Nexon America Inc. v. Gameanarchy LLC

Doing a separate thread for each of these. More documents may follow thanks to donations and as they get publicly released.

This one doesn't have an actual complaint attached to it yet in the full formal version, and no one has had time to reply yet since they've yet to finish identifying defendants.

Nexon America Inc. v. Gameanarchy LLC

Request to counsel to file appropriate forms

03. Trademark (CV-31)

Directive to attempt Alternative Dispute Resolution before wasting the time & resources of the court

04. Notice to Parties of Court-Directed ADR Program (ADR-8)

Request from plaintiff for expidited discovery before evidence can be destroyed or is lost.

05. Declaration of Marc E. Mayer

Request for expidited discovery to determine identities of defendants.

05. Ex Parte Application to Expedite

Propsed Judge's order granting right to subpoenas various internet services to identify defendants.

05. Proposed Order

Actual Copyright Infringement Notice to Court

08. Report on Filing of Copyright Action (Initial Notification)

Actual Judge's order granting right to subpoenas various internet services to identify defendants.

09. Order on Ex Parte Application to Expedite

Defendant's Rebuttal

10. Answer to Complaint (Discovery)

Order for Joint Scheduling

11. Order

12. Joint Report Rule 26(f) Discovery Plan

13. Referral to ADR (No 2) (Mediation Panel) (ADR-12)

14. Order

20. Stipulation for Protective Order

Everyone agrees that certain things may be private and need to remain confidential.

21. Protective Order

Any party can declare something confidential and have it redacted from public documents by showing just cause.



32. Response in Opposition to Motion
Response in Opposition to Motion for lawyer to leave case. Nexon requests default judgment if no lawyer is present to represent the LLC because an LLC can not defend itself unrepresented.

36. Opposition (Motion related)
Refution of the laches defense. Hilariously entertaining read.

37. Opposition (Motion related)
Refutation of the need for Ahnlabs to be present in a case about bypassing hackshield to infringe on Nexon's copyright.

40. Order on Motion to Dismiss Case
Judge refuses both attempts to dismiss.

42. Motion for Summary Judgment
Motion for summary judgement against David Allen Baker & Default judgment against Game Anarchy LLC. Nexon wants $232,964.76 from David.

42a.Declaration of Bradley J. Mullins and Exs. 1 - 13
Lots of exhibits and depositions.

42b. Exhibit Exs. 14 - 26 to Decl. of Bradley J. Mullins
More exhibits

42c. Declaration of Andrew Boortz
More exhibits, including the entire ToS.

42d. Proposed Order
What Nexon would like the proposed order to be/say. $1,432,964.76 judgment. (Unofficial/Not enacted)

51. Order on Application to Seal (document)
Order to seal certain exhibits. (approved)

58. Order on Motion for Summary Judgment
The Court orders Mr. Baker to either hire counsel or filed an opposition to the Motion for Summary Judgment no later than March 18, 2013

59. Objection-Opposition (Motion related)
Very poor assertion that "HackShield is not a Technological Measure that Effectively Controls Access as defined by the DMCA"

60. Statement (Motion related)
Item by item dispute/undisputed list of statements. Interesting read, but really long and references other documents.

61. Declaration (Motion related)
An explanation of some of the disputes from 60. This one is actually more convincing than #59 about why the suit, as it is filed, is fundamentally wrong.

62. Objection-Opposition (Motion related)
More of the disputed explanations from #60. Mostly attempts to declare things as hearsay.

64. Reply (Motion related)
Attorney for the plaintiff proceeds to shred 60/61. Very interesting.

65. Objection-Opposition (Motion related)
Attorney for the plaintiff proceeds to shred 60/62. Very interesting.

66. Statement (Motion related)
Plaintiff attorneys provide supporting reasoning about their request for summary judgement.

67. Order on Motion for Summary Judgment
Summary Judgment Motion is GRANTED on Nexon’s first and eighth claims for relief.
Summary Judgment Motion is GRANTED on Nexon’s fifth claim for relief.
In sum, the Summary Judgment Motion (Docket Nos. 42, 53) is GRANTED.
Summary Judgment Motion is granted as to liability only and as against Mr. Baker only
Nexon also shall file a supplemental brief on how the Default Judgment Motion (againt Game Anarchy LLC itself, which is being used as a separate defendent in this case) should be resolved.

71. Judgment
Mass summmary that Nexon basically got what it wanted on all counts, against both defendents.
Nexon is awarded a monetary judgment against Defendants, jointly and severally, of a sum of $1,432,964.76, broken down thats;

Statutory damages in the minimum allowable amount ($200 per violation) under § 1203©(3)
(A) of the DMCA, for each of Defendants’ 6,000 violations, totaling $1,200,000.
(b) Defendants’ unjust profits attributable to the infringements alleged in the Complaint, as provided by the Copyright Act, 17 U.S.C. § 504, totaling $232,964.76.

72. Report of Determination of Copyright Action (CLOSE)(AO 121)
Copy of the judgment sent to the Register of Copyrights at the library of congress.

74. Request to Dismiss (cause or other)
Nexon requested the court dismiss without prejudice the second, third, fourth, sixth, seventh and ninth claims of their Complaint, with each party to bear its own costs and attorneys’ fees.

75. Order on Request to Dismiss (cause of action or other)
Court order granting #74