Countryman Nevada Case Dismissed After One Settlement, 1:14-cv-01149(CO)

Just a short post to show you how some BitTrorrent Copyright Troll cases run.  Now I’m in NO way saying that all of them end up like this.  Each Troll/Plaintiff is different, as well as the local Troll who is running them.  Malibu Media LLC/Troll Lipscomb runs their operation differently than say a Voltage Pictures case.  BUT the following example points out that the Troll/Plaintiffs are doing this to generate settlements and the claims of cracking down on piracy is pure BS in my opinion.

Case At Hand

Color9SmellThis case is brought to us by Voltage Picture (Nicolas Chartier) and the local Troll attorney Scott Kannady, Brown & Kannady, LLC, Denver, CO.  Case is Countryman Nevada, LLC v. Doe 1 et al (12 Does), Colorado, 1:14-cv-01149.   Complaint_01149(CO)

The case was filed on 22 Apr 14, to include a motion for expedited discovery of ISP subscriber information.  The expedited discovery was rubber-stamped the next day and there after the Troll received the ISP subscriber information.  The case followed the usual path of working settlements and monthly status reports to the court.  Almost three months after filing, Troll/Plaintiff dismissed Doe (#6) after settling.  Approximately one month later (20 Aug 14), Troll Kannady voluntarily dismissed the entire case (11 remaining Does) without prejudice.   Doc_18_VolDismiss_01149(CO)

So one out of 12 Does apparently paid the settlement.  That is an 8.333% settlement rate – piss-poor settlement rate IMO.  But still, how much time, effort, or money did they really have to put out?  $400 and some electronic case filing based off pre-made templates is what I’m guessing – not much.  Assuming Troll/Plaintiff obtained $4,500 for this settlement; that leaves $4,100 to be split between the parties.  So even with one Doe settling, the business model is profitable.

Why Dismiss – Why Not Serve The Does?

This business model is purely designed to extract settlement from ISP subscribers.  The fact that these Troll/Plaintiffs could take these Does to trial does not figure into their plan.  The claims that they are only trying to reduce piracy and recoup lost revenue is another sad joke supported by the facts that –

  • The Troll/Plaintiffs do not send out DMCA take-down notices to the ISPs of the public IP addresses they observe.  Many of the Troll/Plaintiffs do send out DMCA take-down notices, BUT they are usually only sent to Internet Search engines or Tube sites.  As the Troll/Plaintiffs use these DMCA take-down notices in this fashion, I assume they are working – not perfect, but still working.  So why can’t work with the ISPs and their subscribers???
  • They only file cases in the jurisdictions they deem friendly enough for them and where they can find an attorney willing to tarnish their name by handling these cases.  The reason why some jurisdictions look down on these cases is because many of the past ones were questionable (at best) when you looked beyond the threadbare claims. As far as the tarnished reputation for handling these cases; the attorneys will have to fix that on their own – you reap what you sow.

The main reason you don’t see as many Does named/served with a summons/complaint is because this step significantly increases the risk that some ISP subscriber is going to fight back.  We saw this gross mistake made by the Troll Maureen Vandermay in Washington when her client decided to name/serve the Does who refused to settle in case 2:13-cv-00115 (WAED).  This of course led to Elf-Man LLC v. Lamberson case, 2:13-cv-00395, with motions for approximately $200K in attorney fees/costs and sanctions against the Troll/Plaintiff.  Even Malibu Media LLC, is feeling pressure from its efforts to name/served non-settling ISP subscribers.  It is only a matter of time before they cannot cut and run and lose a case.

So based on what I have seen in the Troll Kannady CO cases, I wouldn’t rush off to pay a settlement demand from him.  I expect that if CO court didn’t require monthly status reports from the Troll, these cases would stay open much longer and possibly get more people to pay up.  Judge Hegarty may be making it harder for the Troll/Plaintiffs, but CO is still a BT Copyright Troll haven in need of some reform.  Now as this information makes it into the public view, Troll Kannady and his Plaintiffs may be forced to start naming/serving people in small numbers.  This of course increases their risks and possibly lowers their profit.

DieTrollDie :)   “That’s how you’re gonna beat ‘em, Butch. They keep underestimating you.- Butch Coolidge, Pulp Fiction

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Copyright Troll Elf-Man LLC Files Weak Justification for Default Judgments, 2:13-cv-00115 (WAED)

On 3 Sep 14, Judge Rice denied Troll/Plaintiff’s motion for default judgements against Seven Defendants in Elf-Man LLC case 2:13-cv-00115(WA) and directed Plaintiff to file a response to his concerns.  Previous Article.   *** Late Addition – I forgot to add this document – sorry.  ***  Doc_114_DefaultDenied_00126(WA)  On 3 Sep 14, Judge Rice also denied default judgements against 4 Defendants in The Thompsons Films, LLC, case 2:13-cv-00126.  The judge had the same concern as in the Elf-Man cases.  Judge Rice was clearly able to see this is the same operation, just filed under different Plaintiff names.  Archive Docket (2:13-cv-00126(WA)    DTD Article on 2:13-cv-00126(WA) 

I am a bit surprised that Troll/Plaintiff made a response as I believe they have no additional “evidence” to tell the court.  What does not surprise me is that what they filed is 90% garbage (My opinion & I think a generous one at that).

Here are the documents they filed – you have seen some of these before in one form or another.

DECLARATION OF KURT UEBERSAX IN SUPPORT OF DEFAULT JUDGMENT   Doc_124_Decl_Uebersax_00115(WA)   Denied Plaintiff seeded the movie to BitTorrent and says a “third party distributors” managed the pre-release of the film. Here is “gem” from Mr. Ubersax concerning the piracy of Elf-Man.

At one point there were considerations for a sequel to be made, but all such plans were canceled in part due to the piracy of the first movie and the fact that unless something could be done to stem the piracy of the second film, it would suffer the same fate.

DECLARATION OF PATRICK PAIGE   Doc_125_Decl_Paige_00115(WA)   This is the same tired Paige declaration that Malibu Media LLC used and this Troll/Plaintiff is trying to use it to show IP geolocation technology works.  Too bad is has nothing to say that the public IP address only comes back to the ISP subscriber and not necessarily the alleged infringer.  An investigation is required to determine who actually did this – something that was not done by Troll Lowe or VanderMay.

