16 April 2003


Date:         Tue, 15 Apr 2003 08:18:51 -0700
Sender:       Law & Policy of Computer Communications <CYBERIA-L@LISTSERV.AOL.COM>
From:         Robert Cannon <rcannon101@YAHOO.COM>
Subject:      Re: DMCA notice -- what's required?
To:           CYBERIA-L@LISTSERV.AOL.COM

--- David Lesher <wb8foz@NRK.COM> wrote:
> A friend's ISP got served with an alleged DMCA
> notice.
>
> But:
>
> a) It's email.
>
> b) It's not from a studio or counsel's IP but
> "mightymouse.tronarx.net" (199.4.67.14) which itself
> has bogus DNS.
>
> What is required?
>
> c) And another issue: Many many mail hosts bounce
> mail with wonky DNS. What happens when the threat
> notice is bounced midst the other 1000's per hour 
> that are?
>
> Where is the bar for ""notice""...?


It is kind of hard to sign under oath an email notice.
An ISP has the opportunity to register a DMCA agent
with the LOC.  To be valid, notices are to be served
on the designated agent (and no one else at the ISP).

See 17 USC 512(c)(3):

512(c)(3) Elements of notification. -


(A) To be effective under this subsection, a
notification of claimed infringement must be a written
communication provided to the designated agent of a
service provider that includes substantially the
following:

(i)

A physical or electronic signature of a person
authorized to act on behalf of the owner of an
exclusive right that is allegedly infringed.

(ii)

Identification of the copyrighted work claimed to have
been infringed, or, if multiple copyrighted works at a
single online site are covered by a single
notification, a representative list of such works at
that site.

(iii)

Identification of the material that is claimed to be
infringing or to be the subject of infringing activity
and that is to be removed or access to which is to be
disabled, and information reasonably sufficient to
permit the service provider to locate the material.

(iv)

Information reasonably sufficient to permit the
service provider to contact the complaining party,
such as an address, telephone number, and, if
available, an electronic mail address at which the
complaining party may be contacted.

(v)

A statement that the complaining party has a good
faith belief that use of the material in the manner
complained of is not authorized by the copyright
owner, its agent, or the law.

(vi)

A statement that the information in the notification
is accurate, and under penalty of perjury, that the
complaining party is authorized to act on behalf of
the owner of an exclusive right that is allegedly
infringed.

(B)

(i)

Subject to clause (ii), a notification from a
copyright owner or from a person authorized to act on
behalf of the copyright owner that fails to comply
substantially with the provisions of subparagraph (A)
shall not be considered under paragraph (1)(A) in
determining whether a service provider has actual
knowledge or is aware of facts or circumstances from
which infringing activity is apparent.

(ii)

In a case in which the notification that is provided
to the service provider's designated agent fails to
comply substantially with all the provisions of
subparagraph (A) but substantially complies with
clauses (ii), (iii), and (iv) of subparagraph (A),
clause (i) of this subparagraph applies only if the
service provider promptly attempts to contact the
person making the notification or takes other
reasonable steps to assist in the receipt of
notification that substantially complies with all the
provisions of subparagraph (A).

END STATUTE QUOTE

See Hendrickson v. eBay Inc., Case No. CV 01-0495 RJK
(CD Cal. 2001): copyright owner's notice to Ebay was
deficient where it failed to have a proper signature,
failed to provide specific page where violation
occurred, and failed to include good faith statement
and statement that notice is accurate under penalty of
perjury.  The access provider is not required to sort
through all content based on non-specific allegations.

But Compare ALS Scan Inc. v. Remarq Communities Inc.,
239 f.3d 619 (4th Cir. 2001): Plaintiff's defective
notice made defendant aware that third party's use of
system was infringing, thereby eliminating service
providers immunity unless it acted.

COUNTER NOTICE PROVISION  17 USC 512(g)

(g) Replacement of Removed or Disabled Material and
Limitation on Other Liability. -

(1) No liability for taking down generally. - Subject
to paragraph (2), a service provider shall not be
liable to any person for any claim based on the
service provider's good faith disabling of access to,
or removal of, material or activity claimed to be
infringing or based on facts or circumstances from
which infringing activity is apparent, regardless of
whether the material or activity is ultimately
determined to be infringing.

(2) Exception. - Paragraph (1) shall not apply with
respect to material residing at the direction of a
subscriber of the service provider on a system or
network controlled or operated by or for the service
provider that is removed, or to which access is
disabled by the service provider, pursuant to a notice
provided under subsection (c)(1)(C), unless the
service provider -

(A) takes reasonable steps promptly to notify the
subscriber that it has removed or disabled access to
the material;

(B) upon receipt of a counter notification described
in paragraph (3), promptly provides the person who
provided the notification under subsection (c)(1)(C)
with a copy of the counter notification, and informs
that person that it will replace the removed material
or cease disabling access to it in 10 business days;
and

(C) replaces the removed material and ceases disabling
access to it not less than 10, nor more than 14,
business days following receipt of the counter notice,
unless its designated agent first receives notice from
the person who submitted the notification under
subsection (c)(1)(C) that such person has filed an
action seeking a court order to restrain the
subscriber from engaging in infringing activity
relating to the material on the service provider's
system or network.

(3) Contents of counter notification. - To be
effective under this subsection, a counter
notification must be a written communication provided
to the service provider's designated agent that
includes substantially the following:

(A) A physical or electronic signature of the
subscriber.

(B) Identification of the material that has been
removed or to which access has been disabled and the
location at which the material appeared before it was
removed or access to it was disabled.

(C) A statement under penalty of perjury that the
subscriber has a good faith belief that the material
was removed or disabled as a result of mistake or
misidentification of the material to be removed or
disabled.

(D) The subscriber's name, address, and telephone
number, and a statement that the subscriber consents
to the jurisdiction of Federal District Court for the
judicial district in which the address is located, or
if the subscriber's address is outside of the United
States, for any judicial district in which the service
provider may be found, and that the subscriber will
accept service of process from the person who provided
notification under subsection (c)(1)(C) or an agent of
such person.

(4) Limitation on other liability. - A service
provider's compliance with paragraph (2) shall not
subject the service provider to liability for
copyright infringement with respect to the material
identified in the notice provided under subsection
(c)(1)(C).

=====
| Washington Internet Project |
|     www.cybertelecom.org    |
|  cannon(a)cybertelecom.org  |


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