This site is for those with unauthorized cable TV descrambler problems.
Page last revised 03/03/15
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the Law Office of Gary Ruff:
Unauthorized descrambler possession is detected by the acquisition of purchase records pursuant to civil proceedings and lawsuits and/or criminal prosecution of cable box suppliers or discovery in the home by cable company technicians. More specific information on detection and how the information is utilized as the basis of federal lawsuits follows at the end of this page; but for now, please know that if a cable or satellite provider is alleging you have purchased a pirate-box decoder, do not ignore the matter- for that can lead to a lawsuit and an ignored lawsuit can lead to a judgment against you in “default” for a considerable sum of money. A lawsuit against an individual for in home use of an unauthorized decoder can potentially result in a judgment for $10,000.00 for each violation, plus attorney fees and full costs. Importantly, the relevant statutes set forth both civil and criminal penalties.
Although some have become defendants in lawsuits, many visitors to this site are recipients of a cable company “demand letter”, wherein a sum of money and surrender of an unauthorized decoding device is demanded under threat of legal action. Although these letters may differ somewhat as to content, a demand letter generally raises numerous factual and legal issues.
You may be aware that “issues of fact” and “issues of law” are the only components directing a legal analysis (an analysis as to whether or not an act can be the basis of a civil claim or criminal action). For example: whether or not an election ballot is “dimpled” is an issue of fact; the significance of a “dimple” is an issue of law. Compelled students will remember that neither issue was easy to establish. In fact, the law can be more difficult to establish than the facts (some of the legal issues involved in signal theft cases have yet to be uniformly resolved). In any event:
As to factual issues: the outcome will depend on the factual circumstances associated with the alleged purchase: credibility of invoice evidence, price paid, efficacy of the device(s), device dedication, subscription and viewing records, credibility of service provider witnesses, and credibility of the defendant.
Legal issues are potentially numerous. Three, however, are worthy of particular attention:
How can they prove I took possession of a box and can they use that proof against me in court?
Don’t they have to prove that I used the box to decode their signal?
Do I have to pay for the cable company’s lawyer?
Here follows an actual court case, which is calculated to inform you as to many legal and typical factual details of a pirate-box case. (This is heavy reading; however, those of you with little time can read just the boldface and pick up the important points, including my legal opinion and editorial comment [which follow the case], in about five minutes)
The referenced U.S.C. sections herein (and especially those under Title 47) demand careful reading: among other things, they are a composite of both criminal and civil violations and actual and statutory damages. Fortunately, the LII (legal information institute) sets forth the statutes in an indented fashion that is inclined to make the task easier (at least visually). Your editor expresses his gratitude to them for liberally permitting “links” and for their obvious public service.
United States District Court, S.D. New York.
TIME WARNER CABLE OF NEW YORK CITY, Plaintiff,
Edda BARBOSA, et al., Defendants.
No. 98 Civ. 3522JSMRLE.
Jan. 2, 2001.
REPORT AND RECOMMENDATION
ELLIS, Magistrate J.
This is an action by a cable television system operator against five individuals for unauthorized interception and viewing of plaintiff's "scrambled" cable-borne television signals by means of an illegal decoder device. On May 10, 2000, default judgments were entered against Ziola Diaz, Curtis Flowers, and Karen Smith, the three defendants who are the subject of this Report and Recommendation. The matter was referred to the undersigned for an inquest on damages. Plaintiff seeks damages pursuant to the Communications Act of 1934, as amended, 47 U.S.C. §§ 553(a) and 605(a). For the reasons stated below, I recommend that judgment be entered for plaintiff in the amount of $2,388 against Diaz, $10,788 against Flowers, and $10,188 against Smith.
Time Warner Cable of New York City ("TWCNYC") is a cable television operator which has been awarded franchises by New York City. Pursuant to these franchises, TWCNYC is authorized to construct, operate and maintain cable television programming in New York, Kings, and Queens Counties.TWCNYC programming consists of various tiers of cable television programming and different individual programming channels. "Basic" service is a tier available at a monthly rate which enhances quality reception of broadcast stations and includes a small number of additional programming services. "Standard" service is a higher tier of service which includes an expanded set of TWCNYC's programming services, including all those offered in the Basic service package, but does not include premium and pay-per-view programming. Standard service is offered to individual subscribers at a monthly rate of approximately $30 per month.
