2020-06-20 - Cam Model Protection / Nikocado Avocado: DMCA

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Null

Ooperator
kiwifarms.net
Joined
Nov 14, 2012
Editor's Note: I have no fucking idea who Suzanne T. Farrand is.

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From: CMP Legal <legal@cammodelprotect.com>
To: "legal@kiwifarms.net" <legal@kiwifarms.net>
Subject: DMCA NOTICE
Date: Sat, 20 Jun 2020 11:57:45 +0000

Dear Sir or Madam:

I, the undersigned, state under penalty of perjury that: Cam Model Protection represents Suzanne T. Farrand (hereinafter, "Our Client") in intellectual property and litigation matters. Our Client has recently learned that the content at the following URL(s) (hereinafter, "Listed URL(s)") is hosted and/or shared through your service, and the URL(s) are distributing materials that violate copyright laws, and/or contributes to and induces copyright infringement:


The content that is hosted and/or shared through your service illegally is premium content that is created and copyrighted by our client. You can find the original content at our client’s official website here: https://www.onlyfans.com/NikocadoAvocado

This unauthorized distribution constitutes copyright infringement under the U.S. Copyright Act. Pursuant to 17 U.S.C. 512(c), including other International Copyright Laws. This letter serves as actual notice of infringement. We hereby demand you to immediately and permanently cease and desist the unauthorized distribution of the copyrighted material located at the Listed URLs.

We will use all means possible including injunctions and recovery of attorney's fees, costs and any and all other damages which are incurred by Our Client as a result of any action that is commenced against you. Our Client prefers to resolve this matter without taking legal action, but it is prepared to file a lawsuit if necessary to protect its rights and business. You may avoid legal action by removing the infringing content from your service immediately.

We have a good faith basis that the content at the Listed URL(s) is an infringement of Our Client's rights under copyright law, including but not limited to the DMCA, and that the infringing content is authorized by neither Our Client nor the law.

Our Client requests that you immediately take down the web content located at the Listed URL(s).

Finally, the information in this notice is accurate. If you have any questions, please contact me at the email address or phone number listed below.

Sincerely,

Bruce Wyatt
IP Law Attorney

International Anti-Piracy Operations
Cam Model Protection B.V.
Jagerserf 7
3851SM Ermelo
The Netherlands
Phone: +31(0)85.303.1197
Email: legal@cammodelprotect.com

---

You have failed to directly link what material is infringing. The thread
itself is a discussion forum, whose individual posts and contributions
you do not have ownership of. What material could potentially be
considered the property of your client is used for the purposes of
criticism and ridicule, which is a transformative and fair use. See
Hughes v. Benjamin 2020.

In good faith, I do not believe this is a complete, valid, or otherwise
merited complaint.

Send servicing to this address.

Joshua Moon
913 Beal Pkwy NW
Suite A-1017
Fort Walton Beach, FL

Kind regards,
Josh
 

Jaded Optimist

Me Love You Long Time
True & Honest Fan
kiwifarms.net
Joined
Mar 4, 2015
I looked up 'Cam Model Protection" and I'm guessing Nikado pays for their cheapest plan. He is paying a whopping $169 (up to $469) a month for someone to send bad DMCAs.
Screenshot_2020-06-20-12-44-49-1.png
 

Shaka Brah

Patriotic Ass-Blasting Poster
kiwifarms.net
Joined
Jan 12, 2019
I hope this bitch gets paid a lot because it's not worth having "successfully took down a client's images of his gaping asshole that looks like a vagina which he purposely posted on the Internet for everyone to see" in your resume.
Judging by the payment page, she's extracting big bucks from these cows.
 

Shaka Brah

Patriotic Ass-Blasting Poster
kiwifarms.net
Joined
Jan 12, 2019
I fucking love that the case law cited in Null's response was Sargon of Akkad's case.

