dvd fab - in support of preliminary injunction

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT NEW YORK ADVANCED ACCESS CONTENT SYSTEM LICENSING ADMINISTRATOR, LLC,

Plaintiff, v.

LANNY SHEN d/b/a DVDFAB AND FENGTAO SOFTWARE INC., SUNREG TECHNOLOGIES LTD. d/b/a DVDFAB AND FENGTAO SOFTWARE INC., FENG TAO d/b/a DVDFAB AND FENGTAO SOFTWARE INC., SHEN XINLAN d/b/a AUDIO-DVD CREATOR, and JOHN DOE, JANE DOE and/or XYZ COMPANY d/b/a DVDFAB, RIPPERBLU-RAY.COM, DVDFABB.COM and DVDFFAB.COM,

Defendants.

CIVIL ACTION NO. _____________ DECLARATION OF MATTHEW HEWLETT IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION

MATTHEW HEWLETT, under penalty of perjury, declares and says:

1. I am a private investigator licensed by the State of North Carolina and employed

by Vaudra, Ltd. (Vaudra), a North Carolina-based investigation company. I have been

employed as a private investigator, focusing on intellectual property infringement for the past

nine years. I have been employed by Vaudra since October 2009. I have conducted and/or

participated in approximately seven-hundred investigations involving intellectual property

violations, including through Internet sales.

2. I submit this declaration on behalf of plaintiff Advanced Access Content System

Licensing Administrator, LLC (AACS LA or Plaintiff) in support of its motion for

preliminary injunction against Lanny Shen d/b/a DVDFab and Fengtao Software Inc., SunReg

Case 1:14-cv-01112-VSB Document 10 Filed 02/24/14 Page 1 of 17

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Technologies Ltd. d/b/a DVDFab and Fengtao Software Inc., Feng Tao d/b/a DVDFab and

Fengtao Software Inc., Shen Xinlan d/b/a Audio-DVD Creator, and John Doe, Jane Doe and/or

XYZ Company d/b/a DVDFab, RipperBlu-ray.com, DVDFabb.com and DVDFfab.com

(collectively, the DVDFab Group or Defendants).

3. The following actions were undertaken by myself, or in conjunction with other

Vaudra investigators. If called upon as a witness, I could testify to the following from personal

knowledge and/or a review of Vaudras business files.

4. I am familiar with AACS LAs integrated set of technological measures that

protects motion pictures and television programming embodied on high-definition optical discs

(Blu-ray discs and, formerly, HD DVDs) from unauthorized access, copying and distribution (its

AACS Technology).

5. At the request of AACS LA, Vaudra investigated Defendants sales of software

products designed to circumvent AACS LAs AACS Technology.

Software Purchases, Download and Conveyance

6. We viewed Defendants website located at DVDFab.com, which advertised its

software programs and products including DVDFab Blu-ray Ripper (3D plus); DVDFab Blu-ray

Copy; DVDFab Blu-ray to DVD Converter; DVDFab HD Decrypter; Passkey for Blu-ray; and

Passkey Lite. The website advertises, among other things, that:

DVDFab Blu-ray Copy is the first full-featured Blu-ray copy software powerful enough to remove all Blu-ray copy protections. Blu-ray Copy can copy any Blu-ray to any Blu-ray/DVD/AVCHD disc (playback only in Blu-ray Player) or to your hard drive with just one or a few clicks. . . . The output images and audio qualities are as good as the original. Our server-side technology enables you to access Blu-ray Copy between releases with the latest protection removal fixes, in real time.

DVDFab Blu-ray Ripper (3D Plus) is powerful to rip any Blu-ray since it can remove nearly all Blu-ray protections, no matter the old ones or newly emerged


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ones, like all known AACS copy protections including the newest MKB and bus encryption, Region Code, BD-Live, and UOPs.

DVDFab Blu-ray to DVD Converter can convert any Blu-ray to DVD-Video disc all by itself for you to view using only DVD player or DVD player software. It has the power to remove all known AACS copy protections including the newest MKB and bus encryption, Region Code, BD-Live, and UOPs to help you get access to any Blu-ray movies.