DECLARATION OF MICHAEL PATZER IN OPPOSITION TO DEFENDANT’S POST-DISMISSAL MOTIONS   Doc_126_Decl_Patzer_00115(WA)   Mr. Patzer claims to be an independent contractor predominantly for Excipio GmbH (German company).

Excipio contracts with Crystal Bay Corporation (“Crystal Bay”) to provide Crystal Bay with this data collection system, which is the system that Crystal Bay uses to detect infringement of Plaintiff’s works. Specifically, Crystal Bay licenses the use of Excipio’s system and servers.

Still there is NO mention of who owns or controls the SD “shelf-company” Crystal Bay Corporation (CBC) or who Darren M. Griffin is.  Judge Rice specifically mentioned the concerns raised in the Elf-Man v. Lamberson case (2:13-cv-00395(WA)) about the validity of CBC and its technicians.

SECOND DECLARATION OF DAVID A. LOWE IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT   Doc_127_2nd_Decl_Lowe_00115(WA)   Another waste of digital media in my opinion. It only claims the fees/costs requested were valid and not excessive. It in NO way addresses either of the two reasons judge Rice denied the default judgments in the first place – “Accordingly, the Court directs Plaintiffs to brief and provide evidence supporting its substantive claims and amount of damages against each defaulting defendant separately. Upon a showing substantiating Plaintiff’s claims against each Defendant, the Court will reconsider Plaintiff’s motion for default judgment and request for attorney fees.”   (My emphasis) {Default_Denied_Doc_121_00115(WA)pdf}

DECLARATION OF DANIEL MACEK IN SUPPORT OF DEFAULT JUDGMENT   Doc_128_Decl_Macek_00115(WA)   Mr. Macek (software consultant hired by CBC AND Anti-Piracy Management Company (APMC) employee) wastes 8 pages to tell the court something they already stated – That the Defendants are the ISP subscribers with the public IP addresses they recorded.  The declaration in NO way provides ANY evidence to show that the Defendants were the infringers.  Attached to Mr. Macek’s declaration (filed under seal) is a list of additional BitTorrent files that were being shared by the public IP addresses of the Defendants.  Mr. Macek claims this list of files is so large and disruptive to the Defendants Internet service connection that:

  1. It is “highly” likely the Defendant was the infringer.
  2. The Defendants knew the infringing activity was occurring over their Internet connection.
  3. It was likely a resident and not someone else using Defendant’s WiFi Internet connection.

Threadbare claims with NO supporting evidence.  Then combined this lack of evidence with APMC documentation disclosing that Mr. Macek doesn’t have the technical qualifications to make such a claim, as well as APMC hopes the various courts will not question them on this.

If this is all Troll/Plaintiff plans to file, then I can’t see the judge granting damages or costs/fees.  There is nothing new to the claims and evidence.  They have met the 6 Oct 14, suspense to respond, but the content of the filing in NO way justifies the statutory amount they requested -$30,000.  At best it is a simplistic long-winded recital of their claim – The ISP subscribers infringed upon Plaintiff’s movie because I said so.  This type of response is qualifies then for the Prenda Law “Equine Excrement Award.” Way to go guys!


So we continue to wait for the court to assess these declarations and make its ruling. I truly hope judge Rice see these filings for what they are and fully denies the default judgments. I assume that after he rules on this case, he will move onto the motion for sanctions and fees against Troll/Plaintiff in the Lamberson case.  That will be the fun one!

DieTrollDie :)   Treat people in your debt like family … exploit them.  {Rules of Acquisition #111}

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Copyright Trolls Target Children’s Animated Movie – Khumbia – 6 Cases in IL & CO

You might have seen a recent Tweet (27 Aug 14) of mine concerning a new BitTorrent Copyright Troll Plaintiff (at least in name): Khumba Film Pty. Ltd.  This Troll/Plaintiff filed 4 multi-Doe cases in the Illinois Northern District.   Complaint_06610(IL)   Complaint_EXs_IP_CpyRt_06610(IL)   Copyrights  Upon closer inspection, I found out I missed Khumba’s first filing in Colorado on 23 Jul 14.  Sorry :(   Here are the current Khumba cases (more to come I bet).

  • 1:14-cv-02049 – 12 Does – CO – 23 Jul 14
  • 1:14-cv-02075 – 14 Does – CO – 25 Jul 14
  • 1:14-cv-06610 – 42 Does – ILND – 27 Aug 14
  • 1:14-cv-06609 – 41 Does – ILND – 27 Aug 14
  • 1:14-cv-06608 – 38 Does – ILND – 27 Aug 14
  • 1:14-cv-06605 – 39 Does – ILND – 27 Aug 14             Total of 186 Does

Khumba_TrollColorado and IL again – no surprises here.  Both locations are well-established as friendly for filing BT Copyright Troll law suits.  Khumba is an animated movie about the adventures of a “half-striped” zebra.  You can find the DVD for sale for $10 – $20.  The movie is by the same people who brought you Zambezia, another animated movie that was the subject of 33 Copyright troll cases filed in IL, CO, TN, GA, DE, and FL (16 Jan – 9 Apr 2013).  For the Zambezia cases I counted a total of 981 Does.  As far as I know, no Zambezia cases went past the settlement demand phase – no need to with all the money to be made.  I don’t believe any of the cases even went as far as a default judgment (please correct me if I’m wrong – *** See comments below ***).

Follow The Money

I will use a little Copyright Troll math to highlight why BT copyright trolling will continue – GREED!!!  Let’s say for the previous Zambezia cases the Troll was able to get 50% of the Does to settle for $3,000.

  • 50% Settlement Rate – 490 Does X $3,000 = $1,470,000.
  • 25% Settlement Rate = $735,000.

Troll Costs – Filing 33 cases costs $13,200.  Estimate local attorney fees of $3,000 per case – $99,000 (That is generous IMO).  Estimated Fees/Costs = $112,200.