TWCNYC subscribers may elect to subscribe to one or more "premium" programming services such as Cinemax, Home Box Office and Showtime, for an additional monthly charge per service. Premium services range in price from $7 to $13 per month per service. Currently, the full range of TWCNYC's non-premium and premium programming channels, not including pay per view events, is offered at an average cost to a residential subscriber of approximately $85 per month. TWCNYC also offers pay-per-view programming, which is a service enabling a subscriber to purchase individual movies, sporting events, or other entertainment for a per-event fee over and above the subscriber's regular monthly fee. The pay-per-view service offered by TWCNYC includes selections which typically range in price between approximately $4 and $49.99 per selection and are offered continuously over a 24-hour period. The aggregate cost for each separate and distinct pay-per-view event offered by TWCNYC is approximately $400 per month assuming that each is viewed only once. Most such events can be watched repeatedly each month.
TWCNYC receives the signals to cable television programing service, including its premium and most of its pay-per-view programming channels by transmissions received via orbiting satellites from the producers of such programming. TWCNYC's subscribers pay a monthly fee for the specific level and amount of programming services they have selected and purchased from TWCNYC. Each TWCNYC subscriber is entitled to receive only the level and amount of cable programming and services which that subscriber has specifically selected and paid for.
For a subscriber to receive these transmitted cable television signals on his or her television set, TWCNYC provides each subscriber with a device known as a "converter-decoder," which converts the multiple signals simultaneously transmitted over the system into different "channels," which can be viewed on a subscriber's television set. To prevent theft and unauthorized reception, TWCNYC encodes or "scrambles" the signals to all of its premium and pay-per-view programming services. Programming not purchased will continue to be scrambled and, therefore, will not be viewable on the subscriber's television set.
TWCNYC separately authorizes, either by a technical modification or by a computer command, each of the converter-decoders provided to its subscribers to descramble only those scrambled programming channels which the respective subscriber has selected and purchased. The converter-decoders which TWCNYC provides to its subscribers have the technology feature and function known as "addressability." Addressability is a communication link between a cable operator's central computer and the descrambling and computer circuitry in each converter-decoder provided to its subscribers. Addressability enables a cable operator to send a signal command to the converter-decoders assigned to those subscribers who have purchased a particular program. For pay-per-view programming, another command is sent to converter-decoders to resume scrambling when the purchased program has ended. Addressability also enables a cable operator to upgrade or downgrade their subscribers' authorized levels of service without having to mechanically alter or physically replace a converter- decoder by way of a service call to a subscriber's residence. TWCNYC's contract agreements with its subscribers forbid unauthorized tampering with TWCNYC's equipment and the unauthorized reception of programming services. It is possible, however, for an individual to install a modified or "pirate" converter-decoder onto TWCNYC's cable system or to modify an authorized converter-decoder into a "pirate" model."Pirate" devices enable reception of all scrambled programming, including all premium and pay-per-view channels, without the subscriber paying for such programming.
There is no legitimate function or purpose on a cable system for a converter-decoder which has been modified to descramble all scrambled cable programming, including pay per view events. Such a device is only capable of enabling its user to receive unauthorized cable television programming without having to make payment to a cable operator.
A. Claims Against Ziola Diaz
TWCNYC's claims against the Ziola Diaz arose on January 30, 1997, when a TWCNYC technician during a routine service call at Diaz's home discovered a modified cable television converter-decoder. In accordance with TWCNYC policy, this device was seized by the technician. The converter- decoder seized from Diaz's apartment was secured and brought to TWCNYC's Northern Manhattan facility for testing, where it was examined by TWCNYC's technicians.
Technicians physically examined the device and connected it to TWCNYC's cable system. It was found to descramble (and therefore, allow viewing of) all of TWCNYC's premium and pay-per-view programming channels without authorization.
Diaz was installed as a subscriber to TWCNYC's cable television programming and provided with TWCNYC's authorized converter-decoder on September 20, 1996. Prior to the seizure of the modified cable box, Diaz was subscribing to TWCNYC's standard level of cable service at an approximate cost of $31.70 per month. Diaz disconnected her service on January 30, 1997.
Claims Against Curtis Flowers
TWCNYC's claims against the Curtis Flowers arose on June 3, 1997, when a TWCNYC technician during a routine service call at Flowers' home discovered a modified cable television converter-decoder. This device was seized by the technician. The converter-decoder seized from Flowers' apartment was secured and brought to TWCNYC's Northern Manhattan facility for testing, where it was examined by TWCNYC's technicians.
