UNITED STATES COPYRIGHT
INFRINGEMENT COMPLAINT
Filed by the INDR Music Association
Regional Chairman – New York Office
Office of Legal Counsel
Date of Filing: April 20, 2025
Filed and Submitted to: Google Legal Department, Web Hosting Providers, and Ad Networks
Official Website for Review: https://new.indrmusicassociation.ltd/mp3mn (Links not available)
I. COMPLAINT TITLE
Unauthorized Copyright Circumvention and Infringement of INDR Music Association Works
II. LEGAL BASIS
This complaint is filed under the authority of U.S. Copyright Law and relevant international treaties, including but not limited to:
Title 17, United States Code (U.S.C.) – Copyright Law
17 U.S.C. § 106 – Exclusive Rights of Copyright Holders
17 U.S.C. § 1201 – Circumvention of Copyright Protection Systems (DMCA)
17 U.S.C. § 512 – Limitations on Liability Relating to Material Online
Digital Millennium Copyright Act (DMCA), Public Law 105-304
Berne Convention for the Protection of Literary and Artistic Works
General Principles of Fair Use and Distribution under U.S. Intellectual Property Law
III. DESCRIPTION OF INFRINGEMENT
The INDR Music Association has identified a coordinated and ongoing effort to unlawfully publish, distribute, and allow access to copyrighted musical works under its authority. These activities are occurring via a pirated Russian website known for distributing music content without proper licensing.
Entities involved include:
NCA LLC
LenGrad LLC
Creative Media LLC
Novy Mir LLC
Medialine LLC
Digital Project LLC
AdvMusic LLC (MAIN)
These companies and their partners are allegedly involved in hosting and managing access to copyrighted works that are either ceased from distribution or still under protected contract with the INDR Music Association and its Publishing Copyright Partners.
The website circumvents Digital Rights Management (DRM) protections and enables users to download music illegally, bypassing licensing requirements and denying rightful revenue to rights holders. Furthermore, the Association does not recognize any licensing claims made by these platforms or their affiliates.
IV. ACTION REQUESTED
The INDR Music Association hereby files this formal legal complaint and respectfully requests that the receiving parties take immediate action to:
1. Cease and desist all infringing activity related to the copyrighted works of the INDR Music Association
2. Terminate hosting and ad-serving to any websites or services found in violation
3. Investigate and block all circumvention measures, including the disabling of DRM bypass tools
4. Provide reports and IP logs for further action and litigation, if required
5. Comply with takedown procedures under 17 U.S.C. § 512 and the DMCA framework
This complaint shall be distributed to advertising providers, domain hosts, and IP owners within 30 days of the filing date
V. CERTIFICATION AND SUBMISSION
This complaint is submitted under penalty of perjury, by the authority of the Regional Chairman of the New York Office of the INDR Music Association, in accordance with federal and international law.
Filed By: Regional Chairman – New York Office
Office of Legal Counsel
INDR Music Association
Filed and Sent To:Google Legal Department
Various Ad Providers, Domain Registrars, and Hosting Providers
Review Link for Hosting Providers:
