(canada or even HK?)” ECHTERNACH responded, “In case domains are being seized from the registrar, it would be safer to choose a non-US registrar[.]” vvv.
On or about September 5, 2010, BENCKO sent an e-mail to DOTCOM,
ORTMANN, and VAN DER KOLK. Attached to the e-mail message was a screenshot of BENCKO logged into a Megaupload.com file download page with a filename of “Meet.Dave.2008.avi”. www. On or about November 1, 2010, ECHTERNACH forwarded an e-mail from a Universal Music Group (“UMG”) executive to DOTCOM and ORTMANN, which discussed requirements that UMG would require of Megaupload before they could discuss licensing for MegaBox. Included in the list of requirements was “proactive fingerprint filtering to ensure that there is no infringing music content hosted on its service; proactive text filtering for pre-release titles that may not appear in fingerprint databases at an early stage; terminate the accounts of users that repeatedly infringe copyright; limit the number of possible downloads from each file; process right holder take down notices faster and more efficiently.” xxx.
On or about November 15, 2010, BATATO forwarded an e-mail to
ORTMANN entitled “member-issue” that was received by a Mega Conspiracy employee from a user. In the forward, BATATO wrote “Fanpost ;-)”. The email from the user stated “I paid yesturday however can’t work it out!!!\ I have been trying to see Robin Hod, 3th season, chapter 10, and do not succeed. Please help me solve it – or cancel my payment!” yyy.
On or about December 10, 2010, DOTCOM forwarded a complaint from a
user that “Megakey is not working” to ORTMANN and VAN DER KOLK. In the forward, DOTCOM writes “this doesn’t work yet? we are advertising it. why is it not working?”. In the user’s e-mail, he complained that he installed Megakey, which provides Mega Conspiracy
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