NOTICE OF FILING This document was lodged electronically in the FEDERAL COURT OF AUSTRALIA (FCA) on 18/02/2016 4:21:06 PM AEDT and has been accepted for filing under the Court’s Rules. Details of filing follow and important additional information about these are set out below. Details of Filing Document Lodged: Statement of Claim - Form 17 - Rule 8.06(1)(a) File Number: NSD241/2016 File Title: Foxtel Management Pty Ltd v TPG Internet Pty Ltd & Ors Registry: NEW SOUTH WALES REGISTRY - FEDERAL COURT OF AUSTRALIA Dated: 19/02/2016 9:12:25 AM AEDT Registrar Important Information As required by the Court’s Rules, this Notice has been inserted as the first page of the document which has been accepted for electronic filing. It is now taken to be part of that document for the purposes of the proceeding in the Court and contains important information for all parties to that proceeding. It must be included in the document served on each of those parties. The date and time of lodgment also shown above are the date and time that the document was received by the Court. Under the Court’s Rules the date of filing of the document is the day it was lodged (if that is a business day for the Registry which accepts it and the document was received by 4.30 pm local time at that Registry) or otherwise the next working day for that Registry. Statement of claim No. NSD of 2016 Federal Court of Australia District Registry: NSW Division: General Foxtel Management Pty Applicant TPG Internet Pty (ACN 068 383 737) and others named In schedule 1 Respondents The parties Foxtel 1. The Applicant (Foxtel) IS. and was at all material times: a company duly incorporated in Australia: and able to sue in and by its corporate name and style. 2. Amongst other things, Foxtel: commissions and produces television programs: offers subscription television services in Australia: and offers in Australia. as agent for Presto TV Pty Limited. a subscription online streaming servioe known as 'Presto offering television content. TPG and iiNet 3. The First Respondent is. and was at all material times: a company duly incorporated in Australia; able to be sued in and by its corporate name and style: and Filed on behall ol Foxtel Management Pty Ltd. Applicant Prepared by John Ian Fairbaim Law firm MinterEllison MEJZMEEHQJ rwzuun (c) a carriage service provider, within the meaning given in the Telecommunications Act 1997 (Telco Act) and section 115A of the Copyright Act 1968 (Copyright Act). 4. The Second Respondent is, and was at all material times: (a) a company duly incorporated in Australia; (b) able to be sued in and by its corporate name and style; and (c) a carriage service provider, within the meaning given in the Telco Act and section 115A of the Copyright Act. Optus 5. Each of the Third to Fourteenth Respondents is, and was at all material times: (a) a company duly incorporated in Australia; (b) able to be sued in and by its corporate name and style; and (c) a carriage service provider, within the meaning given in the Telco Act and section 115A of the Copyright Act. Telstra 6. Each of the Fifteenth to Seventeenth Respondents is, and was at all material times: (a) a company duly incorporated in Australia; (b) able to be sued in and by its corporate name and style; and (c) a carriage service provider, within the meaning given in the Telco Act and section 115A of the Copyright Act. Foxtel's copyright 7. Each episode of each of the following television programs is a cinematograph film in which copyright subsists by virtue of Part IV of the Copyright Act: (a) Wentworth (season 3); (b) Open Slather; (c) A Place to Call Home (season 3); and (d) Real Housewives of Melbourne (season 2), (together, the Programs). 2 ME_128085759_1 (W2007) PARTICULARS (i) Each episode of each of the Programs was commissioned by Foxtel pursuant to an agreement for valuable consideration and made in Australia pursuant to such agreements. (ii) Foxtel relies on the following agreements, each of which contains information that is confidential to the parties to the agreements: (A) Wentworth (season 3): Production, Investment and Licence Agreement, Wentworth – Season 3 dated 8 December 2014 between Foxtel and Fremantlemedia Australia Pty Ltd. (B) Open Slather: "Make Em Laugh"/Comedy Project – Deal Memo dated 30 July 2014 between Foxtel and Princess and the Pauper Productions Pty Ltd. (C) A Place to Call Home: A Place to Call Home, Foxtel Production Deal Memo – A Place to Call Home Series 3 & 4 dated 14 October 2014 between Foxtel and Seven Network (Operations) Limited. (D) Real Housewives of Melbourne (season 2): (I) Non-scripted Format Licence Agreement, Real Housewives dated 27 November 2012 between Foxtel and Universal City Studios Productions LLLP; and (II) Production Agreement, The Real Housewives of Melbourne dated 17 December 2014 between Foxtel and Matchbox Production Pty Ltd. (iii) Each episode of each of the Programs includes a copyright notice which appears in the credits when the episode is, and has been, made available to the public including by broadcast on subscription television. (iv) To the extent necessary, Foxtel relies on the presumptions in Division 4 of Part V of the Copyright Act. 8. Foxtel is, and was at all material times: (a) the owner of; (b) further or alternatively an owner of; (c) further or alternatively, an exclusive licensee of, the copyright in each cinematograph film comprising each episode of each of the Programs. 3 ME_128085759_1 (W2007) PARTICULARS (i) Foxtel repeats the particulars to paragraph 7 above. (ii) To the extent necessary, Foxtel relies on section 119 of the Copyright Act. Online Locations The Pirate Bay 9. The Pirate Bay comprises an online location or locations. PARTICULARS (i) The Pirate Bay is or has been located at domain names and internet protocol (IP) addresses including those listed in section 1 of schedule 2 to this Statement of Claim. (ii) The Pirate Bay may be accessed by users of the internet through various domain names including those listed in section 1 of schedule 2 to this Statement of Claim. (The Pirate Bay). 10. Each online location listed in section 1 of schedule 2 to this Statement of Claim for The Pirate Bay is outside of Australia. PARTICULARS (i) IP addresses are allocated in blocks to local Internet registries based on geographical location. (ii) Each of the IP addresses identified in section 1 of schedule 2 to this Statement of Claim has been allocated to a region outside Australia. (iii) To the extent that information is available, the registrant of those domain names is located outside Australia. (iv) To the extent any of those domain names includes a country top level domain name, it is associated with a country outside Australia. 