Archive for the ‘infringement’ tag

Lawsuit against Aereo heads to the Supreme Court

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The New York-based startup Aereo has recently been making waves in the digital television world by creating a low-cost option for consumers to watch and record live broadcast television, providing a service similar to Internet-based streaming websites such as Hulu. Aereo, however, stands apart from these services: Aereo leases to each subscriber an individual remote antenna, allowing these subscribers to view and record certain live television broadcasts on Internet-connected devices without having to purchase a subscription to the entire broadcast packages offered by cable companies. Although Aereo has enjoyed tremendous success in the two years since its founding, Aereo has recently been embroiled in legal battles over whether its business model constitutes a public performance, which would legally require Aereo to obtain retransmission consent from the content providers. Last month, the District Court of Utah became the first to temporarily shut down the service. Judge Dale A. Kimball of the District Court of Utah granted a preliminary injunction sought by broadcasting companies such as Fox claiming that Aereo is stealing their broadcast signals for profit, shutting down Aereo’s services in Salt Lake City and Denver. Such injunctions have been previously denied in the New York and Boston. Aereo founder and CEO Chet Kanojia states that the television industry is terrified of Aereo, and that the company was “extremely disappointed” in the recent decision. Kanojia claims that the antennas used in this service must be treated the same as antennas that people use to pull TV signals for free. This argument rings true in one deep respect – any individual can travel to Radio Shack and upgrade their television antenna. Yet, retransmission is currently illegal, and Aereo has created a service that works around this by renting antennas and virtual connections, a method that is hanging on by a mere technicality. Broadcasting companies such as ABC, Fox, NBC, and CBS have the highest stake in seeing Aereo fall; they currently claim that Aereo is stealing their content, and that their practice could even lead to the end of broadcast television. Major broadcasters have expressed concern that cable providers, who currently pay broadcasters to the tune of $4 billion in transmission fees per year, may set up services similar to Aereo and will no longer pay fees, depriving broadcasters of all profit. American Broadcasting Companies v. Aereo will be heard in front of the Supreme Court in April, featuring “two American archetypes in a battle that could upend the television industry.” As the New York Times states, this decision will have “far-reaching implications for a television industry already in upheaval, facing challenges from online streaming, Internet-enabled TVs, ad-skipping devices, and now, the tiny antennas that Aereo uses to capture broadcast signals." The Aereo issue demonstrates the fundamental difficulty in technology and law – technology is outpacing law faster than ever, while legal standards struggle to keep up with ever-evolving industries.

Just a Playlist… or Something More?

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Music streaming service, Spotify, has yet again found itself at odds with a creator in the music industry. This time around, the disagreement centers on a more novel question: Does a compilation constitute copyrightable intellectual property? According to U.K. based dance-music record label, Ministry of Sound, it does. Ministry of Sound, or MoS, has recently filed a lawsuit in the U.K. High Court against Spotify, claiming copyright infringement. MoS produces compilation albums comprised of songs which the label has not itself created, but has selected and placed in a purposeful, specific order on the album. The record label’s “beef” with Spotify is grounded in the fact that the streaming service currently allows users to create playlists that essentially emulate the compilation albums. Further irritating the label, some users even go as far as to title those playlists “Ministry of Sound.” To be clear, the users are not illegally downloading the MoS albums; they are instead legally listening to the individual tracks through the streaming service and replicating MoS’ order of the tracks in their own playlists. After pleading with Spotify to remove these playlists since last year to no avail, MoS finally had enough and essentially said, “see you in court.” This case will turn on the issue of whether or not the order/structure of the content on MoS’ albums is copyrightable. But what are the odds that a court will actually determine that the compilation albums (in terms of their ordering of songs) constitute copyrightable material? The claim MoS is making is certainly deserving of at least some consideration. Factually, we can see how the artistic compilation of music is the result of a unique, creative process. This process may even require extensive research and hours of dedication to deriving the perfect order. For those reasons, there is an argument to be made that the end result of the process is an original work. Where MoS will likely find its greatest struggle in this lawsuit, however, is in showing that its compilation albums constitute a work original enough to be worthy of copyright protection. Since the filing of the lawsuit, many comments on the relevant articles and blog posts have shown disdain for the idea that taking music that someone else created, and placing it in a specific order on a playlist, could constitute anything that could even remotely be considered copyrightable, or truly original. When MoS’ albums are equated with mere playlists (which are viewed as lists that require no skill or real effort to produce) the future for MoS in this lawsuit against Spotify doesn’t look so bright. While the public consensus seems to be that MoS’ claim simply does not hold water, the worlds of music, technology, and copyright should certainly keep a close eye on this case, as the possibility exists that the UK court could side with MoS. This is an issue of copyright definition and protection that the courts have not yet faced (MoS is the first label to make this type of claim), and it could wind up being a real game changer for the industries involved. If MoS wins, this could strike a major blow to the business model of Spotify and other music streaming services that allow users to create playlists, as playlists are becoming an increasingly prevalent and important form of music consumption. If MoS loses, the compilation sales business model for MoS may prove unsustainable—will people continue buying the compilation albums when they can just recreate the same playlist for free on Spotify? Additionally, MoS’ claim could be the catalyst for similar claims to be brought in US courts. Through these cases, law and technology continue to shape the ways in which we view art and originality. In today’s world, where will the court draw the line of what is and is not art in the sense of copyright? To find out, we’ll just have to stay tuned.

