moment, likely nothing, at least not yet.  There are two ways that Carl Crowell and his team of local attorneys across the US have been enforcing their client’s copyrights.

  1. By sending a DMCA notice directly to the accused downloader through the ISP.  Here, the DMCA notice directs the accused downloader to visit the Rightsenforcement.com website, and pay a settlement for each title allegedly downloaded or streamed using bittorrent, Popcorntime, and (yes, I have heard about this too, but I do not yet understand the mechanics of it), KODI on an Amazon Fire TV Stick.
  2. By filing a copyright infringement lawsuit for $150,000 statutory damages against a set of “John Doe” defendants who were each accused of uploading and/or downloading a particular movie using bittorrent (or an app like Popcorntime which still uses bittorrent to stream movies to its users).

What is the relevance that this list of movies is changing?

The fact that the list of movies is changing means that there are now new copyright holder production companies who have “signed on” to the business model of copyright trolling.  Politics and policy aside, this means that the copyrights on these movies (and the infringement, or the illegal downloading, uploading, duplication, and/or streaming of these movies without a license) will be the subject of future lawsuits.

If you look lower down on the RIGHTSENFORCEMENT.COM client list, you will see titles such as “Dallas Buyers Club,” “Mr. Church,” “The Cobbler,” “Cell,” “Fathers and Daughters,” “I.T.,” “Mechanic: Resurrection,” “Septembers of Shiraz,” “Survivor,” “Automata,” “London Has Fallen,” “Criminal,” “Eliminators,” and more recently, “Undisputed 4,” and “A Family Man.”  Each of these movies have been (and continue to be) the subjects of copyright infringement lawsuits across the federal courts in the U.S.

Expect these new movies to be subjects of coming lawsuits as well.

North Carolina Headhunter Subpoenas Are Due On 8/5.

North Carolina Headhunter Subpoena-based Cases

In June, 2017, our Cashman Law Firm, PLLC had its first glimpse of the North Carolina Headhunter, LLC subpoenas.  Seeing their connection to Carl Crowell’s RIGHTS ENFORCEMENT company, we immediately created a Headhunter Productions FAQ page which addressed the NC Headhunter subpoenas.  The ‘copyright troll’ attorney who filed the NC Headhunter cases is Kathleen Lynch (“Kathleen Maher Lynch”), of Lynch Van Sickle, PLLC in Cary, North Carolina.  If this is the first time you are seeing her law firm’s name and you do not recognize a copyright troll, you are not looking carefully.

Now the name “Kathleen Lynch” might not mean anything to you yet, but if you look at her “Lynch Van Sickle, PLLC” law firm, this might jog your memory of R. Matthew Van Sickle (a.k.a. Ross Matthew Van Sickle) of the I.T. Productions North Carolina lawsuits.  The new law firm name is slightly different (Van Sickle Law, PC [then] vs. Lynch Van Sickle, PLLC [now]), but the ugly troll rears his head.  In other words, looking at Van Sickle’s involvement in this new copyright troll, we must suspect that we are dealing with a RIGHTS ENFORCEMENT copyright troll, and… [checking Carl Crowell’s RightsEnforcement website] vwallah!

A Family Man, Headhunter, LLC ISP subpoena lawsuit | Notice of Subpoena For Records

NC Headhunter Subpoena Cases – This is Wave 1 (July, 2017)

Even though the Headhunter, LLC copyright troll is new and pink, we already understand the strategies of the common troll entity behind the scenes.  Understanding that Matt Van Sickle is Kathleen Lynch’s partner in these lawsuits, now we have an idea of how these cases will unfold because we know the proclivities of the copyright troll lawyers behind the scenes.

We are suggesting that those accused of being a John Doe Defendant in any of the NC Headhunter cases to read the Headhunter Productions Subpoena FAQ, which we posted on our law firm’s website.

[CONTACT AN ATTORNEY: If you have a question for an attorney about the Headhunter, LLC cases and options on how to proceed (even specifically for your case), you can e-mail us at info[at]cashmanlawfirm.com, you canset up a free and confidential phone consultation to speak to us about your Headhunter, LLC case, or you can call us at 713-364-3476 (this is our Cashman Law Firm, PLLC’s number].

Why do we believe a common troll entity is behind the new Headhunter, LLC cases?

[RECAP: Seeing Matt Van Sickle’s name, I immediately realized that we were likely dealing with a common troll entity.  It took 5 seconds to visit Carl Crowell’s RightsEnforcement.com website and see that the “A Family Man” movie was explicitly listed as one of their clients.  This confirmed my suspicion that we were dealing with yet one more common troll entity set of lawsuits.]

I understand that a common troll entity licenses the rights from movie production companies to “enforce” the copyrights for that company.  Here, they approached the production company who filmed and copyrighted the “A Family Man (2016)” movie, and they licensed the rights to enforce (think, sue) the copyrights owned by this production company.  Hence the Headhunter settlement extortion scheme lawsuits were born.

Where are we in the timeline of the Headhunter, LLC cases?

The first wave of Headhunter, LLC cases were filed in June, 2017.  North Carolina federal judges appear to have rubber-stamped these new lawsuits, just as they have done with past bittorrent-based copyright infringement cases.

Headhunter attorney Kathleen Maher Lynch (armed with orders from the NC federal judges) sent subpoenas to AT&T U-verse subscribers, and AT&T subpoena notices (called “Notice of Subpoena for Records”) were sent to the ISP’s subscribers who were implicated in the NC Headhunter lawsuits.  These subpoena notices were all sent by AT&T’s “GLOBAL LEGAL DEMAND CENTER.”

NEXT: NC HEADHUNTER, LLC SUBPOENAS DUE ON AUGUST 5TH, 2017.

*The first wave of NC Headhunter, LLC subpoenas ALL appear to be DUE IN AUGUST, 8/5.*

This means that unless an accused defendant wishes to file a motion to quash the subpoena, AT&T is under a duty to hand over the names of the subscribers accused of being John Doe Defendants in these North Carolina Headhunter, LLC cases.

However, it must be noted that the 8/5 deadline is merely the deadline that AT&T U-verse has given their subscribers.  Chances are that they will provide the names of the subscribers implicated in the North Carolina Headhunter, LLC subpoenas at some future date (as listed on the subpoena itself).

To see the actual deadline by when your AT&T U-verse ISP must hand out your information to the NC Headhunter, LLC attorney, check the subpoena itself included in the packet you received from your ISP.

[CONTACT AN ATTORNEY: If you have a question for an attorney about the Headhunter, LLC cases and options on how to proceed (even specifically for your case), you can e-mail us at info[at]cashmanlawfirm.com, you canset up a free and confidential phone consultation to speak to us about your Headhunter, LLC case, or you can call us at 713-364-3476 (this is our Cashman Law Firm, PLLC’s number].

RESOURCES:

EVERYTHING YOU NEED TO KNOW IN ONE PAGE ABOUT YOUR HEADHUNTER, LLC “A FAMILY MAN” LAWSUIT AND ISP SUBPOENA (FAQ).

What are your options in defending or resolving claims in a Headhunter, LLC North Carolina-based case?

If you have read this far, you are likely one of the John Doe Defendants in this case, and thus here are your options on how our Cashman Law Firm, PLLC (or any other competent copyright litigation attorney) can help you in this case.

OPTION 1: FIGHT

In this option, your attorney would fight this case on your behalf. Since the Headhunter, LLC scam has been exposed through the past lawsuits of their parent entities, the inherent weaknesses in Kathleen Lynch’s case are now well known. This option is more expensive than the other options, but it is probably the most satisfying option when you win and ask for attorney fees from Headhunter, LLC.

OPTION 2: SETTLEMENT NEGOTIATIONS

Settlement negotiations does not mean that you downloaded the movie or that you are guilty of copyright infringement. Rather, it simply means that you want to pay to have the plaintiff attorney dismiss you from the lawsuit. This option can be used by both ‘guilty’ and ‘innocent’ defendants. While I do not recommend an innocent defendant pay ANYTHING to settle the claims against him, I do not judge defendants when they choose this option.

OPTION 3: “NO SETTLEMENT REPRESENTATION”

This is the discounted “no settlement” representation route that I discussed here. In the span of 2-3 hours, I would consult with the client, send over a letter of representation to the plaintiff attorney (to stop him from contacting the client directly). I would then draft a letter to the plaintiff explaining that my client did not do the download, and that we are not interested in anything other than a walkaway settlement, meaning that my client pays no settlement. The purpose of this representation is to put Kathleen Lynch on notice that my client is not the infringer she is looking for.

OPTION 4: “IGNORE” ROUTE REPRESENTATION

The ignore route is best described as ‘playing chicken.’ I best described the “ignore” route, and how it differs from the “no settlement representation” route here. The assumption with the “ignore” route is that Kathleen Maher Lynch is not yet naming and serving defendants in this case, so you would hire our Cashman Law Firm, PLLC to monitor the case for you. We would send over a letter of representation indicating that we are representing you in the case, but we would not engage in settlement negotiations.

The intended client for the ‘ignore’ route is the innocent client that wishes to have a more ‘hands on’ engagement with their case over the “no settlement” representation letter route, where their attorney is actively monitoring the case and having active discussions with the plaintiff attorney. Both ‘guilty’ and ‘non-guilty’ defendants can utilize the “ignore” route, as this option is adjustable based on the circumstances of the client. If Kathleen Lynch decides to start naming and serving defendants, a ‘guilty’ client would likely have me open up settlement negotiations on his behalf, whereas a non-guilty client would instruct me to not settle and adhere to the ‘ignore’ strategy. Obviously getting named and served while in this strategy would be cause to decide whether to shift strategies to the “fight” or “settle” strategy, which is fine.

OPTION 5: ARGUE “MINIMUM STATUTORY DAMAGES” REPRESENTATION

I discussed the “argue minimum statutory damages” representation option in this article. The purpose of this option is to take the settlement negotiations away from a misbehaving plaintiff attorney. Instead of negotiating a settlement (where the plaintiff is asking for too much money), we would file an answer with the court admitting infringement, and we would then make the case for the judge to award minimum statutory damages of $750.

The intended client for the “minimum statutory damages” representation route is a client who did the download and either does not want to go through settlement negotiations, or who wants to take settlement negotiations out of the hands of the plaintiff attorney / copyright troll and leave the damages up to the judge to decide. Obviously since we are admitting guilt in this option, it is appropriate for the client to have done the download to use this strategy.

However you decide to proceed, if I can be of assistance or answer any questions about your Headhunter, LLC North Carolina case, please let me know.

[CONTACT AN ATTORNEY: If you have a question for an attorney about the Headhunter, LLC cases and options on how to proceed (even specifically for your case), you can e-mail us at info[at]cashmanlawfirm.com, you canset up a free and confidential phone consultation to speak to us about your Headhunter, LLC case, or you can call us at 713-364-3476 (this is our Cashman Law Firm, PLLC’s number].

LIST OF RECENT NORTH CAROLINA HEADHUNTER, LLC AT&T SUBPOENA LAWSUITS

Below is the list of NC Headhunter lawsuits filed between 6/16-6/30:

Filed within the North Carolina Eastern District Court:
Headhunter, LLC v. Does 1-9 (Case No. 5:17-cv-00310)
Headhunter, LLC v. Does 1-10 (Case No. 2:17-cv-00029)
Headhunter, LLC v. Doe 1 et al (Case No. 5:17-cv-00318)
Headhunter, LLC v. Does 1-9 (Case No. 5:17-cv-00296)
Headhunter, LLC v. Does 1-11 (Case No. 5:17-cv-00325)

Filed within the North Carolina Middle District Court:
HEADHUNTER, LLC v. DOES 1-8 (Case No. 1:17-cv-00545)

Filed within the North Carolina Western District Court:
Headhunter, LLC v. Does (Case No. 3:17-cv-00342)

WHERE ELSE IS HEADHUNTER, LLC FILING THEIR LAWSUITS (OUTSIDE OF N.C.)?