Technicians physically examined the device and connected it to TWCNYC's cable system.
found to descramble (and therefore, allow viewing of) all of TWCNYC's premium
and pay-per-view programming channels without authorization.
Flowers was installed as a subscriber to TWCNYC's cable television programming and provided with TWCNYC's authorized converter-decoder on October 16, 1994. Prior to the seizure of the modified cable box, the defendant was subscribing to TWCNYC's standard level with two sets of cable service at an approximate cost of $40 per month.. Flowers disconnected his service on June 3, 1997.
C. Claims Against Karen Smith
TWCNYC's claims against Karen Smith arose on May 28, 1997, when a TWCNYC technician went to her home to retrieve TWCNYC's converter-decoder after Smith's service had been disconnected. At that time the technician discovered a modified cable television converter-decoder. This device was seized by the technician. The converter-decoder seized from Smith's apartment was secured and brought to TWCNYC's Northern Manhattan facility for testing, where it was examined by TWCNYC's technicians.
Technicians physically examined the device and connected it to TWCNYC's cable system. It was found to descramble (and therefore, allow viewing of) all of TWCNYC's premium and pay-per-view programming channels without authorization
Smith was installed as a subscriber to TWCNYC's cable television programming and provided with TWCNYC's authorized converter-decoder on November 11, 1994. Prior to the seizure of the modified cable box, Smith was subscribing to TWCNYC's standard level of cable service at an approximate cost of $44.80 per month. TWCNYC disconnected Smith's cable service on May 27, 1997.
defendants have failed to appear or defend in this action and have been
adjudged in default by the orders entered by Judge Martin. "[A] default
judgment entered on well-pleaded allegations in a complaint establishes a
defendant's liability." Bambu Sales, Inc. v. Ozak Trading,
Inc., 58 F.3d 849, 854 (2d Cir.1995)
(quoting Trans World Airlines, Inc. v.
Hughes, 449 F.2d 51, 63 (2d Cir.1971), reversed on other grounds, 409 U.S. 363(1973).
Plaintiff was directed by the undersigned to submit affidavits and any other documentation in support of its request for damages. Plaintiff seeks maximum statutory damages of $10,000 under 47 U.S.C. § 605 for each defendant's violations.
A. Statutory Framework
Section 553(a) of title 47 of the United States Code provides, in pertinent part:
No person shall intercept or receive or assist in intercepting or receiving any communications service offered over a cable system, unless specifically authorized to do so by a cable operator or as may otherwise be specifically authorized by law.
Subsection (b) prescribes criminal penalties for willful violations, and subsection (c) creates a civil cause of action for "any person aggrieved by any violation of subsection (a)(1)." Civil remedies include injunctive relief, damages, costs and attorney's fees. 47 U.S.C. § 553(c)(2). As to damages, the party aggrieved may prove "actual damages" as specified in subsection (c)(3)(A)(I), or, as plaintiff has done here, may elect to receive, under subsection (c)(3)(A)(ii), "statutory damages for all violations involved in the action, in a sum of not less than $250 or more than $10,000 as the court considers just." Whichever method of computation of damages is chosen, the amount awarded may be increased if plaintiff proves willfulness or decreased if defendant proves innocence. 47 U.S.C. §§ 553(c)(3)(B) and (C).
Section 605(a) of title 47 of the United States Code provides, in pertinent part:
No person not being authorized by the sender shall intercept any radio communication and divulge or publish the existence, contents, substance, purport, effect, or meaning of such intercepted communication to any person.
47 U.S.C. § 605(a). Subsections (e)(1) and (2) prescribe criminal penalties, and subsection (e)(3) creates a civil right of action for "person[s] aggrieved." 47 U.S.C. § 605(e)(3)(A). Civil remedies include injunctive relief, costs and attorney's fees, § 605(e)(3)(B)(I) and (iii); and either "actual damages," § 605(e) (3)(C)(I)(I), or "an award of statutory damages for each violation ... in a sum of not less than $1,000 or more than $10,000 ...," § 605(e)(3)(C)(I)(II). In provisions that correspond to § 553(c)(3)(B) and (C), the amount awarded under § 605 may be increased if plaintiff proves willfulness or decreased if defendant can demonstrate innocence. §§ 605(e)(3)(C)(ii) and (iii).
