subscriber in USDC 2015

ect platform by way of

non-exclusive, non-transferable subscriptions between Elsevier and its institutional customers.
According to the terms and conditions of these subscriptions, authorized users of ScienceDirect
must be users affiliated with the subscriber (e.g., full-time and part-time students, faculty, staff


Case 1:15-cv-04282-RWS Document 1 Filed 06/03/15 Page 6 of 16

and researchers of subscriber universities and individuals using computer terminals within the
library facilities at the subscriber for personal research, education or other non-corporate use.)

A substantial portion of American research universities maintain active

subscriptions to ScienceDirect. These subscriptions, under license, allow the universities to
provide their fa

ccess to the ScienceDirect database. Defendants’
piracy is supported by the persistent intrusion and unauthorized access to the computer networks


Case 1:15-cv-04282-RWS Document 1 Filed 06/03/15 Page 8 of 16

of Elsevier and its institutional subscribers, including universities located in the Southern District
of New York.

Upon information and belief, Defendants have unlawfully obtained and continue

to unlawfully obtain student or faculty access credentials which permit proxy connections to

es accessible through paid subscription services such as
ScienceDirect. Instead, Google Scholar provides bibliographic information concerning such articles along with a
link to the platform through which the article may be purchased or accessed by a subscriber.


Case 1:15-cv-04282-RWS Document 1 Filed 06/03/15 Page 9 of 16

information and belief, Sci-Hub obtains the content from the Library Genesis Project repository
and provides that content to the user.

When a user searches on Sci-Hub for an ar


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