Multiple Hash Files In A Single Troll Case – Ripe For A Motion To Quash / Dismiss – Louisiana

30 Mar 12 Update

The following links are to two LA cases with multiple hash files.  The 4: Twenty Media movie is “Teen Anal Sluts” and West Coast Production movie is “Super Anal Black Cougars.” (Wow!  These are obviously great pieces of work that promote the progress of science and useful art (Article I, Section 8, Clause 8 of the U.S. Constitution, AKA: Copyright Clause) –




6:12-cv-00031 (Filed 10 Jan 12) – 4: Twenty Media Inc., v. SWARM SHARING HASH FILES
F1F946C2054A0F885AC01FB07A935F4F238DD391; AND DOES 1-1,341. 

6:12-cv-00670 (Filed 14 Mar 12) – West Coast Productions  Inc., v.  SWARM SHARING HASH FILES 7A41E9DDED8675F90CDDAC6F8E4E2311BABF14E7, 25600BE3C6CC4529AC4247FA9B6BCB8B530857EB, 8653511547D205181DB2B69D2C3B4F732947F3E4, CCDA1BA63666D12E05A652B91008180724F13AB1, D895A3C7A530DDD3C8CD7E0F7DEF6B43211F4E35, EB72BDD147682AF141C1574A78DD848D01C0CDDC, and Does 1-416

I plan to do another post concerning these ripe targets for a MTQ/D, but for now here are the complaints.  Complaint_00670(LA)  Complaint_00031(LA)  On 19 Mar 12, the judge authorized the Troll to serve the subpoena on the ISPs for both of these cases.  I haven’t examined the IP addresses yet, but I really doubt that all of the Does live in the LA jurisdiction.  For some reason the Trolls seem to think LA will be a good area to set up shop.  Well lets not make it too easy for them in this matter.   😉 

Also of note is a DMCA Takedown notice sent to on 5 Mar 12, for “Super Black Anal Cougars.” (DMCA_TC_00670(LA))  Nice try guys, but sending one notice to one torrent tracker site does show you are “actively” fighting piracy.  I must say that I haven’t had the chance to go over all the documents, but it doesn’t appear that any DMCA notices were sent to the ISPs for any of the 416 public IP addresses they recorded (IP_List_00670(LA)).  As they already have the ISP address, filing a DMCA takedown notice is so easy.  Why don’t you want to do them? 



D Cumberbatch brought some information to light concerning some Louisiana cases.  It appears the Troll is filing cases where multiple hash files are listed for the same movie in the complaint.  What I think the troll is trying to claim is that even if the hash file (mathematical calculation) is different, viewing the all files discloses they are actually the same movie.  Someone changed the file (edited it somehow) and then made it available via BT.  As they are the same movie, the Troll wants to claim they should all be lumped into the same copyright infringement case.  If anyone has links to these cases, please post a comment and I will update the post (Thanks D Cumberbatch!).

This type of case is a prime one for a MTQ/D because of improper joinder.  Why?

The Trolls argument (and I haven’t seen these complaints – correct me if I’m wrong) is that all the Doe defendants are joined because the movie is the essentially the same one.  FACT: The content of the movie may be the same, but the files allegedly downloaded/shared ARE NOT the same. 

As each file is different, a BT client treats it as a completely different (and it is!).  You have a better chance of winning the Mega-Jackpot lottery than getting the same SHA-1 hash number for two files (called a “collision”  -1 in 1,461,501,637,330,903,000,000,000,000,000,000,000,000,000,000,000)

Geek Speak:  Yes, I know that duplicate SHA-1 hashes can be produced if you have a large enough field of data to pull from.  That isn’t the point here.  The point is that they are the same general movie (maybe the title page was deleted or a scene or two was shortened), but they are different mathematically.  Plus as the Troll is using the SHA-1 hash file to show how “good” their evidence is, they cannot raise the collision issue as a smoke screen (prevented by “estoppel” –

Here are two files that basically the same.  The second one has a small Red dot added to the “B”.  It doesn’t change the overall content, but IT IS A DIFFERENT FILE.  See the SHA-1 hash for each one.   

SHA-1 Hash for BadE1 = 59AC0B7925A8CFB9615E07F6DF949108C43F21CF

SHA-1 Hash for BadE2 = 56950F5128A72DFDDE9B461D9E1A566A1F11BC1F

Recent Court Orders

Recently an AZ and MI court severed all but Doe#1 in a case primarily because the Plaintiff could not show that ALL the Does downloaded/shared the single movie (only one hash file) entire period in question.  The Plaintiff claimed (as do all other Trolls I know of) that because the hash file is the same, they are properly joined.  Dismiss_Order_00108(AZ)  Dismiss_Order_15231(MI)

The court dismissed this idea on the sound logic that one Doe might have shared with other personnel and left the “swarm” never to return.  New Does could have joined the swarm and shared with others, but not all the Does.  As BT clients are located around the world, the court also stated it is also likely many of the Does shared with people not listed in the complaint, because Plaintiff was limiting its case to those within the jurisdiction to avoid improper joinder claims. 

