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ORDER GRANTING, IN PART, AND DENYING, IN PART, DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT BAIRD, District Judge. I. INTRODUCTION Defendants Internet Billing Co., LLC (“IBill”), Internet Key, Inc. (“Internet Key”), Cavecreek Wholesale Internet Exchange (“CWIE”), and CCBill, LLC (“CCBill”) have filed the instant motions for partial summary judgment of Perfect 10, Inc.’s (“Perfect 10”) copyright, RICO, and state law claims based on safe harbors provided by the Digital Millennium Copyright Act (“DMCA”) and immunity provided by the Communications Decency Act (“CDA”). By this Order, the Court addresses the four motions for partial summary judgment. II. FACTUAL AND PROCEDURAL HISTORY A. Factual History The facts are undisputed unless otherwise noted. 1. Perfect 10 Perfect 10 is the publisher of the adult entertainment magazine Perfect 10 and the owner of the website perfectl0.com. See II Zadeh Decl. at ¶ 2. Perfect 10 has created approximately 5,000 photographic images for display in its magazine and on its website. See id. at ¶ 17. Perfect 10 holds registered U.S. copyrights for these images. See id.; see also Compl. Exh. O (containing copies of the copyright registrations owned when the complaint was filed). In addition, Perfect 10 has several registered trademark/service marks. See II Zadeh Decl. at ¶ 18; see also Compl. Exh. P (containing copies of trademark registrations owned when the complaint was filed). Finally, Perfect 10 is the as-signee of the rights of publicity of many models. See II Zadeh Decl. at ¶ 19-21. 2. IBill IBill is a company that processes payments for online merchants. II Zadeh Decl. at ¶ 22. IBill has nearly 5,000 clients with over 70,000 websites. II Smith Decl. at ¶ 4. Ml material selected and posted by IBill’s clients’ websites is selected and posted by IBill’s clients. Id., ¶ 7. IBill can suspend or terminate its relationship with websites if it becomes aware that the website is violating IBill’s policies or state or federal law. Id., ¶ 8. When IBill suspends or terminates a client, the contents of the clients’ website remains intact and unchanged. Id., ¶ 9 In addition, suspension or termination does not affect the ability of the website’s existing customers (those who have already paid) to obtain access to the website. Id. Suspension or termination does, however, prevent the owner of the website from receiving new payments using IBill’s payment processing services. Id. 3. Internet Key Hank Freeman is the President of Internet Key. I Freeman Decl., ¶ 1; I Cooper Deck, Exh. 1 (Freeman Depo.), at 15:10-20. Internet Key is an age verification system for adult content websites. I Freeman Deck, ¶ 2. Starting in 1997, Internet Key has provided adult verification services, including providing links, to third-party adult content websites. Id. Currently, Internet Key verifies age and provides a link to approximately 30,000 third-party adult content websites that participate in the SexKey system (“Affiliated Websites”). Id. The Affiliated Websites are not owned by Internet Key although some are owned by employees of WCD Enterprises, another company that Freeman owns. Id., ¶ 4; I Cooper Deck, Exh. 1 (Freeman Depo.), at 119:1-5. A user (consumer) cannot access an Affiliated Website without proving he or she is of legal age. I Freeman Deck, ¶ 5. Internet Key provides each Affiliated Website with a site ID and an HTML code to place on their site. Id. When a new user clicks onto an Affiliated Website, a link that tracks the site ID automatically directs the user to sexkey.com for age verification. Id. The user is directed to Internet Key’s registration page, which contains Internet Key’s User Agreement. Id., ¶6. The User Agreement sets forth terms and conditions that a user must certify and agree in order to subscribe to a SexKey membership. Id. Once the user agrees to all the terms of the User Agreement by checking on a box that the user agrees, the user is provided a user password to access all of the Affiliated Websites in the SexKey system. Id., ¶ 8. Internet Key does not store the content of the Affiliated Websites on its computer system. Id., ¶ 13. It only stores information related to the Affiliated Websites’ URLs, site descriptions and webmaster information. Id. Prior to January 22, 2004, the only website Internet Key owned was sexkey.com. Id., ¶ 12. On January 22, 2004, Internet Key started a new website called sksigna-ture.com, which is part of the SexKey system. Id. Internet Key owns or leases all the content contained on sksignature.com. Id. Internet Key also acts as a search engine (similar to Yahoo or Google) for free adult content on the Internet. I Freeman Deck, ¶ 4. Sometimes, when an Affiliated Website is accessed through SexKey, the words “sexkey.com” appear in the URL. I Zadeh Deck, ¶ 65, Exh. 51. Internet Key did not adopt a DMCA policy until August 21, 2002. I Cooper Deck, ¶ 4, Exh. 2 at 27. 4. CWIE Thomas Fisher is the Executive Vice-President of CWIE. Ill CWIE Fisher Deck, ¶ l. CWIE is a provider of web hosting and related Internet connectivity services. Id., ¶ 3. CWIE provides what is referenced within the industry as “ping, power, and pipe.” Id. As a provider of Internet access, website hosting, and other Internet-related services, CWIE offers its clients, and their customers and users, the means to acquire and disseminate public, private, commercial, and non-commercial information. Id. “Ping, power, and pipe” refers respectively to ensuring the “box” or server is on, ensuring power is provided to the server, and connecting the client’s server or website to the Internet backbone via a data center connection. Id. CWIE’s clients are the creators and/or owners of the content they seek to present to consumers via their website. Id., ¶ 4. CWIE is not in the business of producing, designing, supervising or editing the content that appears on CWIE’s clients’ websites. Id. CWIE adopted its repeat in-fringer policy in 1999. Id., ¶ 11. CWIE’s termination policy states that: Engaging in any activity that infringes or misappropriates the intellectual property rights of others is prohibited. This includes copyrights, trademarks, service marks, trade secrets, software piracy, and patents held by individuals, corporations, or other entities. Engaging in activity that violates privacy, publicity, and other personal rights of others is likewise prohibited. CWIE is required by law to remove or block access to client content upon receipt of a proper notice of. copyright infringement or other violations of the law. It is also CWIE’s policy to terminate the privileges of clients who commit repeat violations of copyright laws. III CWIE Fisher Deck, ¶ 9, Exh. A, at 1- 2. 