Dallas Buyers Club, Llc, Plaintiff, v. Vladamir IV Ashentsev, Defendant. Motion and Order

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

DALLAS BUYERS CLUB, LLC,

Plaintiff,

v.

VLADAMIR IV ASHENTSEV,

Defendant.

Case No.: 3: 15-cv-00220-AC

JUDGMENT AND ORDER

This matter before the court on plaintiffs motion, the court finds and ORDERS:

(1) Defendant Vladamir Ivashentsev has willfully infringed the rights of plaintiff in

violation of 17 U.S.C. 501, et seq.

(2) Defendant Vladamir Ivashentsev has willfully attempted to evade service and

refused to participate in these proceedings with notice.

(3) Defendant Vladamir Ivashentsev has been properly served by publication.

( 4) Statutory damages are proper to both compensate the plaintiff and provide notice

and to act as a deterrence to others. Sony BMG Music Entm't v. Tenenbaum, 660 F.3d 487, 500

(1st Cir. 2011), cert. denied, (U.S. May 21, 2012). To compensate the plaintiff and provide

proper notice and deterrence to others, statutory damages in the sum of $10,000 are awarded

plaintiff.

(5) A permanent injunction is ordered enjoining defendant from infringing plaintiffs rights in their motion picture, including without limitation using the internet to reproduce,

JUDGMENT AND ORDER Page 1 of2

Case 3:15-cv-00220-AC Document 34 Filed 10/02/15 Page 1 of 2

distribute or copy plaintiffs motion picture, and further directing defendant to destroy all

unauthorized copies of plaintiffs motion pictures and to delete all software used to make or

distribute those copies or exchange unlicensed content using the BitTorrent protocol.

(6) Defendant is fmther enjoined from using BitTorrent or the Internet for the copying or downloading of unlicensed copyrighted content.

(7) Plaintiff is awarded reasonable costs and fees to be determined pursuant to FRCP

54.

(8) Plaintiff shall effect service of this order by publication in a newspaper of general

circulation in the Portland, Oregon area.

MOTION FOR JUDGMENT AND ORDER Page 1 of 9

Carl D. Crowell, OSB No. 982049 email: [email protected] CROWELL LAW P.O. Box 923 Salem, OR 97308 (503) 581-1240 Of attorneys for plaintiff


DISTRICT OF OREGON

DALLAS BUYERS CLUB, LLC, Plaintiff, v. VLADAMIR IVASHENTSEV, Defendant.

Case No.: 3:15-cv-00220-AC

PLAINTIFFS MOTION FOR A DEFAULT JUDGMENT: DAMAGES AND PERMANENT INJUNCTION AGAINST DEFENDANT

Conferral

As evidenced by the general record and default entered in this action (Dkt. 31) plaintiff is

unable to confer with the defendant and does not know how to reach the defendant.

MOTION

Default being entered against defendant on September 14, Dkt. 31, plaintiff Dallas

Buyers Club, LLC, now moves for a Default Judgment and Order for damages and a permanent

injunction against defendant Vladamir Ivashentsev pursuant to FRCP 55.

As supported by the below memorandum, declaration of counsel and exhibits, plaintiff

respectfully request this Court enter a Default Judgment and Order against the defendant as

prayed for, including:

A. For entry of permanent injunction enjoining defendant from infringing plaintiffs

rights in their motion picture, including without limitation using the internet to reproduce,






B. Ordering defendant to refrain from using BitTorrent or the Internet for the

copying or downloading of unlicensed copyrighted content.

C. For statutory damages pursuant to 17 U.S.C. 504 in the amount $10,000.00 to

give the statute full force and effect and indicate to the general public that plaintiffs claims and

these proceedings should not be disregarded or ignored.

Plaintiff intends to separately file for costs and fees pursuant to FRCP 54.

MEMORANDUM

SCRA - 50 USC App. 521

On information and belief, defendant is not active in the military or subject to the

Servicemembers Civil Relief Act. 50 USC App. 521. Such status is supported by the

communications with the defendant and apparent social media. Decl. Counsel 13. Plaintiff does

not have defendants date of birth or social security number for an official verification. Id.

BACKGROUND

Plaintiff initially brought claims against the defendant as an unknown party and identified

the defendant as DOE-73.37.42.33. Dkt. 1. Plaintiff sought leave for initial discovery and with

leave of the Court subpoenaed ISP Comcast for the identity of the subscriber associated with

Internet protocol (IP) address 73.37.42.33. The subpoena response from Comcast identified

Vladamir Ivashentsev as the subscriber.

In the investigation of this matter, it was ascertained that Vladamir Ivashentsev was the

proper defendant, used BitTorrent, had been subject to prior BitTorrent copyright claims by other

rights holders though Rightscorp, Inc., infringed plaintiffs rights, continued to receive notices



from Rightscorp, Inc., continued infringing activity until he received notice of this suit. Decl.

Counsel 7. As recounted in plaintiffs Motion for Service By Publication in these proceedings

the defendant became non-responsive, evaded service, and eventually moved without providing

any forwarding address. Dkt. 23. Plaintiff was then served by publication pursuant to the Order

of the Court on July 23. Dkts. 25, 26. An Order of Default was then entered on September 14,

205. Dkt. 31.

Plaintiff has no knowledge of the current location of the defendant and though the

defendants telephone number still works and voice mail is left, phone calls are not returned.

Plaintiff has no other means to reach the defendant. Decl. Counsel 12.

ARGUMENT

Once a default is entered against a party, all allegations other than damages are presumed

to be true. Geddes v. United Financial Group, 559 F.2d 557, 560 (9th Cir. 1977) citing Pope v.

United States, 323 U.S. 1, 12, (1944). As such, the allegations of plaintiffs complaint are

deemed true and proven.

1. Plaintiff has proven copyright infringement.

To prevail on a copyright infringement claim a plaintiff must establish (1) ownership of a

valid copyright and (2) copying of constituent elements of the work that are original. Kelly v.

Arriba Soft Corp., 336 F.3d 811, 817 (9th Cir. 2003). Plaintiffs complaint, the allegations of

which must be taken as true, establishes both of these elements. Dkt. 14, 6,7, 26-29.

2. Defendants conduct was willful.

Statutory damages, discussed below, may be increased if the defendant willfully

infringed the plaintiff's copyright. 15 U.S.C. 504(c)(2). Allegations that a defendant acted

willfully are properly deemed to be true once the court enters a default. Derek Andrew, Inc. v.



Poof Apparel Corp., 528 F.3d 696, 702 (9th Cir. 2008). The admitted facts of this case dictate

that the defendant willfully infringed plaintiff DBC's registered copyrights warranting enhanced

statutory damages. Dkt. 14, 13-16, 28.

Further evidence is that defendant was a willful and persistent infringer downloading

hundreds of titles and disregarding multiple notices of infringement from Rightscorp, Inc. Decl.

Counsel 7. Nothing short of filing a civil suit could alter the defendants persistent infringing

behavior.

3. Plaintiff has suffered real harm.

It is sometimes lost on review of copyright enforcement actions that at the heart of this

case is the injury suffered by the plaintiff. In the present case, the motion picture Dallas Buyers

Club is a notable work winning numerous awards and contains the work of numerous actors,

actresses and others who invested their own time and money to bring their motion picture to

fruition. The result of the piracy by defendant and others is not only the loss of a few sales of

tickets or DVDs, but the erosion of an entire industry impacting countless people that contribute

to the final product as plaintiffs and parties like plaintiffs endure losses in the billions of dollars.1

4. Statutory damages should be of a sum sufficient to deter others.

[S]tatutory damages are recoverable without regard to the existence or provability of

actual damages. New Form, Inc. v. Tekila Films, Inc., 357 Fed. Appx. 10, 11 (9th Cir. 2009),

cert. den. 130 S.Ct. 2405 (2010). The United States Supreme Court has held that an award of

statutory damages within the limits prescribed by Congress is appropriate even for uninjurious

1 Projected 2015 digitally piracy value estimated between $80 billion and $240 billion. http://www.iccwbo.org/Advocacy-Codes-and-Rules/BASCAP/BASCAP-Research/Economic-impact/Global-Impacts-Study/ (Ref. June 1, 2015)



and unprofitable invasions of copyright. F.W. Woolworth Co. v. Contemporary Arts, Inc., 344

U.S. 228, 233 (1952).

For the present case it is admitted the actual economic damages suffered by plaintiff are

highly speculative. In the short period of observation from December 26, 2014 to February 22

2015, 176 titles were associated with the defendants IP address. Decl. Counsel, 8. It is

reasonable to assume that the defendants BitTorrent software was active and distributing

plaintiffs motion picture in association with each instance of observed activity. The defendants

BitTorrent software has the ability to facilitate the distribution of hundreds of copies a day, but

even at a 1 to 1 distribution event of one copy of plaintiffs motion picture for each additional

title observed, this would result in hundreds distributions of plaintiffs motion picture. With a

current list price of $29.982, this yields a plausible economic damages figure of thousands of

dollars. Even this figure, though with some rational basis, is admittedly highly speculative and

the actual economic damages are significantly greater, literally incalculable, though the

defendant is personally and directly only one contributor in a larger scheme.

The damages available in copyright claims are specifically designed to overcome their

speculative nature or the needs of a plaintiff to prove actual economic damages. But more

importantly the Copyright Act statutory damages have a specific focus on public harm and

deterrence due to the prevalence and disregard of the greater harm caused. As noted by Senator

Levin in Congressional hearings on peer-to-peer Internet piracy:

In the world of copyright law, taking someones intellectual property is a serious offense, punishable by large fines. In the real world, violations of copyright law over the Internet are so widespread and easy to accomplish that many participants seem to consider it equivalent to jaywalking illegal but no big deal. But it is a big deal. Under U.S. law, stealing intellectual property is just that stealing. It hurts artists, the music industry, the

2 http://www.amazon.com/Dallas-Buyers-Blu-ray-Digital-UltraViolet/dp/B00GUO3C3W (Ref. June 1, 2015; Note: $29.98 retail, discount price of $13.11.)



movie industry, and others involved in creative work. And it is unfortunate that the software being used called file sharing as if it were simply enabling friends to share recipes, is helping create a generation of Americans who dont see the harm. (Sen. Leven, Senate Hrg. 108-275, Sept. 30, 2003) In light of the cavalier attitude of those such as the defendant, many who willfully

disregarding multiple notices, and due to the failure of lesser damages being an effective

deterrent, Congress passed the Digital Theft Deterrence and Copyright Damages Improvement

Act of 1999, Pub. L. No. 106160, 113 Stat. 1774, increasing the maximum damages for the

activity of those such as the defendant from $100,000 to $150,000 to both serve plaintiffs

financial interests and to act as a deterrence to others. Sony BMG Music Entm't v. Tenenbaum,

660 F.3d 487, 500 (1st Cir. 2011), cert. denied, (U.S. May 21, 2012), ( many infringers do not

consider the current copyright infringement penalties a real threat and continue infringing, even

after a copyright owner puts them on notice that their actions constitute infringement and that

they should stop the activity or face legal action. In light of this disturbing trend, it is manifest

that Congress respond appropriately with updated penalties to dissuade such conduct. H.R. 1761

increases copyright penalties to have a significant deterrent effect on copyright infringement. )

For the Court to deny or minimize the statutory damages in this case would thwart the

intent of Congress for increased penalties to act as a deterrent, perpetuating the notion that online

theft is as much a right as many parties seem to believe. Id. Indeed, the record before this court

is that awards of minimum damages have had little impact and if anything have been used to

minimize the significance of the harm caused by defendant and these proceedings. Decl.

Counsel, 9; Exhibit 2, (Anti-enforcement tweet regarding damages of $750 in D. Or. 15-cv-

0002-AC Honestly I do not know why copyright troll Dallas Buyers Club even bothers in

Oregon.) Unless a willful and persistent infringer who repeatedly disregards notices is

subjected to more than the absolute minimum in damages, infringers and the public as a whole



will have difficulty appreciating the significance of plaintiffs claims or even the significance of

these judicial proceedings. Decl. Counsel, 10,11.

Plaintiff DBC asks the Court for a punitive statutory damages award pursuant to 17

U.S.C. 504(c) to effect the intent of Congress and for defendants willful infringement,

disregard or multiple prior notices and blatant disregard of these proceedings. The Court should

also consider that the defendant willfully disregarded these proceedings knowing full well that

the damages commonly being awarded in this District were the statutory minimum indicating a

general indifference to the harm cased by infringers. It is clear that the record minimum

statutory damages are not only an insufficient deterrence to infringers such as defendant, but

insufficient to even compel a defendant to appear and answer plaintiffs complaint or do more

than delay and obstruct plaintiffs enforcement of their rights.

Defendant knew that their conduct constituted willful infringement based on the

allegations of the complaint and observed disregard of prior notices. Dkt. 14, 19, 22. "[A]

willful infringer is exposed to a damage award higher not limited to [sic] the value of the

copyright holder's losses and/or the infringer's benefits. Statutory damages for willful

infringement have a punitive component of which the court must be mindful." Jackson v.

Sturkie, 255 F. Supp. 2d 1096, 1103 (N.D. Cal. 2003). Further, while plaintiff might normally be

permitted to conduct further discovery to ascertain the full scope of the damages at issue in this

case, defendant has intentionally foreclosed such opportunity by refusing to participate in this

process. Jackson, 255 F. Supp. 2d at 1101. As matters now stand, plaintiff only knows the

publicly available BitTorrent content associated with plaintiffs address, which continued well

after notices. Exhibit 1.



As such, plaintiff asks the court to consider the willful acts of the defendant, the statutory

intent of the Digital Theft Deterrence and Copyright Damages Act of 1999, and the very real

injury and needs of the plaintiff and film industry as a whole in setting an award of damages

which will make clear to the defendant and other potential infringers that copyright infringement

penalties are a real threat and that peer-to-peer file sharing causes real harm and award plaintiff a

multiplier for of the minimum damages for his willful infringing conduct, or the sum of

$10,000.00.

5. Plaintiff seeks injunctive relief against defendant in order to prevent continued

infringement.

Plaintiff has sought and is entitled to an injunction pursuant to 17 U.S.C. 501, et seq..

17 U.S.C. 502(a) authorizes an injunction to "prevent or restrain infringement of a copyright."

Defendant by default has admitted to the willful conduct in this case. Based on defendants

willful conduct and disregard of prior notices and these proceedings plaintiff maintains an

injunction is proper.

CONCLUSION

For the foregoing reasons, plaintiff respectfully requests that this Court enter a judgment

against the defendant as prayed for in the complaint, including:

A. For entry of permanent injunction enjoining defendant from infringing plaintiffs

rights in their motion picture, including without limitation using the internet to reproduce,




B. Ordering defendant to refrain from using BitTorrent or the Internet for the

copying or downloading of unlicensed copyrighted content.



C. For statutory damages pursuant to 17 U.S.C. 504 in the amount $10,000.00 to

give the statute full force and effect.

DATED: September 24, 2015.

/s/ Carl D. Crowell Carl D. Crowell, OSB No. 982049 email: [email protected] Crowell Law P.O. Box 923 Salem, OR 97308 (503) 581-1240


DECLARATION OF COUNSEL Page 1 of 3

Carl D. Crowell, OSB No. 982049 email: [email protected] CROWELL LAW P.O. Box 923 Salem, OR 97308 (503) 581-1240 Of attorneys for plaintiff


DISTRICT OF OREGON

DALLAS BUYERS CLUB, LLC, Plaintiff, v. VLADAMIR IVASHENTSEV, Defendant.

Case No.: 3:15-cv-00220-AC

DECLARATION OF COUNSEL IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT; EXHIBIT 1 & 2

Under penalty of perjury I, Carl D. Crowell, hereby state as follows:

1. I am an attorney admitted to practice in Oregon and plaintiffs counsel in this matter.

2. All matters in this declaration are submitted through personal knowledge and belief.

3. I have been an attorney practicing since 1998.

4. In investigation of this matter the defendant has confirmed use of BitTorrent.

5. In this matter once defendant received documents related to this case the defendant

become non-responsive.

6. The defendant actively and persistently evaded service and eventually moved without

leaving a forwarding address, requiring plaintiff to effect service by publication pursuant to the

order of the court.



7. In the investigation of this matter, it was ascertained that Vladamir Ivashentsev was the

proper defendant, used BitTorrent, and his IP address had been sent multiple BitTorrent

copyright notices and claims by rights holders though Rightscorp, Inc., yet continued infringing

activity including the infringement of plaintiffs rights, and still continued to receive notices

from Rightscorp, Inc., refusing to stop until he received notice of this suit.

8. Filed as Exhibit 1 is a record of BitTorrent activity observed associated with the

defendants IP address, which terminates abruptly on notice of this suit.

9. Filed as Exhibit 2 is an image of a Tweet referencing the $750 damages award D. Or.

15-cv-0002-AC, stating Honestly I do not know why copyright troll Dallas Buyers Club even

bothers in Oregon. And linking to a copy of the order awarding minimum damages of $750.

10. I believe that unless there is a clear message that more than minimum damages will be

awarded for willful and persistent infringing activity, the risks of getting caught will not be a

sufficient deterrent for people to consider copyright infringing activity a serious problem.

11. I believe that unless there is a clear message that more than minimum damages will be

awarded for willful and persistent infringing activity, defendants will continue to disregard these

proceedings and even the orders of the court.

12. I have no knowledge of the current location of the defendant and though the defendants

telephone number still works and voice mail is left, phone calls are not returned. I have no other

means to reach the defendant.

///

///



13. Based on my conversations with the defendant I do not believe the defendant is in the

active military service and social media appears to indicate he is a private event DJ, but I do not

have a date of birth or social security number for independent confirmation.

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct.

DATED September 24, 2015.