So after subtracting fees/costs, Troll/Plaintiff still has made a serious profit.  At the 50% settlement rate, the Troll/Plaintiff has made $1,357,800.  25% settlement rate = $622,800.  Wow!!!  Note: the amount the Troll/Plaintiff actually made is unknown and would have varied depending on the percentage of Does that did settle and the settlement amounts the Troll obtained.  As long as they are making a profit, this business model will continue.

More Crystal Bay Corporation (CBC) Garbage

Another interesting point is that for the CO Khumba cases (and will assume the same for IL cases), we have the Troll/Plaintiff using the Infamous BT technical monitoring firm/SD Shelf-Company, Crystal Bay Corporation (CBC) and the German consultant Daniel Macek.   Motion_EarlyDisc_02049(CO)   Decl_Daniel_Macek_02049(CO)   The complaints and declarations from Macek do not bother to disclose who Daniel Macek is, what company he actually works for, or even a basic resume of experience.  The lack of technical experience is not a shock to many of us, as we know Mr. Macek works for the Anti Piracy Management Company (APMC) LLC and they hope that US judges do not question Mr. Macek’s qualifications when he submits these template based declarations seeking early discovery of ISP subscriber information from the ISPs.  As the ILND and CO courts seem to be full of rubber-stamping fools (my opinion), these greedy Trolls keep on filing cases in these jurisdictions.  I can only hope that Judge Rice in WA makes his ruling on the Elf-Man LLC v. Lamberson (2:13-cv-00395 (WA)) motion for attorney fees/costs and sanctions (against Troll/Plaintiff).  In the Lamberson case, CBC was the BT monitoring firm and it used Daniel Macek.  Attorney Lynch informed the court that another “Ghost” of a technician,  Darren M. Griffin, was part of CBC (Known SD shelf company and possible sham) and called into question the truthfulness of Troll/Plaintiff’s technicians and the case as a whole.   If Griffin/CBC ends up being discredited, then these new cases that use CBC (via Daniel Macek) will have a harder time – they might even get dismissed by the Troll en mass.  *** Sorry – correction: I first had Griffin listed as part of the Lamberson case – it was Macek. ***

For the Colorado Does, please drop me an email if you have received your ISP notification, as well as when the settlement demand letters start arriving – please send me copies. Same goes for the IL Does when the notifications start.

Previous Zambezia Articles – 1  2

DieTrollDie :)  “Love the one you’re with.”

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Happy Birthday All!!! is three years old (as of 30 Aug 14).

BDayTartI almost let this get by me again.  The world of BitTorrent Copyright Trolls is still in existence and adapting to the changing environment.  I wanted to take a moment to thank all of the people who have made this last year so interesting for me and the Web site.  I expect no less for the next year!  So on 30 Aug 14, please find the time to raise a glass of you favorite beverage as I toast you all.

Here’s to a long life and a merry one.
A quick death and an easy one.
A pretty girl and an honest one.
A cold beer-and another one!

Update on Malibu Media LLC v. Richard Sadowski, 1:14-cv-00262 (CO)

Here is a short but very interesting update to the Malibu Media case against Mr. Sadowski (1:14-cv-00262 – IP address   This is the case where attorney John Arsenault filed a very good Motion to Dismiss because Plaintiff failed to plead the necessary volitional act in its complaint.   MTD_FSC_Doc26_00262(CO)   Previous Article   My view was (and still is) that attorney Arsenault clearly showed Troll/Plaintiff was only targeting the Defendant because he was the ISP subscriber.  He backed up the motion with sound analysis and case-law to boot. 

Even in a Troll friendly environment such Colorado, Troll/Plaintiff decided NOT to file a reply and decided to settle the matter with the Defendant.  Why???  Because in the off-chance Hegarty/Wiley required Malibu Media to provide more than “an unadorned, the-defendant-unlawfully-harmed-me accusation,”  they would have to disclose more of their internal operations.  Now Malibu Media is ALL about “settlements,” but I surmise this settlement agreement was more to Defendants liking.  On 18 Aug 14, Troll Kotzker dismissed the case with prejudice.   Doc_28_Settlement_Dismiss_00262(CO)   Doc_29_DismissOrder_00262(CO)

Please also note the wording of the dismissal.  The rather common statement that both parties will cover their respective legal bills is missing…  Does this mean that Malibu Media paid  Defendant Sadowski’s legal bills???  I don’t know, but the silence around this case is “interesting.” 

This just goes to reinforce that Malibu Media does not want to litigate these cases unless they can be assured that the defense will not be asking uncomfortable questions concerning their operation and “Who” is really pulling the strings for these cases.  Troll Lipscomb and minions are facing increased pressure from various courts and it is simply a matter of time before they get called to the carpet.  Until then, they will make each Defendant who chooses to fight incur a substantial defense bill to do so.  For those who have the will and ability to fight back – I salute you.

DieTrollDie :)   “I have had people walk out on me before, but not… when I was being so charming.”  {Deckard, Blade Runner}


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Dallas Buyers Club, LLC Attorney Tiptoes Dangerously Near Judge Hughes’ Order.


Thank you to attorney Robert Cashman for publishing this update to the Dallas Buyers Club (DBC) cases in Texas.  It looks like Troll Vogt is going to try the name & serve option that served Troll Maureen VanderMay so well in WA.  All it will take is one of the named Defendants to fight back and this Plaintiff is going to be hurting.  Greed makes people and organization do some pretty stupid things. If you are one of the named defendants, I suggest you contact attorney Cashman to discuss your options.  I will also note that in my “Defendant Answer” page, you can find some “Answer” templates (to include Dallas Buyers Club).

DieTrollDie :)

Originally posted on TorrentLawyer™ - Exposing Copyright Trolls and Their Lawsuits:

After my “Dallas Buyers Club, LLC is a modern-day Icarus Story (TXSD)” article on August 13th, I called Keith Vogt, the plaintiff attorney for Dallas Buyers Club. In our call, I ascertained his motivations regarding how he plans to approach Judge Hughes here in Texas, and what he plans to do with the other cases (duck and run, or push forward).

As I suspected, he expressed no “duck and run” mentality (not even privately), as we have seen in similar past cases with other past “copyright troll” plaintiff attorneys. In fact, Vogt appeared to be undeterred considering the outcome of the case, mentioning that he has NINE (9) other cases alive and well in the Southern District of Texas, seven of which were in their INFANT STAGES and all current cases are assigned to judges other than Judge Hughes.

