To whom it may concern,
The Motion Picture Association (“MPA”) represents the six major film studios (i.e. Paramount Pictures Corporation, Sony Pictures Entertainment Inc., Twentieth Century Fox Film Corporation, Universal City Studios LLC, Warner Bros. Entertainment Inc., Walt Disney Studios Motion Pictures) which companies, whether themselves or through subsidiaries and affiliates (collectively, “MPA Members”), own copyright in a vast number of well-known films and TV programs (“Entertainment Content").
MPA protects the rights and interests of the MPA Members by outreach and, depending on the extent and gravity of the situation, through civil and criminal enforcement, in cooperation with local content protection organizations.
We are writing to you in connection with your operation of the Internet website operating under the domain name xxxxxx.xxx ("Website").
The Website is structurally providing access to the Entertainment Content, as well as other copyrighted content, without the necessary authorization of the rightsholders. The Website is offering a choice of popular films and/or TV programs. In operating the Website, you are infringing copyright and acting unlawfully by facilitating the infringement of copyright (Svensson & Ors. v. Retriever Sverige AB (Case C-466/12, Court of Justice of the European Union (“CJEU”)). This causes significant damage to the MPA Members and other creative industries. Examples of Entertainment Content are found in Exhibit A.
Without prejudice to our contention that you are already well aware of the extensive infringements of copyright, this Notice fixes you with actual knowledge of facts and circumstances from which illegal activities, i.e. copyright infringements, are apparent. According to L’Oreal SA & Ors v. eBay International AG & Ors (Case C-324/09), the CJEU confirmed that, acting as a diligent economic operator, this knowledge allows you to identify the illegal activities of the Website and to take appropriate measures against infringement.
This Notice requires you to immediately (within 24 hours) take effective measures to end and prevent further copyright infringement. All opportunities provided by the Website to download, stream or otherwise obtain access to the Entertainment Content should be disabled permanently.
Please be advised that the links and titles mentioned in Exhibit A are intended to serve merely as an example of a broader unlawful use of copyright protected content by the Website. We expect your full co-operation by disabling access to the Website or, at least, by removing all (links to) Entertainment Content. We note that such Entertainment Content is listed on the Findanyfilm.com website (
All Films. All Above Board | FindAnyFilm).
Finally, we draw your attention that any use of the artwork of the Entertainment Content (e.g. movie or TV show posters) (“Artwork”) is prohibited without authorization of the rights holder. Since the MPA Members haven’t authorized the Website to publish the Artwork, the Website is infringing copyright on that basis as well.
We look forward to your response. If you fail to take the immediately required action to end and prevent further copyright infringements the MPA and the MPA Members expressly reserve the right to pursue all remedies available.