NY:
Headhunter LLC v. Doe-69.124.0.132 et al (Case No. 1:17-cv-04155)
Headhunter LLC v. Doe-173.56.227.169 et al (Case No. 1:17-cv-05314)

OR:
Headhunter, LLC v Doe-71.236.186.17 (Case No. 3:17-cv-00901)
Headhunter, LLC v. Doe-50.53.158.186 (Case No. 3:17-cv-00900)

PA:
HEADHUNTER, LLC v. JOHN DOES 1-11 (Case No. 2:17-cv-02986)
HEADHUNTER, LLC v. JOHN DOES 1-10 (Case No. 2:17-cv-02985)

VA:
Headhunter, LLC v. Doe-73.191.98.246 (Case No. 1:17-cv-00793), and

WA:
Headhunter, LLC v. Doe 1 et al (Case No. 2:17-cv-00987)

[CONTACT AN ATTORNEY: If you have a question for an attorney about the Headhunter, LLC cases and options on how to proceed (even specifically for your case), you can e-mail us at info[at]cashmanlawfirm.com, you canset up a free and confidential phone consultation to speak to us about your Headhunter, LLC case, or you can call us at 713-364-3476 (this is our Cashman Law Firm, PLLC’s number].

CONTACT FORM: If you have a question or comment and you want to keep it *for my eyes only*, please feel free to use the form below. The information you post will be e-mailed to me, and I will be happy to respond.

NOTE: No attorney client relationship is established by sending this form, and while the attorney-client privilege (which keeps everything that you share confidential and private) attaches immediately when you contact me, I do not become your attorney until we sign a contract together.  That being said, please do not state anything “incriminating” about your case when using this form, or more practically, in any e-mail.

Utah ME2 subpoenas are coming due again (7/14).

Utah ME2 Subpoena-based Cases

In March, 2017, our Cashman Law Firm, PLLC had its first interactions with the Utah ME2 subpoenas.  We created a ME2 Productions FAQ page which addressed the UT ME2 subpoenas.  The ‘copyright troll’ attorney who filed the UT ME2 cases is Todd Zenger (“Todd E. Zenger”), and he works for Kirton McConkie in Salt Lake City, Utah. Any e-mails coming from [email protected],” or calls from his “801-328-3600” phone number (or any 801-328-XXXX phone number should cause you to be wary that you have a UT ME2 copyright troll trying to scare you into settling with him for thousands of dollars.

UT ME2 Productions | Utah ME2 subpoena lawsuits
Screenshot from Carl Crowell’s RIGHTSENFORCEMENT.com website, with Mechanic:Resurrection outlined.

UT ME2 Subpoena Cases – Wave 1 (March, 2017)

We wrote about our first impressions of Todd Zenger and the Utah ME2 cases here:

UTAH ME2 SUBPOENAS FROM CENTURYLINK ARE COMING DUE,” written on April 24th, 2017.

We also directed those accused of being a John Doe Defendant in any of the UT ME2 cases to read the ME2 Productions Subpoena FAQ, which we posted on our law firm’s website.

UT ME2 Subpoena Cases – Wave 2 (July, 2017)

The second wave of cases are now upon us.  All filed in June, 2017, Todd Zenger followed the instructions of the common troll entity (which I understand licenses the rights from movie production companies to “enforce” the copyrights for that company), and filed the second wave of lawsuits in June, 2017.  Utah federal judges rubber-stamped these new lawsuits, just as they did the first set of them.

Todd Zenger sent subpoenas to CenturyLink subscribers (just as he did with the first wave of cases), and CenturyLink subpoena notices were sent to the ISP’s subscribers who were implicated in the UT ME2 lawsuits.

UT ME2 SUBPOENAS DUE TOMORROW

*These second wave of UT ME2 subpoenas ALL appear to be DUE TOMORROW, 7/14.*

This means that unless an accused defendant wishes to file a motion to quash the subpoena, CenturyLink is under a duty to hand over the names of the subscribers accused of being John Doe Defendants in these Utah ME2 cases.

However, it must be noted that the 7/14 deadline is merely the deadline that CenturyLink has given their subscribers.  Chances are that they will provide the names of the subscribers implicated in the Utah ME2 subpoenas at some future date (as listed on the subpoena itself).

To see the actual deadline by when your CenturyLink ISP must hand out your information to the UT ME2 attorney, check the subpoena itself included in the packet you received from your ISP.

RESOURCES:

EVERYTHING YOU NEED TO KNOW IN ONE PAGE ABOUT YOUR ME2 PRODUCTIONS, INC. “MECHANIC:RESURRECTION” LAWSUIT AND ISP SUBPOENA (FAQ).

ME2 UTAH SUBPOENAS FROM CENTURYLINK ARE COMING DUE,” written on April 24th, 2017.

What are your options in defending or resolving claims in a ME2 Utah-based case?

If you have read this far, you are likely one of the John Doe Defendants in this case, and thus here are your options on how our Cashman Law Firm, PLLC (or any other competent copyright litigation attorney) can help you in this case.

OPTION 1: FIGHT

In this option, your attorney would fight this case on your behalf. Since the ME2 scam has been exposed, the inherent weaknesses in Todd Zenger’s case are now well known. This option is more expensive than the other options, but it is probably the most satisfying option when you win and ask for attorney fees from ME2 Productions.

OPTION 2: SETTLEMENT NEGOTIATIONS

Settlement negotiations does not mean that you downloaded the movie or that you are guilty of copyright infringement. Rather, it simply means that you want to pay to have the plaintiff attorney dismiss you from the lawsuit. This option can be used by both ‘guilty’ and ‘innocent’ defendants. While I do not recommend an innocent defendant pay ANYTHING to settle the claims against him, I do not judge defendants when they choose this option.

OPTION 3: “NO SETTLEMENT REPRESENTATION”

This is the discounted “no settlement” representation route that I discussed here. In the span of 2-3 hours, I would consult with the client, send over a letter of representation to the plaintiff attorney (to stop him from contacting the client directly). I would then draft a letter to the plaintiff explaining that my client did not do the download, and that we are not interested in anything other than a walkaway settlement, meaning that my client pays no settlement. The purpose of this representation is to put Todd Zenger on notice that my client is not the infringer he is looking for.

OPTION 4: “IGNORE” ROUTE REPRESENTATION

The ignore route is best described as ‘playing chicken.’ I best described the “ignore” route, and how it differs from the “no settlement representation” route here. The assumption with the “ignore” route is that Todd Zenger is not yet naming and serving defendants in this case, so you would hire our Cashman Law Firm, PLLC to monitor the case for you. We would send over a letter of representation indicating that we are representing you in the case, but we would not engage in settlement negotiations.

The intended client for the ‘ignore’ route is the innocent client that wishes to have a more ‘hands on’ engagement with their case over the “no settlement” representation letter route, where their attorney is actively monitoring the case and having active discussions with the plaintiff attorney. Both ‘guilty’ and ‘non-guilty’ defendants can utilize the “ignore” route, as this option is adjustable based on the circumstances of the client. If Todd Zenger decides to start naming and serving defendants, a ‘guilty’ client would likely have me open up settlement negotiations on his behalf, whereas a non-guilty client would instruct me to not settle and adhere to the ‘ignore’ strategy. Obviously getting named and served while in this strategy would be cause to decide whether to shift strategies to the “fight” or “settle” strategy, which is fine.

OPTION 5: ARGUE “MINIMUM STATUTORY DAMAGES” REPRESENTATION

I discussed the “argue minimum statutory damages” representation option last night in this article. The purpose of this option is to take the settlement negotiations away from a misbehaving plaintiff attorney. Instead of negotiating a settlement (where the plaintiff is asking for too much money), we would file an answer with the court admitting infringement, and we would then make the case for the judge to award minimum statutory damages of $750.

The intended client for the “minimum statutory damages” representation route is a client who did the download and either does not want to go through settlement negotiations, or who wants to take settlement negotiations out of the hands of the plaintiff attorney / copyright troll and leave the damages up to the judge to decide. Obviously since we are admitting guilt in this option, it is appropriate for the client to have done the download to use this strategy.

However you decide to proceed, if I can be of assistance or answer any questions about your ME2 Utah case, please let me know.

LIST OF RECENT “WAVE 2” UTAH ME2 CENTURYLINK SUBPOENA LAWSUITS

Below is the list of UT ME2 lawsuits filed between 6/5-6/21:

ME2 Productions v. Does 1-25 (Case No. 2:17-cv-00526)
ME2 Productions v. Does 1-26 (Case No. 2:17-cv-00525)
ME2 Productions v. Does 1-24 (Case No. 2:17-cv-00523)
ME2 Productions v. Does 1-29 (Case No. 2:17-cv-00547)
ME2 Productions v. Does 1-27 (Case No. 2:17-cv-00576)
ME2 Productions v. Does 1-27 (Case No. 2:17-cv-00625)
ME2 Productions v. Does 1-36 (Case No. 2:17-cv-00624)
ME2 Productions v. Does 1-26 (Case No. 2:17-cv-00626)
ME2 Productions v. Does 1-24 (Case No. 2:17-cv-00662)
ME2 Productions v. Does 1-26 (Case No. 2:17-cv-00663)
ME2 Productions v. Does 1-24 (Case No. 2:17-cv-00664)


CONTACT FORM: If you have a question or comment about what I have written, and you want to keep it *for my eyes only*, please feel free to use the form below. The information you post will be e-mailed to me, and I will be happy to respond.

NOTE: No attorney client relationship is established by sending this form, and while the attorney-client privilege (which keeps everything that you share confidential and private) attaches immediately when you contact me, I do not become your attorney until we sign a contract together.  That being said, please do not state anything “incriminating” about your case when using this form, or more practically, in any e-mail.

Rightscorp settlement attorney considerations for a set of DMCA notices.

I was editing the “All I Know About Rightscorp in One Page” master article, and I got into a discussion about the awkwardness of hiring a Rightscorp settlement attorney because of the disproportionate fees paid to our Cashman Law Firm, PLLC to facilitate and handle the settlement versus the sometime miniscule actual settlement payment that ends up being paid to Rightscorp at $20-30/song downloaded.  Because that discussion took too much space on that article, I cut it and pasted it here.

Rightscorp vs. CEG-TEK Settlement Amounts

When representing a client in a CEG-TEK DMCA settlement demand notice, clients would come with 3-20 notices (and at $300/claim, the settlement asking price was $900-$6,000 before settlement negotiations).  Thus, representing a client and having the client pay our fees made sense.

Not necessarily so with a Rightscorp client who received those same 3-20 notices.  At $30/claim, the settlement asking price would be $90-$600 (before settlement negotiations).  Thus, depending on the number of notices, there could be a disproportionate payment to our law firm to handle what could be a mere $30 settlement payment. 

Why to hire a Rightscorp settlement attorney for even ONE (1) Rightscorp DMCA notice.

As a quick caveat, even for a Rightscorp client who received only one DMCA settlement demand letter (where there is no negotiation), the cost of representing a client is less than it would be for a CEG-TEK case because there is less time spent on the representation.  However, the potential client for this one (1) DMCA notice should be aware of the reasons why they are hiring our firm.

[DISCLAIMER: ***Just To Be Clear*** When I use the phrase “Rightscorp settlement attorney,” in no way do I imply that our law firm has any affiliation with Rightscorp, nor do we represent their interests in any capacity.  The term “Rightscorp settlement attorney” was simply a convenient way to put this article in front of someone who receives a Rightscorp DMCA settlement notice for songs downloaded via bittorrent, and they are trying various search engine keywords to learn which attorney can facilitate an anonymous settlement.  “Rightscorp settlement attorney” seemed to capture the essence of the audience we intended to write for, namely, internet users who want to settle claims of copyright infringement from the Rightscorp DMCA notices they received.]

Why you are not hiring an attorney:

First, benefits a client receives… but these are NOT why they are hiring our firm.  For a Rightscorp matter (e.g., one (1) DMCA notice), you are NOT hiring a Rightscorp settlement attorney to:

1) negotiate the settlement amount (paying an attorney sometimes to negotiate a $30 settlement to possibly $28 or $25 is silly);

2) to settle anonymously (technically, you do not need an attorney to accomplish this goal, as you can purchase a VPN subscription and pay your settlement using a credit card obtained without your name on it).