Below is a list of those new cases:

Dallas Buyers Club, LLC…

View original 494 more words

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Defendant Butler Has No Computer Hard Drives – Malibu Media LLC, 1:13-cv-02707 (CO)

Here is a short post, as I have a costume party to get ready for.  Note: I certainly will not be dressing up like a Troll.  This is an update on Malibu Media LLC v. John Butler, 1:13-cv-02707 (CO). Since my last Butler post, the following has happened.

  • MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSES – Troll/Plaintiff requested the court strike three of the five affirmative defenses he asserted (Failure to State a Claim, Assumption of the Risk, and Intervening Cause)   Doc_36_MotionStrike _Answer_02707(CO)
  • UNOPPOSED MOTION FOR EXTENSION OF TIME TO SERVE EXPERT WITNESS REPORT BY PLAINTIFF MALIBU MEDIA, LLC – Troll/Plaintiff asked the court for a 90 day extension (10 Nov 14) to serve expert witness reports.  The Forensic expert (assume it is P. Paige) has not receive the hard drive from the Defendant.  WHY??? Because the Defendant doesn’t have the computer anymore!  Defendant claims to only have a cell phone at this time.   Doc_38_MotionTime_02707(CO)
  • MINUTE ORDER – Judge Hegarty tells Troll Kotzker “NO” to 90 days – only grants 30 additional days.  Discovery is due NLT 17 Nov 14.   Doc_40_MinOrder_02707(CO)
  • RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE – Judge Hegarty agrees with Troll/Plaintiff and Strikes the three affirmative defenses.   Doc_41_Hegarty_REC_02707(CO)
  • DEFENDANT’S OBJECTIONS TO MAGISTRATE’S RECOMMENDATION THAT PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSES BE GRANTEDAttorney Richard Hanes objects to the Recommendation based on – 1) Defendant was deprived of his right to file a response to Plaintiff’s motion and for it to be considered prior to the recommendation; 2) The recommendation lacks legal sufficiency to show that Plaintiff would succeed despite any facts from the Defense (especially since Discovery has not taken place); and 3) the recommendation would deprive the Defendant of his right to defend himself from Plaintiff’s allegations.   Doc_42_OBJ_Hegarty_REC_02707(CO)

HardDrivesWell this just got interesting.  No computer hard drives are available for Troll/Plaintiff to examine.  So what will the Troll do???  The only things I can imagine is using the list of “Other” files that were being shared via BitTorrent on Butler’s IP address, interviewing neighbors, friends, associates, and doing social media searches and records checks.  The “Other” files would somehow need to be able to be linked back to the Defendant’s hobbies, profession, or interests.  Example: Social media searches disclosed the Defendant really likes “Thomas the Tank Engine” and among the “Other” files being shared via BT is 4 DVD rips of Thomas the Tank Engine.

Thomas1As Troll Kotzker has known the computer was long gone and not tried to develop/show any linkage to the allegation, I bet they are grasping at anything.  If they decide to talk to neighbors, they will be looking for anything to show Defendant used BT, anything he said about illegal downloading of copyright protected media, and of course Plaintiff’s movies. The bottom line is the Troll has its work cut out for them to somehow scrape up enough evidence to show a preponderance of evidence in their favor.

Now I’m no Judge Hagerty fan, but it does seem like the judge is getting a little tired of the games Troll Kotzker and Malibu Media/X-Art are playing in CO.  We will see what happens.  It may turn out that Troll/Plaintiff tries to secure a “walk-away” deal with Defendant.  If this goes to trial with no forensic evidence, I will be surprised.

DieTrollDie :)   “You might belong in Gryffindor, Where dwell the brave at heart, Their daring, nerve, and chivalry Set Gryffindors apart…”  {The Sorting Hat, “Harry Potter and the Sorcerer’s Stone”}

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Copyright Troll Malibu Media/X-Art AGAIN Refused To Examine Exculpatory Evidence, 1:13-cv-03184 (CO)

21 Aug 14 Update

Some additional information made it my way after the article was posted.  I cannot validate it, so use you own judgement.  But I will say it does sound very plausible.  Additional information is this color (below).


The following closed Malibu Media/X-Art case is interesting in for two reasons.

  1. What it “Doesn’t” say.
  2. For highlighting the normal course of action for Malibu Media.

The case is a standard Malibu Media copyright troll case in Colorado (1:13-cv-03184), in which a single public IP address/John Doe was sued over allegedly downloading/sharing 12 Malibu Media/X-Art movies.   Complaint_03184(CO)   Complaint_IP_12Movies_03184(CO)   Complaint_12MoviesReg_03184(CO)   As this is a Colorado court, Troll/Plaintiff had no problem obtaining early discovery and getting a rubber stamp of approval from the court based off of questionable documentation from some of our German “friends.”   Discovery_MFR_03184(CO)   Decl_Tobias_Fieser_03184(CO)   Discovery_Order_03184(CO)

Troll_DM1Now after the ISP subscriber information was released on 20 Jan 14, Troll Jason Kotzker followed the standard Malibu Media course of action.  If you have been following these cases, you will know that Malibu Media does not generally send out settlement demand letters.  They let the ISP subscriber start the process by – 1) Contacting Troll Kotzker directly; 2) Hiring an attorney who contacts Troll Kotzker; or 3) Letting the ISP subscriber ignore the matter for a time.

On 20 Mar 14, Troll Kotzker amended the complaint to name the ISP subscriber as the defendant.   A summons was also issued at this time.  One day after filing the amended complaint, the Troll requested an extension of time in which to serve the defendant. The court granted the extension out to no later than 21 Apr 14 (3 months since receiving the ISP subscriber information).

