4 identified defendant sought to actually litigate, Prenda Law would simply dismiss the case. See Ingenuity 13 LLC, 2013 U.S. Dist. LEXIS 64564, at *6-7. As Duffy acknowledged at oral argument, of the more than one hundred cases that AF Holdings has initiated, none has proceeded to trial or resulted in any judgment in its favor other than by default. Oral Arg. Rec. 30:09-20. Nevertheless, according to one article, Prenda Law made around $15 million in a little less than three years. See Kashmir Hill, How Porn Copyright Lawyer John Steel Has Made a ‘Few Million Dollars’ Pursuing (Sometimes Innocent) ‘Porn Pirates’, Forbes (Oct. 15, 2012), http://www.forbes.com/sites/kashmirhill/2012/10/15/howporn-copyright-lawyer-john-steele-justifies-his-pursuit-ofsometimes-innocent-porn-pirates. The present lawsuit is a quintessential example of Prenda Law’s modus operandi. Represented by Prenda Law, AF Holdings brought suit in the United States District Court for the District of Columbia against 1,058 unnamed Does who it alleged had illegally downloaded and shared the pornographic film Popular Demand using a file-sharing service known as BitTorrent. As an attachment to its complaint, AF Holdings listed the 1,058 IP addresses assigned to those subscribers whose Internet connections had been used to share Popular Demand, along with the specific date and time at which it, using what it described as “sophisticated and proprietary peerto-peer network forensic software,” had observed each defendant’s allegedly infringing activity. AF Holdings also attached the purported assignment agreement through which it claims to have acquired the copyright to Popular Demand. Although it has no effect on our resolution of this appeal, other courts have since concluded that at least one of the signatures on this document was forged. See Ingenuity 13 LLC, 2013 U.S. Dist. LEXIS 64564, at *8; AF Holdings LLC v. Navasca, No. C-12-2396, 2013 U.S. Dist. LEXIS 102249,

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