Passkey for Blu-ray can remove . . . all known AACS copy protections including the newest AACS MKB v26, and AACS bus encryption, Region Code, BDLive, and UOPs for Blu-ray. Passkey for Blu-ray is also described with statements that it:

o Remove[s] all known Blu-ray protections

o Help[s] you watch any Blu-ray with no region limit and rip Blu-ray to hard disk,

o . . . decrypts any Blu-ray disc just in seconds to allow you to use other compatible software to deal with now unprotected content.

o . . . is powerful in decryption. Any copy protections and region code are in no mean any barriers in front of it.

o With the help of Passkey for Blu-ray, you can rip Blu-ray to the hard disk on your PC, or use other compatible software to access any Blu-ray content, to copy, clone, burn, etc.

o Passkey for Blu-ray uses a server based system for decryption, and new decryption data will always be added on the server. You can easily get advantage of the server with internet connected. No need to worry about new Blu-ray protections.

Screenshots of Defendants website located at DVDFab.com are attached hereto as Exhibit A,

including, for example, the following excerpt:


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7. We downloaded from Defendants website located at DVDFab.com a PDF copy

of the manual titled A User Guide Of DVDFab 9, located at

http://download.dvdfab.com/manual/dvdfab9/a-user-guide-of-dvdfab9.pdf, a copy of which is

attached hereto as Exhibit B. Among other things, this manual advises users to Make sure that

Remove AACS, BD+, RC, BD-Live, UOPs options are enabled. The names are different copy

protection systems and if you don't remove them - then the Blu-ray DVD will still be copy

protected and cannot be copied. It describes the Remove AACS(Advanced Access Content

System) option as follows: The Advanced Access Content System (AACS) is a standard for

content distribution and digital rights management, intended to restrict access to and copying of

the next generation of optical discs and DVDs. The specification was publicly released in April


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2005 and the standard has been adopted as the access restriction scheme for HD DVD and Blu-

ray Disc (BD).

8. Through Defendants website located at DVDFab.com, we purchased and

downloaded the software programs DVDFab9 and DVDFab PassKey8 and purchased and

obtained the product keys for DVDFab Blu-ray Ripper (3D plus); DVDFab Blu-ray Copy;

DVDFab Blu-ray to DVD Converter; DVDFab HD Decrypter; Passkey for Blu-ray; and Passkey

Lite (collectively, the DVDFab Software). Screenshots and printouts of emails reflecting these

purchases and downloads are attached hereto as Exhibit C. As shown in Exhibit C, we were

directed to the Avangate platform at Avangate.com to pay for the DVDFab Software, we

downloaded the DVDFab Software from Defendants website located at DVDFab.com, and we

received license keys by email from Avangate Customer Service ([email protected]). As

shown in Exhibit C, we received correspondence from the following of Defendants email

addresses in the course of purchasing and downloading the DVDFab Software: web-

[email protected]; [email protected]; [email protected]; [email protected].

9. We downloaded the DVDFab Software and the related product keys to a laptop

computer located in our offices in the United States, and we used the registration keys to unlock

the registered versions of the DVDFab Software. Screenshots reflecting these registration steps

are attached hereto as Exhibit D. Screenshots of the registered software are attached hereto as

Exhibit E, including the following excerpt showing that the software includes a setting for

Remove AACS (Advanced Access Content System):


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We conveyed the laptop computer containing the DVDFab Software to NTS Technical Systems

for software testing.

10. When we attempted to select products to purchase from Defendants websites

located at DVDFab.jp and DVDFab.de, we were redirected to Defendants website located at

DVDFab.com. This happened both when we attempted to select products to purchase from these

websites with a United States IP address and IP addresses based in Japan and Germany

respectively. Screenshots reflecting this redirection are attached hereto as Exhibit F.