5. CCBill Thomas Fisher is the Executive Vice-President of CCBill. III CCBill Fisher Deck, ¶ 1. CCBill’s clients are the creators and/or owners of the content they seek to present to consumers via the Internet. Id., ¶ 3. CCBill is not in the business of producing, designing, supervising or editing the content that appears on CCBill’s clients’ websites. Id. CCBill provides a fully automated Internet service that enables consumers to use credit cards or checks to pay for subscriptions or memberships to e-commerce venues created and offered by CCBill’s clients. Id. CCBill does not own or operate any site for which a subscription or membership is required. Id. As part of its services to its clients, CCBill provides an automated on-line accounting mechanism that clients may use to verify statistical and financial activities processed for them through CCBill’s online Internet automated transaction processing system. Id. Consumers who have joined a client’s venue may cancel their subscription via an email or telephone call directed to CCBill. Id. CCBill has a repeat infringer policy, adopted in 1999, which states: As an ISP, CCBill follows the procedures prescribed by the Digital Milleni-um Copyright Act (DMCA) for notification, takedown, and counter-notification. If you believe that a CCBill client has something on a website that constitutes a [violation] of your copyrights, or if any of your other intellectual property rights [have been] violated, please provide the following information to CCBill’s Registered [DMCA Agent], 1. Your electronic or physical signature. 2. A description of the copyrighted work and where the original work [is located]. 3. A description of where the infringement is located. 4. Your address, telephone number, and email address. 5. A statement by you that you have a good faith belief that the use is not authorized by the copyright owner, agent, or the law. 6. A statement by you, that under penalty of perjury, that the [above] is accurate and that you are the copyright owner or authorized [to act] on the owner’s behalf. Please send all legal notices to ... Id., ¶ 9, Exh. D. B. Procedural History Plaintiff Perfect 10 filed its Complaint against Defendants CCBill, IBill, Paycom Billing Services, Inc., IMA Enterprises, Inc., Clarence Coogan, U. Berger, Cyber-tech Communications, NV, Celebskank, Network Authentication Systems Corporation, CWIE, Netpass Systems, Inc., and Internet Key on September 30, 2002. The Complaint alleges the following claims against all of the Defendants: Claim 1: federal copyright infringement; Claim 2: federal trademark infringement; Claim 3: federal trademark disparagement; Claim 4: wrongful use of registered mark under California state law; Claim 5: violation of right of publicity under California state law; Claim 6: unfair competition under California Business & Professions Code §§ 17200 and under the Lanham Act § 43(a); Claim 7: false and misleading advertising pursuant to California Business & Professions Code §§ 17500 and the common law; Claim 8: RICO (investment of proceeds); and Claim 9: RICO (participation in criminal enterprise). See Compl. On October 16, 2003, the Court ordered the bifurcation of discovery in this case. See October 16, 2003 Minute Order. The first phase of discovery was to relate solely to the Defendants’ defenses to the claims under the CDA and the DMCA. Id. Phase I discovery was closed on January 16, 2003. See November 17, 2003 Minute Order, at 2. The parties have filed evidentiary objections in connection with the motions for summary judgment. The Court will only address the objections to the evidence that .is relevant to the Court’s analysis. III. LEGAL STANDARD Rule 56 of the Federal Rules of Civil Procedure provides that a court shall grant a motion for summary judgment if “the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(c). Material facts are those that may affect the outcome of the case. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). A dispute as to a material fact is genuine if there is sufficient evidence for a reasonable jury to return a verdict for the nonmoving party. Id. The party moving for summary judgment bears the initial burden of informing the district court of the basis of the summary judgment motion and of demonstrating the absence of a genuine issue of material fact for trial. Celotex Corp. v. Catrett, 477 U.S. 317, 323, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986); Katz v. Children’s Hosp. of Orange County, 28 F.3d 1520, 1534 (9th Cir.1994). On an issue for which the nonmoving party has the burden of proof at trial, the moving party need only point out “that there is an absence of evidence to support the nonmoving party’s case.” Celotex, 477 U.S. at 325, 106 S.Ct. 2548. Once this initial burden is satisfied, the non-moving party is required to “go beyond the pleadings and by her own affidavits, or by the depositions, answers to interrogatories, and admissions .on file, designate ‘specific facts’ showing that there is a genuine issue for trial.” Celotex, .477 U.S. at 324, 106 S.Ct. 2548 (internal quotations omitted); see also Nilsson, Robbins, Dalgam, Berliner, Carson & Wurst v. Louisiana Hydrolec, 854 F.2d 1538, 1544 (9th Cir.1988). Where the standard of proof at trial is preponderance of the evidence, the non-moving party’s evidence must be such that a “fair-minded jury could return a verdict for the [non-moving party] on the evidence presented.” Anderson, 477 U.S. at 252, 106 S.Ct. 2505. The court views all facts and draws all inferences therefrom in the light most favorable to the nonmoving party. United States v. Diebold, Inc., 369 U.S. 654, 655, 82 S.Ct.. 993, 8 L.Ed.2d 176(1962). The Court must accept the plaintiffs view of all material disputed facts. LaLonde v. County of Riverside, 204 F.3d 947, 954 (2000). If, however, the nonmoving party’s evidence is “merely colorable” or “not significantly probative,” summary judgment may be granted. Anderson, 477 U.S. at 249-50, 106 S.Ct. 2505. IV. ANALYSIS A. Digital Millennium Copyright Act “The DMCA was enacted both to preserve copyright enforcement on the Internet and to provide immunity to service providers from copyright infringement liability” for “passive,” “automatic” actions in which a service provider’s system engages through a technological process initiated by another without the knowledge of the service provider. H.R. Conf. Rep. No. 105-796, at 72 (1998), reprinted in 1998 U.S.C.C.A.N. 649; H.R.Rep. No. 105-551(1), at 11 (1998).” ALS Scan. Inc. v. RemarQ Cmtys., Inc., 239 F.3d 619, 625 (4th Cir.2001). This immunity, however, is not presumptive, but granted only to “innocent” service providers who can prove they do not have actual or constructive knowledge of the infringement, as defined-under any of the three prongs of 17 U.S.C. § 512(c)(1). Id. The DMCA’s protection of an innocent service provider disappears at the moment the service provider loses its innocence, i.e., at the moment it becomes aware that a third party is using its system to infringe. Id. At that point, the Act shifts responsibility to the service provider to disable the infringing matter, preserving the strong incentives for service providers and copyright owners to cooperate to detect and deal with copyright infringements that take place in the digital network environment. Id. (citations omitted). In the spirit of achieving a balance between the responsibilities of the service provider and the copyright owner, the DMCA requires that a copyright owner put the service provider on notice in a detailed manner but allows notice by means that comport with the prescribed format only “substantially,” rather than perfectly. Id. The Digital Millenium Copyright Act (“DMCA”) creates a “safe harbor” for internet service providers who satisfy the requirements of the statute—protecting them against suits for damages and most injunctive relief. See generally, 17 U.S.C. § 512. There are four separate safe harbors within § 512, each with its own separate requirements. See 17 U.S.C. § 512(a),(b),(c)(1),(d). However, a threshold requirement for any protection by the DMCA is satisfaction of the requirements in § 512(i). The section reads as follows: The limitations on liability established by this section shall apply to a service provider only if the service provider(A) has adopted and reasonably implemented, and informs subscribers and account holders of the service provider’s system or network of, a policy that provides for the termination in appropriate circumstances of subscribers and account holders of the service provider’s system or network who are repeat infringers; and (B) accommodates and does not interfere with standard technical measures. 