RECORD COMPANY, L.P., LONDON-SIRE )
RECORDS INC., LAFACE RECORDS, )
INTERSCOPE RECORDS, HOLLYWOOD )
RECORDS, INC., ELEKTRA )
ENTERTAINMENT GROUP INC., CAPITOL )
RECORDS, INC., BMG MUSIC d/b/a THE RCA )
RECORDS LABEL, ATLANTIC RECORDING )
CORPORATION, ARISTA RECORDS, INC., )
JERRY LEIBER, individually and doing business )
as JERRY LEIBER MUSIC, MIKE STOLLER, )
individually and doing business as STOLLER )
MUSIC, and PEER INTERNATIONAL )
CORPORATION, ))
Plaintiffs, ))
v. ))
SCOUR, INC., ))
Defendant. )
__________________________________________)
NATURE OF THE ACTION
1. Plaintiffs some of the country's leading motion picture studios (or their
affiliates), record companies, and music publishers bring this action for preliminary and
permanent injunctive relief and for damages to protect their copyrighted works from the
expanding piracy over the Internet that is resulting from the willful illegal conduct of defendant
Scour, Inc. ("Scour"). Scour is a for-profit enterprise that is in the business of copyright
infringement. Through its Scour Exchange (or SX) "file-sharing" service, Scour enables and
encourages its users to find and download digital files of plaintiffs' copyrighted motion pictures,
sound recordings, and musical compositions from the computer hard drives of other users and
to do so without permission of or compensation to plaintiffs. Simply put, Scour's service makes
it easy for people to obtain copies of copyrighted works hit movies and popular music
without the permission of or payment to the copyright owner.
2
SNIPPETS:
Plaintiffs some of the country's leading motion picture studios (or their
affiliates), record companies, and music publishers bring this action for preliminary and
expanding piracy over the Internet that is resulting from the willful illegal conduct of
Scour, Inc..
Scour is a for-profit enterprise that is in the business of copyright
to do so without permission of or compensation to plaintiffs.
motion pictures, the works of well-known recording artists and songwriters, and other
copyright laws and not lawfully available for copying and distribution.
commit and facilitate infringement, Scour has cultivated an extensive and rapidly growing user
copying of motion pictures, sound recordings, and musical compositions that are or will
Because the Internet offers
copyright owners of the lawful fruits of their labor and investment.
Plaintiff Twentieth Century Fox Film Corporation is a Delaware corporation and is qualified
Plaintiff Disney Enterprises, Inc. is a Delaware corporation and is qualified to transact
Plaintiff Motown Record Company,
Plaintiff BMG Music d/b/a The RCA Records Label is a New York
Plaintiff Jerry Leiber, individually and doing business as Jerry Leiber
International Corporation will be referred to collectively herein as the "Music Publisher
This is a civil action seeking injunctive relief and damages for copyright
encourages and allows New York residents to download illegal copies of plaintiffs' works.
The Studio Plaintiffs are United States motion picture studios,
available for unlawful and unauthorized copying and distribution over the
Each Record Company Plaintiff has the exclusive rights to,
infringe plaintiffs' copyrights, and it participates in, facilitates, and encourages the
hard drives they wish to make available for other Scour users to copy.
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