True to Troll form, they failed to show the court that they serve the Defendant with a summons/complaint by 21 Apr 14.  On 23 Apr 14, the court issued a show cause order giving the Troll TWO days to explain why the case should not be dismissed. This was a bit of a shock to me as the CO courts have been a Troll favorite for some time. Troll Kotzker then got off his @$$ and filed the paperwork showing the Defendant had been served on 16 Apr 14.  NOTE: I assume the Defendant hired Christina Saunders, Sparkman Foote Minor LLP, to represent him after he was served.   ShowCause_03184(CO)   Def_Served_03184(CO)

On 5 May 14, Defendant filed an answer with the court.   Def_Answer_03184(CO)   The answer is a basic denial with Eight Affirmative Defenses (MISUSE OF COPYRIGHT, ONE SATISFACTION RULE, NO VOLITIONAL CONDUCT, DOCTRINE OF EXHAUSTION, INVALIDITY OR UNENFORCEABILITY OF COPYRIGHT, DE MINIMUS INFRINGEMENT, INJUNCTIVE RELIEF, and FAIR USE).  I think I will add this one to my “Answer Page.”  The first affirmative defense best describes the BT Copyright Trolling business model and lets Troll Kotzker and Troll Lipscomb what is in store.

 First Affirmative Defense: MISUSE OF COPYRIGHT

Plaintiff’s claims are barred by the misuse of copyright. Plaintiff intends to elicit settlement funds from Defendant, rather than prevent infringement of its copyrights. Moreover, Plaintiff has developed and engaged a litigation centric business model, whereby Plaintiff tracks BitTorrent sites in order to locate IP addresses, which may lead to a potential copyright infringer, in order to generate income for the alleged downloads rather than use this as a method to stop infringements. In doing so, Plaintiff has illegally extended its monopoly beyond the scope of copyright and violated public policy underlying the copyright laws.

On 5 May 14, a proposed scheduling order was filed with this “notable,” but otherwise unsurprising report of Troll/Plaintiff refusing to look at the exculpatory evidence – Defendant’s computers.   SchedulingOrder_03184(CO)

Defendant has made several attempts to settle this matter with Plaintiff, and in doing so, has offered Plaintiff exculpatory evidence and the ability to access Defendant’s electronic capable devices, but to date, Plaintiff and Defendant have not reach mutually acceptable settlement terms. The parties believe that early neutral evaluation or a settlement conference facilitated by this Court would help parties in promptly settling this case without incurring further unnecessary cost and expense.   {My Emphasis}

The next interesting document is a report on the 13 May 14, Scheduling and Settlement Conference.   SS_Conference_03184(CO)   The conference only lasted 28 minutes, in which both sides sides agreed to settle.  The unfortunate part of this conference is that the portions in which the Defendant and his wife were questioned by the judge, as well as the settlement terms were sealed.

Additional information – I have been informed that the Defendant brought the hard drive from their computer to the conference.  For some reason, Troll Kotzker did not want take it for examination.  Surprised???  Also that Troll Kotzker got to have a nice conversation with the judge behind closed doors – I don’t think was a good one for Troll Kotzker. 

On 20 May 14, the judge signed the proposed stipulated dismissal (With Prejudice), in which both sides cover their own costs and fees.   Order_Dismiss_03184(CO)

This case is clearly indicative of Troll/Plaintiff who is engaged in a systematic business model to misuse the Copyright Law (My Opinion) in order to generate income.  I can only hope the CO court eventually starts to see this and put a stop to it.  I’m not too hopeful of this as the court decided to seal the interviews it conducted of Defendant and his wife.  I understand sealing the settlement portion, but what is the harm of letting the world see what these people had to say???  I’m sure once Attorney Saunders got involved, she made it clear to Troll Kotzker that the Defendant and his wife didn’t do this, their computers would validate this, and that fighting this would be a no-win for them.  The fact that Troll/Plaintiff refused to examine the systems indicates a bully trying to force a settlement by increasing defense attorney fees.  The fact that the Defendant will incur fees is disgusting in my view.  Troll/Plaintiff did NO real investigation prior to naming/serving the Defendant.  The reckless naming/serving of the Defendant was based ONLY on the fact he was the ISP subscriber (my opinion) and that he did not agree to pay approximately $9,000 (My estimate based on 12 movies X $750) to make the law suit go away.

From this case you can see the Copyright Troll/Malibu Media/X-Art playbook.

Monitor Malibu Media/X-Art torrents – Collect minimal data showing the public IP shared Plaintiff’s works – File a law suit – Seek ISP subscriber information based off questionable companies and support personnel – Wait for ISP subscriber to initiate contact – Seek extensions from the court to serve a defendant – Name/serve a Defendant at the last moment – If summons is answered, work out a settlement (payment to Troll) – If summons is ignored, seek a default judgment – Depose ISP subscriber and other residents – Conduct forensic examinations of systems – Avoid depositions of Colette and Brigham Field – Avoid depositions of IPP personnel – Seek a settlement OR a walkaway deal.

Some people may wonder why a truly innocent Defendant would not take this to the bitter end.  Sounds simple, but until you (as a Defendant) find an attorney willing to work for free, you risk ending up with a HUGE legal bill!  Yes, the Copyright Law does allow for a prevailing side to motion for fees/costs, but that does not mean a court is going to grant it or the exact amount the attorney billed for.  Even after an award from the court, I would expect a hell of a time trying to collect from the idiots.  See this FightCopyrightTrolls article on trying to find the Prenda Law money.  We would all love to see these bozos get put through the legal wringer, but the costs and stress involved can be very high.  In the very recent case of Elf-Man LLC v. Defendant Lamberson, 2:13-cv-00395 (WA), the defense bill is up to approx. $200,000!!!  And this case never really made it into full discovery, much less a trial.  Right now we are waiting to see what Judge Rice does.   The Trolls understand the costs and use it to force defendants to settle simply out of economics – justice in no ways plays a part.  What is really disgusting is the courts in some jurisdictions (CO & IL) know what is going on and decide to do nothing.  The prevailing view is, “Well, that is our legal system, if you don’t like it, change it.”  The little people cannot change it and the courts themselves have the responsibility to police themselves and clean up their own messes or slap down those who would make a mess in it.

