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ATTENTION: La version en français suit celle en anglais.
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Entertainment Software Association
601 Massachusetts Avenue, NW, Suite 300 West
Washington, DC 20001 USA
Attention:
Telus Communications
Re: Copyright Infringement by Telus Communications Subscriber
Using IP 154.20.236.185 on 2023-06-24T07:45:41.27Z (the "Subscriber")
Reference Number 222229268391
Dear Telus Communications:
The Entertainment Software Association ("ESA") is the U.S. trade association that represents the intellectual property interests of companies that publish interactive games for video game consoles, personal computers, handheld devices, and the Internet (hereinafter collectively referred to as "ESA members"). A list of ESA members can be found at www.theesa.com/about-esa/#membership. Under penalty of perjury, we affirm that the information contained in this notice is accurate, and ESA is authorized to act on behalf of ESA members whose exclusive copyright rights we believe to have been infringed as described below.
ESA is providing this notice pursuant to the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512, to request that you take immediate action with respect to infringement of ESA member copyrighted works by your Subscriber.
Using the IP address on the date and time referenced in the subject line of this notice, the Subscriber or someone using their account employed a peer-to-peer service or software to distribute one or more infringing copies of ESA members' games, including the following title:
WATCH DOGS: LEGION - PC
Additional details about Subscriber’s infringing activities are included in Exhibit A attached hereto. Courts in the United States have held consistently that the unauthorized distribution of copyrighted works using peer-to-peer or similar services constitutes copyright infringement. E.g., MGM Studios, Inc. v. Grokster, Ltd., 545 U.S. 913 (2005); BMG Music v. Gonzalez, 430 F.3d 888, 891 (7th Cir. 2005); Arista Records LLC v. Lime Group LLC, 2010 U.S. Dist. LEXIS 46638, *49 (S.D.N.Y. May 11, 2010).
This Subscriber should understand clearly that there are serious consequences for infringement. The US Copyright Act provides for statutory damages of up to $30,000 per work infringed, and up to $150,000 per work for willful infringement. See 17 U.S.C. § 504(c).
We ask that you work with us to protect the intellectual property rights of ESA members by:
1. Providing the Subscriber with a copy of this notice of copyright infringement, and warning the Subscriber that his or her conduct was unlawful and could be subject to civil or even criminal prosecution.
2. Promptly taking steps to stop the Subscriber's infringing activity.
3. Pursuant to 17 U.S.C. section 512(i)(1)(A), as appropriate, terminating the account of the Subscriber if your records show that he or she is a repeat copyright infringer.
ESA has a good faith belief that the Subscriber's reproduction and/or distribution of these copyrighted works as set forth herein is not authorized by the copyright owners, their agents, or the law.
Neither ESA nor its members waive any claims or remedies, or their right to engage in other enforcement activities, and all such claims, rights and remedies are expressly reserved.
Thank you for your prompt attention to this matter. If you have any questions or concerns, please do not hesitate to contact me at
[email protected]. Please include the Notice ID# from this email in any future communication.
Sincerely,
Intellectual Property Enforcement
Entertainment Software Association
Exhibit A - List of Infringing Content
List of infringing content
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WATCH DOGS: LEGION - PC
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INFRINGEMENT DETAIL
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Infringing Work : WATCH DOGS: LEGION - PC