Defendants DVDFab Websites and Social Media Accounts

11. I have reviewed a recent printed ranking report from quantcast.com, the website

of Quantcast, a company that measures web audiences. Quantcast estimates that the DVDFab

website located at DVDFab.com is visited by an estimated 550,650 people in the United States

each month, and it ranks this website as the 3,378th most visited website in the United States. I

have also reviewed a recent printed ranking report from Alexa.com, the website of Alexa, a

prominent provider of traffic data, global rankings and other information on thousands of


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websites. Alexa estimates that 35.2% of visitors to DVDFab.com come from the United States,

followed by United Kingdom (5%), Japan (4.1%), India (4.0%) and China (3.8%). Those printed

reports are attached hereto as Exhibit G.

12. Defendants offer through their DVDFab website located at DVDFab.com a

DVDFab affiliate program, whereby Internet affiliates can earn commissions of up to 60% by

promoting or selling the DVDFab Software on their websites. A screenshot of the page offering

this program is attached hereto as Exhibit H.

13. We also viewed Defendants websites located at the following domains:

DVDFab.net, DVDIdle.com, 3d-video-converters.com, 3dBluRay-ripper.com, Blu-Ray-

ripper.us, Blu-Ray-Software.us, BluRayripper.jp, BluRaysbs3d.com, BluRaysoft.jp,

CopyBluRay.us, DVDFab.jp, DVDFab9.com, DVDvideosoft.jp, kopiersoftware.com,

macBluRaycopy.com, mourlife.com, readtechnews.com, sbs3d.com, sbs3dconverter.com,

sbs3dcopy.com, sbs3dripper.com, tracehotnews.com, videoconverter.jp, wollytech.com, xn--

dvd-ti4bzc1jla2oj3ne.com, 2d-3d-converter.com, copyDVDsoftware.us, sbs3dcreator.com,

DVDFab.de, audio-dvd-creator.com, ripperBluRay.com, DVDFabb.com and DVDFfab.com

(collectively, with DVDFab.com, the DVDFab Domain Names; the websites located at or

operated at all the DVDFab Domain Names shall be referenced as the DVDFab Websites).

Screenshots of each of the DVDFab Websites other than DVDFab.com are attached hereto as

Exhibit I.

14. As shown in Exhibits A & I and based on my review of the DVDFab Websites,

most of the DVDFab Websites use the English language and accept U.S. dollars as payment for

the DVDFab Software, including by major credit cards, including Visa MaterCard, American

Express and Discover. The DVDFab Websites that use other languages, such as Japanese and


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Chinese, and appear to offer for sale or advertise the same suite of products, and redirect the user

to an English DVDFab Website when making a purchase.

15. While the DVDFab Defendants are associated with different DVDFab Websites,

based on my review of the DVDFab Websites and the registration information for the DVDFab

Domain Names, I believe all DVDFab Defendants, and their DVDFab Websites, are operating

together to market, offer for sale and sell the DVDFab software.

16. As shown in Exhibits A & I, the DVD Fab Websites located at DVDFab.com,

DVDFab9.com, DVDFabb.com and DVDFfab.com are mirror images of each other, and the

DVDFab Websites located at DVDFab.jp and DVDFab.de are mirror images of both

DVDFab.com and DVDFab9.com, except that their text is in the Japanese and German

languages respectively. The homepages of those websites appear as follows:

DVDFab.com

DVDFab9.com

DVDFab.jp DVDFab.de


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DVDFfab.com DVDFabb.com

17. Based on my review of the DVDFab Websites, the DVDFab Websites at the

following domains each hyperlink to other DVDFab Websites at least as follows:

DVDFab Website hyperlinks to page(s) of link DVDFab.com DVDFab.jp, DVDFab.de http://www.dvdfab.com/ DVDFab.net DVDFab.com, DVDFab.jp,