Nortel Patent Failure Returns to Haunt Google

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Last week on October 31st, a nightmare scenario that Google hoped to avoid came to pass. Attorneys for Rockstar Consortium filed suit in the Eastern District of Texas against Google and seven handheld device makers that employ Google's Android operating system on their devices. The suit alleges infringement of seven patents all titled “Associative Search Engine.” The patents, 6,098,065; 7,236,969; 7,469,245; 7,672,970; 7,895,178; 7,895,183; and 7,933,883, were filed from 1997 to 2007. Rockstar Consortium was founded in 2011 and is jointly owned by Apple, Microsoft, Blackberry, Sony, and Ericsson. The consortium was founded to bid on the patent portfolio of Canadian telecom company Nortel, which was liquidated at auction in 2011 when the company went bankrupt. At the time, Google attempted to purchase the patents, likely to avoid just such a lawsuit, but their top bid of $4.4 billion was exceeded by Rockstar, which purchased the patents for $4.5 billion. Google’s failure to land the patents may now be costly for them as well as Android device makers. Rockstar is part of an emerging new trend in the “patent troll” movement where large corporations assign or give their patents to small companies, for the purpose of reverse engineering existing products and for extracting licensing fees and damages from alleged patent infringers. This model allows a company with few employees–Rockstar has only about two dozen employees, including ten reverse engineering experts–to obtain license fees from potentially hundreds of tech companies. A small consortium like Rockstar has another advantage in a fight against a tech company like Google, they have no products or business of their own. They cannot be counter sued for infringement because they have no business that would infringe. The crux of the situation is that companies like Apple and Microsoft can inject capital into a Rockstar type partnership, which will then purchase patents and use them to attack Apple and Microsoft competitors while leaving Microsoft and Apple above the fray. The companies backing Rockstar are likely seeking to put a damper on the rabid growth of the Android platform. However, with the talk of legislation to control patent trolls, the Obama administration’s concern over standards essential patents, and the Justice Department’s comments on Rockstar committing to fair terms for standards essential patent licenses, it will be difficult to predict the outcome of this suit. If Rockstar sees success here, this may become the new battlefront between tech companies in the aftermath of the monstrously expensive Apple v. Samsung case.

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November 8th, 2013 at 2:25 pm

Composers of Hit Song File Declaratory Judgment Action

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Faced with the prospect of copyright infringement lawsuits from Bridgeport Music, Inc. (“Bridgeport”) and Marvin Gaye’s heirs (the “Heirs”), the composers of the multinational hit song “Blurred Lines” filed a declaratory judgment action against Bridgeport and the Heirs in the United States District Court for the Central District of California on August 15, 2013.  Through this action, the composers, namely Pharrell Williams, Robin Thicke, and Clifford Harris, Jr., request that the court declare that “Blurred Lines” does not infringe Bridgeport’s composition “Sexy Ways” or Gaye’s composition “Got to Give It Up.” The lawsuit alleges that Bridgeport and the Heirs have continually insisted that “Blurred Lines” infringes their respective compositions and have stated an intention to file a lawsuit for copyright infringement if not compensated.   The composers, however, claim that “[t]here are no similarities between plaintiffs’ composition and those the claimants allege they own, other than commonplace musical elements.”  Instead, according to the suit, the composers “created a hit and did it without copying anyone else’s composition.” Generally, to establish a claim for copyright infringement a plaintiff must establish:  (1) copying of a prior copyrighted work; and (2) a substantial similarity to the prior copyrighted work sufficient to constitute unlawful appropriation.  A plaintiff can generally demonstrate the first element based upon evidence of access to the copyrighted work and similarity.  Here, it does not seem to be disputed that the composers had access to “Sexy Ways” or “Got to Give It Up.”  Indeed, according to the suit, the “intent in producing ‘Blurred Lines’ was to evoke an era.”  The question remains, however, whether the similarities between “Blurred Lines” and the prior works are sufficient to demonstrate “copying” and “substantial similarity.” To date, neither Bridgeport nor the Heirs have filed an answer to the composers’ complaint.

