Case 1:24-cv-00082-JJM-LDADocument 1Filed 02/26/24Page 17 of 41 PageID #: 17
set of cryptographic keys that Yuzu needs to decrypt video game ROMs during its operation.[1]
47. If a user follows Defendant’s instructions and utilizes the unlawful software modules that Yuzu’s website links to—i.e., if the user unlawfully circumvents the Console Measures on a Nintendo Switch and obtains the prod.keys using Lockpick—that user will be able to dump an (encrypted) game ROM of a Nintendo Switch game onto a memory card and decrypt and play that dumped game with Yuzu.
48. This may seem complicated, but in private, Bunnei admits there is a far easier way. When a user raised in a Discord chat operated by Defendant[2] that setting up Yuzu was complicated, Bunnei first said “unfortunately at this time, it’s not as simple as” running a simple script, and there are several “specific manual step[s], hence why to go through the whole process, you need to basically learn what they are.” “Or,” Bunnei added, “users probably just pirate a yuzu folder with everything.”
49. Indeed, on information and belief, most users of Yuzu do not go through the Quickstart Guide and do not circumvent their own Nintendo Switch console to obtain the prod.keys they need, nor do they dump their own games (though both are themselves unlawful). Rather, most obtain the prod.keys and illegal copies of games (which come with the games’ encrypted Title Keys) online.
50. Indeed, libraries of pirated Nintendo Switch ROMs are unfortunately available online. Websites such as NSW2U.COM collect direct download links for thousands of Nintendo Switch titles; NSW2U.COM specifically notes that the ROMs are compatible with Yuzu. Other sites will even package a pirated game ROM with a copy of Yuzu, so that a user
- ↑ The current iteration of YUZU-EMU.ORG does not feature a live link to Lockpick—which had been hosted on GitHub—because recent enforcement action by Nintendo alerting GitHub to the illegal nature of the software caused GitHub to takedown and delist Lockpick. However, since that time, in Yuzu’s Discord server and elsewhere, Defendant’s agents have been referring users to a different website (RENA21.GITHUB.IO/YUZU-WIKI/) which does feature a live link to Lockpick.
- ↑ Discord is an instant messaging application.
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