Thu 26 Jan 2012
Megaupload: A Lot Less Guilty Than You Think
Posted by jennifer under copyright/IP , crime[20] Comments
The recent Department of Justice decision to indict Megaupload for copyright infringement and related offenses raises some very thorny questions from a criminal law perspective. A few preliminaries: I’m responsible for the musings below, but I thank Robert Weisberg of Stanford Law School for taking the time to talk through the issues and giving me pointers to some relevant cases. Also, an indictment contains unproven allegations, and the facts may well turn out to be different, or to imply different things in full context.
DMCA SAFE HARBOR: BELIEVE IT AND IT WILL BECOME REAL: As a matter of criminal law, the discussion of whether Megaupload did what it needed to do to qualify for the DMCA Safe Harbor misses the point. Did they register an agent? Did they have a repeat infringer policy? These are all interesting CIVIL questions. But from a criminal law perspective, the important question is did Defendants BELIEVE they were covered by the Safe Harbor? This is because criminal infringement requires a showing of willfulness. The view of the majority of Federal Courts is that “willfulness” means a desire to violate a known legal duty, not merely the will to make copies.
In other words, for criminal liability, it doesn’t really matter whether the service qualifies, so long as Defendants believed it qualified. If so, they were not intentionally violating a known legal duty, and so their conduct would not satisfy the willfulness element of the offense. For criminal liability after the DMCA safe harbor, as in horseshoes, close may be good enough.
SECONDARY COPYRIGHT LIABILITY AND CRIMINAL LAW:
The heart of this case is whether and when an enterprise can be held criminally liable for the conduct of its users. (For example, both copyright infringement claims (Counts 4 and 5) identify aiding and abetting as a basis for the charge.)
Aiding and abetting is something like the civil liability inducement theory the U.S. Supreme Court created in the 2005 Grokster case. Experts opine that the indictment makes out a pretty good inducement case against Megaupload. But the first question from a defense perspective has to be “Can the Grokster theory of CIVIL liability even be the basis for CRIMINAL copyright claims?” This has never been decided by any Court.
However, the pending Second Circuit case of Puerto 80 Projects v. USA (“Rojadirecta“), raises the issue squarely. There, the plaintiff is challenging the ICE seizure of its Rojadirecta domain names based on an allegation of criminal copyright infringement. For background on the case, and on the ICE domain seizures, check out Techdirt’s coverage.
Rojadirecta’s lawyers at Durie Tangri have challenged the U.S. Government’s assertion that criminal liability arises from linking to infringing content. The lawyers argue that judge-made secondary infringement liability theories, including Grokster style inducement, cannot be the basis for a criminal copyright violation because the criminal copyright statute doesn’t mention secondary liability. Congress considered and rejected statutes that would have created such liability, in COICA and PROTECT IP. In sum, due process doesn’t allow incarceration under a civil legal theory that the Supreme Court dreamed up in 2005. The issues yet to be decided in Rojadirecta apply to the Megaupload case as well.
AGREEMENT + CIVIL VIOLATION = PRISON?: Count 2 is a conspiracy to commit copyright infringement claim, and references unknown parties as members of the conspiracy. Conspiracy entails an agreement to commit an offense and an overt act in furtherance of that agreement. The act in furtherance need not itself be illegal, but there must be an agreement to do an illegal act. The list of overt acts show that the object of the conspiracy was infringement by Mega users. If Defendants agreed with each other to induce others to infringe, and Rojadirecta’s lawyers are correct that inducement is not a crime, there’s a conspiracy only to violate a CIVIL law. If the idea is that Mega conspired with its users to infringe, those users may or may not have been criminally infringing copyright. They were located all over the world, and may or may not have acted willfully, i.e. intended to violate U.S. law. Again, the government would basically have alleged an agreement to violate a U.S. CIVIL law, including by many people who are not subject to U.S. rules.
Is it a federal crime to conspire to induce others to violate a U.S. civil law?