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September 29th, 2013 at 10:47 am

It’s the Sweetest Hat Ever!

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The relationship between the developer of a show, book, or other story and a fan is usually pretty straightforward.  The artist conceives, produces, and distributes a story, the fan consumes the story, and, if the fan really loves the story, consumes all sorts of official merchandise.  It's a win-win situation: the creator collects proceeds from the sales; the fan proclaims her love for the story by proudly displaying merchandise from her favorite creative endeavor. This relationship has grown increasingly tense, however, as sites like Etsy and deviantART enable individual fans of a series to create and sell their own art and merchandise.  Fan art is an external display of love for a creative undertaking, but when fan-developed products are sold, they begin to intrude on the copyright holder's commercial interests. Firefly was a short-lived television show (and basis for the movieSerenity) that developed, and continues to maintain, a large cult following of Browncoats (as fans of the show affectionately call themselves).  One popular piece of Browncoat flair has been the "Jayne Hat," a knitted hat based on the one received by tough guy Jayne Cobb from his mother in Firefly episode "The Message."  This past spring, FOX, the owner of the rights to the Firefly series, started sending cease-and-desist letters to fans selling handmade Jayne Hats on Etsy.  Not coincidentally, around the same time, FOX sold a license to mass-produce Jayne hats, and large retailers like ThinkGeek started selling the officially licensed version (ThinkGeek, not a business to thoughtlessly infuriate the customer base apparent from its name, quickly released a statement distancing themselves from the letters, and now donates all profits from the product to a Browncoat charity). FOX unquestionably has the legal right to stop commercial activity that infringes on its copyrighted material, even though enforcing that right gained the ire of the Browncoats with knitting skills (and their customers).  The owners of the rights to creative content with large fan bases, however, may want to consider the good-will ramifications of cutting down this kind of grassroots fan activity.  Suppressing the genuine love that fans demonstrate for their favorite shows, movies, and books can sour the same consumers that companies rely on to purchase Blu-Rays and licensed swag.  Indeed, FOX may have lightened its touch in this case: at the time of this writing, one can easily find relevant Etsy results for "cunning hat" (the generic term for the Jayne hat) and even a few good results for a home-made Jayne hat. FOX's actions are also a reminder to fans of all kinds to be aware and careful about the way they display their love for their favorite media.  With over 130,000 geeks attending ComicCon, just one of many similar fan conventions held each year, the fanbase for many creative endeavors can be a significant source of business.  Fans should be aware that by selling merchandise subject to copyright, they may be later cursing the sudden but inevitable betrayal of their favorite franchises when the copyright holder accuses them of infringement.

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September 15th, 2013 at 9:37 am

Video Games and Intellectual Property: Chrono Trigger Fan Remakes and Copyright Protection

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Before I start, I’d like to state that I realize that this topic has been beaten to death, but I’d like this to be a continuing series of posts on intellectual property issues in the video game community, and this situation is fairly straightforward and serves as a good introduction to the major issues at hand.

I’ll admit, Chrono Trigger is a very good game. I prefer Chrono Cross personally, but I understand why so many people consider it among the greatest games of all time. The story is lighthearted with some mature undertones, the battle system is simple to learn but has a surprising amount of depth, and the concept of traveling to different periods of time and having your actions affect future timelines was unique and well executed.

It should come as no surprise, then, that the strong fanbase would want more. Chrono Cross took a rather different approach to the series and was released over 10 years ago, and all fans have had since then are a PS1 port plagued with loading time issues and a DS remake that was well received but didn’t satiate long time fans. Long story short, they wanted a new Chrono game, one with updated graphics and a better connection to (or retcon of) Chrono Cross.