DVDFab.de http://www.dvdfab.net/

DVDIdle.com DVDFab.com, audio-dvd-creator.com

http://dvdidle.com/

3d-video-converters.com DVDFab.com, DVDFab.jp, DVDFab.de

http://3d-video-converters.com/

3dbluray-ripper.com DVDFab.jp http://3dbluray-ripper.com/ Blu-Ray-ripper.us DVDFab.com, DVDFab.jp,

DVDFab.de http://blu-ray-ripper.us/

Blu-Ray-Software.us DVDFab.com, DVDFab.jp, DVDFab.de

http://blu-ray-software.us/

BluRaysbs3d.com DVDFab.com, DVDFab.jp, DVDFab.de

http://bluraysbs3d.com/

CopyBluRay.us DVDFab.com, DVDFab.jp, DVDFab.de

http://copybluray.us/

DVDFab9.com DVDFab.com, DVDFab.jp, DVDFab.de

http://dvdfab9.com/

kopiersoftware.com DVDFab.de http://kopiersoftware.com/ mourlife.com tracehotnews.com, wollytech.com,

readtechnews.com, DVDFab.com, Blu-Ray-ripper.us, 3d-video-converters.com, ripperBluRay.com

http://mourlife.com/links/

readtechnews.com 3d-video-converters.com, Blu-Ray-ripper.us, mourlife.com, tracehotnews.com, wollytech.com, ripperBluRay.com, DVDFab.com

http://readtechnews.com/, http://readtechnews.com/links/

sbs3d.com DVDFab.com, DVDFab.jp, DVDFab.de

http://sbs3d.com/

sbs3dconverter.com DVDFab.com, DVDFab.jp, DVDFab.de

http://sbs3dconverter.com/

sbs3dcopy.com DVDFab.com, DVDFab.jp, DVDFab.de

http://sbs3dcopy.com/

sbs3dripper.com DVDFab.com, DVDFab.jp, DVDFab.de

http://sbs3dripper.com/


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tracehotnews.com 3d-video-converters.com, ripperBluRay.com, Blu-Ray-ripper.us, DVDFab.com, mourlife.com, readtechnews.com, , wollytech.com

http://tracehotnews.com/

wollytech.com DVDFab.com, Blu-Ray-ripper.us, mourlife.com

http://wollytech.com/

2d-3d-converter.com DVDFab.com http://2d-3d-converter.com/ copyDVDsoftware.us DVDFab.com, DVDFab.de.

DVDFab.jp http://copydvdsoftware.us/

DVDvideosoft.jp DVDFab.com, DVDFab.jp http://dvdvideosoft.jp/ sbs3dcreator.com DVDFab.com, DVDFab.de,

DVDFab.jp http://sbs3dcreator.com/

DVDFab.jp DVDFab.com, DVDFab.de http://www.dvdfab.jp/ BluRayripper.jp DVDFab.com http://blurayripper.jp/ BluRaysoft.jp DVDFab.jp http://bluraysoft.jp/ videoconverter.jp DVDFab.jp, BluRayripper.jp http://videoconverter.jp/ DVDFab.de DVDFab.com, DVDFab.jp http://dvdfab.de/ audio-dvd-creator.com DVDFab.com http://audio-dvd-creator.com/ ripperBluRay.com DVDFab.com, DVDFab.jp,

DVDFab.de http://ripperbluray.com/

DVDFabb.com DVDFab.com, DVDFab.jp, DVDFab.de

http://www.dvdfabb.com/

DVDFfab.com DVDFab.com, DVDFab.jp, DVDFab.de

http://www.dvdffab.com/

18. Based on my review of the DVDFab Websites, the DVDFab Websites operated at

the following domain names offer downloads of DVDFab Software:

a. DVDFab.com, DVDIdle.com, 3d-video-converters.com, Blu-Ray-

ripper.us, Blu-Ray-Software.us, BluRaysbs3d.com, CopyBluRay.us,

macBluRaycopy.com, sbs3d.com, sbs3dconverter.com, sbs3dcopy.com, sbs3dripper.com,

2d-3d-converter.com, copyDVDsoftware.us, sbs3dcreator.com, audio-dvd-creator.com,

and ripperBluRay.com, each of which links to DVDFab Software files located at

DVDFab.com from which downloads actually take place.

b. DVDFab.jp, 3dBluRay-ripper.com, BluRayripper.jp, BluRaysoft.jp, and

videoconverter.jp, each of which links to DVDFab Software files located at DVDFab.jp

from which downloads actually take place.