The answer to that is an obvious “no”. The conspiracy statute itself makes clear that the object of the conspiracy must be an offense or fraud against the United States, in other words, a federal crime. 18 U.S.C. 371. It is true that Oliver North and John Poindexter were prosecuted for conspiracy to violate Boland Amendment, which prohibited Defense Department spending on the Nicaraguan Contras, but was not itself a crime. And there is a 1979 case (U.S. v. Ruffin, 613 F.2d 408 (2nd cir. 1979), where the defendant was convicted of conspiracy when he convinced an unwitting person to divert federal funds to the defendant’s personal benefit. But both cases constituted fraud involving U.S.taxpayer dollars, which is also a basis for conspiracy liability. Civil violations simply are not.
For these reasons, prosecuting this case against Mega, especially if Defendants get good criminal lawyers who also understand copyright law, is going to be an uphill battle for the government.
A few other points. Some direct infringement convictions look easy, but COUNT 4 IS WEIRDLY INCOMPLETE: I agree with the copyright law experts interviewed by Ars Technica that the most damning allegations in the indictment are the claims of direct infringement, particularly for the prerelease movies. Interestingly, the indictment identifies four films that the defendants supposedly distributed before release: The Green Hornet, Thor, Bad Teacher, Twilight–Breaking Dawn Part 1. But Count 4 only charges one such act of prerelease infringement, the movie Taken. What about the other films? Why were those not also charged?
Finally, this case is extremely interesting from a JURISDICTIONAL standpoint. One of the very first issue to be litigated will be extradition to the United States. Does the United States have jurisdiction over anyone who uses a hosting provider in the Eastern District of Virginia? What about over any company that uses PayPal? That’s a very broad claim of power, and I expect it will be vigorously contested.
We are told that the MPAA lobbied the US government to participate in the action against iiNet (in Australia) which (so far at least) has failed.
I wonder if their strategy (in part) in the case of megaupload, was to go after somebody they believed would be so far outside normal corporate behaviour that they would face less attack for pursuit of the case.
Thanks for taking the time to write this up Jennifer! This was exactly the analysis I was hoping to find somewhere
Two points that distinguish this case from Roja, as far as direct liability goes:
a) Roja did not host the infringing content (point for Roja)
b) Roja did organize the links themselves (point against Roja)
While cases are very similar, I think the eventual ruling will decide whether one of these two things constitutes “wilfulness”.
Also, it is important to note that in Roja, dismissing the original complaint, judge ruled ‘Even
if criminal copyright infringement cannotbe based on allegations of
“contributory infringement” -and I donot so hold’ – so the door on indirect infringement is still wide open.
Your perspective gives me hope that the US government will fail in their attempt to charge megaupload
Back in the day. I remember finding plenty of megaupload links that were deleted by request of some giantic copyright holder.
I don’t really think MU is way too different from youtube. I think the only difference is that youtube hosts only videos and is owned by a US tech giant with a bunch of lawers. Both are services that people use for piracy a lot that would delete uploaded content if there is a valid request from a copyright holder.
Steve… Your hope may be fulfilled, but then what I would like to know is what penalty or punishment lies in store for the FBI under the authority of the US Federal government to deprive a person of his property (the business of Megaupload), without any hearing (due process of law).
This is the biggest problem we face. Even if the US wins its case against Kim Dotcom, et.al., they still dismantled the business without due process.
All of this is super fascinating. I saw this in the horizon but always assumed Youtube would be who the Government went after not some file hosting company…
Mega is a pretty good target for creating a precedent (or spearheading a power grab, or whatever you want to call it), because there is very little sympathy for Kim Dotcom at home in Germany. The opinion of our netizenship here usually is rather univocal when it comes to the long arm (and grabby hand) of Hollywood, but with the amount of animosity Kim Schmitz has stacked against him, there seems to be a notable part of the rather vocal community here that is willing to let this slide just to see that man suffer. hope we get to refocus on the bigger picture before too much room is conceded.