11. The Pirate Bay is available to persons with access to internet connections (Internet Users) and, without charge: (a) provides an organised and searchable index or directory of digital content which Internet Users can browse and from which they can select content of their choice, including movies, television programs, music and games; (b) categorises its index by reference to 'audio', 'video', 'applications', 'games', 'porn' and 'other' content; 4 ME_128085759_1 (W2007) (c) provides a link to a website from which a BitTorrent client software (BitTorrent Client) can be downloaded, being software that provides a user interface for peer-to-peer computer file sharing over the Internet; (d) in conjunction with a BitTorrent Client, allows and invites Internet Users; (i) to upload .torrent files containing information (including the location and file names) about the data comprising the chosen digital content (for example, an episode of a television program) residing on the computers of participating Internet Users; (ii) to download without charge, the selected digital content from other Internet Users within the peer-to-peer network by accessing these .torrent files or links to these .torrent files (together, Links); and (iii) make that content available to other Internet Users without charge or any restriction as to use. Torrentz 12. Torrentz comprises an online location or locations. PARTICULARS (i) Torrentz is located at domain names and IP addresses including those listed in section 2 of schedule 2 to this Statement of Claim. (ii) Torrentz may be accessed by users of the internet through various domain names including those listed in section 2 of schedule 2 to this Statement of Claim. (Torrentz). 13. Each online location listed in section 2 of schedule 2 to this Statement of Claim for Torrentz is outside of Australia. PARTICULARS (i) IP addresses are allocated in blocks to local Internet registries based on geographical location. (ii) Each of the IP addresses identified in section 2 of schedule 2 to this Statement of Claim has been allocated to a region outside Australia. (iii) To the extent that information is available, the registrant of those domain names is located outside Australia. (iv) To the extent any of those domain names includes a country top level domain name, it is associated with a country outside Australia. 5 ME_128085759_1 (W2007) 14. Torrentz is available to Internet Users and, without charge: (a) provides facilities for browsing and searching for Links available from other online locations, which Internet Users can use to search for digital content, including movies, television programs, music and games; (b) provides suggested searches, such as '2015 movies', 'adele', and 'english movies 2015'; (c) provides a link to a website which contains information about a BitTorrent Client; (d) in response to searches, provides a list of websites containing Links, which in conjunction with a BitTorrent Client, allows and invites Internet Users: (i) to download without charge the selected digital content from other Internet Users within the peer-to-peer network by accessing these Links; and (ii) make that content available to other Internet Users without charge or any restriction as to use. TorrentHound 15. TorrentHound comprises an online location or locations. PARTICULARS (i) TorrentHound is located at domain names and IP addresses including those listed in section 3 of schedule 2 to this Statement of Claim. (ii) TorrentHound may be accessed by users of the internet through various domain names including those listed in section 3 of schedule 2 to this Statement of Claim. (TorrentHound). 16. Each online location listed in section 3 of schedule 2 to this Statement of Claim for TorrentHound is outside of Australia. PARTICULARS (i) IP addresses are allocated in blocks to local Internet registries based on geographical location. (ii) Each of the IP addresses identified in section 3 of schedule 2 to this Statement of Claim has been allocated to a region outside Australia. (iii) To the extent that information is available, the registrant of those domain names is located outside Australia. (iv) To the extent any of those domain names includes a country top level domain name, it is associated with a country outside Australia. 6 ME_128085759_1 (W2007) 17. TorrentHound is available to Internet Users and, without charge: (a) provides a searchable index or directory of digital content which Internet Users can browse and from which they can select content of their choice, including movies, television programs and music; (b) categorises its index by reference to most viewed or downloaded torrents in the last 24 hours; (c) provides a link to a website from which a BitTorrent Client can be downloaded; (d) in conjunction with a BitTorrent Client, allows and invites Internet Users: (i) to download without charge, the selected digital content from other Internet Users within the peer-to-peer network by accessing these Links; and (ii) make that content available to other Internet Users without charge or any restriction as to use. IsoHunt 18. IsoHunt comprises an online location or locations. PARTICULARS (i) IsoHunt is located at domain names and IP addresses including those listed in section 4 of schedule 2 to this Statement of Claim. (ii) IsoHunt may be accessed by users of the internet through various domain names including those listed in section 4 of schedule 2 to this Statement of Claim. (IsoHunt). 19. Each online location listed in section 4 of schedule 2 to this Statement of Claim is outside of Australia. PARTICULARS (i) IP addresses are allocated in blocks to local Internet registries based on geographical location. (ii) Each of the IP addresses identified in section 4 of schedule 2 to this Statement of Claim has been allocated to a region outside Australia. (iii) To the extent that information is available, the registrant of those domain names is located outside Australia. (iv) To the extent any of those domain names includes a country top level domain name, it is associated with a country outside Australia. 