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c. DVDvideosoft.jp, which links to DVDFab Software files located at

DVDFab.com and DVDFab.jp from which downloads actually take place.

d. DVDFab9.com, from which downloads actually take place.

e. DVDFab.net, from which downloads actually take place and which links

to DVDFab.com and an external website from which downloads actually take place.

f. DVDFabb.com, from which downloads actually take place and which

links to DVDFab.com from which downloads actually take place.

g. DVDFfab.com, from which downloads actually take place and which links

to DVDFab.com from which downloads actually take place.

h. DVDFab.de and kopiersoftware.com, each of which links to DVDFab

Software files located at DVDFab.de from which downloads actually take place.

19. As shown in Exhibit I, the DVDFab Websites located at mourlife.com,

readtechnews.com, tracehotnews.com, wollytech.com, and xn--dvd-ti4bzc1jla2oj3ne.com appear

in the form of technology blogs that also provide links to the DVDFab Websites, which in turn

provide downloads of DVDFab Software.

20. Defendants maintain social media and online service accounts on Facebook,

Twitter, YouTube and Google+ (their DVDFab Social Media Accounts), screenshots of which

are attached hereto as Exhibit J. As shown in Exhibit J, Defendants Facebook page boasts, inter

alia, that DVDFab is the all-in-one software package for copying Blu-ray/DVD and converting

video files to various portable devices. . . . DVDFab is a software brand owned by Fengtao

Software.Inc which contains DVD Copy, DVD Ripper, Blu-ray Copy, Blu-ray Ripper (3D Plus),

Video Converter, 2D to 3D Converter, Media Player and Passkey. . . . With 4 copy modes, you


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can remove all Blu-ray copy protections and copy any Blu-ray to any Blu-ray/DVD/AVCHD

disc or to your hard drive/Mac with just one or a few clicks.

21. Based on my review of the DVDFab Websites, the DVDFab Websites hyperlink

to and/or allow likes to be registered on Defendants Social Media Accounts as follows:

DVDFab Website hyperlinks to registers likes to DVDFab.com Facebook, Twitter, YouTube,

Google+ Facebook, Twitter, Google+

DVDFab.net Facebook, Twitter, YouTube, Google+

Facebook, Twitter, Google+

3d-video-converters.com Facebook, Twitter, YouTube BluRaysbs3d.com Facebook, Twitter, YouTube DVDFab9.com Facebook, Twitter, YouTube,


sbs3dconverter.com Facebook, Twitter, YouTube sbs3dcopy.com Facebook, Twitter, YouTube sbs3dcreator.com Facebook, Twitter, YouTube DVDFab.jp Facebook, Twitter, YouTube,


DVDFab.de Facebook, Twitter, YouTube, Google+


DVDFabb.com Facebook, Twitter, YouTube, Google+


DVDFfab.com Facebook, Twitter, YouTube, Google+


22. The Internet Corporation for Assigned Names and Numbers (ICANN), the body

that governs domain names, requires all who register domain names to provide accurate

registration information, which is compiled in a network of publicly-available databases

commonly referred to as WhoIs.


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23. Screenshots of WhoIs reports for each of the DVDFab Domain Names including

server information for the DVDFab Websites is attached hereto as Exhibit K. As shown in

Exhibit K, the WhoIs information for each of the DVDFab Domain Names and the DVDFab

Websites themselves contains common identification and address information, as follows:

Domain(s) WHOIS registrant name and/or organization

Org(s) identified on website(s)

WHOIS address WHOIS email(s) (website contact email(s))

DVDFab.com

Lanny Shen DVDFab, Fengtao Software Inc.