Several fan remakes started popping up starting from the early 2000s, but the most notable ones were Chrono Resurrection, Chrono Trigger: Crimson Echoes, and Chrono Trigger HD. Resurrection was a remake of the original game while Crimson Echoes was an interquel that tied together Chrono Trigger and Chrono Cross. These first two were notable in that Square Enix, owner of the copyrights and trademarks related to Chrono Trigger, sent cease-and-desist letters to the developers of these games claiming trademark and copyright infringement.

Square Enix’s arguments were very strong. As derivative works, 17 U.S.C. § 106 gives the original copyright holders the exclusive rights to prepare such works, so the fans had to seek permission before creating work with Square Enix’s copyrights. While the developers might have claimed fair use under 17 U.S.C. § 107, particularly because they would release the games for free, the preemption of sales that Square Enix would supposedly get by making its own remake is enough of an effect on the potential market to bar the fair use defense. Square Enix had them dead to rights.

Chrono Trigger HD, another attempt at a straight remake using the Unreal engine, is taking a different approach. They have no website and they will not include their names in the credits, hoping that Square Enix will not be able to find out who is infringing their IP. This logic, however, is deeply flawed. As has been noted by Mark Methenitisa fellow Greek IP lawyer?!—and Zack Bastian, just because they can’t find the original developers doesn’t mean that the game is any less illegal. They’ll use their resources to take down whatever public disclosures they can find, and if the developers want anyone to play the game outside their torrent circle, they’ll probably have to disclose at some point.

Go figure, the law student likes IP protection. Seriously, though, there are a lot of game IP that fans want revisited. Xenogears deserves a proper disc 2. A third Chrono game would sell like crazy. The movement for a Final Fantasy VII remake is stronger than ever. If The Last Story and Mass Effect 3’s Extended Cut have taught us anything, it’s that game companies are listening to fans. If Microsoft is willing to address their Xbox Live harassment issues because of fan promotion of this web video, Square Enix may be willing to hear out Chrono Trigger fans. Infringing their IP is only going to discourage them from creating new content, which is why we have IP protection in the first place.

Of course, this brings up the question of user-generated content in general, such as the mod kits in the Elder Scrolls games, map editors in Starcraft, and level creators in LittleBigPlanet. DayZ is an interesting case as well, being a mod of Arma 2 that eventually became a retail game. But that’s another post.

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September 27th, 2012 at 11:12 am

Here’s Some Food for Thought…

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Have you ever considered what the prices on a restaurant menu cover? Undoubtedly the prices cover the cost of food, the services of the chefs, waiters, busboys, and even the rent and furniture. But have you ever thought that these prices might cover the background music in the restaurant too? In Title 17 of the United States Code, Congress expressly conferred to copyright holders – composers, songwriters, lyricists, and publishers – the exclusive right to perform or authorize the performance of their works publicly.  The statute expressly defines both “perform” and “in public”.  To “perform” a work is “to recite, render, play, dance, or act it, either directly or by means of any device or process.”  The statute characterizes “in public” as either “(1) to perform or display [a work] at a place open to the public or at any place where a substantial number of persons outside of a normal circle of a family and its social acquaintances is gathered” or “(2) to transmit or otherwise communicate a performance . . . by means of any device or process, whether the members of the public capable of receiving the performance or display receive it in the same place or in separate places and at the same time or at different times.”  So, under these broad definitions, just playing a CD in a restaurant constitutes a “public performance” of those works. Although the statute does include certain enumerated exceptions, an infringer could otherwise be liable for severe financial sanctions: statutory damages currently range from $750 to $30,000 per copyrighted work, or for willful infringement, the court may increase the award to $150,000. Just last year, the Eastern District of North Carolina found Raleigh’s Fosters American Grille liable for statutory damages in the amount of $30,450 for playing only four unlicensed copyrighted songs – and awarded $10,742.25 in attorney’s fees.  In 2008, the Eastern District of Pennsylvania found Schwenksville’s Crazy Carol’s Sports Bar liable for statutory damages in the amount of $16,000 for playing only eight unlicensed copyrighted songs – and awarded $4,830 in attorney’s fees.  Law’s Lunch & Dinner (Riverside, CA), The Vibe (Riverside, CA), Mad Dogs & Englishmen (Tampa, FL), Empire Dine & Dance (Portland, ME), Doug’s Burger Bar (Imperial, MO), Foxy Lady Club (Raleigh, NC), Vanishing Point Bar and Grill, (Mt. Airy, NC) Ron’s Landing (Hampton, NH), Bolero Resort & Conference Center (Wildwood, NJ), and Bacchus (New Paltz, NY) are but ten of the thousands of other restaurants in this country that have been sued for illegally playing songs without proper licensing. A fine to that tune might seem rather severe, but our law nonetheless protects owners of musical works.  It assumes that the owner of a musical work has the right to be paid for use of his property.  Back in 1917, Justice Oliver Wendell Holmes, Jr. wrote that musical performances in restaurants are not “eleemosynary” but rather, “are part of a total for which the public pays” Herbert v. Shanley, 242 U.S. 591, 594 (1917).  While “music is not the sole object [of a patron’s visit to a restaurant],” he continued, “neither is the food, which probably could be got cheaper elsewhere. The object is a repast in surroundings that to people having limited powers of conversation or disliking the rival noise give a luxurious pleasure not to be had from eating a silent music.”  Justice Holmes believed that without pay, music would simply “be given up.”  He thus found it necessary to incentivize the production and dissemination of new works in order to serve the Constitution’s Congressional mandate: “To promote the Progress of Science and useful Arts, by securing for limited Times to Authors and Inventors the exclusive Right to their respective Writings and Discoveries.” No doubt, Justice Holmes saw the copyright owner’s exclusive right to perform or authorize the performance of their works publicly as an incentive that was indispensible to this end. What do you think? Should restaurateurs have to pay just for playing their iPods at their restaurants?