7 ME_128085759_1 (W2007) 20. IsoHunt is available to Internet Users and, without charge: (a) provides an organised and searchable index or directory of digital content which Internet Users can browse and from which they can select content of their choice, including movies, television programs, music and games; (b) categorises its index by reference to 'anime', 'software', 'games', 'adult', 'movie', 'music', 'other', 'series and TV' and 'books'; (c) states what the most popular BitTorrent Clients are; (d) in conjunction with a BitTorrent Client, allows and invites Internet Users; (i) to upload .torrent files containing information (including the location and file names) about the data comprising the chosen digital content (for example, an episode of a television program) residing on the computers of participating Internet Users; (ii) to download without charge, the selected digital content from other Internet Users within the peer-to-peer network by accessing Links; and (iii) make that content available to other Internet Users without charge or any restriction as to use. Access to Online Locations via the Respondents’ internet services 21. The First Respondent provides access for users of its internet service in Australia to the following online locations outside Australia: 22. (a) The Pirate Bay; (b) Torrentz; (c) TorrentHound; and (d) IsoHunt. The Second Respondent provides access for users of its internet service in Australia to the following online locations outside Australia: 23. (a) The Pirate Bay; (b) Torrentz; (c) TorrentHound; and (d) IsoHunt. Each of the Third to Fourteenth Respondents provides access for users of its internet service in Australia to the following online locations outside Australia: (a) The Pirate Bay; 8 ME_128085759_1 (W2007) 24. (b) Torrentz; (c) TorrentHound; and (d) IsoHunt. Each of the Fifteenth to Seventeenth Respondents provides access for users of its internet service in Australia to the following online locations outside Australia: (a) The Pirate Bay; (b) Torrentz; (c) TorrentHound; and (d) IsoHunt. Infringement of copyright - The Pirate Bay Infringement by Internet Users downloading Programs using The Pirate Bay 25. From a date presently unknown to Foxtel, but since at least 18 January 2016, Internet Users in Australia have used, and continue to have the opportunity to use, the Links made available on The Pirate Bay to reproduce the whole or a substantial part of episodes of each of the Programs. PARTICULARS (i) Foxtel repeats paragraph 11 above. (ii) The Links correlating with episodes of the Programs were included on The Pirate Bay and Internet Users downloaded and/or communicated episodes of the Programs via those Links. (iii) Foxtel relies on searches conducted on The Pirate Bay in January 2016 indicating that Internet Users downloaded copies of episodes of each of the Programs from other Internet Users who were running a BitTorrent Client on their computers and who made available online and/or electronically transmitted those episodes to the first mentioned Internet Users. (iv) The Links correlating with episodes of the Programs continue to appear on The Pirate Bay. (v) Foxtel relies on website searches conducted on The Pirate Bay by entering the name of each Program into the search field on The Pirate Bay and pressing 'enter'. In one search session on 21 January 2016, The Pirate Bay showed: 9 ME_128085759_1 (W2007) (A) approximately 253 results, being links to webpages containing Links, for the search term 'wentworth'; (B) 9 results for the search term 'open slather'; (C) approximately 20 results for the search term 'real housewives of melbourne'; and (D) approximately 82 results for the search term 'a place to call home'. Some of the search results were not for the Programs. (vi) On 18 January 2016, an Internet User: (A) downloaded from thepiratebay.se to a BitTorrent Client a Link for an episode of each Program; and (B) used the downloaded Link in the BitTorrent Client to download a copy of an episode of each Program from other Internet Users within the BitTorrent peer-to-peer network. 26. The acts and conduct referred to in paragraph 25, with the exception of steps taken in searches done for the purposes of these proceedings, were done without the licence or authority of Foxtel. 27. By reason of the matters pleaded above, Internet Users in Australia have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. Infringement by Internet Users sharing the Programs using The Pirate Bay 28. Further or alternatively, from a date presently unknown to Foxtel, but since at least 18 January 2016, Internet Users in Australia have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) Foxtel repeats the particulars to paragraph 25 above. 29. The acts pleaded in paragraph 28 were done without the licence or authority of Foxtel. 30. By reason of the matters pleaded in paragraphs 28 and 29 Internet Users have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. 10 ME_128085759_1 (W2007) Infringement by The Pirate Bay and its operators Primary acts of infringement 31. Further or alternatively, from a date presently unknown to Foxtel, but since at least 18 January 2016, The Pirate Bay and/or the operators of The Pirate Bay, has or have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) 32. Foxtel repeats the pleadings and particulars in paragraph 25 - 30 above. The acts of The Pirate Bay, and further or alternatively, the acts of the operators of The Pirate Bay pleaded above were done without the licence or authority of Foxtel. 33. By reason of the matters pleaded in paragraphs 31 and 32 above, The Pirate Bay infringes and/or the operators of The Pirate Bay have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. Secondary infringement by authorisation etc 34. At all material times, the operators of The Pirate Bay: (a) knew and know, or had and have reason to suspect, that the content of The Pirate Bay has been, and will continue to be, used by Internet Users to infringe copyright; (b) further or alternatively, intended and intend that The Pirate Bay be used to infringe copyright, and have encouraged, and encourage, such infringing conduct; (c) had and have the power to prevent the infringements by Internet Users including the infringing acts pleaded above; and (d) have chosen not to take any or any sufficient steps to prevent such infringements or continuing infringements. PARTICULARS (i) Foxtel relies on: (A) the name, appearance and features of The Pirate Bay including the features pleaded at paragraph 11 above and the particulars thereto; (B) the conduct of The Pirate Bay and users of The Pirate Bay; 11 ME_128085759_1 (W2007) (C) the fact that The Pirate Bay provides or facilitates free access for Internet Users to content which is lawfully commercially available elsewhere only for a fee; (D) the absence of legitimate functions of The Pirate Bay; (E) the statements made by the operators of The Pirate Bay in relation to copyright generally and in relation to take-down and equivalent copyright related notices; (F) the general disregard for copyright demonstrated by the operators of The Pirate Bay; (G) the fact that there is no working facility on The Pirate Bay through which to issue a take down notice or through which to contact the operators of The Pirate Bay; (H) the conduct of The Pirate Bay or its operators to hide elements of its activities including changing domains, and other steps taken in order to attempt to avoid investigations and/or court orders in various jurisdictions; and (I) statements made by the public, media and courts in various jurisdictions as to the copyright infringing purposes of The Pirate Bay, which have gone uncontradicted by The Pirate Bay and its operators. 