B. Defendants' Liability
TWCNYC's programming is broadcast via orbiting satellites and is therefore protected under 47 U.S.C. § 605(a) as radio communications, and defendants' unauthorized reception is a violation of 47 U.S.C. § 605(a), which prohibits the unauthorized reception of protected radio communications, as well as § 553(a)(1), which protects all communication by cable systems. International Cablevision, Inc. v. Sykes, 75 F.3d 123, 133 (2d Cir.1996) ( "Sykes II" ); Time Warner Cable of New York City v. U.S. Cable T.V., Inc., 920 F.Supp. 321, 328-29 (E.D.N.Y.1996). TWCNYC is a "person aggrieved" within the meaning of 47 U.S.C. §§ 553(c)(1) and 605(e)(3)(A).
When a court determines that a defendant's conduct has violated both § 605 and § 553 of the Communications Act, a plaintiff may recover damages only under one of those sections. American Cablevision of Queens v. McGinn, 817 F.Supp. 317, 320 (E.D.N.Y.1993). An aggrieved cable operator is entitled to elect to recover damages under § 605 in consideration of § 605's higher damages awards. International Cablevision, Inc. v. Sykes, 997 F.2d 998, 1007 (2d Cir.1993); Sykes II, 75 F.3d at 127.
TWCNYC has elected to recover money damages against each defendant in the form of statutory damages as opposed to actual damages, and seeks enhancement for willful violations. Because this case resulted in a default judgment, there is no evidence to contest the finding of willful violation. Defendants, however, could not have believed that they were legitimately entitled to descramble the broadcasts using the pirate boxes. These were willful violations. Plaintiff is entitled to some enhancement of the damages award. Although it is not possible to know exactly how long defendants profited from the use of the illegal boxes, such use did deprive plaintiff of significant income. The enhancement of damages for willfulness should, therefore, take into account the duration of the violation. For purposes of this Report and recommendation, the Court will assume that the illegal use began immediately upon the start of service by each defendant.
C. Calculation of Damages
TWCNYC seeks maximum statutory damages of $10,000 from each defendant. The Court, however, finds that the statutory goals are served by taking into account the duration of the violation. According to plaintiff, its basic service costs approximately $30 per month while subscription to all premium channels costs approximately $85 per month. The plaintiff thus potentially loses approximately $55 per month when a pirate box allows a user to receive scrambled channels. In addition, the plaintiff provides multiple pay-per-view events, movies, and special events each month. Pay-per-view movies cost approximately $4 per viewing, and special events may cost as much as $50 per broadcast. While it is not possible to know how many movies the defendants would have viewed illegally, more than a dozen movies are available each month. The viewing of ten to twelve movies at $4 per movie and one premium event at $50 would result in an additional loss to plaintiff of approximately $90 to $98 per month. [FN1] Adding this amount to the $55 lost on premium programming, the total loss to plaintiff would be approximately $145 to $153 per month. The Court will use a figure of $150 for its calculations.
FN1. These decoders were used in private residences. While in theory defendants could have viewed every pay-per view offering each time it was broadcast, I have attempted to make a reasonable assessment of actual use by a private violator as opposed to a commercial violator. Time and taste would limit the actual viewing by defendants.
While I find that this amount reasonably approximates the lost revenue from the use of a pirate box, it would not be sufficient deterrence if the damages payable by a violator were limited to the value of the stolen services. There would be no incentive to cease the violation if the penalty were merely the amount that should have been paid. The statute recognizes this fact in setting a minimum damage award of $1,000. I find that the damage award should be roughly equivalent to twice the amount of fees avoided, or approximately $300 per month.
Defendant Diaz began using her pirate box on or about September 1996 and her service terminated in January 1997, or a period of approximately four (4) months. Defendant Flowers began using his pirate box decoder in October 1994 and his service terminated in June 1997, or a period of approximately thirty-two (32) months. Defendant Smith began using his pirate box on or about November 1994 and her service terminated in May 1997, or a period of approximately thirty (30) months. At $300 per month, Diaz shall be liable for damages of $1,200, Flowers for damages of $9,600, and Smith for damages of $9,000.