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May 30th, 2012 at 12:00 pm

Paramount Pictures Speaks to Michigan Law Students about Online Piracy, Cyberlockers

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Last month, copyright students at Michigan Law were able to engage in a Q&A after a presentation from Alfred Perry, the VP of Worldwide Content Protection at Paramount Pictures. The topic? SOPA, PIPA, and the legal issues that surround file-sharing websites, like the recently indicted Megaupload. Many students were eager to engage in a discussion with a representative of the movie industry, especially given the current debate over the Stop Online Piracy Act, and the possibility of future copyright legislation that would address online infringement. As a copyright student myself, I was anxious to hear what a representative of a company that advocates and supports these recent legislative initiatives had to say. During the presentation, I was most impressed by the emphasis that was put on the problem with cyberlockers- online file storage providers. While they have completely legitimate uses such as storing documents, and sharing files, some users post pirated content of movies or TV shows. It seems that major media companies are targeting these sites- Mr. Perry said that "We continue to make criminal referrals." Paramount Pictures stated that their content is not being protected adequately by the current laws. However, these cyberlockers are bound by the Digital Millennium Copyright Act, and are obligated to take down infringing content when given notice that it has been posted. During the presentation, five cyberlockers were identified as "rogue" sites- Fileserve, MediaFire, Wupload, Putlocker, and Depositfiles. In a later email, Mr. Perry explained that "My use of the term 'rogue' was meant to designate those cyberlockers which would fall within the definition of a foreign infringing site." However, MediaFire is a cyberlocker that is located in Texas.  They recently released a press release that addressed these claims. The owner, Tom Landridge said  "MediaFire continues to cooperate fully with the MPAA, RIAA, and various other organizations who work to identify and prohibit the distribution of copyrighted content. We have a variety of advanced automated systems designed to detect violations of our Terms of Service and automatically warn and terminate users." It appears that the war between media companies and cyberlockers is only just beginning. Although it is apparent that studios do not like these companies, there doesn't seem to be a ready solution. Cyberlockers provide a legitimate service, used by many for legitimate purposes. The recent firestorm has caused two sites- Wupload and FireServe to become backup sites, disabling all fire-sharing to avoid the risk of criminal prosecution. While media companies might rejoice, I believe this points to a bigger problem- the media industry business model. Mr. Perry in an e-mail to me, stated "Looking forward, why would anyone invest in an innovative new distribution service if they believed that there would be no legal protection for their fantastic new platform, forcing it to compete with rogue sites that pirate all of their product?". However, this belies the point that these cyberlockers are innovative- it is the reason they receive 41 billion page views a year. While there is no easy solution, and stolen content is a problem, it might be in the best interest of both cyberlockers and the entertainment industry to work together moving forward- sparing cyberlockers the fear of criminal prosecution, and innovating the media distribution business model.