17 U.S.C. § 512(i)(1). Unless this threshold requirement is met, further analysis of the specific safe harbors is not required. The Ninth Circuit has held that § 512(i)(l)(A) has three separate requirements. See Ellison v. Robertson, 357 F.3d 1072, 1080 (9th Cir.2004). Service providers must: (1) adopt a policy that provides for the termination of service access for repeat copyright infringers in appropriate circumstances; (2) implement that policy in a reasonable manner; and (3) inform their clients of the policy. Id. The courts have not defined what reasonable implementation of a repeat in-fringer policy entails. Since the purpose of the DMCA is to relieve internet service providers of the duty of patrolling the Internet for copyright infringements that are not immediately apparent or of which they have no actual knowledge, the DMCA requires that copyright owners inform internet service providers of infringements on the client websites of the internet service providers. See § 512(c)(1)(A) and § 512(c)(3). General or vague allegations of copyright infringements are not sufficient to place internet service providers on “notice” of potential copyright infringements. The DMCA provides requirements for proper notification of possible copyright infringements .in § 512(c)(3)(A). See § 512(c)(3)(A). The purpose behind the notice requirement under the DMCA is to provide the internet service provider with adequate information to find and examine the allegedly infringing material expeditiously. Hendrickson v. Amazon.Com. Inc., 298 F.Supp.2d 914, 917 (C.D.Cal.2003). “Under the DMCA, a notification from a copyright owner that fails to comply substantially with § 512(c)(3) ‘shall not be considered ... in determining whether a service provider has actual knowledge or is aware of the facts or circumstances from which infringing activity is apparent.’ ” Hendrickson v. Amazon.Com. Inc., 298 F.Supp.2d 914, 917-18 (C.D.Cal.2003). In order for a notification to be “DMCA-compliant,” it should substantially fulfill the requirements of § 512(c)(3)(A). ALS Scan, Inc. v. RemarQ Communities, Inc., 239 F.3d 619, 625 (4th Cir.2001). Absolute compliance is not required. Id. Therefore, an internet service provider who receives repeat notifications that substantially comply with the requirements of § 512(c)(3)(A) about one of its clients, but does hot terminate its relationship with the client, has not reasonably implemented a repeat infringer policy. 1. IBill’s Motion for Summary Judgment on Perfect 10’s Copyright Claim IBill argues that Perfect 10’s Claim 1 for copyright infringement is barred by § 512(a) of the DMCA. Perfect 10 opposes summary judgment because, among other reasons, it contends that IBill has not met the requirements for terminating repeat infringers as required by § 512(i). a. Threshold Requirements Under § 512(i) The crux of the dispute between Perfect 10 and IBill is whether the policy adopted by IBill provided for termination of repeat infringers in appropriate circumstances and whether that policy was reasonably implemented. i. Policy for Termination of Repeat In-fringers IBill argues that its policy terminated repeat infringers in appropriate circumstances. IBill states that its policy is that when it receives a notice of copyright infringement that substantially complies with the requirements of the DMCA, IBill suspends payment processing services to that client. See II De Vito Decl. at ¶ 26. If IBill determines that it has received previous complaints about that client or the website, IBill terminates the account permanently. See id. Perfect 10 argues that IBill’s policy does not terminate repeat infringers in appropriate circumstances because it suspends services for particular websites without terminating the webmasters responsible for that material. Therefore, Perfect 10 argues that IBilFs policy does not provide for the termination of service access for repeat copyright infringers. Perfect 10 also argues that IBill has not reasonably implemented its policy because repeat infringers known to IBill were not terminated. The focus of § 512(i) is on infringing users rather than on content. See Perfect 10 v. Cybernet Ventures, Inc., 213 F.Supp 2d 1146, 1177 (C.D.Cal.2002); see also Costar Group, Inc. v. LoopNet, Inc., 164 F.Supp.2d 688, 704 (D.Md.2001). Therefore, an internet service provider that seeks to fall within the safe harbors provided by the DMCA, must adopt a policy that terminates the infringing user, not just the content. IBill has submitted several versions of its infringement policy, the most recent of which states: IBill may, its discretion (sic), disable and/or terminate the accounts of any IBill client who is accused of infringing the rights of others. If you believe that your work has been copied in a way that constitutes copyright infringement, or your intellectual property rights have been otherwise violated, please provide IBill’s Copyright Agent the following information: 1. an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright; 2. a description of the copyrighted work, and a description of where the work is located; 3. your address, telephone number, and email address; 4. a statement by you that you have a good faith belief that the use of the work is not authorized by the copyright owner, agent, or the law; 5. a statement by you, that under penalty of perjury, that the above information is accurate and that you are the copyright owner or authorized to act on the owners’s behalf. Please send such notice to ... II Devito Decl., Exh. B, at 40 (Copyright Policy, 12/9/03). The Court notes that this policy states that it will terminate or disable the accounts of IBill clients who are accused of infringing third-party copyrights. Therefore, there is no genuine issue of material fact that IBill has adopted a policy that terminates repeat infringers in appropriate circumstances. ii. Reasonable Policy Implementation Perfect 10 contends that IBill has not reasonably implemented its policy. IBill replies that its DMCA immunity cannot be defeated by individual instances of non-enforcement because Congress requires reasonable implementation of the policy rather than perfect implementation. IBill also argues that it had no legal obligation under § 512(i) unless the notices of in- fringement were substantially DMCA compliant. IBill is correct that Congress requires reasonable implementation of a repeat infringer policy rather than perfect implementation. See 17 U.S.C. § 512(i)(l)(A). During oral argument, Perfect 10 argued that there is a genuine issue of material fact that IBill does not reasonably implement its repeat infringer policy because IBill has failed to produce its DMCA-notice log. However, the DMCA does not require the internet service provider to keep a log