Legal/Infringement Notices/15 October 2010

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October 15, 2010


Harvey Anderson

Mozilla Corporation

650 Castro Street, Suite 300

Mountain View, CA 94041

Re: Downloader

Dear Mr. Anderson:

I am contacting you on behalf of the Recording Industry Association of America, Inc. (RIAA) and its member record companies. The RIAA is a trade association whose member companies create, manufacture, and distribute the majority of all legitimate sound recordings sold in the United States. RIAA members include Universal Music Group, Sony Music Entertainment, Warner Music Group, and EMI Music North America, and their affiliated record labels. We are writing to notify you of the copyright infringement of sound recordings that is being facilitated by the Downloader software application which is being distributed through your system.

Application: Downloader

Developer: Sergey Kolosov


The purpose of this application is to facilitate the unauthorized downloading of popular sound recordings. The majority of these sound recordings are owned or controlled by RIAA members. Under the U.S. Copyright Act, those who distribute, reproduce, or digitally transmit sound recordings without authorization and those who assist, facilitate, or induce such actions by others are liable for copyright infringement. By indexing, linking to, transmitting, retransmitting, providing access to, and/or otherwise assisting users in streaming and downloading infringing copies of sound recordings, this application is violating U.S. copyright law.

By this letter, we ask that you immediately cease distribution of the Downloader software application on your system, and that you take steps to ensure that its developer is not permitted to infringe upon the copyrights of RIAA members by offering similar applications on your system in the future.

The copyright infringement of RIAA member sound recordings made possible by your distribution of this application is obvious to anyone making use of the application, and undoubtedly will be readily apparent to you upon review. While this letter constitutes notice of infringing activities under the U.S. Copyright Act, it does not in any way constitute a waiver of any right, remedy or action, including the right to recover damages for the infringements referenced in this letter. All such rights, remedies and actions are expressly reserved.

Please do not hesitate to contact me if you should have any questions. You may reach me via e-mail at, by telephone at (202) 775-0101, or by mail at RIAA, 1025 F Street, N.W., 10th Floor, Washington, D.C. 20004.


Mark McDevitt

Vice President, Online Anti-Piracy