No.1905, 1 Building, Yachengyili, Qingnian Road Uptown Beijing Beijing 100025 CN

[email protected], [email protected]

DVDFab.net Lanny Shen DVDFab, Fengtao Software Inc.

No.1905, 1 Building, Yachengyili, Qingnian Road Uptown Beijing Beijing 100025 CN

[email protected]

DVDIdle.com Lanny Shen DVDFab, Fengtao Software Inc.

N/A N/A

3d-video-converters.com, 3dBluRay-ripper.com, Blu-Ray-ripper.us, Blu-Ray-Software.us, BluRaysbs3d.com, CopyBluRay.us, DVDFab9.com, kopiersoftware.com, macBluRaycopy.com, mourlife.com, readtechnews.com, sbs3d.com, sbs3dconverter.com, sbs3dcopy.com, sbs3dripper.com, tracehotnews.com, wollytech.com, xn--dvd-ti4bzc1jla2oj3ne.com, 2d-3d-converter.com,

Xin Lan Shen, SunReg Technologies Ltd.

DVDFab, Fengtao Software Inc. (except macBluRaycopy.com)

112, 14100 Riverport Way Richmand British Columbia V6W 1M3 Canada Tel: (604) 295-3299

[email protected] ([email protected] [on some])


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Domain(s) WHOIS registrant name and/or organization

Org(s) identified on website(s)

WHOIS address WHOIS email(s) (website contact email(s))

copyDVDsoftware.us, Sbs3dcreator.com DVDFab.jp SunReg

Technologies Ltd.

DVDFab, Fengtao Software Inc.

112-0004 Tokyo Koraku-Mori Building, 1-4-14 Kouraku, Bunkyo-ku

[email protected]

BluRayripper.jp, BluRaysoft.jp, dvdvideosoft.jp, videoconverter.jp,

SunReg Technologies Ltd.


577-0013 Higashi-Osaka city 1-3-16, Nagata-Naka

[email protected]

DVDFab.de Feng Tao DVDFab, Fengtao Software Inc.

1316, JiShengBieShu, XiSanQi 100096 Beijing CN

[email protected]

audio-dvd-creator.com

Shen Xinlan Audio-DVD Creator

#1-1905, Yacheng Yili Qingnian Road Uptown Beijing Beijing 100025 CN

[email protected]

ripperBluRay.com Domains By Proxy, LLC

DVDFab, RipperBlu-ray.com

N/A (WHOIS information hidden behind privacy domain company)

N/A ([email protected])

DVDFabb.com DVDFfab.com

Domains By Proxy, LLC


N/A (WHOIS information hidden behind privacy domain company)

N/A

24. As shown in Exhibit K, DVDFab.com is registered with the Chinese registrar

HICHINA ZHICHENG TECHNOLOGY LTD. and its server is located in Quebec, Montreal,

Canada, and the servers for all of the other DVDFab Websites are similarly located outside of the

United States.

25. As shown in Exhibits A & I, the front pages of many of the websites of

defendants Lanny Shen, SunReg Technologies Ltd. Feng Tao, and John Doe, Jane Doe and/or

XYZ Company identify Fengtao Software Inc. or DVDFab as the owner and/or operator of the

site in at least the following ways:

The websites at DVDFab.com, DVDFab.net, DVDFab9.com, DVDFab.jp, DVDFab.de 3dbluray-ripper.com, BluRayripper.jp, BluRaysoft.jp, DVDvideosoft.jp, videoconverter.jp, DVDFabb.com and DVDFFab.com


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state at the bottom of their front pages 2003-2014 Fengtao Software Inc. All Rights Reserved.

The website at DVDIdle.com states at the bottom of its front page 2001-2010 Fengtao Software Inc.

The websites at 3d-video-converters.com, BluRaysbs3d.com, and sbs3d.com state at the bottom of their front pages Copyright (C) [sic] DVDFab.com All Rights Reserved.