CROWELL LAW /s/ Carl D. Crowell

Carl D. Crowell, OSB No. 982049 Email: [email protected] Tel: 503-581-1240


Exhibit 1 / Page 1 of 5

IP: 73.37.42.33 USDC Oregon 15-cv-00220-AC

No. IP Torrentname Category Date

1. 73.37.42.33 UHF (1989) [1080p] Video 2014/12/26-2015/01/15 2. 73.37.42.33 Fantastic Mr Fox (2009) [1080p] Video 2014/12/27 3. 73.37.42.33 Ace Ventura: When Nature Calls (1995) [1080p] Video 2014/12/27 4. 73.37.42.33 12 Years a Slave (2013) [1080p] Video 2014/12/27 5. 73.37.42.33 FileSick.com-WordWeb 7.1.rar Software 2014/12/27 6. 73.37.42.33 22 Jump Street (2014) [1080p] Video 2014/12/27 7. 73.37.42.33 Teenage Mutant Ninja Turtles (2014) [1080p] Video 2014/12/27-2015/01/26 8. 73.37.42.33 Blazing Saddles (1974) [1080p] Video 2014/12/27-2015/02/19 9. 73.37.42.33 A Haunted House 2 (2014) [1080p] Video 2014/12/27-2015/02/22 10. 73.37.42.33 Anna Karenina (2012) [1080p] Video 2014/12/31 11. 73.37.42.33 Muppets Most Wanted (2014) [1080p] Video 2014/12/31 12. 73.37.42.33 Tammy (2014) [1080p] Video 2014/12/31-2015/02/21 13. 73.37.42.33 The Hunger Games Catching Fire (2013) [1080p] Video 2015/01/02-2015/01/17 14. 73.37.42.33 The November Man (2014) [1080p] Video 2015/01/02-2015/01/20 15. 73.37.42.33 Madagascar 3 Europes Most Wanted (2012) [1080p] Video 2015/01/08 16. 73.37.42.33 Bad Country (2014) [1080p] Video 2015/01/08 17. 73.37.42.33 Better Off Dead... (1985) [1080p] Video 2015/01/08-2015/01/13 18. 73.37.42.33 Batman The Dark Knight Returns Part 1 (2012) [1080p] Video 2015/01/11-2015/01/12 19. 73.37.42.33 Into the Storm (2014) [1080p] Video 2015/01/11-2015/01/26 20. 73.37.42.33 Lucy (2014) [1080p] Video 2015/01/11-2015/02/11 21. 73.37.42.33 Dolphin Tale 2 (2014) [1080p] Video 2015/01/11-2015/02/20 22. 73.37.42.33 Just Cause (1995) [1080p] Video 2015/01/11-2015/02/22 23. 73.37.42.33 My Week With Marilyn (English) DVDRip Video 2015/01/12 24. 73.37.42.33 The Lorax (2012) [1080p] Video 2015/01/12 25. 73.37.42.33 Eternal Sunshine of the Spotless Mind (2004) [1080p] Video 2015/01/12 26. 73.37.42.33 Life of Pi (2012) [1080p] Video 2015/01/12 27. 73.37.42.33 Con Air (1997) [1080p] Video 2015/01/12 28. 73.37.42.33 Django Unchained (2012) [1080p] Video 2015/01/12 29. 73.37.42.33 Donnie Brasco (1997) [1080p] Video 2015/01/12 30. 73.37.42.33 A 2015/01/12 31. 73.37.42.33 [NIF Team] Log Horizon 2 - 12 Sub ITA (720p)[5A38C064].mp4 Video 2015/01/12 32. 73.37.42.33 How to Train Your Dragon 2 (2014) [1080p] Video 2015/01/12-2015/01/20