This is yet another example of the Americans flexing their muscles and dictating to other countries.
I have read the full indictment and believe that the US Government will lose for a number of reasons most of which have been covered above.
It is ridiculous to try to hold Mega responsible for the content stored on their servers.
Would a mobile phone company be help liable if a drug dealer were to use the service in order to arrange drug deals?
I think not!
I also think that their case has been unduly prejudiced even before it has stated and for that reason alone the case should be dropped.
I am of course referring to the title “Mega conspiracy” that has been attached to the defendants.
The dictionary has several meanings for the word conspiracy and they are:-
1) an evil, unlawful, treacherous, or surreptitious plan formulated in secret by two or more persons; plot.
2) a combination of persons for a secret, unlawful, or evil purpose: He joined the conspiracy to overthrow the government.
3) Law . an agreement by two or more persons to commit a crime, fraud, or other wrongful act.
The term “Mega Conspiracy” would instantly give the uninitiated the impression that the defendants were guity – long before they stand trial.
This is, if anything, a civil matter and the US Government should keep their noses out of this matter – unless of course the back handers that they are probably receiving from the music and film industry are too good to resist.
I really do hope that the US Government gets a good spanking in this matter.
I have a lot of questions!
Megaupload was taking down links upon receiving DMCA requests and they were fully aware it was a potential threat to Megauploads business model.
After all, they were getting those requests by the thousands.
Fortunately for them, their business was growing faster than they were getting those requests.
They knew it was something to keep an eye on.
That alone convinces me they “believed” they were covered.
But that does raise a question :
How fast do you need to take down (links to) copyrighted material ?
Consider this :
I read that some copyright owners were uploading their copyrighted materials to YouTube so they could submit thousands of DMCA requests (and perhaps get paid for the damages they suffered).
It gets worse, I saw an example where the copyright owners submitted DMCA requests, and among those were requests for files they didn’t even own the copyright to.
Things like this could easily ruin a business (because of the costs associated with take down requests) and turn someone into guilty in a matter of seconds because you will no longer “believe” your services are covered.
Reading your article, I guess it’s just a matter of time before Australia goes after the Megaupload guys, no ?
They have Australian citizenship!
My second guess is the US is not gonna waste time and they are gonna go after the users who violated the copyright. Or am I wrong about that ?
About your question : Does the United States have jurisdiction over anyone who uses a hosting provider in the Eastern District of Virginia?
If the answer is no, and you’re in the business of violating copyright, then all you have to do is use a server in a country that has no intentions of going after you.
I don’t think it’s ok to violate someone’s copyright, but what I don’t agree with is how they decide to shut down a business because of a bunch of accusations.
Can I issue take down requests and have the government take down a few financial institutions ? Would that work ?
Who’s gonna pay for all the damages when the Megaupload guys are found not guilty ?
One last thing, something not covered by the media.
Kim had communicated to his “employees” that he wanted to copy 100% of all the content on YouTube.
Based on your article, that doesn’t make him guilty, but it sure is interesting. I just wonder what motivated him to want something like that.
The NZ Judge noted (during bail proceedings) that the defendants appeared to have a good arguable defence against at least the IP infringement allegations.
What counted for extradition purposes was whether or not the alleged offences would attract a sentence of more than a year in NZ. The civil offences in general would not: but the criminal ones, including the money-laundering, would.
If the FBI is filing criminal allegations simply to get the civil offenders extradited and on US soil, that would explain the lack of attention to detail in the criminal and federal indictments.