Plaintiff has submitted an affidavit by Jennean R. Lee indicating the tasks performed, the hours spent, and the rate requested. I have examined the supporting documentation and conclude that plaintiff's attorney's fees and disbursements were reasonable and adequately documented. Plaintiff seeks a total award of $3,564, divided equally between the three defendants. I therefore recommend that TWCNYC be awarded $1,188 against each defendant.
willful violation of § 605(a), I recommend that defendant Diaz pay statutory
damages of $1,200, plus costs and attorney's fees of $1,188, for a total of
$2,388. For willful violation of § 605(a),
I recommend that defendant Flowers pay statutory damages of $9,600, plus costs
and attorney's fees of $1,188, for a total of $10,788. For willful violation of
I recommend that defendant Smith statutory damages of $9,000, plus costs and
attorney's fees of $1,188, for a total of $10,188. Judgment should be entered
Pursuant to Rule 72, Federal Rules of Civil Procedure, the parties shall have ten (10) days after being served with a copy of the recommended disposition to file written objections to this Report and Recommendation. Such objections shall be filed with the Clerk of the Court and served on all adversaries, with extra copies delivered to the chambers of the Honorable John S. Martin, 500 Pearl Street, Room 1620, and to the chambers of the undersigned, Room 1970. Failure to file timely objections shall constitute a waiver of those objections both in the District Court and on later appeal to the United States Court of Appeals. See Thomas v. Arn, 474 U .S. 140, 150 (1985); Small v. Secretary of Health and Human Services, 892 F.2d 15, 16 (2d Cir.1989) (per curiam ); 28 U.S.C. § 636(b)(1) (West Supp.1995); Fed.R.Civ.P. 72, 6(a), 6(e).
Time Warner Cable of New York City v. Barbosa
END OF DOCUMENT
Editor’s Notes: The above case is one of many; it was selected because it offers clear and detailed explanations of the issues relevant to a cable theft case. It is important to note that these judgments were issued in “default”; that is: the defendants did not appear to defend themselves
ADMISSIBILITY OF DECODER SUPPLIER INVOICES AND RECORDS IN COURT
Note that the boxes were discovered by cable company technicians. Lately, however, and due to aggressive efforts on behalf of cable service providers, computer records of decoder sales by various suppliers are coming into cable company hands and being utilized as a basis for prosecution of the purchasers. Generally, this occurs when the decoder provider (manufacturer or reseller) is successfully prosecuted under civil and/or criminal provisions of the statutes referred to in the prior case and the records are acquired as part of a settlement agreement, seized by law enforcement officials, or pursuant to a Writ of Seizure. It should be noted that although these purchase and/or shipment records may be used as a basis of claims against you, they are not necessarily admissible against you in court. The admissibility in court thereof is subject to Federal Rules of Evidence Rule 803(6) and Rule 807, and may be the object of a fairly complex study.
In order to evaluate your position relevant to a “pirate-box” prosecution, you must understand a legal principle known as “burden of proof”. Your editor’s clients frequently point out that the plaintiff must prove “use” of the device; mere possession is no violation of the law. That is correct, but not necessarily of practical effect. This, as the civil standard of proof (known as “preponderance of evidence”) requires the finder of fact (judge or jury) to make a decision based upon which is the most probable.
Now, cable company end user cases rarely go to trial. Typically, they either settle or default and get large default judgments against them. However, let us assume that during the course of a trial, the cable company has presented credible (for the sake of our example, we shall assume it to be admissible) evidence of the purchase of a viable decoder, but no direct evidence of actual use; together with evidence that defendant was a cable subscriber (had access to the “feed”) and that the device required little or no technical skill to activate (even if technical skill is required, it is frequently possible for the plaintiff to successfully secure a verdict against the defendant).
At the conclusion of plaintiff’s case, defense counsel will ask for a dismissal (or directed verdict if a jury trial) on the ground that the cable company has offered no direct evidence that the box was actually used to decode the signal (for that is the heart of the matter); therefore, plaintiff has not made a prima facie case and the matter should end here, without the subscriber having to testify. Whereupon, the plaintiff’s attorney stands up and says the equivalent of:
“Look, your Honor: the subscriber maintains a cable subscription and does not subscribe to premium channels or order pay-per-view movies. She purchased a ‘decoder’ for $199.00, plus shipping and handling. The purchased decoder has no recognized legitimate purpose and is capable of decoding our encoded programming without authorization. Therefore, the subscriber had the means for unauthorized decoding at her disposal: the “feed” from the cable company, the decoding device (for which she disbursed a sum of money and the installation of which required no technical skill) and (presumably) she possessed a television. If she weren’t going to use it why would she spend good money for it? Accordingly, it is more likely than not that the purchased decoder was utilized by the subscriber to unlawfully decode our encoded signal.”
