Whether the mental state requirement of 'knowing, or, . . . having reasonable grounds to know' that removal or alteration of copyright management information ('CMI') in violation of 17 U.S.C. § 1202(b) 'will induce, enable, facilitate, or conceal an infringement' requires proof of 'identifiable' and 'likely' future copyright infringement, a 'pattern of conduct' or 'modus operandi' involving policing infringement by tracking CMI, or whether a plaintiff may simply prove that removal or alteration of CMI makes 'infringement generally possible or easier to accomplish' without the need for simultaneously proving removal or alteration of CMI resulted in a 'particular act of infringement'

QUESTION PRESENTED Whether, in order to satisfy the mental state requirement of “knowing, or, . . . having reasonable grounds to know” that removal or alteration of copyright management information (“CMI”) in violation of 17 U.S.C. § 1202(b) “will induce, enable, facilitate, or conceal an infringement,” a plaintiff must prove “identifiable” and “likely” future copyright infringement as a result of removal or alteration of CMI, or a “pattern of conduct” or “modus operandi” involving policing infringement by tracking CMI, as the Ninth Circuit held, or whether a plaintiff may instead simply prove that removal or alteration of CMI makes “infringement generally possible or easier to accomplish” without the need for simultaneously proving removal or alteration of CMI resulted in a “particular act of infringement,” as the Register of Copyrights has advocated.