Sample Settlement Letter

RE: NOTIFICATION OF COPYRIGHT INFRINGEMENT CLAIMS CASE ID#_________

March 21, 2007

Dear Sir/Madam:

We have asked your Internet Service Provider to forward this letter to you in advance of our filing a lawsuit against you in federal court for copyright infringement. We represent a number of large record companies, including EMI Recorded Music, SONY BMG MUSIC ENTERTAINMENT, Universal Music Group and Warner Music Group, as well as all of their subsidiaries and affiliates (“Record Companies”), in pursuing claims of copyright infringement against individuals who have illegally uploaded and downloaded sound recordings on peer-to-peer networks.

We have gathered evidence that you have been infringing copyrights owned by the Record Companies. We are attaching to this letter a sample of the sound recordings you were found distributing via the LimeWire (LimeWire) peer-topeer network. In total, you were found distributing 345 audio files, a substantial number of which are sound recordings controlled by the Record Companies.

The reason we are sending this letter to you in advance of filing suit is to give you the opportunity to settle these claims as early as possible. If you contact us within the next twenty (20) calendar days, we will offer to settle the claims for a significantly reduced amount compared to what we will offer to settle them for after we file suit or compared to the judgment amount a court may enter against you. If you are interested in resolving this matter now, please contact our Settlement Information Line at _________________ or, alternatively, you may settle this matter immediately online at www.p2plawsuits.com, using the CASE ID# that appears at the top of this letter.

In deciding whether you wish to settle this matter, here are some things you should consider:

The Copyright Act imposes a range of statutory damages for copyright infringement. The minimum damages under the law is $750 for each copyrighted recording that has been infringed (“shared”). The maximum damage award can be substantially more. In addition to damages, you may also be responsible for paying the legal fees we incur in order to pursue these claims, and are subject to having an injunction entered against you prohibiting you from further infringing activity.
Now that you are aware that a lawsuit may be filed against you, there is an obligation for you to preserve evidence that relates to the claims against you. In this case, that means, at a minimum, the entire library of recordings that you have made available for distribution as well as any recordings you have downloaded, need to be maintained as evidence. Further, you should not attempt to delete the peer-to-peer programs from your system – though you must stop them from operating. For information on how to do this, you may visit https://www.unitedmusic.ch/index.php/en/.

This is a serious matter and to the extent you have any questions, we strongly encourage you to contact us to ask those questions. Finally, if you would like more information regarding music downloading/file sharing and peer-to-peer networks, please visit www.p2plawsuits.com.

IF WE DO NOT HEAR FROM YOU WITHIN TWENTY (20) CALENDAR DAYS FROM THE DATE OF THIS LETTER, THEN WE WILL FILE SUIT AGAINST YOU IN FEDERAL COURT.

We are not your lawyers, nor are we giving you legal advice. We urge you to consult with an attorney immediately to advise you on your rights and responsibilities.

Sincerely,

________________

EXHIBIT A

IP Address: _________ 2007-02-07 _________ EST
CASE ID#______________
P2P Network: LimeWire (LimeWire)
Total Audio Files: 345

SONY BMG MUSIC
ENTERTAINMENT
Michael Jackson
Billie Jean
Thriller 41-965

Warner Bros. Records Inc.
Red Hot Chili
Peppers
Otherside Californication 174-922

Interscope Records
Limp Bizkit
Faith Three Dollar Bill, Y'all$
238-798

UMG Recordings, Inc.
3 Doors Down
Kryptonite
The Better Life 277-407

BMG Music
Eve 6
Inside Out
Eve 6 257-983

BMG Music
Lit
My Own Worst Enemy
A Place in the Sun 264-272

Elektra Entertainment Group Inc.
Third Eye Blind
Jumper
Third Eye Blind 188-673

UMG Recordings, Inc.
Semisonic
Closing Time
Feeling Strangely Fine 251-980

SONY BMG MUSIC
ENTERTAINMENT
Train
Meet Virginia
Train 298-334

UMG Recordings, Inc.
Tom Petty
American Girl
Long After Dark 50-037