Neutral Citation Number: 2023:DHC:2806 indexing such links when it comes to its knowledge that such content is illegal. This Court finds the suggestion untenable that the user/victim must approach either the intermediary in question or the Courts every single time the NCII content is duplicated. Such a suggestion also frustrates the legislative intent behind the IT Rules which devises a time-bound schedule in removal of such content. An approach that entails the victim/user having to sift through the internet to identify and then share every URL hosting their NCII is unconscionable in the eyes of this Court. Offending Entities Possess the Requisite Technology 53. Moreover, search engines cannot hide under the garb of not possessing the adequate technology to remove NCII content which has been reported without the victim/user having to approach the intermediary again and again. As per the Affidavit of Google LLC, hash-matching technology, which generates a unique identifier/fingerprint/hash, exists for the purpose of removing CSAM. This technology further allows detection and removal of the matched content that has previously been removed. For the purposes of removal of NCII, once such content has been identified and removed, the hash-matching technology can store only the unique identifier pertaining to the NCII content and in the event that such content is re-uploaded, it can filter out the same by going through its database of such fingerprints. A similar tool has already been built by Meta, available on www.stopncii.org to curtail the spread of NCII, and it can be used by the victim to create a unique fingerprint of the offending image which is stored in the database to prevent re-uploads. The tool is meant to compare this fingerprint (or hash) with the hashes of all the other images available on the site; if any image is Signature Not Verified Digitally Signed By:SHAZAAD ZAKIR Signing Date:26.04.2023 17:19:50 W.P.(CRL) 1505/2021 Page 78 of 88

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