35. By reason of the matters pleaded in paragraph 34 above, the operators of The Pirate Bay have authorised each of the acts of infringement pleaded in paragraphs 25 and 28 above. 36. The acts of the operators pleaded above were done without the licence or authority of Foxtel. 37. By reason of the matters pleaded in paragraphs 31, 32 and 34 - 36 above, The Pirate Bay infringes and/or the operators of The Pirate Bay have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. 38. Further or alternatively, by reason of the matters pleaded in 25 - 30 and 34 above, the operators of The Pirate Bay procured or induced, or joined in a common design with, Internet Users to do the infringing acts pleaded in paragraphs 25 and 28 above, and continue to do so. 12 ME_128085759_1 (W2007) 39. In the premises, the operators of The Pirate Bay are joint tortfeasors in the Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Facilitation of infringement by The Pirate Bay 40. Further or alternatively, by reason of the matters pleaded in paragraphs 11, 25, 28, and/or further or alternatively, paragraph 34 above, The Pirate Bay and further or alternatively, the operators of The Pirate Bay has and have facilitated, and continue to facilitate, Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Infringement of copyright – Torrentz Infringement by Internet Users downloading Programs using Torrentz 41. From a date presently unknown to Foxtel, but since at least 21 January 2016, Internet Users in Australia have used, and continue to have the opportunity to use, the Links made available on the websites to which Torrentz provides links (Third Party Websites) to reproduce the whole or a substantial part of episodes of each of the Programs. PARTICULARS (i) Foxtel repeats paragraph 14 above. (ii) The Links correlating with episodes of the Programs were included on the Third Party Websites and Internet Users downloaded and/or communicated episodes of the Programs via those Links. (iii) Foxtel relies on searches conducted on Torrentz in January and February 2016 indicating that Internet Users downloaded copies of episodes of each of the Programs from other Internet Users who were running a BitTorrent Client on their computers and who made available online and/or electronically transmitted those episodes to the first mentioned Internet Users. (iv) The links to the Third Party Websites containing Links correlating with episodes of the Programs continue to appear on Torrentz. (v) Foxtel relies on website searches conducted on Torrentz by entering the name of each Program into the search field on Torrentz and pressing 'enter'. In one search session on 23 November 2015, Torrentz showed: (A) approximately 376 results, being links to pages on Torrentz which contain links to the Third Party Websites containing Links, for the search term 'wentworth'; (B) ME_128085759_1 (W2007) 22 results for the search term 'open slather'; 13 (C) 60 results for the search term 'real housewives of melbourne'; and (D) 90 results for the search term 'a place to call home'. Some of the search results were not for the Programs. (vi) On 21 or 22 January 2016 or 5 February 2016, an Internet User: (A) downloaded from a Third Party Website to a BitTorrent Client a Link for an episode of each Program; and (B) used the downloaded Link in the BitTorrent Client to download a copy of an episode of each Program from other Internet Users within the BitTorrent peer-to-peer network. (vii) Foxtel relies on further searches conducted on Torrentz on 3 February 2016 after take down notices were sent to Torrentz, which still found a significant number of results for episodes of the Programs. 42. The acts and conduct referred to in paragraph 41, with the exception of steps taken in searches done for the purposes of these proceedings, were done without the licence or authority of Foxtel. 43. By reason of the matters pleaded above, Internet Users in Australia have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. Infringement by Internet Users sharing the Programs using Torrentz 44. Further or alternatively, from a date presently unknown to Foxtel, but since at least 21 January 2016, Internet Users in Australia have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) Foxtel repeats the particulars to paragraph 41 above. 45. The acts pleaded in paragraph 44 were done without the licence or authority of Foxtel. 46. By reason of the matters pleaded in paragraphs 44 and 45 Internet Users in Australia have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. 14 ME_128085759_1 (W2007) Infringement by Torrentz and its operators Primary acts of infringement 47. Further or alternatively, from a date presently unknown to Foxtel, but since at least 21 January 2016, Torrentz and/or the operators of Torrentz, has or have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) 48. Foxtel repeats the pleadings and particulars in paragraph 41 - 46 above. The acts of Torrentz, and further or alternatively, the acts of the operators of Torrentz pleaded above were done without the licence or authority of Foxtel. 49. By reason of the matters pleaded in paragraphs 47 and 48 above, Torrentz infringes and/or the operators of Torrentz have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. Secondary infringement by authorisation etc 50. At all material times, the operators of Torrentz: (a) knew and know, or had and have reason to suspect, that the content of Torrentz has been, and will continue to be, used by Internet Users to infringe copyright; (b) further or alternatively, intended and intend that Torrentz be used to infringe copyright, and have encouraged, and encourage, such infringing conduct; (c) had and have the power to prevent the infringements by Internet Users including the infringing acts pleaded above; and (d) have chosen not to take any or any sufficient steps to prevent such infringements or continuing infringements. PARTICULARS (i) Foxtel relies on: (A) the appearance and features of Torrentz including the features pleaded at paragraph 14 above and the particulars thereto; (B) the conduct of Torrentz and users of Torrentz; 15 ME_128085759_1 (W2007) (C) the fact that Torrentz, via the Third Party Websites, provides or facilitates free access for Internet Users to content which is lawfully commercially available elsewhere only for a fee; (D) the absence of legitimate functions of Torrentz; (E) the general disregard for copyright demonstrated by the operators of Torrentz; (F) the conduct of Torrentz or its operators to hide elements of its activities including changing domains, and other steps taken in