DieTrollDie :)  “You know how you get to Carnegie Hall, don’t ya? Practice.  {Lt. Aldo Raine – Inglourious Bastards}

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Troll Hierl (Dallas Buyers Club LLC) Claims DC Appeals Court Was Wrong In AF Holdings Ruling (1:14-cv-02162)

In an ongoing Copyright Troll case (1:14-cv-02162) in ILND, Troll Michael Hierl tells the court that the Electronic Frontier Foundation’s (EFF) “Blackjack” analogy that the DC Court of Appeals adopted in AF Holdings case (1:12-cv-00048 / 12-7135) was wrong.   Docket_15Aug14_02162(IL)   On 23 Jun 14, Troll/Plaintiff filed it’s memorandum on joinder and responded to Doe #17’s motion to quash.   Troll Response_02162(IL)   Troll Response_EXs_02162(IL)   It was refreshing to see an ILND court actually considering a motion to quash from a Pro Se Doe.   MTQ_Doe17_02162(IL)

Note: the court did inform Doe #17, that prior to accepting the motion, she would need to take part in a hearing scheduled for 9 Jun 14.  Doe #17 took part in the hearing via telephone and the judge accepted the motion.   During the hearing judge Gary Feinerman also raised the issue of the recent Appeals court ruling (AF Holdings, LLC v. Does 1-1058, — F.3d —-, 2014 WL 2178839 (D.C.Cir. 2014)), as well as how it may affect Doe #17’s Motion.

On 23 Jun 14, Doe #17 filed the following letter with the court.  In it, she informs the court she is 52 years old, denies downloading/sharing Dallas Buyers Club, and doesn’t know how this could have happened.  She states that for approx. 5 months they had continuing Internet issues/problems.  Once the problems were fixed, the WiFi Internet password was freely given to multiple friends and guests to use when visiting the residence.   Doc_29_Doe17_Ltter_02162(IL)

Subsequently the judge gave Doe #17 until 29 Aug 14, to make a reply to Troll/Plaintiff’s response, as well as setting status hearing for 11 Sep 14.   Doc_30_MinOrder_02162(IL)

Of course Troll Hierl does not care as to actually download/shared the movie, as that would mean doing a real investigation.  What is really interesting is I’ve been informed that during the hearing, the judge repeatedly asked Troll Hierl if he was going to dismiss Doe #17 based on what he was hearing.  Troll Hierl decided to ignore the request/suggestion from the court – probably not the smartest thing.

Troll Response To Doe #17′s Motion

In its response, Troll/Plaintiff claims that -

  1. The AF Holdings decision is not controlling upon the court.
  2. There are material errors in the legal analysis in AF Holdings.
  3. Additional technical arguments relating to how BitTorrent works support joinder.
  4. The AF Holdings ruling was intended to punish and corral an out-of-control litigant, and its should not be extended to Plaintiffs who follow the rules.  {This is the one I nearly choked on when I first read it.}
  5. Defendant’s remaining arguments do not merit quashing the subpoena.

I hope this judge gets wind of Daniel Macek, Crystal Bay Corporation (CBC), and the apparent fraud associated with the bogus “Shelf-Company.”  I hope Doe #17 files some sort of a reply, as the judge is clearly open to the possibility of quashing the subpoena and severing the Does.  For now I will talk about the ridiculous claim that the AF Holdings decision was flawed.

Blackjack Analogy – A Refresher (Quote from the DC Appeals Court Decision)

But AF Holdings has provided no reason to think that the Doe defendants it named in this lawsuit were ever participating in the same swarm at the same time. Instead, it has simply set forth snapshots of a precise moment in which each of these 1,058 Does allegedly shared the copyrighted work snapshots that span a period of nearly five months. Two individuals who downloaded the same file five months apart are exceedingly unlikely to have had any interaction with one another whatsoever. Their only relationship is that they used the same protocol to access the same work. To paraphrase an analogy offered by amicus counsel at oral argument, two BitTorrent users who download the same file months apart are like two individuals who play at the same blackjack table at different times. They may have won the same amount of money, employed the same strategy, and perhaps even played with the same dealer, but they have still engaged in entirely separate transactions. And “[s]imply committing the same type of violation in the same way does not link defendants together for the purposes of joinder.” {My Emphsis}

In his response, Troll Hierl states that members of a BT swarm are more akin to a cooperating group of “card-counters” working together to gain an advantage against the Blackjack dealer.  He claims that joinder of ALL 36 Does in this case is proper because like the cooperation of the card-counters, the Does all took part downloading/sharing the same movie (torrent/SHA-1 hash file).  Where did Troll Hierl get this idea???  From our friendly German players – Daniel Macek.  If you remember, Daniel Macek is responsible for providing early discovery declarations to the Anti-Piracy Management Company (APMC) and the local Troll counsels.   Daniel_Macek_Cardcounting_EX4_02162(IL)

What the Troll doesn’t tell the court is that even with this pretty “card-counting” analogy add-on and explanation of the “Distributed Hash Table” and “Peer Exchange,” there is still NO evidence to show that ANY of these 36 Does shared ANY part of the movie with EACH OTHER.  Where is the “Cooperation” that makes the card-counting analogy work???  If there is direct evidence showing cooperation, please disclose it – not a simplistic claim based on the protocol.  The problem the Troll has is that they have NO records to back this up – Period – their system does not and cannot record this information.

BT Discussion

The Troll BT clients appear to other swarm BT clients a new swarm member (a leecher with no data to share).  It then makes its request for data from a swarm member (seeder or leecher).  When the Troll BT client get a small piece of data from a swarm member, it records the public IP address, date/time, as well as packet capture (PCAP) data showing how it got the data.  Their system may record all the data they obtained from various “individual” swarm members, but they have NO insight into which BT clients shared data between themselves.  They would need to actually be inside the individual systems to see and record who shares with whom.  The only basis for their claims of proper joinder is the SHA-1 hash file.

Consider This Scenario

A Troll files a case in the ILND against 25 public IP addresses that resolve back to this district.  The time frame of the alleged infringement is 30 days.  At the beginning of the monitoring period, only 5 of the 25 ILND swarm members are seeders and not sharing data between other seeders (they already have a full copy of the data).  So we can accurately state that no data exchange would have occurred between the seeders – only seeders to leechers AND leechers to leechers.  BUT, the Trolls do NOT show anything like this.  WHY???  Because their system ONLY records the data they obtain from “individual” BT clients/IP addresses.   They claim that since the hash files match and the jurisdiction is correct, joinder is appropriate.  What the Troll actually has is 25 “individual” records that their BT client received a small amount of data from the 25 BT clients on a date/time.  Possibly sufficient to file 25 single Doe cases, but nothing to support joinder.

