Case 1:24-cv-00082-JJM-LDADocument 1Filed 02/26/24Page 19 of 41 PageID #: 19
55. Yuzu performs the same functions when a user attempts to play an unauthorized Nintendo Switch game ROM. Yuzu unlawfully decrypts the ROM’s Game Encryption by (1) identifying the encrypted Title Key that accompanies the game file and using keys in the prod.keys to decrypt the Title Key, and (2) decrypting the game ROM using the Title Key. Yuzu unlawfully decrypts unauthorized copies of both physical cartridge and Nintendo eShop games, which come in two different file types, using slightly different methods. See supra ¶ 33. But both methods require cryptographic keys from the prod.keys and result in decryption of an encrypted ROM. Then the unauthorized game is able to be played in Yuzu. All of this, of course, is without Nintendo’s authorization.
56. Yuzu also allows users to dump a “RomFS” directory,[1] which is a game’s decrypted file system and which includes the game’s audiovisual assets. As described on YUZU-EMU.ORG, this includes the game’s “textures, text, fonts, sounds, or other graphical assets.” Although it is not possible to play the game solely from this directory, users can use the outputted copies of the game’s audiovisual content to modify the content and thus alter gameplay in Yuzu the next time the game is run. On information and belief, this feature is how many pirates access and distribute game assets from prerelease games, as described in more detail below. Yuzu’s access and copying of any Nintendo game’s audiovisual assets is without Nintendo’s authorization and would not be possible without Yuzu decrypting the game’s Game Encryption.
- Yuzu is Used for Widespread Piracy and Defendant Has Knowledge of the Infringements.
57. Any copy of a Nintendo Switch game ROM not on an authorized cartridge or console is an unauthorized copy and therefore infringing. Copies played in Yuzu would
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