of its notifications. IBill has submitted the actual DMCA-notifications it has received which are sufficient to demonstrate that IBill tracks its notifications. II DeVito Deck, Exhs. P-T. Perfect 10 has submitted notifications that Perfect 10 or its counsel sent to IBill of infringements of Perfect 10’s copyrights. II Zadeh Deck, ¶29, Exhs. 19-33. Exhibit 19 is an email dated August 24, 2001, sent from Perfect 10’s counsel to IBill, which identifies 12 websites that are IBill clients which Perfect 10 states have infringements of Perfect 10’s and third-party copyrights. II Zadeh Deck, Exh. 19 at 204. The email only identifies the websites that contain the allegedly infringing material, it does not identify the URLs of the images nor does it identify which of Perfect 10’s images are being infringed. Under § 512(c)(3)(A)(ii) and (iii), DMCA-compli-ant notification must identify the copyrighted work claimed to have been infringed and the material that is claimed to be infringing with “information reasonably sufficient to permit the service provider to locate the material.” This notification does not fulfill either of those requirements because it does not identify Perfect 10’s images or give IBill sufficient information to locate the infringing material. These websites may contain more than one hundred images at different URLs; it is Perfect 10’s responsibility, under the DMCA, to provide IBill with enough information to allow IBill to locate the infringing material. The Court finds that the August 21, 2001 email does not substantially comply with the requirements of the DMCA and therefore, does not constitute proper notification under § 512(c)(3)(A). The next notification is an email from Norman Zadeh, the President of Perfect 10, dated August 28, 2001 which identifies a Perfect 10 copyrighted image that appeared on celebclub.com on August 19, 2001 by its URL, celebclub.com/par-to/New/080301/Kovari-Kristina/nif.gif. II Zadeh Decl., Exh. 21 at 209. This email identifies one image by its URL in a manner that allows IBill to locate the infringing image. Although it does not comply with any of the other requirements of § 512(c)(3)(A), it does provide IBill with sufficient information to locate the allegedly infringing material and, as such, substantially fulfills the requirements of § 512(c)(3)(A). Exhibits 20 and 22-33 all suffer from the same deficiencies as Exhibit 19. They contain emails from Norman Zadeh to IBill that make general allegations of copyright infringement and do not provide the exact location of the infringing images and do not identify the Perfect 10 images that are being infringed. II Zadeh Decl., Exh. 20, 22-33. IBill notes this problem in one of its emails to Norman Zadeh which states: “The point I am trying to make is that without an URL (www.* * *.eom) I cannot attempt to figure out each URL.” II Zadeh Decl., Exh. 29 at 220. Perfect 10 also argues that “[d]espite the fact that Perfect 10 complained to IBill about the website femalecelebrities.com on at least 7 separate occasions”, a Concordance electronic search of IBILL’s document production revealed only two documents containing the term “femaleeelebrities.com.” II Zadeh Deck, ¶ 89. However, Perfect 10 has not identified the DMCA-compliant notification that Perfect 10 sent to IBill notifying IBill of infringements on femalecelebrities.com. Therefore, the Court finds that this evidence is not probative of IBill’s failure to reasonably implement its repeat infringer policy. Therefore, Perfect 10 has only identified a single notification, the email dated August 28, 2001, that provides IBill with sufficient notification to locate an allegedly infringing image on the website celebclub.com. On August 27, 2001, IBill sent Perfect 10 an email stating that celeb-club.com’s IBill account was suspended. II DeVito Deck, Exh. T at 186. In IBill’s interrogatory responses, IBill admitted that celebclub was a client of IBill as of September 30, 2003. II Zadeh Deck, Exh. 16 at 169. Perfect 10 has not presented the Court with any evidence to demonstrate that the infringing image remained on celebclub.com after IBill received the August 28, 2001 notification. The Court finds that, as to Perfect 10’s copyrights, Perfect 10 has not raised a genuine issue of material fact that IBill did not reasonably implement its repeat in-fringer policy or that IBill has not met the threshold requirements in § 512(i). b. Safe Harbor Under § 512(a) IBill argues that it falls within the safe harbor in § 512(a) which provides: a) Transitory digital network communications. A service provider shall not be liable for monetary relief, or, except as provided in subsection (j), for injunctive or other equitable relief, for infringement of copyright by reason of the provider’s transmitting, routing, or providing connections for, material through a system or network controlled or operated by or for the service provider, or by reason of the intermediate and transient storage of that material in the course of such transmitting, routing, or providing connections, if— (1) the transmission of the material was initiated by or at the direction of a person other than the service provider; (2) the transmission, routing, provision of connections, or storage is carried out through an automatic technical process without selection of the material by the service provider; (3) the service provider does not select the recipients of the material except as an automatic response to the request of another person; (4) no copy of the material made by the service provider in the course of such intermediate or transient storage is maintained on the system or network in a manner ordinarily accessible to anyone other than anticipated recipients, and no such copy is maintained on the system or network in a manner ordinarily accessible to such anticipated recipients for a longer period than is reasonably necessary for the transmission, routing, or provision of connections; and (5)the material is transmitted through the system or network without modification of its content. 17 U.S.C. § 512(a). Perfect 10 argues that IBill does not fall within the safe harbor provided in § 512(a) because it does not transmit the infringing material at issue in this case. Perfect 10 argues that § 512(a) only provides protection for internet service providers that transmit the allegedly infringing material, not other material, such as credit card information. Perfect 10 relies on In re Aimster Copyright Litigation, 252 F.Supp.2d 634, 659-660 (N.D.Ill.2002), to support its argument. Perfect 10 relies on the section of § 512(a) that refers to the transmission of the material; it has failed, however, to address the section of § 512(a) which refers to the provision of a connection to the material. The section provides that “an internet service provider shall not be liable ... for infringement of copyright by reason of the provider’s ... providing connections for material through a system or network controlled or operated by or for the service provider, or ...” § 512(a). IBill provides a connection to the material on its clients’ websites through a system which it operates in order to provide its clients with billing services. Perfect 10’s reliance on In re Aimster Litigation is misplaced because that case dealt with the transmission of material, not the provision of a connection to the material. See In re Aimster Litigation, 252 F.Supp.2d at 659-660. The Court finds that there is no genuine issue of material fact that IBill has met the requirements of § 6120) and § 512(a). Therefore, the Court grants IBill’s motion for summary judgment and finds that IBill is entitled to protection under the safe harbor provided in § 512(a). 2. Internet Key’s Motion for Summary Judgment on Perfect 10’s Copyright Claim Internet Key contends that it is entitled to summary judgment on Perfect 10’s Claim 1 for copyright infringement because the claim falls within the safe harbor provided by the DMCA under § 512(d). Perfect 10 counters that Internet Key does not fall within the safe harbors provided by the DMCA because Internet Key has not adopted and implemented a reasonable repeat infringer policy. As a preliminary matter, the Court notes that Perfect 10 has submitted evidence of infringements on Internet Key’s Affiliate Websites that were displayed on the Internet prior to August 21, 2002 wh'en Internet Key implemented its DMCA policy. See, e.g., I Zadeh Decl., ¶ 43, Exh. 33. Internet Key has not submitted a DMCA policy that was provided to its clients prior to August 2002 as required under § 512(i). Therefore, Internet Key has not met the threshold requirements of § 512(i) for the period before August 2002 and Perfect 10 may maintain its claim for copyright infringement that occurred prior to August 21, 2002. a. Direct Infringement Perfect 10 argues that Internet Key is not entitled to protection under the DMCA because it is a direct copyright infringer and therefore, not merely an internet service provider. Perfect 10’s basis for this argument is that since some of the employees of WCD Enterprises, which is also owned by Freeman, own some of the Affiliate Websites, Internet Key is liable for the infringements on those websites. Perfect 10 relies on H.A.S. Loan Serv., Inc. v. McColgan, 21 Cal.2d 518, 523, 133 P.2d 391 (1943), to support its argument that a corporate entity cannot avoid liability when it splits its business functions with another related corporation and that Internet Key should be considered the alter ego of WCD Enterprises. An alter ego theory of liability would require Perfect 10 to demonstrate, as its prima facie case (1) that there is such unity of interest and ownership that the separate personalities of [two entities] no longer exist and (2) that failure to disregard [their separate identities] would result in fraud or injustice.” American Tel. & Telegraph Co. v. Compagnie Bruxelles Lambert, 94 F.3d 586, 591 (9th Cir.1996). The fact that some of the Affiliate Websites are owned by the employees of a separate company which is owned by the President of Internet Key does not raise a genuine issue of material fact that there is such unity of interest and ownership that the separate personalities of Internet Key and WCD Enterprises no longer exist. Furthermore, Perfect 10 has not presented evidence that WCD Enterprises owns the Affiliate Websites, but that certain employees of WCD Enterprises own the Affiliate Websites. Even if Perfect 10 had raised a genuine issue of material fact that WCD Enterprises was the alter ego of Internet Key, Perfect 10 has not provided evidence that there is a' unity of interest between WCD Enterprises’ employees and the company WCD Enterprises. Therefore, the Court finds this argument without merit. Perfect 10 also notes that sometimes, when an Affiliated Website is accessed through SexKey, the words “sex-key.com” appear in the URL. I Zadeh Deck, ¶ 65, Exh. 51. However, Perfect 10 has not provided the Court with any precedent that this fact alone imparts direct infringer liability onto Internet Key without demonstrating that Internet Key or its employees actually engaged in the infringing conduct. Infringement occurs when a defendant violates one of the exclusive rights of the copyright holder. 17 U.S.C. § 501(a). A plaintiff can establish direct infringement by demonstrating that a defendant used the copies in any of the ways described under 17 U.S.C. § 106, which include: (1) reproduction of the copyrighted work, (2) preparation of derivative works based upon the copyrighted work, (3) distribution of copies of the copyrighted work to the public by sale or other transfer of ownership, or (4) display of the copyrighted work publicly. 17 U.S.C. § 106. In order to prevail, defendants must “actively engage in” and “directly cause” one of the activities recognized in the Copyright Act. See Perfect 10 v. Cybernet, 213 F.Supp.2d 1146, 1168 (C.D.Cal. 2002) (citing Religious Tech. Ctr. v. Netcom On-Line Communication Servs., Inc., 907 F.Supp. 1361 (N.D.Cal.1995); Sega Enters., Ltd. v. MARTHA, 948 F.Supp. 923, 931 (N.D.Cal.1996); Playboy Enters., Inc. v. Russ Hardenburgh, Inc., 982 F.Supp. 503 (N.D.Ohio)). Without evidence that Internet Key actively engaged in or directly caused the alleged infringements, this argument is equally unavailing. b. Threshold Requirements Under § 512(i) Perfect 10 contends that Internet Key does not satisfy the threshold requirements under § 512(i). To reiterate, § 512(i) requires service providers to: (1) adopt a policy that provides for the termination of service access for repeat copyright infringers in appropriate circumstances; (2) implement that policy in a reasonable manner; and (3) inform their clients of the policy. See Ellison v. Robertson, 357 F.3d 1072, 1080 (9th Cir.2004). Perfect 10 does not dispute that Internet Key informs the webmasters of its Affiliate Websites (“Affiliate Webmasters”) of its policy. Therefore, the two remaining issues before the Court are whether Internet Key has adopted a policy that provides for the termination of repeat infringers in appropriate circumstances and whether Internet Key implements that policy in a reasonable manner. i. Policy for Termination of Repeat In-fringers Internet Key has submitted its copyright infringement policy. Dykeman Deck, ¶ 14, Exh. A. Perfect 10 argues that the policy fails on its face because “it is entirely possible for a website owned by a given webmaster to receive copyright infringement complaints week after week and nonetheless to remain part of SexKey, provided that Internet Key does not receive complaints about ... three different websites owned by the same webmaster.” II Opp. at 10:17-21. Perfect 10 bases its argument on the section of Internet Key’s policy which refers to webmasters, which states: Banned Webmaster If a webmaster, identified by either the webmaster’s name, vendor ID or common ownership entity, has had three (3) websites which have been denied participation in the SexKey program in accordance with this policy, that webmaster will be denied participation in its program of any webmaster or website in its discretion. II Dykeman Deck, Exh. A at 11. However, the policy also states that for websites, if Internet Key receives DMCA-compliant notification, Internet Key will: • Act expeditiously to remove links to, or disable access, to the allegedly infringing material • Take reasonable steps to promptly notify the accused subscriber that the Company has removed or disabled access to the allegedly infringing material. • Forward a copy of the written notification to the accused subscriber, and inform the accused subscriber of counter notification procedures. Repeat Offenders The participation of any website deemed to be a repeat offender will be terminated. Banned Websites Pending receipt of a