BT Monitoring By The Trolls

The Trolls monitor for infringing torrent files belonging to their clients.  As the BT protocol is used world-wide, the IP locations are all around the world.  Now the Trolls may record ALL the data world-wide for a particular torrent/hash file, but I suspect for economy sake, they limit their actual recording to IP addresses in jurisdictions they file suit in.  Note: You may notice that we don’t currently have Malibu Media/X-Art or Voltage Pictures copyright infringement law suits in California.  That isn’t because no one in CA uses BT to infringe upon these Plaintiffs.  It is only because the Trolls choose not to ply their business model in an environment that doesn’t trust them and will raise uncomfortable question. Here is a quote from the APMC presentation dealing with the declarations Daniel Macek is responsible for providing to local counsels.

- paragraph 1 is a serious declaration that’s stating everything is true & accurate.
– paragraph 2 in regards to software consultant (i.e., he can talk about software issues), & we’re hoping the judge won’t question his qualifications too much. {My Emphasis}

My point with mentioning Troll BT “filtering” is it actually removes the BT clients that were probably more likely to have shared data among the swarm members in these cases.

Troll Actions Show Why Joinder Is Improper

IID1 - CopyWhen the Trolls filter their BT monitoring results to fit a specific hash file, jurisdiction, and time period, they are actually hurting themselves.  Why so???  Isn’t it proper to only file suits against the IP addresses in the proper jurisdiction???  It is proper to file cases in the right jurisdiction and have a single hash file, but by “filtering” the IP addresses they significantly reduce the probability that these swarm members actually shared data among themselves.

Going back to the previous scenario swarm of 25 BT clients filtered down to the ILND jurisdiction.  If we were able to remove the Troll filter, we may find out that for the same 30 day time-frame, there were actually 500 other “World-Wide” BT swarm members for this hash file.  That means that the ILND IP addresses only made up 5% of the world wide swarm (single hash file) for that time period.  NOTE: Swarm participant numbers can and do vary, but the likelihood that a majority came from ILND (or any single district) is ridiculous.  That means it is much more probable that a leeching member of this BT swarm got its data from a swarm member residing outside of the ILND jurisdiction – approx. 95% likelihood.  Percentages vary, but not in favor of the Troll.

Adding to the unlikely chance that two IP address in the same jurisdiction actually shared is the uncertain nature of BT client member’s connection to the swarm and the Internet in general.  How many swarm members disconnected from BT or simply turned off their computers for various lengths of time – hours, days, weeks???  This also does not take into account that fact that people who run BT are known to stop sharing some content.  I.e. a BT user downloads a file and decides he doesn’t like it, so he deletes the torrent file and data file.  He is no longer sharing it with anyone else.

So the Troll card-counting “cooperation” theory is weak and inaccurate at best.  BT users come and go from swarms all the time, just like at the Blackjack analogy shows. There is NO Troll records to show ANY individual BT swarm members shared files among themselves.  Note: I know that sharing among BT members does occur – it is the nature of the BT protocol.  But it is ridiculous to allow the Trolls to make these claims of joinder simply for the economy of their abusive business model.  The Trolls do not “follow the rules,” they simply play them to their advantage and totally avoid the “spirit” of the law – to the courts and the Does detriment.

DieTrollDie    “The Defendants have liable Plaintiff under the disguise of such childish and unsophisticated pseudonyms as ‘die troll die.’”  – a statement like that could cost you $11K!


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Where in the World is Darren M. Griffin? – Elf-Man v. Lamberson Case # 2:13-cv-00395 (WA)

26 Aug 14 Update

As of noon today, there has been ZERO response by Troll/Plaintiff concerning the claims by attorney Lynch that Darren M. Griffin and the Crystal Bay Corporation (CBC) are simply shams in a BitTorrent Copyright Trolling operation designed to milk settlements (thousands of dollars a piece) from ISP subscribers accused of downloading/sharing a GARBAGE movie (my opinion).

So what does this TOTAL lack of response indicate???  To me it indicates that Troll/Plaintiff has nothing to say or provide to the court that wouldn’t be laughed at OR dig a hole even deeper for them.  They already know they have lost this case; it is just a matter of how much the court awards defendant Lamberson.  The Troll doesn’t want to pay out any of their ill-gotten gains, but it is better than being given a Prenda Law-Like order to explain their operation in detail and show why they should not be stomped on by the court.  Judge Rice is a former prosecutor, so we hope the slimy Troll/Plaintiff antics pushed his buttons in just the right way.  Anything that comes from this court that slams or even questions the validity of CBC will be used by Doe Defender in the various Dallas Buyers Club cases that are in multiple jurisdictions.  If that happens, I expect to see a rush to dismiss cases.  Til then we laugh at Mike Meiers for being such a turd (another one of my opinions).

DTD :)


Attorney Lynch has filed his reply to the Troll/Plaintiff response to his motions for fees/costs and sanctions.  The documents are at the bottom of this article.   I will not go into great detail as it would be very long, but attorney Lynch points out very clearly that fees and cost associated with this case are warranted and in no way excessive.  Troll/Plaintiff was given multiple chances to shut this down and simply pay Defendant Lamberson’s fees/costs. It appears that Troll VanderMay really screwed up and didn’t follow the Anti-Piracy Management Company (APMC) Seven-step process for running these cases. Her grandiose mistake was naming people and serving them.

One “mistake” Ms. VanderMay made under the seven-step playbook was in filing a First Amended Complaint, naming defendants, and serving them – Step Six above. None of the other Elf-Man counsel did that. Indeed, each of the 14 other Elf-Man cases filed by counsel other than Ms. VanderMay follows the smooth seven-step pattern outlined above: (i) file, (ii) favor, (iii) serve, (iv) wait, (v) favor, (vi) repeat, (vii) withdraw.  {Doc #95, page 24}

Attorney Lynch makes a great case for sanctions based on recklessness, bad faith, and multiplying the matter needlessly. The more I read these documents, the more I have flashbacks of Prenda Law.