Why you ARE hiring an attorney (even for one (1) DMCA Notice):

Obviously when we can negotiate the settlement price, we do.  And, the settlement negotiations are negotiated anonymously, and are paid anonymously, meaning that Rightscorp will never learn your identity or that you settled the claims against you.  That way, they will never be able to contact your ISP to shut down your account claiming you are an infringer, and they will never be able to vindictively harm you after a settlement.  However, these are not the reasons you hired our law firm to handle the DMCA notice(s) you received from Rightscorp.

You ARE hiring a Rightscorp settlement attorney to facilitate and handle the settlement in a way that does not admit guilt on your behalf (when needed, we will negotiate the terms of the agreement to suit your circumstances). More importantly, we settle the claims against you in a way that puts Rightscorp, and their BMG Music, Sony Records, and the other music copyright holder clients ON NOTICE that the settlement we processed on your behalf was done by our Cashman Law Firm.

What is the benefit of putting everyone ON NOTICE that you are represented by an attorney?

Putting everyone ON NOTICE means that all future communications will need to come directly through our firm, and not to you.  Should these companies’ lawyers contact the you directly, this would be a breach of the ethics rules which could cost them their law licenses.

Preventing other “games” played against those who settle.

Most importantly, by having a Rightscorp settlement attorney such as myself to settle the Rightscorp claims on your behalf, this prevents any further “games” or activities that may occur (e.g., with asking for additional settlement money for other titles allegedly downloaded, robocalling, or contacting the ISPs to shut down the internet accounts of those who paid a settlement to Rightscorp).

Why $30/song is comparatively better than the alternatives.

In sum, representing a Rightscorp client still takes time, but the fact that the accused downloader is only paying a $30 settlement amount (or some miniscule dollar amount compared to the thousands of dollars which are paid in the movie lawsuits and DMCA settlement demand notices), this should be a happy fact.  Why happy?  Be happy that you were not sued, that you are not dealing with a CEG-TEK or RIGHTSENFORCEMENT ($300/movie title) scenario, and that you were merely caught downloading just a few songs, where the settlement amount will be $30/song.

UN4 Productions movie lawsuits spread with Boyka: Undisputed 4

UN4 Productions ISP Subpoenas sent

I don’t take pleasure in writing this, but there is a new copyright troll on the block named UN4 Productions, Inc. (a Millennium Films company). For the past two weeks, UN4 Productions ISP subpoenas have been going out to internet users informing them that they have been implicated as being a John Doe defendant in the UN4 Productions lawsuit (a.k.a. the Boyka: Undisputed 4 lawsuit). Each lawsuit claims copyright infringement damages of $150,000 for the illegal download or streaming of the Boyka: Undisputed 4 movie using bittorrent, or some other streaming device.

The name Boyka generally means “One Who Terrifies in Battle,” fitting for a gory fighting movie. Boyka: Undisputed 4 focuses on the story of Yuri Boyka, a mixed martial arts fighter.

Boyka: Undisputed 4 Video Trailer (click here)

Why the Boyka: Undisputed 4 ISP subpoenas mirror what we have seen

As soon as I looked into this new copyright troll, I realized that this is a “wolf in sheep’s clothing” copyright troll. The UN4 Productions ISP subpoena that you just received in the mail is coming from the same copyright enforcement entity (think Carl Crowell, or rightsenforcement.com) who just finished sending you bittorrent lawsuits for the ME2 Productions movie lawsuits, the Cook Productionsmovie lawsuits, the I.T. Productions movie lawsuits, LHF Productions movie lawsuits (think, London Has Fallen), and so many others.

Are the Boyka: Undisputed 4 movie lawsuits targeting a particular ethnic group??

The difference here with the Boyka: Undisputed 4 lawsuit is that this pirated movie has been dressed up as an ethnic movie (the previews I saw had arabic subtitles). Think, ME2 Productions, Inc. with no shirt, ripped bloody muscles, adrenaline-pumping punches all in line with the three previous Undisputed 4 movies [Undisputed (2002), Undisputed II: Last Man Standing (2006), and Undisputed III: Redemption (2010]).

UN4 Productions ISP subpoenas sent for the Boyka: Undisputed movie lawsuit
antfrank / Pixabay

“tracking an ethnic-based movie based on a specific nationality”

Again, just in case you did not get my innuendo. The twisted offense here with the Boyka: Undisputed 4 lawsuit is that the  UN4 Productions copyright trolls have developed a new way of catching people — by tracking an ethnic-based pirated movie based on a specific nationality.  They spread a fishnet, monitor the downloads, and vwallah!  They catch bittorrent downloaders with ethnic names. When that defendant claims “it isn’t me who did the download!” the plaintiff attorney just chuckles at Youssef, Oleksiy, Omar, or whichever ethnic name just happened to be the same ethnic group or nationality for whom the movie was made.

UN4 Productions ISP subpoenas sent for the Boyka: Undisputed movie lawsuit

How you can understand the Boyka: Undisputed 4 cases

First of all, at some point this evening, I will be writing a FAQ page so that you can understand what is going on with your Boyka: Undisputed 4 lawsuit.  I will be posting that link here.

To keep things simple, when you think of the UN4 Productions ISP subpoena you just received, or when you think about the Boyka: Undisputed 4 movie lawsuit, just think to yourself, “this is ME2 Productions in disguise. Same rules apply.” With the UN4 Productions lawsuit, the plaintiff attorney lawyers are exactly the same lawyers as with the ME2 Productions, Cook Productions, LHF Productions lawsuits we’ve been seeing for months now.

Thus, you must come to the logical conclusion that the Boyka: Undisputed 4 movie lawsuit is simply another Carl Crowell (RightsEnforcement.com) common troll lawsuit with the same attorney characters we have seen before. We can infer that behind the scenes, the common troll entity (with MPAA’s blessing) approached the real production company of the Boyka: Undisputed 4 movie, and offered to license the rights to monetize the copyright rights on behalf of the Boyka: Undisputed 4 copyright holder (this means, sue defendants, extort multi-thousand dollar settlements from each John Doe Defendant, name some, dismiss some).

How we at the Cashman Law Firm, PLLC understand the Boyka: Undisputed 4 cases.

In sum, because we know the copyright enforcement entity behind the scenes of this lawsuit (think, APMC, or Anti-Piracy Management Company), and because we know the proclivities of the plaintiff attorneys (who names and serves, who settles, etc.) coupled with the federal judges who are assigned the various cases in each federal district court, we can predict with some relative certainty what will happen in each case.

Whether that means filing a motion to quash an ISP subpoena, whether that means we will recommend that we defend your case, or whether we settle the claims against you or simply convince the plaintiff attorneys that it was not you who did the download (no settlement representation), there are a number of options we could take to represent our clients in these cases.

Here are the cases:

UN4 Productions ISP subpoenas ordered in the Colorado District Court
[Most cases assigned to Judge Wiley Y. Daniel]
UN4 Productions, Inc. v. Doe 1 et al (Case No. 1:17-cv-01419, Case No. 1:17-cv-01477, Case No. 1:17-cv-01577, Case No. 1:17-cv-01253, Case No. 1:17-cv-01299)

UN4 Productions ISP subpoena ordered in the Hawaii District Court
… v. Doe 1 (Case No. 1:17-cv-00282)

UN4 Productions ISP subpoenas ordered in the Illinois Northern District Court
UN4 PRODUCTIONS, INC. v. DOES 1-22 (Case No. 1:17-cv-04865)
… v. DOES 1-25 (Case No. 1:17-cv-04868)
… v. DOES 1-21 (Case No. 1:17-cv-04866)
… v. DOES 1-18 (Case No. 1:17-cv-04863)
… v. DOES 1-23 (Case No. 1:17-cv-04861)

UN4 Productions ISP subpoenas ordered in the Indiana Northern & Southern District Courts
UN4 Productions, Inc. v. Doe 1 et al (Case No. 3:17-cv-00473, Case No. 1:17-cv-00257, Case No. 1:17-cv-00228, Case No. 1:17-cv-02037, Case No. 1:17-cv-02070, Case No. 1:17-cv-01710)

UN4 Productions ISP subpoenas ordered in the New York Eastern & Southern District Courts
UN4 Productions, Inc. v. Doe-67.243.172.121 et al (Case No. 1:17-cv-03621)
… v. Doe-173.68.177.95 et al (Case No. 1:17-cv-03278)
… v. Doe-184.152.88.112 et al (Case No. 1:17-cv-04817)

UN4 Productions ISP subpoenas ordered in the North Carolina Eastern District Court
UN4 Productions, Inc v. Doe 1 et al (Case No. 5:17-cv-00278, Case No. 5:17-cv-00286, Case No. 5:17-cv-00317, Case No. 5:17-cv-00232, Case No. 7:17-cv-00109)
UN4 Productions, Inc v. John Doe 1-12 (Case No. 5:17-cv-00238)

UN4 Productions ISP subpoenas ordered in the North Carolina Middle District Court
… v. DOES 1-10 (Case No. 1:17-cv-00502)
… v. DOES 1-10 (Case No. 1:17-cv-00528)
… v. DOES 1-12 (Case No. 1:17-cv-00444)
… v. DOE 1, et al. (Case No. 1:17-cv-00453)

UN4 Productions ISP subpoenas ordered in the North Carolina Western District Court
… v. Does (Case No. 3:17-cv-00295, Case No. 3:17-cv-00297, Case No. 3:17-cv-00315, Case No. 3:17-cv-00329, Case No. 3:17-cv-00282, Case No. 3:17-cv-00284)

UN4 Productions ISP subpoenas ordered in the Ohio Northern & Southern District Courts
… v. Does (Case No. 3:17-cv-01190)
… v. Does 1-11 (Case No. 5:17-cv-01185)
… v. Does 1-12 (Case No. 1:17-cv-00388)
… v. Does 1-11 (Case No. 2:17-cv-00492)

UN4 Productions ISP subpoenas ordered in the Oregon District Court
… v. Doe-76.27.210.76 (Case No. 3:17-cv-00721)
… v. Doe-71.238.54.166 (Case No. 3:17-cv-00722)

UN4 Productions ISP subpoenas ordered in the Pennsylvania Eastern District Court
… v. JOHN DOES 1-9 (Case No. 2:17-cv-02481)
… v. JOHN DOES 1-15 (Case No. 2:17-cv-02768)

UN4 Productions ISP subpoenas ordered in the Texas Southern District Court
… v. Doe 1 et al (Case No. 4:17-cv-01685)
… v. Does 1-13 (Case No. 4:17-cv-01788)
… v. Does 1-13 (Case No. 4:17-cv-01834)

UN4 Productions ISP subpoenas ordered in the Washington Western District Court
[Most cases assigned to Judge Robert S. Lasnik]
… v. Doe 1 et al (Case No. 2:17-cv-00892, Case No. 2:17-cv-00786, Case No. 2:17-cv-00785)

Defense Against the Dark Arts of Copyright Trolling, and its effects.

WHY FIGHT?

The purpose of this post is not to educate, but to share an experience I went through over the weekend.  I spent some time reviewing the various cases where John Doe Defendants have fought back, and the results (even when the attorney did a good job defending the case) were not what I expected.  And then it occurred to me that the Defense Against the Dark Arts of Copyright Trolling unmasks a problem with the bittorrent-based copyright infringement lawsuits — namely, that they will never end.

Defense Against the Dark Arts of Copyright Trolling (“DADA”) = Good & Bad

Professor Sag’s Paper (Defense Against The Dark Arts of Copyright Trolling) was meant to expose the extortion scheme that is behind each of the bittorrent cases we fight every day, and in hindsight, it did a lot of good, but it also did some bad.

Good:

The good it did was that it exposed and confirmed the suspicion that the same players have been (and continue to be) behind each of the lawsuits filed across the US.  Whether it is RIGHTSENFORCEMENT.com (Carl Crowell), APMC, or any of the other names or corporate shell entities working together and using the same German companies (Guardaley) and their so-called “experts” is irrelevant.  The scheme is the same, and this group of individuals who are soliciting movie companies and having them license the rights to sue for copyright infringement is the same, and the list of production companies who are signing onto copyright trolling as an effective method of making money from copyrights is growing.

