Case 1:24-cv-00082-JJM-LDADocument 1Filed 02/26/24Page 27 of 41 PageID #: 27
2020, the day before Xenoblade Chronicles was released, that the game was running in Yuzu:
73. Bunnei has repeatedly made clear that they have dumped games. For those games, Bunnei has circumvented the Console Measures and the Game Encryption and has made unauthorized reproductions.
COUNT ONE
(Trafficking in Circumvention Technology in Violation of 17 U.S.C. § 1201(a)(2))
74. Plaintiff repeats and realleges every allegation contained in paragraphs 1 through 73 as if fully set forth herein.
75. Section 1201(a)(2) of the DMCA, 17 U.S.C. § 1201(a)(2), prohibits, in a general sense, the trafficking in technology primarily designed to circumvent technological measures that effectively control access to copyrighted works. The statute provides, in pertinent part,
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