MOTION PICTURE ASSOCIATION OF AMERICA, INC.
15503 VENTURA BOULEVARD
ENCINO, CALIFORNIA 91436

UNITED STATES
PHONE: (818) 728-8127 
Email: MPAA23@pacbell.net                                       
Anti-Piracy Operations

Jeanne Smythe
Vice Chancellor
Finance/Administration
CB#3420, 101 Abernethy Hall
University of North Carolina at 
Chapel Hill
Chapel Hill, NC 27599-3420
Copyright@unc.edu
Fax: 919-962-5334

Date: March 16, 2000  

RE:     Illegal Provision of DeCSS/Circumvention Device

Site/URL:       ils.unc.edu/inls183/resources.shtml#DVD
                MPAA File#: 5-671-294

Dear Jeanne Smythe:

The Motion Picture Association of America is authorized to act on
behalf of the following copyright owners:

Columbia Pictures Industries, Inc.
Disney Enterprises, Inc.
Metro-Goldwyn-Mayer Studios Inc.
Paramount Pictures Corporation
TriStar Pictures, Inc.
Twentieth Century Fox Film Corporation 
United Artists Pictures, Inc.
United Artists Corporation
Universal City Studios, Inc.
Warner Bros., a Division of
Time Warner Entertainment Company, L.P.

We have knowledge that the above-referenced Internet site is providing
a circumvention device commonly known as DeCSS.  DeCSS is a software
utility that decrypts or unscrambles the contents of DVDs (consisting
of copyrighted motion pictures) or otherwise circumvents the
protection afforded by the Contents Scramble System (CSS) and permits
the copying of the DVD contents and/or any portion thereof.  As such,
DeCSS is an unlawful circumvention device within the meaning of 17
U.S.C.  1201(a)(2),(3).  Providing or offering DeCSS to the public on
your system or network violates the provisions of 1201(a)(2) which
prohibits the "manufacturing, importing or offering to the public,
providing, or otherwise trafficking" in an unlawful circumvention
device.

On January 20, 2000, the United States District Court for the Southern
District of New York granted a Preliminary Injunction prohibiting the
Internet posting or other provision of DeCSS, having found that DeCSS
was a prohibited circumvention device within the meaning of
1201(a)(2) and that the offering, providing or trafficking of DeCSS
on the Internet violated 1201(a)(2).  That court thus enjoined:

Posting on any Internet web site, or in any other way manufacturing,
importing or offering to the public, providing, or otherwise
trafficking in DeCSS, and (b) posting on any Internet web site, or in
any other way manufacturing, importing or offering to the public,
providing, or otherwise trafficking in any technology, product,
service, device, component, or part thereof, that: (i) is primarily
designed or produced for the purpose of circumventing, or
circumvention the protection afforded by, CSS, or any other
technological measure that effectively controls access to plaintiffs'
copyrighted works or effectively protects the plaintiffs' rights to
control whether an end user can reproduce, manufacture, adapt,
publicly perform and/or distribute unauthorized copies of their
copyrighted works or portions thereof. . .

The Superior Court of Santa Clara County, California also recently
granted a Preliminary Injunction against the Internet posting of
DeCSS.

If you are bound by an injunction, maintaining the DeCSS utility on
your system or network violates the above injunction[s] and risks
court sanctions for contempt.

Even if you are not bound by this injunction, we submit the legal
rationale of these opinions would apply to the activities complained
of herein.  Thus we still request you comply with this request.

We hereby demand that you:

1) take appropriate steps to cause immediate removal of DeCSS from the
above identified URL, along with such other actions as may be
necessary or appropriate to suspend this illegal activity;

2) provide appropriate notice to the subscriber or account holder
responsible for the presence of DeCSS on your system or network,
advising him/her of the contents of this notice and directing that
person to contact the undersigned immediately at the e-mail address
provided above;

3) advise us of the name and physical address of the person operating
this site; and

4) maintain, and take whatever steps are necessary to prevent the
destruction of, all records, including electronic records, in your
possession or control respecting this URL, account holder or
subscriber.

By copy of this letter, the owner of the above-referenced URL and/or
email account is hereby directed to cease and desist from the conduct
complained of herein.

Thank you for your cooperation in this matter.  Your immediate response
is requested.

The information in this notification is accurate, and we declare,
under penalty of perjury, that the Motion Picture Association of
America is authorized to act on behalf of the owner[s] of exclusive
rights described above.

Should you have any questions, please contact us at the above listed
address.

Respectfully,
The Motion Picture Association of America