Bad:

The problem is that Sag’s Defense Against the Dark Arts of Copyright Trolling paper also emboldened the plaintiff attorneys, and it has inspired many of them to “legitimize” these kinds of lawsuits, almost as if “legitimization” is their new mission statement and credo.  Plaintiff attorneys I speak to all now speak about “changing the way so-and-so district court sees our kinds of lawsuits,” as if they have all been coached by the same individual or group working in unison to change how federal courts view copyright infringement lawsuits, in spite of their inherent weaknesses.

How the Defense Against the Dark Arts of Copyright Trolling paper affected the Cashman Law Firm, PLLC

Since Sag’s Defense Against the Dark Arts of Copyright Trolling paper has come out, our Cashman Law Firm, PLLC now offers the following services to accused defendants:

  1. Fight and defend in court
  2. Settle out of court
  3. Represent, but don’t settle (meaning, help the plaintiff attorney understand that my client did not do the download)
  4. “No Settlement” letter

FIGHT AND DEFEND IN COURT:

This is the romantic option.  Have your victory in court and expose these guys for the scheming scum they are.  Vindicate the client, show the world they should not have been selected to be named-and-served defendants in the first place.

SETTLE OUT OF COURT:

This is frowned on by everyone, except the defendant who decides that this is the cheapest option.  Our law firm settles cases too, and in many circumstances we have leverage when negotiating a settlement.  Contrast this with settlement factories (you know who you are), who scare defendants into settling even when they did not do the download.  These settlement factories appear to promise one set of settlements, get the client to pay their volume-based fee, and then hit the defendant with a higher settlement amount claiming it is the client’s fault the settlement was higher (when the ‘deal’ they had with plaintiff attorneys in the first place was this higher ‘premium’ amount they prearranged with the plaintiff attorney).  See here for details.

REPRESENT, BUT DON’T SETTLE:

This is the preferred option for the innocent defendant who did not do the download.  I have called this mode of representation many things over the years, but the point of it is 1) to keep the plaintiff attorney far away from the defendant, 2) to keep an open line of communication between the plaintiff attorney and the defendant, and 3) to monitor the case so that the innocent defendant does not need to worry about the various filings, hearings, and documents that are filed in their case.  The ultimate goal of this “ignore” option is to inform the plaintiff attorney that my client was not the one that did the download, and to help him/her understand this by providing documentation and an open line of communication.  Eventually, the plaintiff attorney will need to decide whether to dismiss my client or move forward against him/her, but this will be based on the evidence, not based on bullying, threats, or coercion.  And if that becomes the circumstances, our firm is prepared to defend the client in the courtroom.

“NO SETTLEMENT” LETTER (as suggested by the Defense Against the Dark Arts of Copyright Trolling paper):  

This is the “no settlement letter” option suggested by Matthew Sag’s paper.  In the Defense Against the Dark Arts of Copyright Trolling, Prof. Sag suggested that the threat to name-and-serve a defendant if they do not settle is a *bluff*.  Counter the plaintiff attorney’s accusation with a denial letter sent by an attorney indicating that no infringement occurred, and that the client will not entertain a settlement.  The total representation should take 2-3 hours at most, but there is no ongoing representation — meaning, our firm is not monitoring the case, we are not interacting with the plaintiff attorney (only minimally, if necessary to substantiate something we wrote in the letter), and we are not spending time additional time arguing with the plaintiff attorney, or going back and forth on the evidence, or arguing the merits of the case — something that can cause the cost of defending a client to skyrocket.  This, according to the paper should provide the innocent defendant enough legal protection to inform the plaintiff attorney that they did not do the download and that they will not settle.[Should the client wish to have a more complete representation, we offer the “REPRESENT, BUT DON’T SETTLE” option, and we offer it as a flat fee service.]

Defense Against the Dark Arts of Copyright Trolling and the various paths of representation.
geralt / Pixabay

Prof. Sag’s Defense Against the Dark Arts of Copyright Trolling paper gave us direction.

I would say that the main benefit derived from Sag’s Defense Against the Dark Arts of Copyright Trolling paper is that the issues surrounding the mass bittorrent cases filed across the US have been defined.  The “lines in the sand” have been drawn, so to speak.  The scheme of the copyright holders has been revealed (I have not discussed the scheme or its details in this article).

We now know that the copyright holders are trying to prove that “snapshot” infringement is copyright infringement, whereas we look to establish that the “substantial similarity” standard of copyright law must be adhered to.  They look to prove that an IP address implicates the account holder while we look to prove that the IP address does not implicate the account holder (just to name a few points).

Sag’s Defense Against the Dark Arts of Copyright Trolling paper has shed a clear light on what case law needs to be established in each of the federal districts across the US.  This will take work, and it will take a number of years before we generate a consensus of law in each federal district.

The Defense Against the Dark Arts of Copyright Trolling paper also gave the copyright trolls direction.

The problem is that when a fraud is exposed, those committing the fraud double-down and get emboldened to prove that their side is right.  The copyright holders have a clear advantage over the defense counsel, as they have hundreds of lawsuits where they spew the same lines in every court trying to sway the judges to their side of the argument.  And, it costs them almost nothing to get their argument before a court.  However, for an individual defendant who hires a law firm like mine, we can only represent the defendants who come to our firm and choose to have us fight the case on their behalf (rather than settle or choose one of the other less confrontational options).

It is no secret that it costs more to defend a case in the courtroom than it does to settle it.  As a result, there are significantly fewer attorneys on our defense side who have the ability to get their arguments in front of the judges.  Rather, we are tasked with doing what is in the “best interest of our client,” and that is often to take active steps to avoid the costs of litigation.  So while we protect our client (one at a time), we are not the heroes who are slaying the copyright troll dragon.  And, while our Cashman Law Firm, PLLC does our best to starve the copyright trolls by avoiding settlements whenever possible (“no settlement” representation), copyright trolls do not require a lot of food to continue growing like a cancer.

The Defense Against the Dark Arts of Copyright Trolling paper’s suggested solution: Attorney Fees

The Defense Against the Dark Arts of Copyright Trolling paper suggested that attorneys such as myself should take my case pro bono (meaning, for free) or at a reduced rate so that we can get our attorney fees from the copyright trolls (those filing the lawsuits) rather than from the client.  His logic was that copyright law (in theory) allows a defendant to recoup attorney fees he paid to his attorney from the other side if he is successful in his defense (or more specifically, when the prevailing party gets a judgement “on the merits” of the case).

The problem is that even if the attorney is successful in fighting the case, the copyright trolls will dismiss their lawsuit against the defendant before he is able to get a judgement “on the merits.”  In other words, they deprive the successful defendant from obtaining attorney fees by dismissing the defendant as soon as they realize he has a winning case.

Counterclaims as a strategy to “lock-in” a copyright troll (to prevent dismissals)

Several accomplished attorneys have filed counterclaims trying to “lock in” the plaintiff attorney / copyright troll into the lawsuit, so that if they try to dismiss the defendant from the lawsuit, the defendant can still proceed on his counterclaims and collect the attorney fees he paid to his attorney when they win the case.  However, as glorious as a strategy as this is — and I credit the attorneys who thought of this strategy (and I am willing to share their names here if they allow me to) — to my own dismay, I have seen this strategy in practice fall on its face in a number of places.

My weekend.

This was the subject of my weekend research — reviewing cases filed across the US where the defense attorney filed a counterclaim against the copyright holder, and watching to see the plaintiff attorney try to squirm out of the counterclaim.  In some places they are successful and in some places they are not.  However, this is the disheartening reality I saw over the weekend — regardless of whether the plaintiff attorney succeeded in “locking-in” the plaintiff with his or her counterclaim, the judge months later still forced the parties to attend a settlement conference, and days later, a stipulation of dismissal was filed with the court indicating that the parties settled out of court.

“After all those months of fighting!” I thought.  I couldn’t believe it, but I saw it with my own eyes.  So, as glorious as it is to fight the case, I still see the cases settling out of court months or years later because neither party is willing to take the case to trial because of the costs involved.

In short, seven years later, the bittorrent lawsuits are still a “game of chicken.”  [Two cars drive at each other head on and full speed, and the first car to swerve out of the way loses.]  The game is still the same.  We’ve just had each side drive the metaphorical “car” deeper into the lawsuits.  Now plaintiff attorneys name-and-serve defendants.  Now plaintiff attorneys force accused defendants into discovery (forcing them to answer questions under oath via interrogatories, depositions, etc.) before dismissing them.  However, in the “olden days,” defendants did not need to pay any attention to the lawsuits.  Now the louses have figured a way to force defendants “neck first” into the litigation, so they are going to spend their hard-earned money either defending themselves or settling.

Defense Against the Dark Arts of Copyright Trolling and "Playing Chicken."
Netsyscom / Pixabay

The Grim Reality — More lawsuits are coming.

In sum, the ‘bad’ that Matthew Sag’s Defense Against the Dark Arts of Copyright Trolling paper did is that it exposed a harsh reality — that unless people fight back, these cases will prevail like a cancer on the court system, and many thousands more will be sued.   He also exposed that although the plaintiff’s case is weak, changing the minds of the judges en masse can only happen if people call the bluff of the copyright trolls and fight them on the merits of the case and oppose being dismissed when they are dismissed from the lawsuit.

If we want to see these cases disappear, we still have to fight the cases.  We need to file answers with the courts, and we need to expose the weaknesses of the cases to the judges.  Eventually, the plaintiff attorney will need to drop Guardaley or improve their tracking capabilities to remove accidentally implicating non-guilty defendants as John Doe Defendants in these cases.  They will need to do a whole slew of things which I can outline in another article when I have the time.  Most importantly, however, the issues surrounding the cases will need to be hashed out *in* the courtroom.  The cases will never go away until this happens.

What I found out this weekend is that even those who fight back eventually settle.  Whether the settlement is “plaintiff takes nothing,” who knows, but the cases all settle.

FOR IMMEDIATE CONTACT AN ATTORNEY: To set up a free consultation to speak to an attorney about your lawsuit, click here.  Lastly, please feel free to e-mail me at info [AT] cashmanlawfirm.com, or call 713-364-3476 to speak to me now about your case (I do prefer you read the articles first), or to get your questions answered.

CONTACT FORM: Alternatively, sometimes people just like to contact me using one of these forms.  If you have a question or comment about what I have written, and you want to keep it *for my eyes only*, please feel free to use the form below. The information you post will be e-mailed to me, and I will be happy to respond.

NOTE: No attorney client relationship is established by sending this form, and while the attorney-client privilege (which keeps everything that you share confidential and private) attaches immediately when you contact me, I do not become your attorney until we sign a contract together.  That being said, please do not state anything “incriminating” about your case when using this form, or more practically, in any e-mail.

Malibu Media California cases ordered to reveal geolocation accuracy.

BIt is nice to see when a house of cards starts to shake.  It reminds me that with a gentle blow, all the cards can come tumbling down.  SJD shares that Malibu Media California Cases (X-Art) are about to experience some wind.

Kudos to Sophisticated Jane Doe at Fight Copyright Trolls for breaking this story.  Her article, entitled “Judge Alsup threatens to bar further Malibu Media cases in his district until the accuracy of the geolocation technology is fully vetted” is a worthwhile read. This is true EVEN for those who do not delve into the details of what happens in Malibu Media California cases versus Malibu Media Texas cases filed by Andrew Kumar and Michael Lowenberg.

California Judge Alsup Order Asks To Scrutinize Maxmind Geolocation Services.

Malibu Media, LLC has filed 6,000+ lawsuits across the US relying on a Maxmind geolocation database which they use to determine which infringers to sue (based on their city and/or zip code), and in which federal court to sue them.

The zip code data becomes relevant internally because Malibu Media targets accused defendants who live in ‘wealthy’ neighborhoods and ignores defendants who they believe do not have the ‘assets’ to pay them the ransom they demand from each accused downloader.

Taken from Maxmind’s site, they even offer services which provide their customers the estimated average income of each infringer so that Malibu Media can focus their efforts on only the ‘highest income infringers.’

Average Income (US Only)The weighted average income in US dollars per person for the zip code(s) associated with the IP address.