Case 3:15-cv-00220-AC Document 33-1 Filed 09/24/15 Page 1 of 5


33. 73.37.42.33 Predestination (2014) [1080p] Video 2015/01/12-2015/02/18 34. 73.37.42.33 Before I Go to Sleep (2014) [1080p] Video 2015/01/12-2015/02/18 35. 73.37.42.33 The Boxtrolls (2014) [1080p] Video 2015/01/12-2015/02/19 36. 73.37.42.33 The Book of Life (2014) [1080p] Video 2015/01/12-2015/02/19 37. 73.37.42.33 Blood Ties (2013) [1080p] Video 2015/01/12-2015/02/20 38. 73.37.42.33 Sex After Kids (2013) [1080p] Video 2015/01/12-2015/02/20 39. 73.37.42.33 TMNT (2007) [1080p] Video 2015/01/12-2015/02/22 40. 73.37.42.33 Gone Girl (2014) [1080p] Video 2015/01/12-2015/02/22 41. 73.37.42.33 The Good Lie (2014) [1080p] Video 2015/01/12-2015/02/23 42. 73.37.42.33 Brave (2012) [1080p] Video 2015/01/13 43. 73.37.42.33 Dogma (1999) [1080p] Video 2015/01/13 44. 73.37.42.33 Lost in Translation (2003) [1080p] Video 2015/01/13 45. 73.37.42.33 American Hustle (2013) [1080p] Video 2015/01/13 46. 73.37.42.33 Maleficent (2014) [1080p] Video 2015/01/13 47. 73.37.42.33 Edge of Tomorrow (2014) [1080p] Video 2015/01/13 48. 73.37.42.33 Transformers Age of Extinction (2014) [1080p] Video 2015/01/13 49. 73.37.42.33 Guardians of the Galaxy (2014) [1080p] Video 2015/01/13 50. 73.37.42.33 The Equalizer (2014) Video 2015/01/13-2015/01/25 51. 73.37.42.33 Dawn of the Planet of the Apes (2014) [1080p] Video 2015/01/13-2015/02/09 52. 73.37.42.33 Life (1999) [1080p] Video 2015/01/13-2015/02/10 53. 73.37.42.33 This Is Where I Leave You (2014) Video 2015/01/13-2015/02/19 54. 73.37.42.33 The Trip to Italy (2014) [1080p] Video 2015/01/13-2015/02/19 55. 73.37.42.33 Side Effects (2013) [1080p] Video 2015/01/13-2015/02/20 56. 73.37.42.33 Thunder and the House of Magic (2013) [1080p] Video 2015/01/13-2015/02/20 57. 73.37.42.33 Sin City A Dame to Kill For (2014) [1080p] Video 2015/01/13-2015/02/23 58. 73.37.42.33 2 Guns (2013) [1080p] Video 2015/01/13-2015/02/27 59. 73.37.42.33 Shanghai Knights (2003) [1080p] Video 2015/01/14 60. 73.37.42.33 Pocahontas (1995) [1080p] Video 2015/01/14 61. 73.37.42.33 Sherlock Holmes (2009) [1080p] Video 2015/01/14 62. 73.37.42.33 Hotel Transylvania (2012) [1080p] Video 2015/01/14 63. 73.37.42.33 Delivery Man (2013) [1080p] Video 2015/01/14-2015/01/15 64. 73.37.42.33 Beauty and the Beast (1991) [1080p] Video 2015/01/14-2015/02/01 65. 73.37.42.33 Reasonable Doubt (2014) [1080p] Video 2015/01/14-2015/02/10 66. 73.37.42.33 What If (2013) [1080p] Video 2015/01/14-2015/02/13 67. 73.37.42.33 In Secret (2013) Video 2015/01/14-2015/02/20 68. 73.37.42.33 The Machine (2013) [1080p] Video 2015/01/14-2015/02/21 69. 73.37.42.33 Catch Me If You Can (2002) [1080p] Video 2015/01/14-2015/02/22