Bollywood & Hollywood: Opportunity for Collaboration through Reform of Policies Governing Copyright and Plagiarism

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The Bollywood film industry has been using ideas from foreign films since its inception. This “borrowing” has ranged from melodies for background scores to entire plot summaries and even translated dialogues. However, with the advent of technology and the increasing popularity of Bollywood cinema in the United States, we are beginning to see American film producers “borrowing” Bollywood film elements as well. Prominent examples are the use of the Bollywood song “Chamma Chamma” from the Hindi movie China Gate as a dance number in Moulin Rouge; the use of the Bollywood song “Chaiyya Chaiyya” as the title song for the Hollywood movie Inside Man; and the Black Eyed Peas sampling of songs from both Don and Apradh on the track “Don’t Phunk with my Heart”. The media exchange between both nations is increasing as Bollywood actors and directors are entering the Hollywood industry while Hollywood filmmakers and production companies are trying to break into the Bollywood media market. As the cross-border media sharing intensifies, the need for answers regarding legal implications for both nations increases. While both countries have copyright statutes and are signatories to numerous treaties regarding intellectual property rights there is a lack of enforcement of these provisions in the Indian courts. There is a great need for international collaboration between the United States and Indian governments to work towards a solution to this legal issue. As evidenced by the Indian High Court’s ruling against Will Smith’s production company’s suit against the Bollywood producers who re-made Hitch without permission, the two governments have vastly different approaches to intellectual property rights enforcement. Without some way for Hollywood and Bollywood film producers to compromise and reach a mutual understanding regarding sampling each other’s productions, the creativity that could be fostered by increased communication is hindered. Furthermore, without some sort of reprimand for producers who abuse their “sampling” privileges and effectively steal whole works of others, relations between these two film industry giants will be frayed. For further reading on this topic, check out this, this, & this.  

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March 20th, 2012 at 2:54 pm

Free Speech Online is No LOL Matter to the American Public

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The people have spoken—and the people want their digital freedom! As the 112th Congress found out just last week, the prospect of the federal government infringing on the open and free Internet has been both politically tumultuous as well as philosophically unpopular in the eyes of the American Public.

Currently, the Digital Millennium Copyright Act governs copyright infringement activities which take place on the Internet. Yet, there was a growing sense among some in the entertainment industry--and in Congress--that this Act was not doing enough to protect IP rights. So, lawmakers responding to pressures from the entertainment industry devised a new bill to combat online piracy, developed two broadly worded anti-piracy bills--the Stop Online Piracy Act (SOPA) and the Protect Intellectual Property Act (PIPA). The move pitted Hollywood and its woes over unauthorized downloading, against Silicon Valley techies who claim that "the legislation would hand the government Orwellian powers over the Internet." However, just recently certain lawmakers--including the bill's co-sponsor Republican Sen. Marco Rubio of Florida--withdrew their support. Even the White House came out publicly against SOPA.

A key impetus to the sudden turn in popularity for the bills came from a staged anti-SOPA protest on January 18th from Internet sites such as Google, Wikipedia, and Craigslist.com. Wikipedia, for example, "went dark" and shut down completely. The site's co-founder, Jimmy Wales explained his concern in a recent CNN interview over the broad language in the bill, citing apprehension over the unprecedented amount of power the bill would give the government to take over the Internet and its content--Wikipedia and similar sites would struggle to function under the effects of SOPA due to the sheer number of links they would be required to check when posting content. Wales also affirmed his belief that "when it comes to First Amendment concerns, censoring the Internet is never going to be the right answer."

For now, Congress has put further debate on these bills on-hold, although it is clear that the fight is far from over. On January 21st the FBI shut down the file-sharing website Megaupload as part of what seems to be the federal government's theme for 2012: taking a hard anti-piracy stance. The debate also touches upon the existential question of whether Internet access is a basic human right or whether it is simply a vital tool which our society has obligations to guard against potential abuse in the face of an increasingly interconnected world.

For now, we can just remain thankful that the government has backed down and we are still able to catch up on missed episodes of Glee on various Megaupload-like sites--even if they have Japanese subtitles.

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February 4th, 2012 at 6:16 pm

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