-729 I am also satisfied that the target online locations, by providing the functionality to which I have referred, facilitate the infringement of the applicants’ copyright in the applicants’ cinematograph films: see s 115(1)(b). 30 The more difficult issue in this case is whether the “primary purpose” requirement of s 115(1)(c) is satisfied. THE PRIMARY PURPOSE REQUIREMENT 31 The primary purpose requirement imposes an important limitation on the power of the Court to make an order under s 115A. As explained in Roadshow (referring to the Revised Explanatory Memorandum to the Copyright Amendment (Online Infringement) Act 2015 (Cth)) at [48]-[49]: [48] The requirement that the online location have as its primary purpose copyright infringement or the facilitation of copyright infringement provides an important check on the operation of s 115A. Thus, the fact that a particular website makes some unlicensed copyright material available online or is routinely used by some users to infringe copyright does not establish that the primary purpose of the website is to infringe or facilitate the infringement of copyright. The s 115A(1)(c) requirement is explained in the Revised Explanatory Memorandum as follows: 38. The Court must also be satisfied that the primary purpose of the online location is to either infringe copyright, or facilitate the infringement of copyright generally. This is an intentionally high threshold for the copyright owner to meet as a safeguard against any potential abuse. For example, the ‘primary purpose’ test would prevent an injunction to disable access to an art gallery website operated outside of Australia that may contain an unauthorised photograph. Thus, a website such as www.youtube.com or www.blogger.com would not prima facie satisfy the test as being an online location that infringes or facilitates infringement of copyright. Technology and technological change is not to be chilled or targeted by this amendment. 39. The primary purpose test would also prevent an injunction to block an online location operated overseas that provides legitimate copyright material to individuals within another geographic location, but are not licensed to distribute that copyright material in Australia. For example, the United States iTunes store does not operate with the primary purpose of infringing copyright or facilitating the infringement of copyright and therefore access to this online location would not be disabled under an injunction. The test is also not intended to capture Virtual Private Networks (VPNs) that are promoted and used for legitimate purposes, or merely used to access legitimate copyright material distributed in a foreign geographic market. VPNs have a wide range of legitimate purposes and have no oversight, influence or control over their customers’ activities. 40. The primary purpose test would direct the Court to consider the principal activity for which the online location exists and the