70. 73.37.42.33 Soul Surfer (2011) [1080p] Video 2015/01/15 71. 73.37.42.33 Tangled (2010) [1080p] Video 2015/01/15-2015/02/01 72. 73.37.42.33 Mary and Max (2009) [1080p] Video 2015/01/15-2015/02/09 73. 73.37.42.33 Elysium (2013) [1080p] Video 2015/01/15-2015/02/11 74. 73.37.42.33 If I Stay (2014) [1080p] Video 2015/01/15-2015/02/13 75. 73.37.42.33 Dallas Buyers Club (2013) [1080p] Video 2015/01/15-2015/02/19 76. 73.37.42.33 Autmata (2014) [1080p] Video 2015/01/15-2015/02/19 77. 73.37.42.33 A Christmas Story (1983) Video 2015/01/17 78. 73.37.42.33 310 to Yuma (2007) [1080p] Video 2015/01/20-2015/01/28 79. 73.37.42.33 The Equalizer (2014) [1080p] Video 2015/01/20-2015/02/08 80. 73.37.42.33 A Walk Among the Tombstones (2014) [1080p] Video 2015/01/20-2015/02/18 81. 73.37.42.33 Fury (2014) [1080p] Video 2015/01/20-2015/02/19 82. 73.37.42.33 The Best of Me (2014) [1080p] Video 2015/01/20-2015/02/19 83. 73.37.42.33 Ronin (1998) [1080p] Video 2015/01/20-2015/02/22 84. 73.37.42.33 The Art of War (2000) [1080p] Video 2015/01/20-2015/02/23 85. 73.37.42.33 Arthur and the Invisibles (2006) [1080p] Video 2015/01/20-2015/02/27 86. 73.37.42.33 The Croods (2013) [1080p] Video 2015/01/21 87. 73.37.42.33 Ghostbusters II (1989) [1080p] Video 2015/01/21-2015/02/13 88. 73.37.42.33 Austin Powers - Goldmember (2002) [1080p] Video 2015/01/25 89. 73.37.42.33 Grown Ups 2 (2013) [1080p] Video 2015/01/25 90. 73.37.42.33 The Hobbit The Desolation of Smaug (2013) [1080p] Video 2015/01/25-2015/01/26 91. 73.37.42.33 St. Vincent (2014) [1080p] Video 2015/01/25-2015/02/18 92. 73.37.42.33 The Little Death (2014) [1080p] Video 2015/01/25-2015/02/18 93. 73.37.42.33 Mystic River (2003) [1080p] Video 2015/01/25-2015/02/19 94. 73.37.42.33 Monster House (2006) [1080p] Video 2015/01/25-2015/02/20 95. 73.37.42.33 Bachelor Night (2014) [1080p] Video 2015/01/25-2015/02/21 96. 73.37.42.33 Alexander and the Terrible, Horrible, No Good, Very Bad Day (2014) Video 2015/01/25-2015/02/27 97. 73.37.42.33 The Bag Man (2014) [1080p] Video 2015/01/26 98. 73.37.42.33 Dinner for Schmucks (2010) [1080p] Video 2015/01/26-2015/02/22 99. 73.37.42.33 Pain & Gain (2013) [1080p] Video 2015/01/27 100. 73.37.42.33 The Pirate Fairy (2014) [1080p] Video 2015/01/27-2015/02/20 101. 73.37.42.33 Oz the Great and Powerful (2013) [1080p] Video 2015/01/28 102. 73.37.42.33 Jack Ryan Shadow Recruit (2014) [1080p] Video 2015/01/28 103. 73.37.42.33 The Game (1997) [1080p] Video 2015/01/28 104. 73.37.42.33 Mr. Peabody and Sherman (2014) [1080p] Video 2015/01/28 105. 73.37.42.33 Batman Assault on Arkham (2014) [1080p] Video 2015/01/28 106. 73.37.42.33 Agora (2009) [1080p] Video 2015/01/28-2015/02/08



107. 73.37.42.33 Tokarev (2014) [1080p] Video 2015/01/28-2015/02/19 108. 73.37.42.33 Turbo (2013) [1080p] Video 2015/01/29 109. 73.37.42.33 Signs (2002) [1080p] Video 2015/01/29 110. 73.37.42.33 Conspiracy Theory (1997) [1080p] Video 2015/01/29-2015/02/22 111. 73.37.42.33 Snitch (2013) [1080p] Video 2015/01/31 112. 73.37.42.33 The World's End (2013) [1080p] Video 2015/01/31 113. 73.37.42.33 Monsters Inc (2001) [1080p] Video 2015/01/31-2015/02/18 114. 73.37.42.33 Fading Gigolo (2013) [1080p] Video 2015/01/31-2015/02/20 115. 73.37.42.33 Snake Eyes (1998) [1080p] Video 2015/02/01-2015/02/10 116. 73.37.42.33 Clear and Present Danger (1994) [1080p] Video 2015/02/01-2015/02/11 117. 73.37.42.33 The Devils In The Details (2013) [1080p] Video 2015/02/01-2015/02/22 118. 73.37.42.33 Pirates of the Caribbean - On Stranger Tides (2011) [1080p] Video 2015/02/03 119. 73.37.42.33 The Monuments Men (2014) [1080p] Video 2015/02/03 120. 73.37.42.33 The Matrix (1999) [1080p] Video 2015/02/08 121. 73.37.42.33 WALL-E (2008) [1080p] Video 2015/02/08 122. 73.37.42.33 Paranorman (2012) [1080p] Video 2015/02/08 123. 73.37.42.33 Despicable Me (2010) [1080p] Video 2015/02/08 124. 73.37.42.33 The.Hunger.Games.Mockinjay.Part.1.2014.720p.BRRip.XviD.AC3.SANTi Video 2015/02/08 125. 73.37.42.33 946_88888888service_brat_school_girl.wmv Video 2015/02/08 126. 73.37.42.33 Big Hero 6 (2014) [1080p] Video 2015/02/08-2015/02/19 127. 73.37.42.33 Dressed to Kill (1980) [1080p] Video 2015/02/08-2015/02/20 128. 73.37.42.33 Dumb and Dumber To (2014) [1080p] Video 2015/02/08-2015/02/20 129. 73.37.42.33 The Bourne Supremacy (2004) [1080p] Video 2015/02/09 130. 73.37.42.33 The Bourne Ultimatum (2007) [1080p] Video 2015/02/09 131. 73.37.42.33 Mulan (1998) [1080p] Video 2015/02/09 132. 73.37.42.33 Need for Speed (2014) [1080p] Video 2015/02/09 133. 73.37.42.33 The Maze Runner (2014) [1080p] Video 2015/02/09 134. 73.37.42.33 Austin Powers - International Man of Mystery (1997) [1080p] Video 2015/02/09-2015/02/12 135. 73.37.42.33 How the Grinch Stole Christmas (2000) [1080p] Video 2015/02/09-2015/02/19 136. 73.37.42.33 Star Wars Episode I The Phantom Menace (1999) [1080p] Video 2015/02/09-2015/02/19 137. 73.37.42.33 The Book of Esther (2013) [1080p] Video 2015/02/09-2015/02/19 138. 73.37.42.33 Austin Powers - The Spy Who Shagged Me (1999) [1080p] Video 2015/02/10 139. 73.37.42.33 My Bosses Daughter (2003) [1080] Video 2015/02/10 140. 73.37.42.33 This Is the End (2013) [1080p] Video 2015/02/10 141. 73.37.42.33 Virtuosity (1995) [1080p] Video 2015/02/10 142. 73.37.42.33 Broken (2012) [1080p] Video 2015/02/10-2015/02/20 143. 73.37.42.33 The Art of the Steal (2013) [1080p] Video 2015/02/10-2015/02/20