order to attempt to avoid investigations and/or court orders in various jurisdictions; (G) statements made by the public, media and courts in various jurisdictions as to the copyright infringing purposes of Torrentz, which have gone uncontradicted by Torrentz and its operators; (H) the fact that access to many of the Third Party Websites has been blocked by court order or otherwise in other jurisdictions; (I) Torrentz contains a set of instructions to submit take down notices, which informs Internet Users to send any such notices to abuse@torrentz.eu. Foxtel sent various take down notices to this address. Only those Links in respect of which specific identifiers where given were taken down; (J) The following correspondence occurred between Foxtel and the email address in (H): (I) On 1 December 2015, emails were sent to abuse@torrentz.eu containing take down notices for each of the Programs in respect of specified URLs that contain Links for the Programs. On 3 December 2015, the specified URLs could no longer be accessed. (II) On 11 December 2015, an email was sent to abuse@torrentz.eu containing a take down notice for Wentworth, including in respect of URLs specified in the email that contain Links for Wentworth. On 14 December 2015, the specified URLs could no longer be accessed. However, other URLs containing Links for Wentworth remained accessible on Torrentz on 14 December 2015. (III) On 14 December 2015, an email was sent to abuse@torrentz.eu containing a take down notice for 16 ME_128085759_1 (W2007) Wentworth, including in respect of URLs specified in the email that contain Links for Wentworth. On 18 December 2015, the specified URL could no longer be accessed. However, other URLs containing Links for Wentworth remained accessible on Torrentz on 18 December 2015. (IV) On 18 December 2015, an email was sent to abuse@torrentz.eu containing a take down notice for season three of Wentworth in respect of the total number (being 121) of results that appeared in a search results list for 'wentworth s03' (Wentworth Search Results). A sample of URLs in the Wentworth Search Results was included in the email. On 4 January 2016, the specified URLs could no longer be accessed. However, other URLs containing Links for season three of Wentworth remained accessible on Torrentz on 4 January 2016. (V) On 4 January 2016, an email was sent to abuse@torrentz.eu containing a take down notice for season three of Wentworth in respect of the total number (being 125) of Wentworth Search Results. On 12 January 2016, the total number of Wentworth Search Results had reduced to 79 results. (VI) On 15 January 2016, an email was sent to abuse@torrentz.eu containing a take down notice for season three of Wentworth in respect of the total number (being 69) of Wentworth Search Results. On 21 January 2015, Foxtel received a reply email requesting 'info_hash values'. (ii) Foxtel relies on website searches conducted on Torrentz by entering the name of each program into the search field on Torrentz and pressing 'enter'. In one search session on 3 February 2016, Torrentz showed: (A) 374 results, being links to webpages containing Links, for the search term 'wentworth'; (B) 50 results for the search term 'wentworth s03'; (C) 3 results for the search term 'open slather'; (D) 30 results for the search term 'real housewives of melbourne'; and (E) 99 results for the search term 'a place to call home'. Some of the search results were not for the Programs. 17 ME_128085759_1 (W2007) 51. By reason of the matters pleaded in paragraph 50 above, the operators of Torrentz have authorised each of the acts of infringement pleaded in paragraphs 41 and 44 above. 52. The acts of the operators pleaded above were done without the licence or authority of Foxtel. 53. By reason of the matters pleaded in paragraphs 47, 48 and 50 - 52 above, Torrentz infringes and/or the operators of Torrentz have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. 54. Further or alternatively, by reason of the matters pleaded in paragraphs 41 - 46 and 50 above, the operators of Torrentz, procured or induced, or joined in a common design with, Internet Users to do the infringing acts pleaded in paragraphs 41 and 44 above, and continue to do so. 55. In the premises, the operators of Torrentz are joint tortfeasors in the Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Facilitation of infringement by Torrentz 56. Further or alternatively, by reason of the matters pleaded in paragraphs 14, 41, 44 and/or further or alternatively, paragraph 50 above, Torrentz and further or alternatively, the operators of Torrentz has and have facilitated, and continue to facilitate, Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Infringement of copyright – TorrentHound Infringement by Internet Users downloading Programs using TorrentHound 57. From a date presently unknown to Foxtel, but since at least 21 January 2016, Internet Users in Australia have used, and continue to have the opportunity to use, the Links made available on TorrentHound to reproduce the whole or a substantial part of episodes of each of the Programs. PARTICULARS (i) Foxtel repeats paragraph 17 above. (ii) The Links correlating with episodes of the Programs were included on TorrentHound and Internet Users downloaded and/or communicated episodes of the Programs via those Links. (iii) Foxtel relies on searches conducted on TorrentHound in January 2016 indicating that Internet Users downloaded copies of episodes of each of the Programs from other Internet Users who were running a BitTorrent Client on their computers and who made available online and/or 18 ME_128085759_1 (W2007) electronically transmitted those episodes to the first mentioned Internet Users. (iv) Foxtel relies on website searches conducted on TorrentHound by entering the name of each Program into the search field on TorrentHound and pressing 'enter'. In one search session on 21 January 2016, TorrentHound showed: (A) 222 results, being links to webpages containing Links, for the search term 'wentworth'; (B) 6 results for the search term 'open slather'; (C) 42 results for the search term 'real housewives of melbourne'; and (D) 78 results for the search term 'a place to call home'. Some of the search results were not for the Programs. (v) On 21 January 2016, an Internet User: (A) downloaded from torrenthound.com to a BitTorrent Client a Link for an episode of each Program; and (B) used the downloaded Link in the BitTorrent Client to download a copy of an episode of each Program from other Internet Users within the BitTorrent peer-to-peer network. 58. The acts and conduct referred to in paragraph 57, with the exception of steps taken in searches done for the purposes of these proceedings, were done without the licence or authority of Foxtel. 59. By reason of the matters pleaded above, Internet Users in Australia have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. Infringement by Internet Users sharing the Programs using TorrentHound 60. Further or alternatively, from a date presently unknown to Foxtel, but since at least 21 January 2016, Internet Users in Australia have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) Foxtel repeats the particulars to paragraph 57 above. 19 ME_128085759_1 (W2007) 61. The acts pleaded in paragraph 60 were done without the licence or authority of Foxtel. 62. By reason of the matters pleaded in paragraphs 60 and 61 Internet Users in Australia have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. Infringement by TorrentHound and its operators Primary acts of infringement 63. Further or alternatively, from a date presently unknown to Foxtel, but since at least 21 January 2016, TorrentHound and/or the operators of TorrentHound, has or have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) 64. Foxtel repeats the pleadings and particulars in paragraph 57 - 62 above. The acts of TorrentHound, and further or alternatively, the acts of the operators of TorrentHound pleaded above were done without the licence or authority of Foxtel. 65. By reason of the matters pleaded in paragraphs 63 and 64 above, TorrentHound infringes and/or the operators of TorrentHound have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. Secondary infringement by authorisation etc 66. At all material times, the operators of TorrentHound: (a) knew and know, or had and have reason to suspect, that the content of TorrentHound has been, and will continue to be, used by Internet Users to infringe copyright; (b) further or alternatively, intended and intend that TorrentHound be used to infringe copyright, and have encouraged, and encourage, such infringing conduct; (c) had and have the power to prevent the infringements by Internet Users including the infringing acts pleaded above; and (d) have chosen not to take any or any sufficient steps to prevent such infringements or continuing infringements. 20 ME_128085759_1 (W2007) PARTICULARS (i) Foxtel relies on: (A) the name, appearance and features of TorrentHound including the features pleaded at paragraph 17 above and the particulars thereto; (B) the conduct of TorrentHound and users of TorrentHound; (C) the fact that TorrentHound provides or facilitates free access for Internet Users to content which is lawfully commercially available elsewhere only for a fee; (D) the absence of legitimate functions of TorrentHound; (E) the general disregard for copyright demonstrated by the operators of TorrentHound; (F) the fact that there is no working facility on TorrentHound through which to issue a take down notice. On 2 December 2015, the contact form at www.torrenthound.com/contact was used to send take down notices for each of the Programs in respect of specified URLs that contain Links for the Programs. Those URLs were still able to be accessed on 3, 4, 7 and 14 December 2015 and 4 and 12 January 2016; (G) the conduct of TorrentHound or its operators to hide elements of its activities including changing domains, and other steps taken in order to attempt to avoid investigations and/or court orders in various jurisdictions; and (H) statements made by the public, media and courts in various jurisdictions as to the copyright infringing purposes of TorrentHound, which have gone uncontradicted by TorrentHound and its operators. 67. By reason of the matters pleaded in paragraph 66 above, the operators of TorrentHound have authorised each of the acts of infringement pleaded in paragraphs 57 and 60 above. 68. The acts of the operators pleaded above were done without the licence or authority of Foxtel. 69. By reason of the matters pleaded in paragraphs 63, 64 and 66 - 68 above, TorrentHound infringes and/or the operators of TorrentHound have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. 21 ME_128085759_1 (W2007) 70. Further or alternatively, by reason of the matters pleaded in paragraphs 57 - 62 and 66 above, the operators of TorrentHound, procured or induced, or joined in a common design with, Internet Users to do the infringing acts pleaded in paragraphs 57 and 60 above, and continue to do so. 71. In the premises, the operators of TorrentHound are joint tortfeasors in the Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Facilitation of infringement by TorrentHound 72. Further or alternatively, by reason of the matters pleaded in paragraphs 17, 57, 60 and/or further or alternatively, paragraph 66 above, TorrentHound and further or alternatively, the operators of TorrentHound has and have facilitated, and continue to facilitate, Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Infringement of copyright – IsoHunt Infringement by Internet Users downloading Programs using IsoHunt 73. From a date presently unknown to Foxtel, but since at least 21 January 2016, Internet Users in Australia have used, and continue to have the opportunity to use, the Links made available on IsoHunt to reproduce the whole or a substantial part of episodes of each of the Programs. PARTICULARS (i) Foxtel repeats paragraph 20 above. (ii) The Links correlating with episodes of the Programs were included on IsoHunt and Internet Users downloaded and/or communicated episodes of the Programs via those Links. (iii) Foxtel relies on searches conducted on IsoHunt in January 2016 indicating that Internet Users downloaded copies of episodes of each of the Programs from other Internet Users who were running a BitTorrent Client on their computers and who made available online and/or electronically transmitted those episodes to the first mentioned Internet Users. (iv) The Links correlating with episodes of the Programs continue to appear on IsoHunt. (v) Foxtel relies on website searches conducted on IsoHunt by entering the name of each Program into the search field on IsoHunt and pressing 'enter'. In one search session on 21 January 2016, IsoHunt showed: 22 ME_128085759_1 (W2007) (A) 189 results, being links to webpages containing Links, for the search term 'wentworth'; (B) 13 results for the search term 'open slather'; (C) 30 results for the search term 'real housewives of melbourne'; and (D) 26 results for the search term 'place to call home'. Some of the search results were not for the Programs. (vi) On 21 January 2016, an Internet User: (A) downloaded from isohunt.to to a BitTorrent Client a Link for an episode of each Program; and (B) used the downloaded Link in the BitTorrent Client to download a copy of an episode of each Program from other Internet Users within the BitTorrent peer-to-peer network. 74. The acts and conduct referred to in paragraph 73, with the exception of steps taken in searches done for the purposes of these proceedings, were done without the licence or authority of Foxtel. 75. By reason of the matters pleaded above, Internet Users in Australia have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. Infringement by Internet Users sharing the Programs using IsoHunt 76. Further or alternatively, from a date presently unknown to Foxtel, but since at least 21 January 2016, Internet Users in Australia have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) Foxtel repeats the particulars to paragraph 73 above. 77. The acts pleaded in paragraph 76 were done without the licence or authority of Foxtel. 78. By reason of the matters pleaded in paragraphs 76 and 77 Internet Users in Australia have infringed and continue to have the opportunity to infringe, the copyright in the cinematograph films comprised in each episode of each of the Programs. 23 ME_128085759_1 (W2007) Infringement by IsoHunt and its operators Primary acts of infringement 79. Further or alternatively, from a date presently unknown to Foxtel, but since at least 21 January 2016, IsoHunt and/or the operators of IsoHunt, has or have: (a) made available online and thereby communicated to the public; and/or (b) electronically transmitted and thereby communicated to the public, the whole or a substantial part, of episodes of each of the Programs, and continue to do so. PARTICULARS (i) 80. Foxtel repeats the pleadings and particulars in paragraph 73 - 78 above. The acts of IsoHunt, and further or alternatively, the acts of the operators of IsoHunt pleaded above were done without the licence or authority of Foxtel. 81. By reason of the matters pleaded in paragraphs 79 and 80 above, IsoHunt infringes and/or the operators of IsoHunt have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. Secondary infringement by authorisation etc 82. At all material times, the operators of IsoHunt: (a) knew and know, or had and have reason to suspect, that the content of IsoHunt has been, and will continue to be, used by Internet Users to infringe copyright; (b) further or alternatively, intended and intend that IsoHunt be used to infringe copyright, and have encouraged, and encourage, such infringing conduct; (c) had and have the power to prevent the infringements by Internet Users including the infringing acts pleaded above; and (d) have chosen not to take any or any sufficient steps to prevent such infringements or continuing infringements. PARTICULARS (i) Foxtel relies on: (A) the appearance and features of IsoHunt including the features pleaded at paragraph 20 above and the particulars thereto; (B) the conduct of IsoHunt and users of IsoHunt; 24 ME_128085759_1 (W2007) (C) the fact that IsoHunt provides or facilitates free access for Internet Users to content which is lawfully commercially available elsewhere only for a fee; (D) the absence of legitimate functions of IsoHunt; (E) the statements made by the operators of IsoHunt in relation to copyright generally and in relation to take-down and equivalent copyright related notices; (F) the general disregard for copyright demonstrated by the operators of IsoHunt; (G) the fact that there is no working facility on IsoHunt through which to issue a take down notice. On 2 December 2015, the contact form at isohunt.to/contact-us was used to send take down notices for each of the Programs in respect of specified URLs that contain Links for the Programs. The URLs were still able to be accessed on 3, 4, 7 and 14 December 2015 and 4 and 12 January 2016; (H) the conduct of IsoHunt or its operators to hide elements of its activities including changing domains, and other steps taken in order to attempt to avoid investigations and/or court orders in various jurisdictions; and (I) statements made by the public, media and courts in various jurisdictions as to the copyright infringing purposes of IsoHunt, which have gone uncontradicted by IsoHunt and its operators. 83. By reason of the matters pleaded in paragraph 82 above, the operators of IsoHunt have authorised each of the acts of infringement pleaded in paragraphs 73 and 76 above. 84. The acts of the operators pleaded above were done without the licence or authority of Foxtel. 85. By reason of the matters pleaded in paragraphs 79, 80 and 82 - 84 above, IsoHunt infringes and/or the operators of IsoHunt have infringed, and continue(s) to infringe copyright in the cinematograph films comprised in episodes of each of the Programs. 86. Further or alternatively, by reason of the matters pleaded in paragraphs 73 - 78 and 82 above, the operators of IsoHunt procured or induced, or joined in a common design with, Internet Users to do the infringing acts pleaded in paragraphs 73 and 76 above, and continue to do so. 25 ME_128085759_1 (W2007) 87. In the premises, the operators of IsoHunt are joint tortfeasors in the Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Facilitation of infringement by IsoHunt 88. Further or alternatively, by reason of the matters pleaded in paragraphs 20, 73, 76 and/or further or alternatively, paragraph 82 above, IsoHunt and further or alternatively, the operators of IsoHunt has and have facilitated, and continue to facilitate, Internet Users’ infringement of copyright in the cinematograph films comprised in episodes of each of the Programs. Consequences of infringing conduct: loss and damage 89. Foxtel derives income from subscription fees for its subscription television services provided in Australia and also from otherwise dealing with its ownership and control of rights in television programs, including copyright in the Programs. 90. A significant factor in Foxtel’s ability to attract subscribers is the exclusivity in Australia of a proportion of the programming it offers, including the Programs, the Australian premieres of which were exclusive to Foxtel's subscription television services. Following their exclusive premiere on Foxtel’s subscription television services, two of the Programs have been licensed to Presto TV. 91. Persons who have downloaded and further or alternatively, electronically transmitted, episodes of each of the Programs without charge as pleaded above, include Internet Users in Australia accessing the internet by means of the services of each of the Respondents. PARTICULARS (i) Foxtel repeats the pleadings and particulars in paragraphs 25, 28, 41, 44, 57, 60, 73 and 76 above. (ii) The locality of Internet Users accessing or sharing content through Links available from each of The Pirate Bay, Torrentz (via Third Party Websites), TorrentHound and IsoHunt is denoted by the nationality of the flag that often appears beside the IP address of the Internet User in the 'Peers' section of the BitTorrent Client whilst the relevant content is downloading. 