Defendants Hotfile Corp. and Anton Titov operate www.hotfile.com (“Hotfile” or the
“Hotfile website”), a system that enables copyright infringement on a mindboggling scale.
Hotfile is responsible for billions of infringing downloads of copyrighted works, including
plaintiffs’ valuable motion picture and television properties. As with other adjudicated pirate
services that came before it, from Napster and Grokster to Isohunt and Limewire, Hotfile exists
to profit from copyright infringement. As with those other adjudicated infringers, the evidence is
unmistakable that Hotfile actively fosters the massive copyright infringement that fuels its
business. As with those other infringers, more than 90% of the files downloaded from Hotfile
are copyright infringing, and nearly every Hotfile user is engaged in copyright infringement.