The websites at sbs3dconverter.com, sbs3dcopy.com, sbs3dripper.com, and sbs3dcreator.com state at the bottom of their front pages [or (C)] 2011[or 2001]-2014 DVDFab.com All Rights Reserved.

The website at copyDVDsoftware.com states at the bottom of its front page 2011-2014 Copy DVD Software Copyright 2011 DVDFab.com All Rights Reserved.

The website at blu-ray-software.us states at the bottom of its front pages Owned By DVDFab, and the website at copybluray.us states at the bottom of its front page Belongs to DVDFab.com.

The website at kopiersoftware.com bears on its front page the graphic title

.

26. As shown in Exhibit K, the following domains share the IP address,

178.79.168.161: 3d-video-converters.com, 3dBluRay-ripper.com, Blu-Ray-ripper.us, Blu-Ray-

Software.us, BluRaysbs3d.com, CopyBluRay.us, kopiersoftware.com, macBluRaycopy.com,

mourlife.com, readtechnews.com, sbs3d.com, sbs3dconverter.com, sbs3dcopy.com,

sbs3dripper.com, tracehotnews.com, wollytech.com, 2d-3d-converter.com,

copyDVDsoftware.us, Sbs3dcreator.com, and audio-dvd-creator.com.

27. As shown in Exhibit K, the following domains share the IP address,

106.187.54.102: BluRayripper.jp, BluRaysoft.jp, DVDvideosoft.jp, videoconverter.jp, and xn--

dvd-ti4bzc1jla2oj3ne.com.


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28. As shown in Exhibit K, the following domains share the IP address, 70.38.71.25:

DVDFab.com, DVDFab.net, DVDIdle.com, DVDFab.de, DVDFab.jp, DVDFabb.com and

DVDFfab.com.

29. We investigated the physical addresses as shown in WhoIs and to which the

DVDFab Domain Names are registered. We learned the following:

a. The address for Defendants Lanny Shen and Shen Xinlan

(No.1905, 1 Building, Yachengyili, Qingnian Road Uptown, Beijing, Beijing, 100025

CN) is vacant.

b. The address for Defendant SunReg Technologies Limited

(112, 14100 Riverport Way, Richmand, British Columbia V6W 1M3 Canada) is for a

vacant residential apartment unit. We placed a call to (604) 295-3299 and received a

message stating number has been disconnected.

c. The address for Defendant SunReg Technologies Limited (112-0004,

Tokyo, Koraku-Mori Building, 1-4-14 Kouraku, Bunkyo-ku) is for an office building,

whose list of tenants to our knowledge does not include any defendant.

d. The address for Defendant SunReg Technologies Limited (577-0013,

Higashi-Osaka city, 1-3-16, Nagata-Naka) is for a hotel, Richmond Hotel Higashi-Osaka.

e. The address for Defendant Feng Tao (1316, JiShengBieShu, XiSanQi,

100096, Beijing, CN) appears to be a residential address, and our investigation yielded no

connections between this address and Defendant Feng Tao or any business.

f. The address given as a contact address for Fengtao Software Inc. on

DVDFab.com, DVDFab.net, DVDFab.de, DVDFab.jp, DVDFabb.com and


DVDFfab.com was No.38, Haidian Dajie, Haidian Dist, Beijing, China. Such a company

could not be located at that address.

30. We searched for, and could not locate, a registration to do business in China by

Fengtao Software Inc.

31. We searched for, and did not locate any records for the business SunReg

Technologies Ltd. in Canada.

32. All of the communications that we had with Defendants were made through their

websites and by email, and we at no time received true physical addresses or identities for

defendants through these means.

I declare under penalty of petjury under the laws of the United States of America that the

foregoing is true and colTect.

Executed this I"! day of f?j_.,.t-~q~v 2014 in Charlotte, North Carolina. -- r

Matthew Hewlett

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dvd fab - in support of preliminary injunction

Documents

dvdfab bluray ripper

fengtao software

lanny shen dba dvdfab

dvdfab group

feng tao dba dvdfab

bluray copy protections

bluray player

software programs