In any event, based upon the above example, it is possible for the cable company to make a “prima facie case” against the subscriber.
A “prima facie case” is a case that will prevail until contradicted and overcome by other evidence. Or, stated differently: plaintiff’s evidence will reasonably allow the conclusion that plaintiff seeks if defendant produces no credible evidence to rebut it.
If the plaintiff cable company can establish a prima facie case, it then falls to the subscriber to present proof that plaintiff’s signal was not decoded without authorization. Examples include, but are not limited to: defendant was not a cable service subscriber; defendant did not take possession of a “pirate-box”; “pirate-box” in issue was not competent to decode the signal; box was never used to decode the signal; decoding was in fact authorized; or (and importantly), there are mitigating circumstances which are relevant to the issue of damages; etc. In fact, “damages” are an important issue in the litigation of these cases.
In American courts, and generally speaking, each party to a lawsuit pays for its own lawyer without regard to which party wins. However, you will note that in the above case, various awards of attorney’s fees were granted to the cable companies. That is because these particular statutes provide that the “aggrieved party” who prevails (wins the lawsuit) is entitled to attorney fees (plus various other costs, including investigation expenses). By law, only the cable or satellite provider can be an “aggrieved party” (see VJC Productions, Inc. v. Kydes, 903 F. Supp. 42). This means that if the subscriber loses he must pay for the service provider’s attorneys. However, if the service provider loses it is not required to pay for the subscriber’s attorney fees. Including discovery, conferences and trial, a proceeding in federal court tends to be formal and elaborate. This is decidedly to the advantage of the signal providers. Therefore, defendants must greet litigation with strategies calculated to reduce or eliminate liability for signal provider attorney fees and shorten and “informalize” proceedings.
It should be noted that prosecutions under 47 U.S.C. §§ 553(a) allow the judge to award to the signal provider and against the losing defendant “reasonable” attorney fees and recovery of full costs (it’s discretionary). However, 47 U.S.C. § 605(a) makes an award of “reasonable” attorney fees and full costs mandatory against a losing defendant (the judge’s discretion reaches only to what is “reasonable”).
Unless resolved, signal theft civil cases work their way through three stages:
I. Service providers directly solicit the subscriber for a sum of money and return of the box.
II. Legal action, which if successful, terminates with
judgment against subscriber.
III. Judgment collection.
Both federal statutes under which these civil actions are prosecuted (47 U.S.C. §§ 553(a) ; 605(a) and the “Wiretap Act”) also set forth criminal penalties; in fact, they are primarily criminal statutes. That being the case, prudence dictates that any settlement agreement, even one made prior to the commencement of a lawsuit, be drafted so as not to facilitate a criminal prosecution for signal theft (or another civil claim for similar conduct).
Although these websites provide a great amount of helpful information, it is disconcerting to be suddenly and unwillingly cast into a situation you do not understand. Even if you are a fast study, the law relevant to signal theft is complex and the courts have developed varying interpretations thereof. Moreover, cable companies and their agents do a lot of posturing* regarding settlement sums. They are well aware as to which attorney has the specialized knowledge and command of the subject necessary to have prompt and significant impact upon the outcome.
* Assertions that exaggerated or inflated positions are policy and which disassemble when confronted by a knowledgeable specialist.
Lastly, remember it is difficult to negotiate for yourself without imparting incriminating information to the adversary.
The Law Office of Gary Ruff presents the preceding as a public service. Gary is experienced in defending against cable and satellite TV company claims for signal theft, including unauthorized decryption and illegal or unauthorized possession of decoding equipment. His experience and familiarity with the subject, together with “economies of scale”* permit him to provide these services for very reasonable fees.
*For example: the vast majority of necessary court papers, discovery demands, and motions used in defending these claims are already in our computers. When that is the case, we don’t have to charge you to research and write a new document; instead, we charge you considerably less to edit and submit the one in our files.
The Law Office of Gary Ruff
“Defending Consumers Against Electronic Piracy Claims” TM
21 Pulaski Rd., Ste 154
Kings Park, N.Y. 11754
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