Counter Notification, participation of the website subject to a Notification will be suspended. A website will be permanently prohibited from participating in the SexKey program upon receipt by the Company of a second Notification. Id. The policy provides that Internet Key will disable access to an Affiliate Website after it receives a single notification of an infringement. It also provides that it will permanently ban a webmaster from Internet Key after it has received three notifications regarding websites of any particular webmaster. Therefore, Perfect 10’s characterization of Internet Key’s policy is incorrect. Perfect 10 also argues that Internet Key has not adopted a reasonable termination policy because there is a discrepancy in the evidence regarding the identity of Internet Key’s copyright agent. Internet Key’s termination policy, which is located on its website, sexkey.com, states that Lawrence Walters is Internet Key’s copyright agent. I Dykeman Decl., Exh. A at 8-9. During his deposition, Freeman stated that Internet Key’s copyright agent is the company CSC in Delaware. I Cooper Deck, Exh. 1 at 121. Perfect 10 argues that Internet Key changed its copyright agent and did not inform its subscribers of the change. However, Perfect 10 has not submitted any evidence that the copyright agent has changed or that notifications sent to Walters were not responded to by Internet Key. Internet Key may have more than one copyright agent or the company CSC may have hired Walters to be the individual copyright agent. Furthermore, every notification submitted as evidence in this case was addressed to Freeman, not Walters or CSC. Therefore, Internet Key likely has more than one individual who responds to notifications of copyright infringement. The Court finds, therefore, that Perfect 10 has failed to raise a genuine issue of material fact that Internet Key has not adopted a policy that terminates repeat infringers in appropriate circumstances. ii. Reasonable Policy Implementation Perfect 10 contends that Internet Key received substantially-compliant DMCA notifications and that Internet Key did not disable access to the infringing websites. The parties dispute whether Perfect 10 provided Internet Key with DMCA-compli-ant notification of infringements. Since Internet Key’s DMCA policy was not adopted until August 21, 2002, the Court will only look at notifications that were received by Internet Key after August 21, 2002. Perfect 10 states that in its October 17, 2002 document production to Internet Key, Perfect 10 provided Internet Key with thousands of pages of printouts from Sex-Key affiliated websites which infringed either Perfect 10’s or celebrities’ rights. I Zadeh Deck, ¶ 24, Exh. 14 (representative examples of the print-outs). Some of the print-outs contain the names of Perfect 10 models in the URLs. Id. On March 13, 2002, Internet Key received a list of names of Perfect 10 models. I Freeman Decl., ¶35, Exh. D, at 29-34. Internet Key states that the October 17, 2002 document production contained 22, 185 pages of documents. I Reply, at 7:3-11; see also I Zadeh Deck, ¶ 25, Exh. 15. Accompanying the production was a letter from Sean Morris of Arnold & Porter which states: With this letter I am sending you several boxes of documents that contain examples of the voluminous infringements on websites affiliated with Internet Key, Inc. (“SexKey”) and other defendants in this case. These documents should assist you in assessing the scope of the infringements at issue in the above-referenced lawsuit and the potential damages SexKey. • The documents that accompany this letter represent examples of the infringements at issue in this ease; these documents are not the only instances of wrongful conduct by the defendants. • The documents that accompany this letter contain examples of both (i) infringements of Perfect 10 material; and (ii) infringements of third-party copyrights and rights of publicity. These documents were collected from so-called “celebrity” sites, which are easily locatable and are comprised of images that clearly infringe the copyrights and publicity rights of Perfect 10 and others. • The infringements of Perfect 10 material are readily identifiable, especially in connection with the information contained in the complaint, and all come from celebrity sites. • To further aid you in your assessment of the potential damages your company faces in this case, we have often included a full-sized printout of the image that constitutes infringement of Perfect 10’s material ... I Zadeh Deck, Exh. 15. Perfect 10 has also submitted evidence that despite its notification of these infringements, the websites that contained the images were still active in October 2003. I Zadeh Deck, ¶ 46, Exh. 35. For example, in October 2002, Perfect 10 produced an image of Perfect 10 model Genevieve Maylam printed from the website cpics.adultmas-ters.net. I Zadeh Deck, ¶ 14, Exh. 14, at 40. In October 2003, the same image was still available on the same website. I Za-deh Decl., ¶ 46, Exh. 35, at 1041. The issue before the Court, therefore, is whether the notice provided by Perfect 10 is substantially DMCA-compliant. If the notice is substantially DMCA-compliant, then Perfect 10 has raised a genuine issue of material fact that Internet Key has not reasonably implemented its termination policy. First, Internet Key objects to this evidence because it argues that post-litigation notices cannot be considered for purposes of the DMCA. To support its argument, Internet Key relies on Hendrickson v. Ebay, Inc., 165 F.Supp.2d 1082, 1092 n. 12(C.D.Cal.2001). However, in that case, the Court found that a discovery response by the plaintiff in that case was not DMCA-compliant because it was not under oath, did not attest to a good faith belief of the alleged infringements, and did not attest to the accuracy of the allegations. Id. The Court did not state that the discovery response was insufficient because it was provided after the complaint was filed. Id. Therefore, Internet Key’s reading of the case is incorrect. Under § 512(c)(3)(A)(ii), DMCA-compliant notification requires that the accusing party identify the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, provide a representative list of such works at that site. The notification requirements also require that the notification contain a statement that the information in the notification is accurate, under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed. § 512(c)(3)(A)(vi). -Perfect 10’s letter states that the document production contains infringements by Internet Key and the other defendants in this case of Perfect 10’s copyrights and the copyrights of third parties. However, the letter accompanying the document production does not identify which documents were found on Internet Key’s Affiliate Websites. The letter also does not contain a statement that the information in the notification is accurate. The letter also does not state that the author has a good faith belief that the information in the letter is accurate nor is there a declaration under penalty of perjury. The letter does state that the enlarged images are Perfect 10’s images and include the specific URLs of the images. Therefore the letter identifies which images are infringements of Perfect 10’s copyrights; however, the letter does not identify Perfect 10’s copyrights themselves, only the infringing