Case 1:24-cv-00082-JJM-LDADocument 1Filed 02/26/24Page 3 of 41 PageID #: 3
copy of prod.keys (that ordinarily are secured on the Nintendo Switch). Users obtain the prod.keys either through unlawful websites or by unlawfully hacking a Nintendo Switch console. The lead developer of Yuzu—known online under the alias "Bunnei"—has publicly acknowledged most users pirate prod.keys and games online, and Yuzu's website provides instructions for its users telling them how to unlawfully hack their own Nintendo Switch and how to make unauthorized copies of Nintendo games and unlawfully obtain prod.leys. Only because Yuzu decrypts a Nintendo Switch game file dynamically during operation can the game be played in Yuzu. In other words, without Yuzu's decryption of Nintendo's encryption, unauthorized copies of games could not be played on PCs or Android devices.
6.With Yuzu in hand, nothing stops a user from obtaining and playing unlawful copies of virtually any game made for Nintendo Switch, all without paying a dime to Nintendo or to any of the hundreds of other games developers mand publishers making and selling games for the Nintendo Switch. In effect, Yuzu turns general computing devices into tools for massive intellectual properly infrigement of Nintendo and others' copyrighted work.
7.Defendant employs several developers who operate as the company's agents, including Yuzu's author and lead developer, Bunnei. Defendant traffics in the Yuzu software on a website yuzu-emu.org, on github.com, and recently, on Google Play (an app store for android devices). yuzu-emu.org provides detailed instructions[1] and FAQs on how to install Yuzu and get it running with unlawful copies of Nintendo Switch games. yuzu-emu.org also has a blog section with regular posts about updates to the software (which include discussion of different Nintendo games running in the emulator), a list of thousands of Nintendo Switch games that Yuzu developers have tested in Yuzu and confirmed can be played, and screenshots of Nintendo Switch games being played in the emulator. The website additionally links to a variery of other circumvention software that can hack into the Nintendo
- ↑ See Quickstart Guide, Yuzu, https://yuzu-emu.org/help/quickstart (accessed February 21, 2024).
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