Delhi HC Grants Temporary Relief To Universal City Studios Against PlayIMDb, StreamIMDb Pirate Sites

The Delhi High Court has recently granted an ex parte ad interim injunction in favour of Universal City Studios Productions LLLP against several alleged rogue streaming websites, including playimdb.com and streamimdb.ru, which were accused of facilitating unauthorized streaming of copyrighted films such as Fast X, F9: The Fast Saga, and The Secret Life of Pets 2.

The bench comprising Justice Tushar Rao Gedela held that, “The material on record demonstrates that the defendants have devised a mechanism whereby users are redirected from legitimate IMDb title pages to unauthorized streaming interfaces merely by altering the domain structure while retaining the same IMDb Title ID. Such conduct, coupled with the use of domain names incorporating the expression 'IMDb', prima facie reflects dishonest adoption intended to exploit the goodwill and recognition associated with IMDb and to induce users into accessing infringing streams under the guise of legitimacy.”

Universal City Studios Productions LLLP, a California-based entertainment company, alleged that defendants including playimdb.com and streamimdb.ru employed a modus operandi whereby users were instructed to insert the word “play” before “imdb” in legitimate IMDb links, which redirected them to unauthorized streaming platforms hosting the plaintiff's copyrighted films.

The Studios submitted that the choice of names by the defendant domains suggested an attempt to imply that IMDb content could be played or streamed through them, even though IMDb primarily functions as a title information database and directs users to authorised viewing platforms.

It further submitted that it held exclusive rights in films including Fast X, F9: The Fast Saga, and The Secret Life of Pets 2, and that these activities violated its exclusive rights under Section 14(d) of the Copyright Act, 1957, causing irreparable harm to its revenue and substantial investment.

At the prima facie stage, the Court noted that the websites appeared to function through embedded rogue video players, pirate libraries, and cyberlockers, deliberately structured to facilitate large-scale copyright infringement.

Upon examining the material on record, the Court was satisfied that the activities attributed to the defendants prima facie amounted to unauthorized hosting, streaming, reproduction, communication, and making available of copyrighted content to the public in violation of Sections 14 and 51 of the Copyright Act, 1957.

It observed that the defendants' acts infringed the plaintiff's rights, causing irreparable harm to its revenue streams and undermining the substantial investment made in producing the original content.

It observed, “The pleadings indicate that the defendants are not passive intermediaries but are actively facilitating infringement through embedded players, redirect mechanisms, backend source resolution systems, and instructional material guiding users on how to access pirated content. The very architecture of the impugned websites appears to have been designed predominantly for dissemination of infringing content and circumvention of legitimate distribution channels.”

It held that the balance of convenience lay in favour of the plaintiff, as the continued operation of the impugned websites would lead to the uncontrolled circulation of pirated copies that monetary damages could not adequately compensate for.

Accordingly, the Court restrained the defendants and associated mirror, redirect, or alphanumeric websites from hosting, streaming, reproducing, distributing, making available, or communicating the plaintiff's copyrighted content to the public.

Domain Name Registrars were directed to lock or suspend the defendants' domain names and provide the plaintiff with registrant details, including names, KYC details, credit card information, mobile numbers, and related particulars, within 72 hours.

Additionally, internet service providers were directed to block access to the infringing websites, while the Department of Telecommunications and the Ministry of Electronics and Information Technology were directed to issue notifications to ensure implementation of the blocking directions.

The court also granted liberty to Universal City Studios Productions LLLP to seek impleadment of newly discovered infringing websites before the Joint Registrar and approach the Court for extension of the injunction against such entities as the suit progresses.

For Plaintiff: Advocate Saikrishna Rajgopal; Advocate Siddharth Chopra; Advocate Suhasini Raina; Advocate Mehr Sidhu; Advocate Raghav Goyal; Advocate Affain Moin; and Advocate Aditya Thakur.

For Defendants: CGSC Satya Ranjan Swain, along with GP Naveen for Defendant Nos. 22 and 23.