92. In the premises, Foxtel’s programs have been, and continue to be, available without charge outside Foxtel’s subscription packages, and Foxtel has thereby suffered and will suffer loss and damage, including lost subscription fees, lost opportunity to earn subscription fees, lost opportunity to earn licensing fees, and other damage from loss of control over copyright in episodes of the Programs. 26 ME_128085759_1 (W2007) Primary purpose of Online Locations 93. The primary purpose of The Pirate Bay is to infringe or facilitate the infringement of copyright (whether or not in Australia). PARTICULARS (i) Foxtel refers to the pleadings and repeats the particulars in paragraphs 9 - 11, 25, 28 and 34 above. 94. The primary purpose of Torrentz is to infringe or facilitate the infringement of copyright (whether or not in Australia). PARTICULARS (i) Foxtel refers to the pleadings and repeats the particulars in paragraphs 12 - 14, 41, 44 and 50 above. 95. The primary purpose of TorrentHound is to infringe or facilitate the infringement of copyright (whether or not in Australia). PARTICULARS (i) Foxtel refers to the pleadings and repeats the particulars in paragraphs 15 - 17, 57, 60 and 66 above. 96. The primary purpose of IsoHunt is to infringe or facilitate the infringement of copyright (whether or not in Australia). PARTICULARS (i) Foxtel refers to the pleadings and repeats the particulars in paragraphs 18 - 20, 73, 76 and 82 above. Consideration referred to in section 115A(5)(d) 97. Access to The Pirate Bay has been disabled by orders of courts in various jurisdictions on copyright related grounds, including in the United Kingdom and Ireland. 98. Access to Torrentz has been disabled by court order in the United Kingdom on copyright related grounds. 99. Access to TorrentHound has been disabled by court order in the United Kingdom on copyright related grounds. 100. Access to IsoHunt has been disabled by court order in the United Kingdom on copyright related grounds. Relief 101. Foxtel claims the relief specified in the accompanying Originating Application. 27 ME_128085759_1 (W2007) Date: 18 February 2016 This pleading was prepared by Richard Lancaster SC, Justine Beaumont of counsel and John Fairbairn, partner, MinterEllison. Certificate of lawyer John Ian Fairbairn certify to the Court that, in relation to the statement 01 claim filed on behalf 0' the Applicant, the factual and legal material available to me at present provides a proper basis {or each allegation in the pleading. Date: 18 February 2016 28 Schedule 1 No. NSD of 2016 Federal Court of Australia District Registry: Sydney Division: General Respondents Second Respondent: iiNet Limited (ACN 068 628 937) Third Respondent: Optus Networks Pty Limited (ACN 008 570 330) Fourth Respondent: Optus Mobile Pty Limited (ACN 054 365 696) Fifth Respondent: Uecomm Pty Limited (ACN 079 083 195) Sixth Respondent: Optus Fixed Infrastructure Pty Limited (ACN 092 450 783) Seventh Respondent: Uecomm Operations Pty Limited (ACN 093 504 100) Eighth Respondent: Vividwireless Pty Ltd (ACN 137 696 461) Ninth Respondent: Vividwireless Group Ltd (ACN 008 082 737) Tenth Respondent: Virgin Mobile (Australia) Pty Limited (ACN 092 726 442) Eleventh Respondent: Alphawest Pty Limited (ACN 009 222 931) Twelfth Respondent: Optus Wholesale Pty Limited (ACN 092 227 551) Thirteenth Respondent: Optus Internet Pty Limited (ACN 083 164 532) Fourteenth Respondent: Optus Backbone Investments Pty Limited (ACN 138 676 356) Fifteenth Respondent: Telstra Corporation Limited (ACN 051 775 556) Sixteenth Respondent: Pacnet Services (A) Pty. Ltd. (ACN 056 783 852) Seventeenth Respondent: Pacnet Internet (A) Pty Ltd (ACN 085 213 690) Date: 18 February 2016 29 ME_128085759_1 (W2007) Schedule 2 A. The Pirate Bay Domain name IP address 1. thepiratebay.se 141.101.118.194,141.101.118.195 2. bayproxy.pw 104.27.167.96,104.27.166.96 3. downloadbay.eu 104.28.1.53,104.28.0.53 4. fastpiratebay.co.uk 104.27.174.252,104.27.175.252 5. fastpiratebay.eu 104.28.26.119,104.28.27.119 6. magnetsearch.org 104.24.122.173,104.24.123.173 7. mypirateproxy.com 104.28.20.2,104.28.21.2 8. pirate.guru 104.28.17.148,104.28.16.148 9. pirateahoy.eu 104.28.30.50,104.28.31.50 10. piratebay.host 198.41.249.68,162.159.240.69 11. piratebaymirror.eu 104.28.2.19,104.28.3.19 12. piratebayproxy.be 104.24.118.137,104.24.119.137 13. piratebays.co 104.27.168.249,104.27.169.249 14. piratebays.co.uk 104.31.76.114,104.31.77.114 15. pirateproxy.ca 104.28.2.122,104.28.3.122 16. pirateproxy.tf 104.25.209.20,104.25.208.20 17. pirateproxy.wf 104.28.4.182,104.28.5.182 18. pirateproxy.yt 104.27.138.238,104.27.139.238 19. thebay.tv 104.28.6.185,104.28.7.185 20. thepiratebay.am 198.105.254.11 21. thepiratebay.casa 104.27.154.76,104.27.155.76 22. thepiratebay.cd 104.31.76.84,104.31.77.84 23. thepiratebay.cr 104.28.4.236,104.28.5.236 24. thepiratebay.expert 104.18.32.141,104.18.33.141 25. thepiratebay.gd 104.24.100.99 26. thepiratebay.gs 104.24.99.150 27. thepiratebay.la 104.28.2.115 30 ME_128085759_1 (W2007) 28. thepiratebay.mn 104.27.156.189 29. thepiratebay.org 104.18.40.167,104.18.41.167 30. thepiratebay.uk.net 104.18.58.238,104.18.59.238 31. thepiratebay.vg 104.28.4.121 32. thepiratebay.xn--fiqs8s 104.28.2.96,104.28.3.96 33. thepiratebay.xn--q9jyb4c 104.27.144.26,104.27.145.26 34. thepiratebay-proxy.com 104.28.10.55,104.28.11.55 35. thepirateboat.eu 104.28.6.62,104.28.7.62 36. tpbmirror.us 104.28.7.41,104.28.6.41 37. urbanproxy.eu 104.28.13.69,104.28.12.69 B. Torrentz Domain name IP address 1. torrentz.eu 185.87.144.3,185.87.144.4,185.87.147.3,185.87.147.4 2. torrentsmirror.com 104.28.29.56,104.28.28.56 3. torrentz.ch 185.87.144.3,185.87.144.4,185.87.147.3,185.87.147.4 4. torrentz.com 72.52.4.119 5. torrentz.hk 185.87.147.4,185.87.144.3,185.87.144.4,185.87.147.3 6. torrentz.in 185.87.147.3,185.87.147.4,185.87.144.3,185.87.144.4 7. torrentz.li 185.87.147.4,185.87.144.3,185.87.144.4,185.87.147.3 8. torrentz.me 185.87.144.3,185.87.144.4,185.87.147.3,185.87.147.4 9. torrentz.ph 185.87.147.4,185.87.144.3,185.87.144.4,185.87.147.3 10. torrentz-proxy.com 185.87.144.3,185.87.144.4,185.87.147.3,185.87.147.4 11. tz.ai 185.87.144.3,185.87.144.4,185.87.147.3,185.87.147.4 31 ME_128085759_1 (W2007) C. TorrentHound Domain name IP address 1. torrenthound.com 88.80.6.5 2. torrenthound.at 104.31.88.28,104.31.89.28 3. torrenthound.cm 104.31.80.128,104.31.81.128 4. torrenthound.immunicity.info 104.28.2.124,104.28.3.124 5. torrenthound.ru 104.24.100.232,104.24.101.232 6. torrenthound.to 88.196.31.41 7. torrenthound.unlocktor.eu 5.45.77.184 8. torrenthound-proxy.com 104.18.58.145,104.18.59.145 D. IsoHunt Domain name IP address 1. isohunt.to 198.41.189.233,198.41.190.233 2. isohunt.duhsoft.com 5.45.75.223 3. isohunt.kooaba.net 5.45.64.109 4. isohunt.st 173.236.194.74 5. isohunters.net 78.142.19.12 32 ME_128085759_1 (W2007)