More relevant to the Malibu Media California cases and SJD’s article, geolocation data is important because filing a lawsuit against a defendant who does not live in that district deprives the court of jurisdiction to hear the case against that defendant.  This is called ‘personal jurisdiction.’

But, in the California Malibu Media Cases, this “Maxmind” service might cause the downfall of all of the Malibu Media California cases.  Why?  Because Judge Alsup is about to figure out exactly how the geolocation services work.

You could bet that if they fall in California, I will be sharing what made those cards fall with the judges in Texas, NJ, NY, (and since I follow Malibu plaintiff attorney Jackie James around with her Malibu Media cases), CT too.  Why?  Because California Judge Alsup’s rulings are binding only in the California federal courts.  However, in all other federal courts, they are still PERSUASIVE.

If I had one wish, it would be for Judge Alsup to also review the Guardaley Black Box.

Not to look a gifthorse in the mouth, but when I wrote this article initially, I thought that Judge Alsup was going to investigate Guardaley’s black box.  Here is why:

Malibu Media California Cases | Soon to fall like a House of Cards
wilhei / Pixabay

“Because we download fragments from you, you must have the entire file.”

The Guardaley bittorrent tracking system dips in to various bittorrent swarms and connects with computers to download tiny bittorrent file fragments with the logic that if the download from a particular internet user’s computer was successful, then [LOGIC JUMP] that user must have the entire file downloaded on his computer.

This identical black box issue applies to the other MOVIE LAWSUITS too.

It should be noted that without getting into conspiracy theories about how the MPAA / RIAA colluded with Malibu Media, LLC and the other pornography companies to break copyright, other mainstream movie cases potentially ‘have egg on their faces’ too with Judge Alsup’s order.

Why?  Because whether we are dealing with a Malibu Media, LLC case, a ME2 Productions case, a Cook Productions case, a I.T. Productions case, or even a WWE Studios Finance Corp. movie… you are still dealing with RIGHTSENFORCEMENT, Carl Crowell, Anti-Piracy Management Company (APMC), and ultimately… Guardaley, the German company behind each of the various US-based shell companies selling rights to use their black box bittorrent tracking software.

I could also bet that these same companies are likely using the same “Maxmind” geolocation services as well (since they cut-and-paste their boilerplate strategies, whether applying their system to internet users accused of downloading pornography, e-books, or movie content).

How much of the infringing file must you have for Malibu Media to prove copyright infringement?

If Judge Alsup continues to investigate Malibu Media’s cases beyond the Maxmind geolocation services, I encourage him to also investigate the Guardaley black box.

QUESTIONS TO ASK:  Judge Alsup might ask how the system chooses to connect to the computers, and whether it randomly selects one “block” (a file fragment; often 16 KB in size) hundreds of blocks, or millions of blocks (Malibu Media bittorrent files (“.torrent” files) usually comprise a siterip which contains multiple movie files contained in one bittorrent “.torrent” file.  Each movie file can be hundreds of MEGABYTES large, and the total bittorrent “.torrent” file can potentially be MULTIPLE GIGABYTES large).

Simplifying the numbers:  Assuming a .torrent file contains 1GB of movie files (1GB = 1,000 MB = 1,000,000 KB), and that 1GB torrent is broken down into 16 KB blocks (file fragments), then the Malibu Media X-Art Movie bittorrent will be broken down into 62,500 blocks.  If Malibu Media’s Guardaley black box shows that they have successfully downloaded 100 separate 16KB blocks, that means that they have established only that accused infringer has downloaded 1.6 MB of a 1 GB torrent file.  At 200 KB/s (not going into the minute differences between a Kilobyte and a Kilobit), that means that the downloader participated in the bittorrent swarm downloading Malibu Media’s Siterip content for a total of 8 seconds, and that they have only 1.6 MB of Malibu’s X-Art movie (1.6 MB of 1 GB = .0000016% of Malibu’s Siterip, hardly enough to prove that it was “more likely than not” that the accused John Doe Defendant committed copyright infringement.

If Malibu Media’s Guardaley black box is selecting and connecting to only a small number of blocks (a small set of file fragments, noting that there are potentially tens of thousands of blocks needed to complete a download) this does not prove that the accused defendant downloaded anything more than the number blocks the Guardaley black box software tracked the user as possessing on his or her computer.

Malibu Media California Cases and the “Preponderance of Evidence Standard”

Malibu Media, LLC will counter that the evidence they need to prove is “more likely than not,” namely, that it is more likely than not that the accused downloader downloaded enough of the infringing file to constitute copyright infringement.  This is also called the “preponderance of evidence” standard of proof in legal speak.  Thus, Malibu Media, LLC will not need to prove that the entire file was downloaded; only that ‘it was more likely than not’ that the file was downloaded.

However, for the Malibu Media California cases, I am hoping that the plaintiff attorney will need to prove to Judge Alsup that this is the case, and to do this, they will have to open their black box software up to Daubert-level scrutiny.  If they fail in this task, Malibu Media California cases will end and the next ‘wave’ of cases will need to be spread across other federal courts, sans California.  Looking into the geolocation technologies (which Malibu Media, LLC claims is 100% accurate), however, is a good start.

He just used the words…”HEARSAY.”

Of interest to me is something that Fight Copyright Troll’s article didn’t talk about — namely, that UNLESS THE MAXMIND GEOLOCATION SERVICES CAN BE VETTED, the printouts and data Maxmind purports to share about an accused John Doe Defendant’s location is nothing other than HEARSAY.  (See Judge Alsup’s Order, p.2, line 12).

The declaration parroted several hearsay statements about the accuracy of Maxmind from its website.

To the copyright troll attorneys who read my blog to learn what we are thinking about as far as strategy: While I am not making a big deal to flush out the hearsay issue, I just wanted to take a moment to point out that those same words just came out of Judge Alsup’s mouth.  Namely, that the so-called geolocation evidence that the Maxmind services provide might not even be admissible at trial because the it is considered HEARSAY, and likely not admissible under the hearsay exceptions.

Since these words came out of his mouth, I bet it is a good idea to have a good explanation prepared why the data provided by the Maxmind geolocation service should not be considered hearsay and thus inadmissible as you are trying to reach that “more likely than not” evidence standard.

Malibu Media Copyrights No Longer Filed, but X-Art is still FILMING?

Five days ago, I wrote an article noting that Malibu Media copyrights were no longer being filed.  I noted that from 2012-2015, Colette and Brigham Field, owners of X-Art (Malibu Media, LLC) filed over 100+ copyrights each year, and that to date they have filed over 6,000 copyright infringement lawsuits in federal courts across the US.  Because the number of copyright filings dropped off in 2016 (and now in 2017, there were ZERO copyright filings to date) I mistakenly assumed that Malibu Media was no longer filming porn videos.

This morning, I read an article by Breitbart author Warner Todd Huston that not only is X-Art still filming their porn videos, but that they did so from NBA star Chris Bosh’s 10,755-square-foot mansion in Pacific Palisades, California.  Pictures of Bosh’s 1.5 acre estate [now the backdrop of future X-art.com films] can be found here.

Malibu Media still filming X-Art porn videos, but are filing NO COPYRIGHTS.

The fact that valid Malibu Media copyrights exist has been the tactical keystone to justify the thousands of copyright infringement lawsuits they have filed over the years.  To date, Malibu Media holds 731 copyrights, each of which have been used or asserted against those who have downloaded their films using bittorrent.

Copyright.gov Malibu Media Copyrights

Malibu Media copyrights, just like every other action taken by Colette and Brigham Field are filed are maneuvers to maximize the profitability of their X-Art adult films (even to the point of complaining that the Bosh house was full of toxic mold and rat droppings in order to recoup a $92,000 security deposit):

…the mansion was unsafe and filled with toxic mold, roof leaks, rat droppings, plumbing problems, and slow internet connections. The couple is suing to get their $92,000 security deposit back.

What I do not understand is why they are not filing copyrights for these new films.  There must be a REASON — a tactical reason — whether it is to scheme, scam, or extort money from some family or some internet user who has stumbled upon their films.  Why to date are there ZERO copyright filings for their new movies?

Malibu Media Copyrights To Date (Filed 2009 – YTD 2017)

Here is a tally of the number of copyrights filed by Malibu Media to date:

  • In 2009, Malibu Media, LLC filed for only 2 copyrights.
  • In 2010, 15 copyrights.
  • In 2011, 61 copyrights.
  • In 2012 (when they first started suing), 129 copyrights.
  • In 2013, 177 copyrights.
  • In 2014, 189 copyrights.
  • In 2015, 112 copyrights.
  • In 2016, 46 copyrights.
  • In 2017, ZERO copyrights filed.

Malibu Media movies, and why it is important to know this list.

MALIBU MEDIA MOVIES

Malibu Media, LLC is the biggest filer of copyright lawsuits, possibly ever.  Since 2012, Malibu Media, LLC filed 6,000+ cases filed in federal district courts across the U.S. (and counting).  Their lawsuits sue for $150,000 in copyright infringement damages for the unlawful download of ONLY ONE MALIBU MEDIA MOVIE, but in their filing against the individual ISP account holder, they accused that subscriber of downloading tens, sometimes over 100 films. Malibu Media movies are no longer filmed (or, at a minimum, they are no longer filing copyrights for any new movies), but it appears as if 100% of their efforts is on tracking users who view those movies without authorization over the internet.

Malibu Media, LLC has been accused of not properly publishing their movies before suing defendants, and more often than not, internet users have reported that they were sued for downloading Malibu Media movies which were not yet posted on Malibu Media LLC’s X-Art.com website.  Curiously, Malibu Media movies first appear as “leaked” onto the bittorrent networks.  Recently, it has become a question as to whether Malibu Media, LLC is running what is called a ‘honeypot’, similar to what John Steele of Prenda Law Inc. was caught doing.

Malibu Media, LLC deceptively takes advantage of the three-month rule loophole as codified in 17 U.S.C. § 412  by suing for Malibu Media movies which were not copyrighted at the time the alleged downloads took place.  Thus, any internet user who took the time to visit the Copyright.Gov website to check on the status of Malibu Media movies before downloading them (a ‘careful’ infringer) often will not find the searched-for Malibu Media movie title, yet Malibu Media still claims copyright rights over that movie.

What makes Malibu Media, LLC especially dangerous?

I normally wouldn’t spend the time on an article like this, but what makes Malibu Media, LLC especially dangerous to a copyright infringement defendant is that unlike other copyright holders who file a lawsuit as soon as infringement is detected, Malibu Media, LLC waits.

Malibu Media, LLC does not immediately file the lawsuit once infringement is detected.  Rather, using technology akin to wiretapping, they will watch the IP address and network of their suspected infringer, and they will sit in the background like a virus and will log each and every movement, web page visited, and every movie watched (legally, illegally).

NOTE: Both I and Professor Sag have gone in depth about the lack of evidence Malibu Media, LLC has in their cases.  Like the other ‘common troll’ copyright trolls and those affiliated with Guardaley and their German shell company counterparts, the type of ‘evidence’ Malibu Media, LLC appears to log and produce is ‘snapshot’ evidence.  Snapshot evidence is proof that on a certain date and time, a computer having an IP addressed assigned to a defendant’s internet account was ‘in the room’ (in a bittorrent swarm).  However, this is not evidence that actual copyright infringement happened, or that they actually logged anything other than a snapshot.  Similarly, this “other evidence” they have when they track you 1) is likely inadmissible because it is illegal, and 2) if it is not wiretapping and it was obtained with legal means, it is likely prejudicial character evidence.  And even if it is not, 3) it is still likely hearsay.

Once Malibu Media’s German investigators have enough so-called ‘evidence’ on an alleged infringer, they will file a copyright infringement for one lawsuit, and as an attachment, they will list “other Malibu Media movies” they claimed were also downloaded, some logged months or even over a year before the lawsuit was filed.

I used the term ‘wiretapping’, which is illegal.  However, wiretapping is not the subject of this article.  The point to acknowledge is that Malibu is somehow tracking the activities of its selected targets, and once it has amassed enough incriminating data on that defendant, they file a lawsuit.

How do I know that Malibu is tracking their users?

The fact that Malibu Media, LLC is actually tracking the activities of their targeted users over a long period of time was not immediately clear to me.

