National Intellectual Property Rights Coordination Center
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Thanks for your input.
Information about the Individual/Business that violated intellectual property rights:
Business Name
Warner Music Group Corp.
Full Name
Madonna Louise Ciccone
Location
Company Name: Warner Music Group Corp.
Street Address: 1633 Broadway
City: New York
State: NY (New York)
Zip Code: 10019
Country: USA
Phone Number
+1-212-275-2000
Email Address
officeofcompliance@wmg.com
Other Identifiers about the Individual/Business that violated intellectual property rights:
Web Site
https://www.wmg.com/
IP Address
Social Media Site
https://www.facebook.com/warnermusicgroup
Social Media User Account
Type of Commodity:
Does your complaint involve a government contract?
no
What type of commodity was involved?
CDs Piracy: Music
Other/Miscellaneious (Specify)
MV
Description of the Incident:
Description of the Incident
To the U.S. Department of Justice, Computer Crime and Intellectual Property Section (CCIPS), and the National Intellectual Property Rights Coordination Center (IPR Center),
My name is Gou Sutou, also known professionally as “chocoraru,” a Japanese independent creator, songwriter, producer, filmmaker, and creator of the music-film series “Naked Mermaid Alien.”
I am submitting this referral to request that the appropriate U.S. federal authorities review evidence concerning what I believe may constitute willful copyright infringement involving my previously published musical and audiovisual works.
The principal individual identified in my complaint is Madonna Louise Ciccone, together with any producers, directors, record-label personnel, distributors, or other persons or entities whose participation may be established by the evidence.
I have prepared documentary evidence comparing my earlier works with sixteen subsequently released works associated with Madonna. The materials include chronological publication records and detailed comparisons involving lyrics, narrative concepts, audiovisual expression, scene construction, recurring imagery, and the interconnected “music cinema” structure used across multiple works.
My works were publicly released before the works identified in my complaint. The chronology is therefore a central part of the evidence I am submitting.
This is not intended merely as an allegation based upon a general similarity in artistic style. I have compiled the specific elements that I believe require investigation, together with evidence of the dates on which my works were published and made publicly accessible.
The evidence package includes, among other materials:
Identification and publication dates of my original works;
Identification of the sixteen works associated with Madonna that I am asking authorities to examine;
Side-by-side comparisons of the relevant lyrics, audiovisual elements, concepts, sequences, and other expressive elements;
Evidence establishing the chronology of publication;
Records concerning the online publication and distribution of my works;
Materials concerning the availability and potential access to my works before the subsequent works were released;
Information concerning the record labels, platforms, producers, and other entities potentially connected with the distribution of the works;
Information concerning related civil proceedings or contemplated proceedings, where applicable; and
Additional electronic records and supporting documentation that can be provided to investigators upon request.
I respectfully request that CCIPS, the FBI, the IPR Center, and/or the appropriate United States Attorney’s Office review these materials and determine whether the evidence warrants investigation under applicable United States federal law, including, where appropriate, 17 U.S.C. § 506(a), 18 U.S.C. § 2319, or any other applicable federal statutes.
I understand that the determination of whether conduct constitutes a federal criminal offense belongs to U.S. law-enforcement authorities and prosecutors. I am therefore submitting the evidence for independent evaluation rather than asking the agencies to accept my conclusions without investigation.
Because the relevant works have been commercially distributed internationally, including through major digital platforms, I believe preservation of electronic records may be important. I am prepared to provide original files, publication records, platform records, correspondence, screenshots, videos, comparison materials, and other supporting evidence in my possession.
I am a Japanese national residing in Japan and am willing to cooperate with U.S. investigators remotely or through the appropriate international law-enforcement channels. I can provide further documentation and clarification in English as required.
Please confirm the appropriate procedure for formally submitting my complete evidence package and any large audiovisual files associated with this referral.
Thank you for your consideration.
Sincerely,
Gou Sutou
Professional name: chocoraru
Japan
Creator / Songwriter / Producer / Filmmaker
“Naked Mermaid Alien”
https://www.linkedin.com/in/sutougou/
Evidence package:
hf=true&sd=true
Subject of referral:
Suspected willful copyright infringement involving previously published musical and audiovisual works
Additional Facts Requiring Investigation: Coachella Complaint and Subsequent Removal of My Works
I would also like to bring to the attention of federal investigators a sequence of events that I believe warrants independent investigation.
I submitted a copyright-related protest concerning the alleged unauthorized use of elements of my works in connection with Coachella.
Following that protest, significant actions were subsequently taken against the distribution and availability of my works.
My YouTube channel and/or content was removed or disabled, and my works were also removed or made unavailable through Apple.
In addition, DistroKid, my distributor, received communications indicating that my content would no longer be accepted for distribution by both platforms.
I possess records relating to these events, including platform and distributor communications, removal records, dates, and other electronic documentation.
An additional fact that may be relevant to the investigation is that Madonna was present at Coachella during the relevant period.
I am not asking the Department of Justice or federal investigators to assume that Madonna, Apple, YouTube, DistroKid, Coachella, or their respective personnel coordinated these events.
Rather, because of the chronology, I respectfully request that investigators determine whether there was any connection between:
my copyright-related complaint or protest concerning Coachella;
any persons who became aware of that complaint;
Madonna or persons acting on her behalf;
communications involving Apple, YouTube, DistroKid, Coachella, record labels, management, producers, or other relevant parties;
the subsequent removal or disabling of my works and channel; and
any loss, deletion, suppression, or unavailability of electronic evidence relevant to the underlying copyright allegations.
Because some of the affected material may itself constitute evidence concerning the chronology and public availability of my earlier works, I am particularly concerned about preservation of relevant electronic records.
I therefore respectfully request that investigators consider whether preservation of relevant platform records, internal communications, account records, removal records, distributor communications, and other electronically stored information is appropriate.
I can provide the communications I received through DistroKid, records concerning the Apple and YouTube actions, evidence concerning the timing of my Coachella protest, and records establishing the prior publication of my works.
I respectfully ask federal investigators to determine independently whether these events are connected or unrelated.
Organizations
Have you already reported this crime to any law enforcement or government agencies? If yes, please indicate the organizations/ individuals that you contacted (select all that apply)
Digital Piracy
Other (Specify Other)
Do you have pertinent documents/correspondence in paper or electronic form?
yes
Contact Information
Full Name
Sutou Gou
Business Name
chocoraru
Phone Number
81
Email Address
WARNING REGARDING KNOWINGLY PROVIDING FALSE INFORMATION
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■声優業界、生成ＡＩの被害深刻＝無断模倣で第三者が報酬―ベテラン声優ら「権利認めて」
(時事通信社 - 09月27日 07:31)
https://news.mixi.jp/view_news.pl?media_id=4&from=diary&id=8965173
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