Now add the fact that these LA cases have multiple different hash files and it raises even more doubt that All the Does in these cases shared ALL THE FILES for the entire period in question.  For most BT users, having multiple copies of essentially the same file/movie is a waste of time and unlikely to occur. 

I don’t know what the LA courts think of the Trolls and their cases, but it is worth a try to bring this up in a MTQ/D.  If you already have an attorney for one of these cases, please pass this information onto them.  Many courts seem to put less stock in what a Pro Se MTQ/D has to say than if a lawyer actually files it – Judicial snobbery if you ask me.        

DieTrollDie 🙂

“Some ships are designed to sink…other require our assistance”

About DieTrollDie

I'm one of the many 'John Does' (200,000+ & growing in the US) who Copyright Trolls have threatened with a civil law suit unless they are paid off. What is a Copyright Troll? Check out the Electronic Frontier Foundation link -
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32 Responses to Multiple Hash Files In A Single Troll Case – Ripe For A Motion To Quash / Dismiss – Louisiana

  1. Raul says:

    You made a maddeningly difficult concept understandable for a tech dummie and Freetard like me . Thanks once again!

  2. DieTrollDie says:

    Here is cut/paste from case6:12-cv-00031, 4Twenty v. Does 1-1341 (Teen Anal Sluts).

    “Of the 1,341 John Doe Defendants, geolocation technology places at least seven of them in the state of Louisiana (John Does 84, 118, 154, 183, 206, 722, 1225, and 1290). Upon information and belief, John Doe 154 resides in St. Mary Parish, Louisiana, which is within the Western District of Louisiana. John Does 154 and 722 happen to have identical IP addresses, and may or may not be the same individual, also participated in two of the Swarm Sharing Hash Files at issue in this suit.”

    The Troll could only could find Seven (7) LA IP addresses? Out of 1341 Does? It is also of some note that on 8 Mar 12, the Troll voluntarily dismissed WITHOUT prejudice 494 Does from this case. The 494 Does had COMCAST and Time Warner Cable as their ISP. Is the Troll trying to prevent the ISP lawyers from getting involved in this case? Interesting and sneaky. You will fail Trolls.

    DTD 🙂

  3. Sorry, accidentally hit “post” button…

    I haven’t examined the IP addresses yet, but I really doubt that all of the Does live in the LA jurisdiction.

    As for the first case, it is in the complaint. As I wrote in my post about Joseph “AnalTeenSluts” Peiffer,

    – Jurisdiction. This is simply laughable: only 7 of 1,341 Does reside in Louisiana, and Mr. Peiffer admits that.

    One particular statement regarding jurisdiction is arrogant and funny at the same time:

    Defendants nationwide purposefully availed themselves to the jurisdiction of this Court and should anticipate being haled into court in this State.

  4. Jr says:

    It’s funny, I’m in Louisiana visiting with family and currently have 2 unsecured connections from the neighbors. I don’t think people understand what the ramifications of this. I fixed one but the other lady knew she was sharing said thanks and baked me a pie. In both cases the set up was done by the cable company without a password.

  5. accused says:

    I am one of the accused in one of these LA cases.. I have been trying to get a lawyer but nobody understood or could take my case. My information from the isp will be released soon.. Too soon. How do i defend myself if my info is released and i still cant find a lawyer? I dont know what to do.

    • DieTrollDie says:

      Give the Troll the Richard Pryor Response when he calls. For many of the Does, having a lawyer file a motion for you is expensive and doesn’t work. If you are up to it and know there is nothing on your system, file the motion yourself. Bottom line: The Troll evidence is WEAK and they DO NOT want to take you to trial. They only want your money. Look at all the case history – they only threaten to take peole to trial. Default judgementas are even few and far between for the Trolls.

      DTD 🙂

      • gi says:

        But .they say they can get Information from ISP Provider and they will use that for Evidence

      • DieTrollDie says:

        The ONLY thing they will get from the ISP is (1) who was assigned the IP address for the specific date/time (You – Name, address, telephone number, email address) & (2) MAC address of your cable/DSL modem. There is NO real “Evidence” to show you did this. The public IP address is weak evidence and the Troll knows it. That is why they have been stating in court documents that the ISP subscriber may not be the actual offender and that is why they don’t name and serve people with summons.