images. Under § 512(c)(3)(A)(ii) & (iii), the notification is required to identify both the.eopyrighted image and the infringing image. The purpose behind the notice requirement under the DMCA is to provide the internet service provider with adequate information to find and examine the allegedly infringing material expeditiously. Hendrickson v. Amazon.Com, Inc., 298 F.Supp.2d 914, 917 (C.D.Cal.2003). Congress’ intent was that both the copyright owner and the [internet service provider] cooperate with each other to detect and deal with copyright infringement that takes place on the Internet. Id. at 916-17. The Court finds that Perfect 10’s blanket statement that infringements of Perfect 10’s copyrights are contained within 22,000 pages of documents without identification of Perfect 10’s copyrights, without an identification of which documents were printed off of Internet Key’s Affiliate Websites, and without a statement that the notification is accurate does not constitute notice that is substantially compliant with the requirements of § 512(c)(3)(A). Perfect 10 has not identified any other DMCA-compliant notices sent to Internet Key after Internet Key instituted its repeat infringer policy to trigger the implementation of Internet Key’s policy. In the absence of evidence of DMCA-compliant notice, the Court finds that Perfect 10 has failed to raise a genuine issue of material fact that Internet Key failed to implement its termination policy in a reasonable manner. Therefore, there is no genuine issue of material fact that Internet Key has met the threshold requirements under § 512(i). c. Safe Harbor Under §§ 512(d) and 512(a) Section 512(d) states: (d) Information location tools. A service provider shall not be liable for monetary relief, or, except as provided in subsection (j), for injunctive or other equitable relief, for infringement of copyright by reason of the provider referring or linking users to an online location containing infringing material or infringing activity, by using information location tools, including a directory, index, reference, pointer, or hypertext link, if the service provider-— (1)(A) does not have actual knowledge that the material or activity is infringing; (B) in the absence of such actual knowledge, is not aware of facts or circumstances from which infringing activity is apparent; or (C) upon obtaining such knowledge or awareness, acts expeditiously to remove, or disable access to, the material; (2) does not receive a financial benefit directly attributable to the infringing activity, in a case in which the service provider has the right and ability to control such activity; and (3) upon notification of claimed infringement as described in subsection (c)(3), responds expeditiously to remove, or disable access to, the material that is claimed to be infringing or to be the subject of infringing activity, except that, for purposes of this paragraph, the information described in subsection (e)(3)(A)(iii) shall be identification of the reference or link, to material or activity claimed to be infringing, that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate that reference or link. 17 U.S.C. § 512(d). Perfect 10 contends that Internet Key does not fall within the safe harbor provided by § 512(d) because Internet Key (1) does not use an information location tool, (2) has actual knowledge of infringements, (2) is aware of facts or circumstances from which infringing activity is apparent. Perfect 10 argues that Internet Key does not use an information location tool as defined in § 512(d) because Internet Key is not like Yahoo! or Google which provide links to millions of websites with whom it has no relationship. Perfect 10 reasons that because Internet Key merely links to a relatively small universe of websites with whom it has in place contractual relationships and established review procedures, it is not entitled to protection under § 512(d). Section 512(d) does not state that the safe harbor is limited to internet service providers that provide links to millions of websites. Nor does § 512(d) state that the use of an information location tool is limited to internet service providers that do not have contractual relationships with their affiliate websites. Therefore, these arguments are without merit. Section 512(d) refers to service providers who refer or link users to an online location containing infringing material or infringing activity, by using information location tools, including a directory, index, reference, pointer, . or hypertext link. § 512(d). Internet Key’s sexkey.com website provides that function and is therefore covered by § 512(d). Pursuant to § 512(d), the internet service provider must also (1) not be aware of facts or circumstances from which infringing activity is apparent and (2) not receive a financial benefit directly attributable to the infringing activity, in a case in which the service provider has the right and ability to control such activity. Perfect 10 argues that Internet Key fails both of these requirements. Perfect 10 argues that Internet Key should have known there were copyright infringements on its clients’ websites because of the disclaimers on some of those websites. The disclaimers generally claim that the copyrighted images are in the public domain or that the webmaster is posting the images for newsworthy purposes. I Zadeh Deck, Exh. 22. These disclaimers are not sufficient to raise a red flag of copyright infringement. Therefore, Perfect 10 has not demonstrated that Internet Key was aware of facts or circumstances from which infringing was apparent. The second requirement is that the internet service provider not receive a direct financial benefit directly attributable to the infringing activity when it has the right and ability to control such activity. A right and ability to control infringing activity, “as the concept is used in the DMCA, cannot simply mean the ability of a service provider to remove or block access to materials posted on its website or stored in its system.” Costar Group, Inc. v. Loopnet, Inc., 164 F.Supp.2d 688, 704 (D.Md. 2001). Internet Key’s right and ability to control infringing activity is limited to disconnecting the webmasters’ access to Internet Key’s service. That type of control is not sufficient, under the DMCA, to demonstrate a “right and ability to control” the infringing activity. As recognized in Perfect 10 v. Cybernet Ventures, Inc., 213 F.Supp.2d 1146, 1181 (C.D.CaI.2002), “closing the safe harbor based on the mere ability to exclude users from the system is inconsistent with the statutory scheme.” Id. Since Internet Key does not have a right and ability to control the infringing activity, the Court need not address whether Internet Key receives a direct financial benefit from the infringing conduct. Additionally, Internet Key serves another function. Namely, when a user goes to one of Internet Key’s Affiliate Websites, the user is directed to the Internet Key sign-up page for age verification purposes. I Freeman Decl., ¶¶ 5-8. This function falls outside of the parameters of § 512(d) because Internet Key is not referring users to other websites through a directory, index, reference, pointer, or hypertext link. However, this function falls within the purview of § 512(a) which provides: a) Transitory digital network communications. A service provider shall not be liable for monetary