Legal/Infringement Notices/05 September 2012

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From: Monolith Graphics <goth at monolithgraphics dot com> Date: September 5, 2012 12:57 AM To:, Konstantin Machabeli <>,, CC:, Maria Chernenko <> Subject: DMCA - COPYRIGHT INFRINGEMENT & COUNTERFEITING NOTICE


cc. MVD (Russian Ministry of Justice) and the FBI of the United States.

I am the legal representative for the publisher MONOLITH GRAPHICS, and the recording artist NOX ARCANA. We own 320 copyrighted sound recordings which are the subject of a valid US Certificate of Copyright.

1. Firefox (Mozilla) is providing means to access and download unauthorized copies of NOX ARCANA's copyrighted sound recordings via distribution of the plug-in " Downloader":

This plug-in has enabled users of to download millions of copies of our songs without compensation to the artist and without permission of the copyright owners. has disabled the plug-in promotional page (see, and we routinely send DMCA notices to VK for the removal of unauthorized audio files. HOWEVER Firefox continues to distribute this plug-in and VK continues to allow its use.

We demand that Mozilla/Firefox immediately disable ALL 68+ versions of the Plug-in known as " Downloader", remove the plug-in file from the download area, and block any future versions from being published to the Firefox download area.

2. The "VKontakte" network is providing unauthorized copies of NOX ARCANA's copyrighted sound recordings. is hereby ordered to REMOVE ALL audio files listed on the following pages, and block all copies of this music from being uploaded to VK servers ever again.

3. See attached files showing public downloads made possible by this conspiracy between Mozilla and VKontakte.


AFFIDAVIT / GOOD FAITH OATH: I have a good faith belief that the use of the described material in the manner complained of is not authorized by the copyright owner, its agent, or the law. I swear that the information in the notification is accurate and, under penalty of perjury, that I am the copyright owner or am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Regards, Russell Williams

Monolith Graphics [intentionally removed] Cleveland, OH 44144 USA

nox at noxarcana dot com goth at monolithgraphics dot com