One area attorney Lynch covers in great detail is the fact that “Darren M. Griffin,” Crystal Bay Corporation (CBC), does not appear to be a real person.  Document #94 explains this in detail.  Attorney Lynch tells the court that even in all their responses, only Troll VanderMay bothers to briefly mention Darren Griffin.  All the others players are completely silent of this matter – the silence is telling.

No one from Elf-Man LLC vouches for Mr. Griffin. No one from Crystal Bay Corporation vouches for him. No one from Vision Films (who also used Mr. Griffin on its Elf-Man declarations) vouches for him. No one from APMC, IPP, Excipio or GuardaLey vouches for him.

Ms. VanderMay does not vouch for Mr. Griffin. She claims at page 10 of her Declaration, ECF No. 84, that “To this day I have no information which would suggest that anyone by this name played any role in the subject investigation.” Mr. Lamberson was accused of being “observed infringing” at 04:39:20PM on December 2, 2012. “Darren M. Griffin” submitted a declaration to the Eastern District of Tennessee, that he was responsible for observing Doe # 40 infringing Elf-Man at 04:19:53PM on December 2, 2012. “Darren M. Griffin” submitted a declaration to the District of Colorado, that he was responsible for observing Doe # 82 infringing Elf-Man at 5:07:08PM on December 2, 2012. How could he not be the witness to the “observation” of Mr. Lamberson’s accused infringement, when it comes directly between two of his other observations within the same hour? Ms. VanderMay’s ignorance of this point is an example of multiplication – if she had only inquired in October 2013, and told us all the truth, the case would not have gone forward.   {Doc #94, pages 6-7}

Griffin_GhostHe also points out that Mr. Griffin provided declarations for early discovery in 195 cases during the period of June 2012 – November 2013.    Doc_95-4_GriffinCases_ExhibitD_00395(WA)   Many of the Plaintiff are TCYK, Lynn Peak Productions, Power of Few, BKGTH Productions, Killer Joe Nevada, The Thompsons, etc.  If it is shown that Mr. Griffin is a “Ghost,” that means there is multiple violation of Title 18 § 1001, False Statements (Criminal charge) – AND that is just a start of the possible criminal charges – mail/wire fraud, etc.  This screams US Attorney interest.

So What Does All This Mean?

Well based on fact that we have multiple cases (i.e. Dallas Buyers Club) open that are still using Crystal Bay Corporation (CBC) declarations, via German Daniel Macek, this has the potential to explode on the Trolls.  This may also affect Malibu Media cases, as the BitTorrent monitoring company and related personnel used to support Malibu Media appear to be the same, just using different names.

I expect the Trolls (and their bosses) to be watching what the judge does here.  If he decides to demand further information on Darren Griffin, or even have him appear in court, I expect a mass exodus to kill any cases related to CBC.  More to come on this; now we wait on the court.

I leave you with this funny bit from attorney Lynch.

We do not request over 50 hours of legal intern and staff time in legal research and the continued investigation into the existence of Elf-Man LLC declarant “Darren M. Griffin,” including the many activities necessary to prove that a fictitious person is fictitious when the fictitious person fails to claim whether or not he is fictitious, even after being directly accused of being fictitious.  {Doc #92, page 8}

DieTrollDie :)   “May thy knife chip and shatter.”  {Fremen taunt, Dune}

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Darren M. Griffin, Crystal Bay Corporation: Doesn’t Pass the Duck Test – Possible FRAUD Upon The Courts

Time for a Duck Test again. If you are unfamiliar with this term, it simply means that if something looks like a duck, swims like a duck, and quacks like a duck, then it probably is a duck.

On 4 Aug 14, Michael Patzer, Excipio GmbH, disclosed that the “Forensic Investigative Service” provider, Crystal Bay Corporation (CBC), a South Dakota Shelf-Company, contracts its BitTorrent monitoring systems/servers from Excipio GmbH (Germany).  [Also see this article]   Doc_89_Decl_MichaelPatzer_Rule 11_00395(WA)   Not a great shock, as we assumed that the German BT monitoring companies were behind this aspect. What has been a bit of a mystery is who is “Darren M. Griffin,” “software consultant,” that CBC uses to support various Copyright Troll cases.  Mr. Griffin is responsible for providing declarations that justified the early discovery of ISP subscriber’s information in multiple cases (with multiple different Plaintiffs) in the US.

Internet search are pretty sparse for Mr. Griffin.  The name is relatively common, but nothing matching a software consultant for a company (CBC) that provides forensic investigative services to copyright owners.  Couple that with the fact that CBC is a SD shelf-company run out of a mail-drop and it looks like Mr. Griffin doesn’t exists.  That or Mr. Griffin is another Alan Cooper (AKA: Fraud upon the court).  See the later part of this previous post for additional details on CBC.

Now I know some people are going to say that DTD is simply a pro-piracy lunatic and there is nothing suspicious about this.  Then I suggest the doubters (and judges!) need to look just a little deeper and not take what the Copyright Trolls have to say at face value.

Time For A Closer Look

I decided to take a small sampling of the declarations from Darren M. Griffin.  Note: I know there are plenty more out there, so please feel free to send me a copy of any Darren M. Griffen declarations you have.  Here are the five I used –   Decl_Griffin_01658(GA) Decl_Griffin_00603(TN) Decl_Griffin_00129(TN) Decl_DGriffin_02911(CO) Complaint_Decl_Griffin_00727(AZ)

I then took screen-shots of the signature portions of the declarations and grouped them together.  I guess signing your initials could be a signature – but it still seems very odd and suspicious IMO.  Take a look and tell me what YOU think.  I’m no hand-writing expert, but none of them look the same or even similar.  It looks like the stupid Trolls couldn’t even keep the signatures straight – How very Prenda of them.  I also want to point out that under two of the signatures is the number “60998770.1″ – If anyone has an idea of what this means, please contact me.




So do you think Darren M. Griffin passes the Duck Test?  My opinion is it sure looks like a “FRAUD” and not a duck.

DieTrollDie :)   “Rule #2: Double Tap” {Zombieland}


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