        DTD 🙂

  6. Joe says:

    Talk to Nicolas Ranallo ( on resources tab of site ), or Rob Cashman ( ). They are TX and CA, but still may be able to point you in the right direction. Do a little research before calling any old torrent lawyer you find on google, as some have switched sides. To the best of my knowledge, the two above are “clean” 🙂

  7. eric says:

    I just recieved papers on this case yesterday. I found your site very informative, but im still not sure what to do. It is a scam, and a lie, the specific titles mentioned were not downloaded by me. after getting in trouble with my provider i stopped downloading anything months and months ago. The weird thing is that i have a static ip address, and both copies of the subpoena have different ip addresses on them. When I search for info on this case I end up on this website that will “sell” me court documents pertaining to the case. It seems like an elaborate scam. I am wondering wether I should contact anyone about this at all… anyone have any thoughts?

  8. Doe-eyed_Deer says:

    Raul, bill me! With the amount of work you guys have done, it’s like having free legal counsel and I am ever thankful for it.

  9. Pissed Off says:

    Ok so I just got sent a letter – filed in Pennsylvania by West Coast – So my ISP Century Link/Qwest is letting me know they have to give my IP info etc – I live in Washington – does this even apply to me? cause for concern ? grrrrrrr changing passwords right NOW!

  10. gi says:

    I just got that subpoena today .and how i should start step 1 ….please help me

  11. S. says:

    I just received the subpoena today with a letter from Comcast. I live in northern California and the IP address highlighted in Exhibit A does *not* match my IP address. Should I contact a lawyer? Should I contact anyone? Should I basically do nothing?

    • DieTrollDie says:

      As IP addresses change, you should contact COMCAST and verify that you were assigned the public IP address in question for the date/time period the Troll is claiming. If it isn’t you, then send a letter to the Troll informing him of this – still do not really talk to the troll – only what COMCAST tells you.

      If you were assigned that IP address for the date/time in question, you can either hire an attorney, file a motion Pro Se, or do nothing. If you haven’t read the Newbie/Noob section, do it now. If the case was not filed in the area you live, the Troll will have to file a new case in your jurisdiction. Unless you have money to burn, I would not hire an attorney at this point. For most people, I believe ignoring the Troll and waiting it out to be the best course of action. If you get a call from the Troll, give him the Richard Pryor response and hang up.

      If you can stand the heat, you may try your hand at filing a motion to quash/dismiss. It informs the court of relevant issues (improper joinder & No Does ever served with complaint summons) and causes more work for the troll. No guarantee it will work, but it isn’t going to hurt to try.

      DTD 🙂

  12. Shawn says:

    My wife got one of these letters since her name is on the ISP account. Needless to say she was beyond livid. Thanks to your site I see that we more than likely have nothing to worry about. I’ll be keeping a close eye on the case and have instructed my wife to use the Richard Pryor response if she receives any phone calls. We are in Oklahoma and not in Louisiana.

    Thank you for all the information. It is much appreciated.

  13. DJ says:

    I recently received a letter from my ISP stating that my info will be released. I did some research on the case # and determines this is the same case. I reside in LA currently, but I know for a fact that I did not DL this “movie”. I am in college and stay in an apartment complex with other individuals who had access to my Internet during that time. What are the chances that I will be brought upon trial. I would also like to know when and if I should hire an attorney.

    • DieTrollDie says:

      Bottom line: Slim to none. Don’t hire an attorney unless your are served a summons or deposition supoena. IMO

      If you can, file a motion and fight back. Otherwise give the Troll the Richard Pryor Response. The Troll will try to tell you are responsible and unless you give up information on who possibly did it (roommates or guests, etc.), you are at fault. LIES!!!! Keep good records and a log of what the Troll does. Don’t run away and make the Troll think you are a good canidate for a default judgement.

      DTD 🙂

      • John Deaux says:

        From what I gathered filing a motion to quash and not have my info, is potentially a waste of time seeing that I am in Louisiana and alot of motions do not get passed. However I could be wrong in thinking that.

  14. Doh! says:

    Has anyone gotten a status update on this case? I thought some motions were supposed to be decided on July 18th, but nothing on the docket reflects whether or not that happened? thanks!

  15. Basir Waahid says:

    Spoke to my lawyer here in Las Vegas and he basically stated what DTD has been saying all along. Until I am served a Supoena physically in my hand from the state of “Lousiana”, do nothing. If I didn’t mind the threatening letters or phone calls, he wasn’t going to file any dismissals. They also told me, if they do serve me from Louisiana, they’ll recommend me a lawyer in that state.

  16. Pingback: Paul Lesko, Simmons Law Firm, underage pornography and the end of trolls in Louisiana « Fight Copyright Trolls

  17. tammy says:

    My husband just received a letter from century link about a subpoena that is asking for our info on a 4-30-12 can anyone fill me on on this please..

  18. Pingback: The Thompsons Cases – Copyright Trolls Join Unrelated BitTorrent Activity | DieTrollDie

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