In 2013, Malibu Media was listing “other downloaded movies and copyrighted titles” in their lawsuit filings.  Back in 2013, Malibu Media, LLC spent quite a bit of time trying to establish that their defendants were ‘serial’ infringers, and thus the judge should rule that any innocuous downloads should be considered ‘willful infringement’.  (‘Willful infringement’ carries statutory damages of $150,000, whereas ‘non-willful infringement’ can allow for minimum statutory damages of only $750).  Malibu’s goal at the time was to prove that since the defendant was a ‘serial infringer,’ meaning, since he downloaded all of these other titles, he must have downloaded their adult videos as well, as claimed in the lawsuit complaint.

The courts obviously did not like Malibu’s practice of including “other non-Malibu titles downloaded,” and they ruled that this evidence was prejudicial character evidence.  Since then, Malibu Media, LLC stopped including this extraneous data (although, this has not stopped other copyright attorneys from doing the same thing out of the court).

Thinking back, however, the question the attorney defending the case should have asked (it wasn’t my client’s case) was not only whether the so-called evidence of other downloaded movies is prejudicial character evidence, but whether Malibu Media, LLC broke federal and state wiretapping laws to acquire that information.

Just yesterday, I wrote that Malibu Media, LLC was on a three-month hiatus, and that based on their pattern of filing lawsuits, I did not expect new lawsuits to be filed until the summer.  However, for users watching and viewing Malibu Media movies, it occurred to me that they have already likely tagged you and are actively tracking your internet activities.  They will likely continue to do so until they file suit in their next round of lawsuits.

What can we do about it if Malibu is already tracking me?

Remember, Malibu Media only files lawsuits against defendants who have a history of viewing their copyrighted movies.  So if you were tagged, the best way to minimize your chances of being sued is to stop viewing Malibu Media movies.

However, as soon as you see the X-Art.com logo featured at the top of this page in Malibu Media movies’ intro clips, it is likely too late.  They have likely already tracked that, so unplugging the power from the wall won’t change the fact that they just monitored you downloading their adult film.  It is better to be aware of the sheer number of Malibu Media movies already copyrighted, and to be aware of which adult movie titles belong to Malibu Media, LLC.  Better yet, it is a good idea not to get tracked at all, but that is outside the scope of this article (and take those precautions at your own risk), especially since we do not yet understand how they are tracking your activities.

How can I look up the Malibu Media movies which have been copyrighted?

The Copyright.Gov page allows you to do a search.  You would search for “Malibu Media” in the “Name”.

When you do the search, you will see the following page snippet; click on “Malibu Media, LLC” (as of writing this article, they have 731 titles copyrighted).

Copyright.gov Malibu Media Search

How Many Malibu Media movies were filed each year?

This is not exactly relevant or useful (yet), but it is still interesting to note.

  • In 2009, Malibu Media, LLC filed for only 2 copyrights.
  • In 2010, 15 copyrights.
  • In 2011, 61 copyrights.
  • In 2012 (when they first started suing), 129 copyrights.
  • In 2013, 177 copyrights.
  • In 2014, 189 copyrights.
  • In 2015, 112 copyrights.
  • In 2016, 46 copyrights.
  • In 2017, ZERO copyrights filed.

Obviously, I can pull a lot of information from this data, namely that the number of Malibu Media movies filmed appears to follow the number of copyright infringement lawsuits filed for the sharing of these titles, as if they were filmed for the sole purpose of suing for the infringement of these titles.

I also want to note that at the peak of their lawsuits — 2013-2014, they filed a total of 366 full length adult videos.  That’s a lot of video taping (and a lot of something else) — almost one full length adult film churned out every other day.

Lastly, it is notable that in 2016 and 2017, the number of new Malibu Media movies dropped to 46 in 2016, and ZERO in 2017.  At this point, Malibu Media, LLC and X-Art.com are no longer in the adult film business.  Their activities appear to now comprise 100% copyright trolling.

Can I see the list of Malibu Media, LLC movie titles?

And last, but not least, the list of Malibu Media movies currently copyrighted (in ABC order).