relief, or, except as provided in subsection (j), for injunctive or other equitable relief, for infringement of copyright by reason of the provider’s transmitting, routing, or providing connections for, material through a system or network controlled or operated by or for the service provider, or by reason of the intermediate and transient storage of that material in the course of such transmitting, routing, or providing connections, if— (1) the transmission of the material was initiated by or at the direction of a person other than the service provider; (2) the transmission, routing, provision of connections, or storage is carried out through an automatic technical process without selection of the material by the service provider; (3) the service provider does not select the recipients of the material except as an automatic response to the request of another person; (4) no copy of the material made by the service provider in the course of such intermediate or transient storage is maintained on the system or network in a manner ordinarily accessible to anyone other than anticipated recipients, and no such copy is maintained on the system or network in a manner ordinarily accessible to such anticipated recipients for a longer period than is reasonably necessary for the transmission, routing, or provision of connections; and (5) the material is transmitted through the system or network without modification of its content. 17 U.S.C. § 512(a). The section provides that “an internet service provider shall not be liable ... for infringement of copyright by reason of the provider’s ... providing connections for material through a system or network controlled or operated by or for the service provider, or ...” § 512(a). Internet Key provides a connection to the material on its clients’ websites through a system which it operates in order to provide its clients with adult verification services. Therefore, Internet Key’s services fall within the purview of both §§ 512(a) and 512(d). The Court finds that there is no genuine issue of material fact that Internet Key is entitled to the safe harbors pursuant to §§ 512(a) and 512(d). Based on the foregoing, Internet Key’s motion for summary judgment for infringements after August 21, 2002 based on the safe harbors under § 512(d) and § 512(a) is granted. However, Internet Key’s motion for summary judgment on Perfect 10’s copyright infringement claim for infringements before August 21, 2002 is denied. 3. CWIE’s and CCBill’s Motions for Summary Judgment on Perfect 10’s Copyright Claim Since the parties address many of the issues regarding CWIE and CCBill together, the Court will address these Defendants together for issues where the evidence overlaps. CWIE and CCBill assert that they are entitled to summary judgment on Perfect 10’s Claim 1 for copyright infringement because they fall within the safe harbors provided by the DMCA under § 512. a. Threshold Requirements Under § 512(i) Perfect 10 argues that CWIE and CCBill do not reasonably implement their repeat infringer policies under § 512(i). Perfect 10 cites to CWIE and CCBill’s DMCA notice spreadsheet and argues that many of the webmaster names are not included in the spreadsheet. Ill Fisher Deck, Exh. C. Perfect 10 contends that CWIE and CCBill do not track the actual webmasters of the websites for which they receive notifications. The Court has reviewed the spreadsheet and finds that a few of the webmaster names are missing from notifications that were either resolved by the copyright owner and the webmaster or were not DMCA-compliant. The Court finds that the fact that a few of the webmaster names are missing from the spreadsheet in instances where the notice was deficient or the issue was resolved is not sufficient to raise a genuine issue of material fact that CWIE and CCBill do not reasonably implement their repeat infringer policies. Perfect 10 has submitted notifications of infringement of Perfect 10’s copyrights that it sent to CCBill and CWIE which it claims are DMCA-compliant. The first is a letter from Perfect 10’s counsel to Fisher dated August 10, 2001. Ill Zadeh Decl., Exh. 14. The letter identifies several websites which Perfect 10 claims contain infringements of Perfect 10’s copyrights. Id. at 144. The letter only identifies the websites that contain the allegedly infringing material, it does not identify the URLs of the images nor does it identify which of Perfect 10’s images are being infringed. Under § 512(c)(3)(A)(ii) and (iii), DMCA-compli-ant notification must identify the copyrighted work claimed to have been infringed and the material that is claimed to be infringing with “information reasonably sufficient to permit the service provider to locate the material.” This notification does not fulfill either of those requirements because it does not identify Perfect 10’s images or give CCBill and CWIE sufficient information to locate the infringing material. These websites may contain more than one hundred images at different URLs; it is Perfect 10’s responsibility, under the DMCA, to provide these Defendants with enough information to allow them to locate the infringing material. The Court finds that the August 10, 2001 letter does not substantially comply with the requirements of the DMCA and therefore, does not constitute proper notification under § 512(e)(3)(A). The next notification is an email Norman Zadeh sent to Fisher on February 6, 2002 which identifies websites which contain images of celebrities but does not identify websites which contain Perfect 10’s copyrighted images. III Zadeh Decl., Exh. 17. Therefore, this email does not comply. The next notification is a letter from Perfect 10’s counsel dated March 12, 2002 which suffers from the same deficiency as Exhibit 14 above. III Zadeh Deck, Exh. 18. It does not identify the allegedly infringing material with enough specificity to allow CCBill and CWIE to locate the information. Exhibit 20 (email dated March 28, 2002) also suffers from the same lack of specificity. Perfect 10 also identifies Exhibit I to the Complaint as notification of violations of Perfect 10’s copyrights. Exhibit I to the Complaint lists websites that Perfect 10 contends contain Perfect 10 infringements. See Compl., Exh. I. The Court finds that Exhibit I is not DMCA-compliant because it does not give the Defendants sufficient notification to allow them to locate the allegedly infringing material. Perfect 10 has also submitted its RICO Case Statement which Perfect 10 produced to Defendants on December 19, 2002. III Zadeh Decl., Exh. 26 at 317-321. The RICO Case Statement does not identify the URLs of the allegedly infringing material or identify Perfect 10’s copyrighted images. Id. Therefore, this notification does not substantially comply with the requirements of § 512(c)(3)(A). Perfect 10 also identifies a July 14, 2003 email sent to Fisher which had attached to it an Excel spreadsheet which identifies websites and the names of Perfect 10 models who appear on those websites. Ill Zadeh Decl., Exh. 29. Perfect 10 argues that this spreadsheet contains the URLs of the infringing images, however, the Court is unable to locate a single URL that is the URL for the actual infringing image. Id. Most of the URLs provided refer to the “members only” area of the website, not the URL of the specific image within the “members only” area of the website. Id. Again, this is not the type of not