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Somebodies attorney had a brainfart
(c) Plaintiffs have taken active steps to conceal their infringement,
including from Plaintiffs or other music copyright owners. While Plaintiffs' sound
recordings and musical compositions are contained in the "full" versions of the
Videos (accessible only to paid members of their website), Defendants have
stripped the music out of the "sample" versions of those Videos (accessible for free
to the public), replacing it with "stock" music.
37. The harm to Plaintiffs is immediate, massive and obvious. In no
uncertain terms, Defendants have stolen Plaintiffs' sound recordings and musical
compositions and used them for a purpose that they know Plaintiffs and their
recording artists and/or songwriters would not consent to. Defendants have done
so in order to attract members to their website and thereby profit from the use.
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