144. 73.37.42.33 The Pirates! In an Adventure with Scientists! (2012) [1080p] Video 2015/02/11 145. 73.37.42.33 Internet Download Manager [IDM] v6.21 Build 11 + Crack-REiS Software 2015/02/11 146. 73.37.42.33 Spider Man 2 (2004) [1080p] Video 2015/02/12 147. 73.37.42.33 Silver Linings Playbook (2012) [1080p] Video 2015/02/12-2015/02/19 148. 73.37.42.33 Epic (2013) [1080p] Video 2015/02/12-2015/02/19 149. 73.37.42.33 Despicable Me 2 (2013) [1080p] Video 2015/02/13 150. 73.37.42.33 Playboy Poland - January 2015 eBook 2015/02/13 151. 73.37.42.33 Horrible Bosses 2 (2014) [1080p] Video 2015/02/13-2015/02/19 152. 73.37.42.33 Natural Born Killers (1994) [1080p] Video 2015/02/14 153. 73.37.42.33 The League of Extraordinary Gentlemen (2003) Video 2015/02/18 154. 73.37.42.33 Hot Tub Time Machine (2010) [1080p] Video 2015/02/18 155. 73.37.42.33 Lucky Number Slevin (2006) [1080p] Video 2015/02/18 156. 73.37.42.33 The Call (2013) [1080p] Video 2015/02/18 157. 73.37.42.33 Foxcatcher (2014) [1080p] Video 2015/02/18-2015/02/23 158. 73.37.42.33 Madagascar Escape 2 Africa (2008) [1080p] Video 2015/02/19 159. 73.37.42.33 Stranger Than Fiction (2006) [1080p] Video 2015/02/19 160. 73.37.42.33 Die Hard 3 (1995) [1080p] Video 2015/02/19 161. 73.37.42.33 Die Hard (1988) [1080p] Video 2015/02/19 162. 73.37.42.33 Gangs of New York REMASTERED (2002) [1080p] Video 2015/02/19 163. 73.37.42.33 Traffic (2000) [1080p] Video 2015/02/19 164. 73.37.42.33 Night Train to Lisbon (2013) [1080p] Video 2015/02/19 165. 73.37.42.33 Spider Man (2002) [1080p] Video 2015/02/19 166. 73.37.42.33 2015/02/19 167. 73.37.42.33 The Hangover Part III (2013) [1080p] Video 2015/02/19-2015/02/20 168. 73.37.42.33 Speed Racer 92008) [1080p] Video 2015/02/20 169. 73.37.42.33 Lilo and Stitch (2002) [1080p] Video 2015/02/20 170. 73.37.42.33 Cold Comes the Night (2013) [1080p] Video 2015/02/20 171. 73.37.42.33 RoboCop (2014) [1080p] Video 2015/02/20 172. 73.37.42.33 Endless Love (2014) [1080p] Video 2015/02/20 173. 73.37.42.33 Spider Man 3 (2007) [1080p] Video 2015/02/20-2015/02/22 174. 73.37.42.33 Cloudy with a Chance of Meatballs 2 (2013) [1080p] Video 2015/02/21 175. 73.37.42.33 Tarzan (2013) [1080p] Video 2015/02/22 176. 73.37.42.33 2015/02/22


EXHIBIT 2


Documents

Dallas Buyers Club, Llc, Plaintiff, v. Vladamir IV Ashentsev, Defendant. Motion and Order