MOVIE TITLE#DATE:
Above the Air.PA00019442002015
After Hours.PA00017804612011
Afternoon Picnic.PA00018269982013
Afternoon Snack.PA00018332672013
Afterthoughts.PA00019094792014
Alexis Lovely and Ready to Fuck.PA00019704602015
All About Anna.PA00018861952014
All I Want for Christmas.PA00019869762015
All Oiled Up.PA00018851872014
All Tied Up.PA00018660772013
Almost Famous.PA00018646872013
Alone in My Room.PA00018596632013
Alone is a Dream Left Behind.PA00018609842013
Amazing Grace.PA00018064772012
Among the Wildflowers.PA00019547942015
And Then There Was You.PA00018746152013
Angel Afternoon Delight.PA00017768352012
Angel Dust.PA00019442012015
Angel Journey to the East.PA00017694902011
Angel Seaside Romp.PA00017715282012
Angelica Means Angel.PA00019097822014
Angie VIP Lounge.PA00017717052011
Anneli Dream Girl.PA00017694892011
Anneli Leila Menage a Trois .PA00017716622012
Another Night.PA00018333592013
Any And All For You.PA00019086772014
Apartment in Madrid.PA00018269922013
Apartment Number Four.PA00018359542013
Apertif Our Style.PA00018745222013
Are You Man Enough.PA00019507612015
Arrest Me.PA00018719412013
Art of Anal Sex.PA00017768342011
Artiste.PA00020201802016
Aspirations.PA00018346692013
Aspirations.PA00018385942013
Asstastic.PA00020150882016
At Home With Tiffany.PA00018804962014
Au Paradis.PA00018958462014
Aurora Wants It All.PA00020252412016
Awakening.PA00018688062013
Awe Inspiring Orgy.PA00019177122014
Baby Blues.PA00018678872013
Back For More.PA00019284272014
Back to Bed.PA00018476562013
Backdoor Lover.PA00017859582011
Backstage.PA00017979432012
Bad Girls.PA00018476612013
Barely Fits.PA00019284122015
Be With Me.PA00019075742014
Beautiful Girl.PA00019097842014
Beautiful Place.PA00019954802016
Bedtime Hijinks.PA00019127762014
Being Me.PA00018025602012
Best Blondes.PA00018658162013
Best Friends With Benefits.PA00019351022015
Black and White.PA00018312262013
Black Lingerie Bliss.PA00018064682012
Black On White.PA00019094892014
Black Widow.PA00019871832015
Blindfold Me : 2.PA00018678902013
Blindfold Me and Tie Me Up.PA00018678882013
Blindfold Me Baby.PA00019029712014
Blonde Ambition.PA00017797962012
Blonde In My Bedroom.PA00018692472013
Blonde Perfection.PA00019260612014
Blonde Teenage Dream.PA00020252372016
Blondes Love Brunettes.PA00019373762015
Body Language.PA00018680962013
Bohemian Rhapsody.PA00018675842013
Bottoms Up.PA00018385962013
Bound By Desire.PA00019507602015
Brazilian Love Affair.PA00018950952014
Breakfast at Eves.PA00019094802014
Breakfast in Bed.PA00017872532012
Brilliant Jillian.PA00018826482014
Bring Me To My Knees.PA00019321062015
Bunny Love.PA00018431092013
Burning.PA00018609512013
By Myself.PA00018161672012
Cabin And My Wood.PA00019739972015
California Dreams.PA00017805642012
California Surf Fever.PA00019539532015
Call Me Fox.PA00019212912014
Cant Let Go.PA00019177132014
Caprice Makes Me Cum.PA00019740232015
Caprice Tropical Vibe.PA00017768022011
Capture Me.PA00019442022015
Caribbean Christmas.PA00019260932014
Carla Intimate.PA00017787672012
Carlie Beautiful Blowjob .PA00017620792010
Carlie beautiful blowjob & 9 other titles; motion pictures.V3621D3962012
Carlie Beautiful Blowjob / by Malibu Media, LLC.PA00013971912011
Carlie Big Toy Orgasm.PA00017768392010
Carlie Big Toy Orgasm / by Malibu Media, LLC.PA00013971922012
Carlie Leila Strawberries and Wine .PA00017620812010
Carlie Leila Strawberries and Wine / by Malibu Media, LLC.PA00013971902011
Carmen An Afternoon to Remember.PA00017759022012
Carmen Leila Christmas Vacation.PA00017717062011
Carmen Poolside Striptease.PA00017716722012
Carry Me Home.PA00019084522014
Cassie My Love.PA00018660532013
Casual Affair.PA00018004712012
Casual Sex.PA00018208572012
Cat Fight.PA00019160432014
Catching the Sun.PA00019507622015
Catching Up.PA00018893912014
Chloe Loves Carl Part 2.PA00019065612014
Christmas Story.PA00018745272013
Circles of Bliss.PA00018332972013
Classic Beauty.PA00018064732012
Clean and Wet.PA00018609552013
Close to the Edge.PA00018005792012
Cloudy Hot Day.PA00019187902014
Cock Teaser.PA00019953342016
Come Close.PA00019051402014
Come From Behind.PA00018632482013
Come Fuck With Me.PA00020149512016
Come Inside From the Cold.PA00018624842013
Come to Me.PA00017913502011
Come To Me Now.PA00018921812014
Come To My Window.PA00017995762012
Come Together Part #1.PA00019428402015
Come Together Part #2.PA00019428412015
Coming Late.PA00019042862014
Competition.PA00019321162015
Connie True Love.PA00017759032012
Constance Aaron X-Art on TV.PA00017717072011
Coucher Avec une Autre Fille.PA00018017152012
Creamy.PA00018746172014
Cristalina.PA00017939722011
Crush on Kush.PA00020149352016
Cum In Get Wet.PA00019239482014
Cum Inside the Fantasy Suite.PA00019420002015
Cum on the Floor.PA00019148182014
Cum With Me.PA00018177142012
Cum Worthy.PA00019364742015
Cut Once More Please.PA00019054912014
Czech Beauties.PA00018596542013
Czechmates.PA00020149322016
Daddy’s Office.PA00017768382010
Daddy’s Office / by Malibu Media, LLC.PA00013971842012
Dancing Romance.PA00019039152014
Dangerous Game.PA00018105052012
Dangerous When Wet.PA00019547932015
Dark Desires.PA00018596582013
Date Night at Home.PA00018646892013
Day to Remember.PA00018118502012
Daydream.PA00018104552012
Deep Awakening.PA00019493682015
Deep Blue Passion.PA00018851682014
Deep Down In Me.PA00019229552014
Deep In Love.PA00020150852016
Deep Inside Caprice.PA00017768372011
Deep Longing.PA00018257222013
Deepest Desires.PA00019351102015
Digital Love.PA00018630552013
Do It To Me One More Time.PA00019441982015
Do Me Darling.PA00019212972014
Do Not Keep Me Waiting Part #1.PA00019412832015
Do Not Keep Me Waiting Part #2.PA00019412842015
Domination.PA00019739992015
Domination Part 2.PA00019740012015
Dorm.PA00017804682011
Double Daydreams.PA00018692462013
Double Oh Heaven.PA00019187362014
Double Tease.PA00018921832014
Dream Come True.PA00018003562012
Dream of You.PA00019095162014
Dreams do Come True.PA00018519792013
Dressed to Thrill.PA00019739952015
Drinks For Two.PA00019055122014
Dripping Desires.PA00019187372014
Dripping Pleasures.PA00019412852015
Early Morning Orgasm.PA00019145362014
East Meets West.PA00019260882014
Elevated Erotica.PA00019095132014
Elle Hearts Girls.PA00018476522013
Emilie Is All Alone.PA00018899132014
Enchanting Real Orgasms.PA00018332952013
Enjoy My Backdoor.PA00019041492014
Enjoy the Ride.PA00019260862014
Epic Love.PA00018980912014
Erotic Encounter.PA00019657582015
Erotic Stretching and Sex.PA00018622932013
Evening at Home.PA00017825592012
Evening at Home Part 2.PA00017852042012
Everlasting Friendship.PA00018346202013
Everlasting Friendship.PA00018385952013
Every Guys Perfect Threesome.PA00020151132016
Every Mans Sexy Camping Trip.PA00019670792015
Exposed And Aroused.PA00019212932014
Falling For You.PA00018460972013
Fantasy Come True.PA00018746292013
Farewell.PA00018004732012
Fascination With My Body.PA00018851892014
Fashion Fantasy.PA00018851852014
Fashion Models.PA00018385992013
Fashion Models Are Bisexual.PA00019260852014
Faye Prelude to an Orgy.PA00017768362011
Featherlight.PA00018346182013
Feeling Frisky.PA00018806712014
Finding Elysium.PA00018147842012
Fine Fingerfucking.PA00020150982016
Fireside Fantasy.PA00019076072014
First and Forever.PA00018631122013
First Lesbian Experience.PA00019470932015
First Love.PA00018064762012
First Time.PA00019260922014
Flexible Beauty.PA00018118532012
Floating Emotions.PA00018871262014
Foot Fetish.PA00017939702012
For Your Eyes Only.PA00019094852014
Forever You Part #1.PA00019239652014
Forever You Part #2.PA00019239662014
Formidable Beauty.PA00018147852012
Four Play.PA00020149382016
Four-Way Fuckathon.PA00019785122015
Four Way In 4K.PA00019954992016
Four Ways.PA00019145322014
Foursome.PA00017804702011
Freckle Faced Fox.PA00019704542015
From Three to Four.PA00018980592014
From Three to Four Part 2.PA00019029702014
Fuck Me More.PA00019239572014
Fucking Ballerinas.PA00019284042015
Fucking Goddesses.PA00019160512014
Fucking Hot Threesome.PA00019577002015
Fucking Perfection.PA00017895072011
Fucking Picnic.PA00019704872015
Fun for Three.PA00019147312014
Get Wild At Home.PA00018774702014
Getting Down.PA00018386012013
Getting Our Pussies Wet For You.PA00019953322016
Getting Ready for Bed.PA00018806692014
Getting Ready For You.PA00018747442014
Gift From Colette.PA00018729692013
Gift From Vegas.PA00019740042015
Girl in a Room.PA00018609682013
Girl in My Shower.PA00017835492009
Girl in My Shower / by Malibu Media, LLC.PA00013971782012
Girl Like You.PA00018270062013
Girl’s Fantasy.PA00018192942012
Girls Just Want to Have Fun.PA00019470902015
Girls Love Pink and Diamonds.PA00018622902013
Girls Night.PA00017939712012
Girls Night Out.PA00017624092011
Girls Who Like Girls.PA00018526762013
Girly Girls.PA00018622842013
Give Me More.PA00019043112014
Give Me More Part 2.PA00019054792014
Go Down On Me.PA00019041312014
Go Fish.PA00018804692014
Going Strong.PA00018596602013
Good Morning Baby.PA00018476552013
Good Morning I Love You.PA00019412872015
Good Morning Melissa.PA00020201752016
Good Night Kiss.PA00018729702013
Good Vibrations.PA00018003592012
Grace Angelic.PA00018000222012
Green Eyes.PA00018430902013
Group Sex.PA00018921822014
Grow Up With Me.PA00018661852013
Happy Birthday Capri.PA00018460872013
Happy Couple.PA00017944612012
Happy Ending.PA00017804642011
Hayden Pink and Tight.PA00017768052011
Heart & Soul.PA00018153532012
Heaven Sent.PA00017881362012
Heavenly Brunettes.PA00017807662012
Her First Threesome.PA00017913492011
Her First Time.PA00018630462013
High School Dropouts.PA00018719342013
Highrise Rendezvous.PA00019082132014
Hippie Chic.PA00019461892015
Holiday in Spain.PA00017804662011
Horsing Around.PA00019955022016
Hot Bath for Two.PA00019147342014
Hot Brunettes.PA00018659572013
Hot Chocolate.PA00018596572013
Hot In Here.PA00019900012016
Hot Number.PA00018784562014
Hot Orgasm.PA00019039222014
Hot Sauna.PA00017804712011
Hot Summer Rain.PA00019239602014
Hot Winter Fox.PA00019740182015
House of the Rising Sun.PA00018064752012
I Am In the Mood.PA00018806722014
I Can Not Wait.PA00018774732014
I Know You Love Me.PA00019461902015
I Like Cherry Pie.PA00020252422016
I Love James Deen.PA00018609822013
I Love X-Art.PA00018332962013
I Touch Myself.PA00018460842013
I Want to Tell You.PA00018720822013
I Want You To Want Me.PA00019253352014
I Want You To Watch Me.PA00018921792014
I Will See You In The Morning.PA00018747462014
Ibiza Love.PA00018208552012
If Only It Were You.PA00017906562011
In Bed.PA00018118972012
In Bed With Me.PA00019351012015
In Charge.PA00018659562013
In For The Night.PA00018746702014
In Love with a Girl.PA00018660522013
In Love With Lexi.PA00018333182013
In Love With Little Caprice.PA00019749932015
In My Living Room.PA00018950882014
In the Blind.PA00019094872014
In The Dark.PA00019084512014
In the Garden of Ecstasy.PA00020149402016
In the Mirror.PA00019321182015
Infinite Luvv.PA00019586062015
Insanely Gorgeous.PA00018852052014
Inside Caprice.PA00019900042015
Inside Perfection.PA00018177562012
Inspiration.PA00018017142012
Instant Erotica.PA00019160582014
Intimate Experience.PA00018476572013
Introducing Angelica.PA00018182832012
Introducing Diana.PA00017895112012
Introducing Kaylee.PA00017836462012
Introducing Kennedy.PA00019657592015
Introducing Kenzie.PA00018622862013
Introducing Kiki.PA00018609652013
Introducing Maya.PA00019284292015
Introducing Mila.PA00018596522013
Introducing Veronika.PA00017768012012
Invisible.PA00018268602013
It Has Always Been You.PA00018784242014
It Is A Fine Line.PA00018804372014
Je Mappelle Belle.PA00019212942014
Jennifer Naughty Angel.PA00017768092010
Jennifer Naughty Angel / by Malibu Media, LLC.PA00013971852012
Jillian Multiple Orgasms.PA00020151162016
Journey.PA00018656032013
Jumping on the Bed.PA00018332982013
Just Jennifer.PA00019038422014
Just Married.PA00017804722011
Just Natalie.PA00019229532014
Just the Three of Us.PA00018806702014
Just the Two of Us.PA00017816722011
Just Watch.PA00018980922014
Just Watch Part 2.PA00019029642014
Kacey Jordan Does Xart.PA00019160652014
Kat Translucence.PA00017620732009
Kat Translucence / by Malibu Media, LLC.PA00013971762011
Katka Cum Like Crazy.PA00017620742010
Katka Cum Like Crazy / by Malibu Media, LLC.PA00013971892011
Katka Sweet Surprise.PA00017620752010
Katka Sweet Surprise / by Malibu Media, LLC.PA00013971882011
Keep Cumming Kylie.PA00019670822015
Keep on Cumming.PA00019419992015
Kitty Will Play.PA00020201832016
Knock On My Door.PA00018957632014
Kristen Girl Next Door.PA00017620762010
Kristen Girl Next Door / by Malibu Media, LLC.PA00013971872011
Kristin and Nine Unleashed.PA00020151072016
LA Love.PA00017904582010
LA Love / by Malibu Media LLC.PA00013980152010
LA Plans.PA00018692482013
Late for Work.PA00018333602013
Leila Faye Awesome Threesome.PA00017768042011
Leila Faye Awesome Threesome / by Malibu Media, LLC.PA00013971812012
Leila Last Night.PA00017759062012
Leila Naked in the Hot Sun.PA00017768032011
Leila Sex On The Beach.PA00017620832010
Leila Sex On The Beach / by Malibu Media, LLC.PA00013971832011
Let Me Join You.PA00019364752015
Let Me Take Your Picture.PA00018624862013
Life In The Fast Lane.PA00019733402015
Light My Fire.PA00019239612014
Like a Dove.PA00017904572012
Like the First Time.PA00017788442012
Like the Sun.PA00018659552013
Lily Ivy Like the First Time.PA00019869782015
Lipstick Lesbians.PA00018177552012
Lisa’s Hidden Cam.PA00019145342014
Lisas Playroom.PA00019470912015
Listen To Me Cum.PA00019082112014
Little China Girl.PA00019441992015
Little Lover.PA00017949762012
Little Play Thing.PA00019405972015
Little Rain Must Fall.PA00018226532013
Little Time For Myself.PA00018774742014
Lonesome Without You.PA00018871082014
Lost In My Own Moment.PA00018772532014
Love at First Sight.PA00018727562013
Love From USA.PA00019284302015
Love Story.PA00018192962012
Love With A View.PA00018633692013
Lovely Lovers.PA00017873302012
Lovers at Home.PA00018688162013
Lovers in Paradise.PA00017804632011
Lovers Lane.PA00019586222015
Lovers Quarrel.PA00018142472012
Lovers Way.PA00019051412014
Loving Angels.PA00018177522012
Loving It Hard And Deep.PA00019953312016
Luckiest Man Alive.PA00019962162016
Luminated Emotions.PA00019222752014
Luminescense .PA00018692492013
Lunchtime Fantasy.PA00017817022012
Lying Around.PA00018727542013
Mad Passion.PA00018310832013
Maddy Me Crazy.PA00019493672015
Made for Each Other.PA00018609742013
Make Love To Me.PA00019704952015
Make Me Feel Beautiful.PA00018596512013
Make Up Sex.PA00019387712015
Making Music.PA00018837692014
Malibu Moments.PA00018622832013
Malibu Moments II.PA00018609582013
Many Shades of Grey.PA00018720832013
Marry Me Caprice.PA00018476502013
MaryJane Young Love.PA00017624042011
Masseuse.PA00017796342011
Maybe Yes.PA00019314752015
Me Myself And I.PA00019336862015
Meet Me in Madrid.PA00018476582013
Meet My Lover From Austria.PA00018980942014
Megan Morning Bath.PA00017620772010
Megan Morning Bath / by Malibu Media, LLC.PA00013971932011
Midnight Passion.PA00019336852015
Mile High Club.PA00018772492014
Mina’s Fantasy.PA00017620782010
Mina’s Fantasy / by Malibu Media, LLC.PA00013971772011
Miss Me Not.PA00018177632012
Miss Perfect.PA00018092842012
Miss You.PA00018332622013
Model Couple.PA00018526772013
Model Couple on Vacation.PA00018746132013
Morning Desires.PA00018192922012
Morning Fantasy.PA00017804742012
Morning Glory.PA00019029682014
Morning Meditation.PA00018826502014
Morning Memories.PA00018064692012
Morning Tryst.PA00018003552012
Move With Me.PA00018789802014
Much Needed Vacation.PA00018660832013
Mutual Orgasm.PA00017833572011
Muy Caliente.PA00019336832015
My Best Friend’s Boyfriend.PA00017895102011
My Blue Heaven.PA00019670772015
My Days in Rome.PA00018861872014
My Love.PA00017796922011
My Naughty Girl.PA00018680942013
Names.PA00018431062013
Natural Beauty.PA00017804672011
Naughty & Nice.PA00018192902012
Never Better.PA00019260872014
New Romance.PA00018609722013
Newlyweds.PA00018596622013
Nice and Slow.PA00019160382014
Night of Excitement.PA00020201772016
Nina Needs It Now.PA00020151122016
No Hurry.PA00018688112013
No Turning Back Part #1.PA00018745242013
No Turning Back Part #2.PA00018745252013
Not Alone.PA00018894102014
Oh Mia!PA00018526742013
Old Enough to Know Better.PA00018385972013
On My Own.PA00017949652012
One and Only Caprice.PA00017804622012
One Day In Paradise.PA00020150992016
One Night Stand.PA00017949732012
One Show For Each.PA00019212952014
Only Girls.PA00018526782013
Only Lorena.PA00018476542013
Only The Lonely.PA00019065632014
Our Little Cum Cottage.PA00019145372014
Out of This World.PA00018332942013
Paint Me Beautiful.PA00019086742014
Paint Me White.PA00019097852014
Paradise Found.PA00017833622012
Party Boat.PA00018624852013
Perfect Girls.PA00017834542012
Perfect Lovers.PA00017859592011
Perfect Match.PA00018624192013
Perfect Timing.PA00018958482014
Perfect Together.PA00018052622012
Perfectly Taylored.PA00020151092016
Photo Fantasy.PA00018086312012
Photo Finish.PA00018746162013
Pink Magic.PA00019321042015
Pink Orgasm.PA00017979442012
Pink Perfection.PA00018870982014
Play Me.PA00018476592013
Playful And Wet.PA00019387702015
Playing Dress Up.PA00018747422014
Pleasant Surprise.PA00019351072015
Pool Party for Three.PA00018596562013
Poolside Passion.PA00018118512012
Poolside Pleasure.PA00019314772015
Poolside Romp.PA00017851222011
Positively in Love.PA00018003582012
Precious Metal.PA00019082482014
Prelude to Passion.PA00018161662012
Pretty Babies.PA00018359532013
Pretty Back Door Baby.PA00017894272012
Pretty Bad Girl.PA00019095042014
Pretty Little Belle.PA00018784252014
Pretty Pink.PA00019160552014
Private Time.PA00018049662012
Puffy Nipple Lovers.PA00019733412015
Pure Aubrey.PA00019260842014
Pure Grace.PA00018004842012
Pure Passion.PA00017804732011
Putting On A Show For You.PA00018928892014
Queen of Hearts.PA00019147202014
Raw Passion.PA00018609792013
Ready for Bed.PA00018311992013
Ready For Love.PA00018729682013
Ready or Not.PA00018526752013
Red Hot.PA00018105032012
Red Hot and Ready.PA00019351042015
Red Hot Summer.PA00017804692011
Red Satin.PA00018288922013
Remembering Strawberry Wine.PA00018851842014
Rendezvous.PA00018893972014
Retro Romp.PA00019442032015
Rich Girl Part 2.PA00017628082011
Rich Girl – Part One.PA00017804752011
Risky Business.PA00018784552014
Rock Me Baby.PA00019837452015
Rock Me Baby.PA00019075922014
Rollergirl.PA00020150812016
Rolling in the Sheets.PA00018476532013
Romance In The Garden.PA00020252382016
Romantic Memories.PA00017903752012
Romp at the Ranch.PA00019539522015
Roommates.PA00017862652012
Rope Priority.PA00018957602014
Rose Petals.PA00018385982013
Rub Me the Right Way.PA00019493662015
Rub Me The Right Way Too.PA00020150952016
Russian Connection.PA00018861892014
Russian Invasion.PA00018086292012
Sacred Romance.PA00018257212013
Santas Little Helper.PA00018745202013
Sapphic Experience.PA00017933642012
Sapphic Waltz.PA00018431102013
Sapphically Sexy.PA00019215422014
Saturday Eve.PA00019095112014
Season of Love.PA00018772522014
Secret Weapon.PA00018460982013
Secretary.PA00019283972015
Seeing Double.PA00018248402013
Seize the Moment.PA00019493712015
Self Pleasure.PA00017913512011
Selfie Love.PA00019351062015
Sent From Heaven.PA00018192952012
Serving Seduction.PA00019167042014
Sex and Submission.PA00018826492014
Sex At The Office.PA00019900032016
Sex Drive.PA00019962292016
Sex With Glasses.PA00019039142014
Sexual Vanity.PA00019284222015
Sexy and Wild.PA00019145302014
Sexy En Noir.PA00019097832014
Sexy In The City.PA00019055112014
Sexy Lazy Afternoon.PA00019412812015
Sexy Summer Camp.PA00019900022016
She Bad.PA00018622952013
She Is On Fire.PA00019364762015
She’s A Spinner.PA00019145212014
She’s Not Alone.PA00019145352014
Should Have Seen Your Face.PA00019351052015
Show You My Love.PA00017871212011
Show You My Love.PA00017939692011
Side By Side.PA00018052612012
Silver Bullets.PA00017903732012
Silvie Centerfold.PA00017747622012
Silvie Eufrat Strip Poker.PA00017759092012
Silvie the Siren.PA00018430892013
Simply Stunning.PA00018431032013
Sizzling Hot.PA00019284332015
Skin-Tillating Sex For Three.PA00019739932015
Sleepover.PA00018386002013
Slippery Sensations.PA00018956682014
Slow Motion.PA00017878752012
Smarty Pants.PA00019127742014
Sneak n Peek.PA00017915222012
Sneaking In.PA00018609622013
Snow White and the Prince.PA00018460952013
So Beautiful.PA00018689192013
So Close Together.PA00018609762013
So Cute.PA00019298022015
So Right Its Wrong.PA00018720842013
So Young.PA00018774722014
Soul Mates.PA00018133612012
Spanish Garden.PA00017913522011
Spanish Heat.PA00019177092014
Sparks.PA00019160392014
Spellbound Lovers.PA00019229542014
Spilled Milk.PA00018332992013
Spontaneous.PA00018609772013
Spread Across The Floor.PA00019373782015
Spread Wide Open.PA00019321152015
Spur of the Moment.PA00018201922013
Starting Over.PA00018036632012
Stay for a While.PA00018596612013
Stay with Me.PA00017804652011
Still Mine.PA00019253462014
Still With Me.PA00018133602012
Strawberry Blonde.PA00017944502012
Strawberry Morning.PA00019260892014
Studio Part #1.PA00019366212015
Studio Part #2.PA00019314762015
Submissive Seduction.PA00018784202014
Suds And Sex.PA00019953332016
Sultry Summer Invitation.PA00019442062015
Summertime.PA00019222742014
Summertime Lunch.PA00019070782014
Sunday Afternoon.PA00018003532012
Sunday Afternoon Solo.PA00018226752013
Sunset Memories.PA00019212962014
Super Cutie.PA00019298042015
Super Nymphs.PA00019373832015
Superhot Sexting.PA00020252392016
Supermodel Sex.PA00019670752015
Surprise Surprise.PA00018921862014
Surrender to Seduction.PA00019533672015
Susie Forever.PA00020149392016
Sweet Awakening.PA00019070772014
Sweet Dreamers.PA00018837712014
Sweet Moment.PA00018729672013
Sweet Sensations.PA00019962302016
Sweet Surrender.PA00018848612014
Sweetest Dreams.PA00018201942013
Take Me Now.PA00019373802015
Take Your Picture.PA00019428632015
Tantalizing Fox.PA00020149502016
Tantric Massage.PA00018921802014
Tarde Espanola.PA00018153452012
Taste Me.PA00019127732014
Tatiana the Voyeur.PA00017768082011
Tease and Please.PA00018719372013
Tease Me Please Me.PA00019260952014
Technicolor Dreams.PA00018431012013
Teenage Dream.PA00017914912012
Teenage Lust.PA00020252402016
Then They Were Three.PA00018177612012
These Girls Are On Fire.PA00020149482016
They Meet Again.PA00018660492013
They Only Look Innocent.PA00018774712014
They Seem So Sweet.PA00019041512014
This Is What Heaven Looks Like.PA00019869752015
This Really Happened.PA00018609702013
This Side of Paradise.PA00018026032012
Those Beautiful Lips.PA00019314782015
Thought Of You.PA00019071042014
Thought of You Part 2.PA00018956652014
Three for the Show.PA00018086302012
Three in the Morning.PA00017833602011
Three Way Is The Best Way.PA00018784262014
Threes Company.PA00018049392012
Threesome With a View.PA00020151102016
Through the Looking Glass.PA00018519802013
Thunderstorm Love.PA00019095072014
Tickle My Pink.PA00019740092015
Tie Her Up For Me.PA00019065512014
Tiffany Sex with a Supermodel.PA00017620222011
Tiffany Teenagers In Love.PA00017620192010
Tiffany Teenagers In Love / by Malibu Media, LLC.PA00013971822011
Tiffanys Tight Ass.PA00019127722014
Tight and Wet.PA00019231762014
Tight and Wet.PA00019239592014
Tight Ass Teen.PA00019387482015
Time to Go.PA00017807712012
Tiny Seductress.PA00019740112015
Together Again.PA00018192882012
Together at Last.PA00018460962013
Too Hot To Handle.PA00019253452014
Tori The Endless Orgasm.PA00017620822010
Tori the endless orgasm & 6 other titles.V3621D3972012
Tori The Endless Orgasm / by Malibu Media, LLC.PA00013971862011
Transcendence.PA00017995772012
Triple Play.PA00019507632015
Triple Threat.PA00018609612013
Trophy Wife.PA00018837672014
Tropical Sexcapades.PA00020149422016
Truth or Dare.PA00018460992013
Tuesday Morning.PA00018288972013
Twice as Nice.PA00019953352016
Twice The Fun.PA00019373812015
Two Boys and a Girl.PA00018288962013
Two By Two.PA00018980932014
Two Cocks In Karla.PA00019953362016
Two Fingers Deep.PA00019740142015
Ultimate Blowjob.PA00017768062011
Unbelievably Beautiful.PA00018053152012
Unbreelievable.PA00019388302015
Under My Blanket.PA00019252982014
Underwater Lover.PA00018064742012
Undress Me.PA00018692382013
Unforgettable View Part II.PA00018177652012
Unforgettable View Part One.PA00018177592012
Unveiling Part #2.PA00018661882013
Unveiling Part One.PA00018631052013
Up Close and Personal.PA00018596532013
Vacation Fantasy.PA00018142502012
Veronica Wet Orgasm.PA00017624122011
Veronika Coming Home.PA00017747612012
Wake Me Up.PA00018871052014
Wake Me Up Like This.PA00018622892013
Want You.PA00018226502013
Warm and Fuzzy.PA00018727532013
Warm Inside.PA00018208562013
Watching.PA00019260902014
Waterfall Emotions.PA00018177572012
Way I Feel.PA00018747452014
We Love Ourselves.PA00018609442013
Wet Dream.PA00018003572012
What a Girl Wants II.PA00018476602013
White Hot.PA00018004722012
Why I Love Czech Girls.PA00019222722014
Wild at Heart.PA00017859692012
Wild Things.PA00018092872012
Without Words.PA00018596502013
Wonder Waltz.PA00018596552013
Wonderful World.PA00018476512013
Working Out Together.PA00018248412013
Xmas Cums Once A Year.PA00019871842015
Yeah Baby.PA00018596592013
Yoga in the Sky.PA00017947152012
Yoga Master & Student.PA00018226512013
Young & Hot.PA00017949692012
Young and the Restless.PA00018431112013
Young Passion.PA00018118522012
Yours Forever.PA00019075732014
Zeppelin on Fire.PA00018746142014