That being said, how fucking many of these foreign DMCA mills exist? Has Cam Model Protection ever won or even filed a lawsuit, or does it just spam scary-sounding legal threats?
It has to rankle that people are being BTFO'd by Sargon's case law. Also yeah a lot of these places exist. Lawyers are an unscrupulous group and plenty of them will fire off a DMCA no matter how stupid as long as you pay up. If you see a camwhore who has "DMCA Protected" slapped all over her screen, chances are she's suckered by one of these people (or using it like a magic talisman).
 

The Un-Clit

After the Dimensional Merge, pussy eats YOU!
True & Honest Fan
kiwifarms.net
Joined
Oct 11, 2014
I find it funny beyond all levels of schadenfreude that Nicocado and Dirty Sanchez actually start off their disgusting mugbang and assbang videos with the following disclaimer:
Nico hoist on his own petard.png


Yep. Protected criticism. As it is for everyone turning your disgusting faggotry into parodies and discussing the pair of yours horrible deformed cocks and dirty blown out assholes. So go away already.
 
Last edited:

Null

Ooperator
kiwifarms.net
Joined
Nov 14, 2012
Hi Josh,

All the following URLs contain our clients stolen content, please remove these for us. Thanks in advance;

https://kiwifarms.net/attachments/1587557675682-jpg.1248089/

https://kiwifarms.net/attachments/1585640250040-jpg.1248090/

https://kiwifarms.net/attachments/1585635687195-jpg.1248091/

https://kiwifarms.net/attachments/1585635651823-jpg.1248092/

https://kiwifarms.net/attachments/vlcsnap-2020-06-11-11h44m04s986-png.1389922/

https://kiwifarms.net/attachments/vlcsnap-2020-06-11-11h28m00s040-png.1389918/

https://kiwifarms.net/attachments/vlcsnap-2020-06-11-11h43m16s061-png.1389920/

https://kiwifarms.net/attachments/vlcsnap-2020-06-11-11h44m20s976-png.1389923/

https://kiwifarms.net/attachments/vlcsnap-2020-06-11-12h21m30s026-png.1389924/

https://kiwifarms.net/attachments/vlcsnap-2020-06-12-19h37m50s138-png.1389928/

https://kiwifarms.net/attachments/vlcsnap-2020-06-12-19h38m09s902-png.1389930/

https://kiwifarms.net/attachments/vlcsnap-2020-06-12-19h38m56s460-png.1389931/

https://kiwifarms.net/attachments/vlcsnap-2020-06-15-12h55m54s315-png.1389932/

https://kiwifarms.net/attachments/vlcsnap-2020-06-11-11h40m48s870-png.1389919/

https://kiwifarms.net/attachments/1378696/

https://kiwifarms.net/attachments/1379239/

https://kiwifarms.net/attachments/1380667/

https://kiwifarms.net/attachments/1383327/

https://kiwifarms.net/attachments/1363062/

https://kiwifarms.net/attachments/3840x2487_429ee52bad1a01c8841eb38d70519870-jpg.1363062/

https://kiwifarms.net/attachments/1363088/

https://kiwifarms.net/attachments/1363105/

https://kiwifarms.net/attachments/3840x2880_0df07d87ba14927cfaec006d110b471f-jpg.1363066/

https://kiwifarms.net/attachments/1024x768_d02f1a2bed8750df5cb1ec26448c85dd-jpg.1363059/

https://kiwifarms.net/attachments/3840x2880_13edb295e6ed00c5b02dd7b5891a7919-jpg.1363071/

https://kiwifarms.net/attachments/3840x2880_51fcb4eb9b5df1fcbbfe168f9580fed8-jpg.1363072/

https://kiwifarms.net/attachments/3840x2880_64c606c0d87603afac610a29e47ce458-jpg.1363074/

https://kiwifarms.net/attachments/3840x2880_98ce0373ce099affc715446ab33e3ed2-jpg.1363075/

https://kiwifarms.net/attachments/3840x2880_7869c6f9fd05fa5a010c65fe598269e2-jpg.1363078/

https://kiwifarms.net/attachments/3840x2880_64540e2a715277b392a7ff310faf2b8c-jpg.1363080/

https://kiwifarms.net/attachments/3840x2880_b87e05964d2522cc0e3030a71a1d58ce-jpg.1363082/