We as non USA citizens will watch this case with a lot of concern. If the USA government wins this case what does this mean for anyone in the world? Does it mean that when it comes to the use of the internet, is everyone subject to USA law. Frightening thought and it would show who really owns and controls the internet, it’s content and it use. 😞
On the jurisdictional question, I can tell you that if you host content on a server that you know to be located in the Eastern District of Virginia, in litigation (civil or criminal) about whether that content is infringing you will be subject to the jurisdiction of the Eastern District of Virginia in 100 out of 100 cases. My understanding of this case is that the U.S. is indeed alleging that the defendants knew that the content was hosted on a server in Virginia (indeed, they allegedly intended it that way to speed up downloads to U.S. users).
So, if these fellows are convicted and imprisoned by an American court I suppose one of the big lessons will be that, yes, if you intentionally upload content to a server in the United States, for the purpose of better allowing users in the United States to join you in violating the IP laws of the United States, by infringing the IP rights of companies with major operations in the United States, you are subject to being brought to account in the United States.
(As you may have sensed, I’m not terribly sympathetic to the defendants here.
Nor, I’d wager, will the sentencing judge be if they are convicted.)
The jurisdiction issue is interesting. Large sites like megaupload mirror their content at different hosting sites spread around the globe. Thus, I suspect that the hosting location in the USA was just one of many. Does the “sufficient minimum contacts” test for long-arm civil jurisdiction of states apply to federal criminal actions by the US federal government? If jurisdiction in this case does turn on the location of hosting, why would any non-USA based firm ever host in the USA?
The other issue is why a New Zealand / Hong Kong to obey US Law?
If China/New Zealand pass similar law (DCMA?), does it mean China/New Zealand can use same reson to request FBI to catch who-ever in US?
US recognizes 195 independent countries around the world, does it mean US citizen could also subjective to other 195 country’s law?
[...] all the rules that should have given them an umbrella under the safe harbor provisions. In fact, according to legal analysis solicited of experts by Jennifer Granick of The Shout suggests that while Megaupload might have left themselves open to civil proceedings (which would [...]
In case anyone is interested in New Zealand extradition law a summary is provided by the Ministry of Foreign Affairs at: http://www.mfat.govt.nz/downloads/treaties-and-international-law/Extradition-Act-summary.pdf
There is also a relevant treaty at:
http://newzealand.usembassy.gov/uploads/images/o16y8MOyHW2l-jJTxaMpeQ/ExtraditionUSNZ.pdf
Just wanted to remind you all where it all started.
As Spanish citizen I was really surprised when I first heard that M. Alan Solomont (US ambassator in Madrid) was pushing spanish authorities in order to pass a SOPA/PIPA-kind Rule in Spain. All was aiming to one single target: prevent the broadcasting of the Superbowl last march 2011. Surprising thing is that such law got rid of the judges at a stroke and was approved at once. Therefore, the gov of Spain has now license to censore at will.
Spanish gov throught the pressume of US amabassator in Madrid, which was his own under the Big (notice the capital B) pressure of major companies, finally “convinced” Spanish authorities to pass the law.
As a result we have a law in Spain, which collides head on with our jurisprudence and Constitution.
In truth i’m really looking forward to see our first “Megaupload” case here in Spain because it is going to lead straight to a failure of the basic principles of separation of powers so jealously guarded by our constitution.
Just wanted to remind you all where it all started.
As Spanish citizen I was really surprised when I first heard that M. Alan Solomont (US ambassator in Madrid) was pushing spanish authorities in order to pass a SOPA/PIPA-kind Rule in Spain. All was aiming to one single target: prevent the broadcasting of the Superbowl trough Rojadirecta last march 2011. Surprising thing is that such law got rid of the judges at a stroke and was approved at once. Therefore, the gov of Spain has now license to censore at will.
Spanish gov throught the pressume of US amabassator in Madrid, which was his own under the Big (notice the capital B) pressure of major companies, finally “convinced” Spanish authorities to pass the law.
As a result we have a law in Spain, which collides head on with our jurisprudence and Constitution.
In truth i’m really looking forward to see our first “Megaupload” case here in Spain because it is going to lead straight to a failure of the basic principles of separation of powers so jealously guarded by our constitution.