In Summary

In closing (if you even got this far in the article), be aware that Malibu Media, LLC is no longer in the adult movie business, but rather, in the copyright enforcement business. Their entire operation is based on monetizing the value of the 700+ copyrights they have filed with the copyright office. Similarly, I must assume that 100% of their operations budget is going into the costs of enforcement, namely, computer servers, and the costs of monitoring each of the hundreds of defendants I expect they are currently tracking and will be suing in the coming months.

If you are interested in Malibu Media, LLC content, get a membership to their site (but do not expect to see new content). Do not view any of their content via bittorrent networks, as this is how they are compiling their lists of who to sue. In fact, if you see anything X-Art related, it’s probably a safe bet just to click away from the site and shut the window. Even streaming can get you sued these days.

And if you are sued, our Cashman Law Firm, PLLC can be of assistance to you. Malibu Media, LLC cases all suffer from the same inherent faults, and that gives our clients a number of options on how to ignore, fight, or settle claims against our clients.


CONTACT FORM: If you have a question or comment about what I have written, and you want to keep it *for my eyes only*, please feel free to use the form below. The information you post will be e-mailed to me, and I will be happy to respond.

NOTE: No attorney client relationship is established by sending this form, and while the attorney-client privilege (which keeps everything that you share confidential and private) attaches immediately when you contact me, I do not become your attorney until we sign a contract together.  That being said, please do not state anything “incriminating” about your case when using this form, or more practically, in any e-mail.

Motions to Quash ISP Subpoena Letters, Malibu Media Lawsuits, Rightscorp DMCA Settlement Notices, and Helping John Does.