https://kiwifarms.net/attachments/3840x2880_c9bf957ec796c9ce9dcd0b0b62008aba-jpg.1363083/

https://kiwifarms.net/attachments/640x852_1a0f7fac0d327fd8356227b687a1b7ad-jpg.1363085/

https://kiwifarms.net/attachments/640x852_6c596ada5b2405cff566704cc1836e82-jpg.1363088/

https://kiwifarms.net/attachments/640x852_df6754cae92fe99c5337492b52d3f5c8-jpg.1363089/

https://kiwifarms.net/attachments/720x1280_4a4e5bd5329b0eca20f883bbe45a711e-jpg.1363091/

https://kiwifarms.net/attachments/749x862_628ff19ad78ee727f13cd11b4fd1f116-jpg.1363094/

https://kiwifarms.net/attachments/750x981_c25e4aae214eca6becf45d8dcab71f6c-jpg.1363095/

https://kiwifarms.net/attachments/768x1024_e4ba1588c4731c3cf1dd27fd7514cc41-jpg.1363097/

https://kiwifarms.net/attachments/1629x2172_8e71c2853d3947fe90b3175103099cf3-jpg.1363098/

https://kiwifarms.net/attachments/1632x1224_f58d305e01ef09b1f85a29d4cb59faad-jpg.1363099/

https://kiwifarms.net/attachments/2048x1536_3906ef907572ee4e9d3a9e98d15f8fcc-jpg.1363100/

https://kiwifarms.net/attachments/960x1280_b00c4b89e3d9851baf7941e64b840133-jpg.1363104/

https://kiwifarms.net/attachments/2448x3264_09c6d4b5b629e83e944a7891d77b46b9-jpg.1363105/

https://kiwifarms.net/attachments/1...c07b688a3a2b85161915dcb8c38edff1-jpg.1363118/

https://kiwifarms.net/attachments/3024x3024_ea98e8e10ff44a216f1e4860529e09fd-jpg.1363121/

https://kiwifarms.net/attachments/3024x4032_89868694bdacfe4d514ac533613af2d1-jpg.1363123/

https://kiwifarms.net/attachments/3635x2743_93e52e186370b77a3f299a660cc1af30-jpg.1363125/

https://kiwifarms.net/attachments/3840x2178_34a35b3595e1fc5165761224b7687757-jpg.1363126/

https://kiwifarms.net/attachments/46392258-7b14429d-1155-4b72-80e5-03e63230e65f-jpeg.1363128/

https://kiwifarms.net/attachments/480x640_745dc5e4590ed64b5171dcfe8b2b08a9-jpg.1363129/

https://kiwifarms.net/attachments/640x852_4e4b70f2a87c42d14669531710b48254-jpg.1363130/

https://kiwifarms.net/attachments/640x852_6332046b44a6c4759b8aecffcd890e83-jpg.1363131/

https://kiwifarms.net/attachments/768x1024_53be346ac15dc0237e6d732488c79f2c-jpg.1363132/

https://kiwifarms.net/attachments/3024x4032_69b796ac79c1b13fcd7f8555382a79ff-jpg.1363134/

https://kiwifarms.net/attachments/3088x2320_a4513afb551032bc0f3810c37acae6a1-jpg.1363135/

https://kiwifarms.net/attachments/3840x2880_64eb6456def69d4766f8a7da107da84a-jpg.1363137/

https://kiwifarms.net/attachments/3840x2880_6a0faaffb9aef34f06057aaa2d7a55ea-jpg.1363070/

https://kiwifarms.net/attachments/3840x2880_fb1667a8ff7d9524604e6435fe9d561d-jpg.1363138/

https://kiwifarms.net/attachments/1379239/


Bruce from the Netherlands 😉

---

Dear Sir or Madam:

I, the undersigned, state under penalty of perjury that: Cam Model Protection represents Suzanne T. Farrand (hereinafter, "Our Client") in intellectual property and litigation matters. Our Client has recently learned that the content at the following URL(s) (hereinafter, "Listed URL(s)") is hosted and/or shared through your service, and the URL(s) are distributing materials that violate copyright laws, and/or contributes to and induces copyright infringement:

https://kiwifarms.net/attachments/1367822/

https://kiwifarms.net/attachments/1360884/

https://kiwifarms.net/attachments/1378346/

https://kiwifarms.net/attachments/1363203/

https://kiwifarms.net/attachments/1585635651823-jpg.1248092/

https://kiwifarms.net/attachments/1321767/

https://kiwifarms.net/attachments/1305377/

https://kiwifarms.net/attachments/1587557675682-jpg.1248089/

https://kiwifarms.net/attachments/1585640250040-jpg.1248090/

https://kiwifarms.net/attachments/1585635687195-jpg.1248091/

https://kiwifarms.net/attachments/1585635651823-jpg.1248092/

https://kiwifarms.net/attachments/20200516_011327-jpg.1297683/

https://kiwifarms.net/attachments/20200516_011311-jpg.1297684/

https://kiwifarms.net/attachments/1587557675682-jpg.1248089/

https://kiwifarms.net/attachments/1585640250040-jpg.1248090/

https://kiwifarms.net/attachments/1585635687195-jpg.1248091/

https://kiwifarms.net/attachments/1578807071019-jpg.1309929/





The content that is hosted and/or shared through your service illegally is premium content that is created and copyrighted by our client. You can find the original content at our client’s official website here: https://www.onlyfans.com/NikocadoAvocado

This unauthorized distribution constitutes copyright infringement under the U.S. Copyright Act. Pursuant to 17 U.S.C. 512(c), including other International Copyright Laws. This letter serves as actual notice of infringement. We hereby demand you to immediately and permanently cease and desist the unauthorized distribution of the copyrighted material located at the Listed URLs.

We will use all means possible including injunctions and recovery of attorney's fees, costs and any and all other damages which are incurred by Our Client as a result of any action that is commenced against you. Our Client prefers to resolve this matter without taking legal action, but it is prepared to file a lawsuit if necessary to protect its rights and business. You may avoid legal action by removing the infringing content from your service immediately.

We have a good faith basis that the content at the Listed URL(s) is an infringement of Our Client's rights under copyright law, including but not limited to the DMCA, and that the infringing content is authorized by neither Our Client nor the law.

Our Client requests that you immediately take down the web content located at the Listed URL(s).

Finally, the information in this notice is accurate. If you have any questions, please contact me at the email address or phone number listed below.



Sincerely,

Bruce Wyatt
IP Law Attorney

International Anti-Piracy Operations
Cam Model Protection B.V.
Jagerserf 7
3851SM Ermelo
The Netherlands
Phone: +31(0)85.303.1197
Email: legal@cammodelprotect.com

---

I have already responded to your DMCA notice. The alleged works are
necessary and used in combination with community criticism and ridicule.
This is not the reserved market for the copyright holder. This is a new
market created by the fair use of the alleged works. The experience of
seeing this material on the Kiwi Farms, subjected to the intense
scrutiny of the users therein, is a different experience sold on
OnlyFans. Its commerce value is not the only thing of importance in this
matter.

I'm also not sure if this is a template you are copy and pasting without
changing names, but I don't know how Suzanna T. Farrand is the owner of
this material featuring Nicholas Perry.

Under penalty of perjury, I believe the work in question is used fairly
for the purposes of criticism and ridicule. Send servicing to the
following address.

Joshua Moon
913 Beal Pkwy NW
Suite A-1017
Fort Walton Beach, FL 32547

This is the second time I have attested under penalty of perjury and
with good faith that the material in question is used fairly. You are
now informed on this matter. If you continue to send me DMCA takedown
notices, I will consider action against your client under 17 USC
§ 512(f) and will file a complaint with the New York Bar Association.

I cannot believe I am receiving a legal complaint over this disgusting,
greasy anus. I'd bet this is not what you were expecting to use your law
degree for when you started going to school.

Kind regards,
Joshua Moon
 
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