Whether a plaintiff alleging a violation of § 1202(b) is required to demonstrate that the defendant's 'intentional[] remov[al] or alter[ation]' of CMI 'conveyed in connection with copies of [the plaintiff's] work' was connected, linked or associated in some identifiable way to known instances of infringement, even though the plain language of the statute contains no such requirement

QUESTION PRESENTED ‘ Section 1202(b) of the Copyright Act, as amended by the Digital Millennium Copyright Act (DMCA), provides that “[{nJo person shall, without the : authority of the copyright owner or the law: (1) intentionally remove or alter any copyright management or...having reasonable grounds to know, that it will induce, enable, facilitate, or conceal an infringement of any right under this title.” 17 U.S.C. § 1202(b). Section 1202(c) of the statute defines “copyright management information” (CMI) to include “information conveyed in connection with copies...of a work...in digital form” such as the “title,” “name of...the author,” and “fildentifying numbers or symbols referring to such . information or links to such information.” 17 U.S.C. §1202. The question presented is: Whether a plaintiff alleging a violation of § 1202(b) is required to demonstrate that the : defendant’s “intentional[] remov[al] or alter[ation]” of : CMI “conveyed in connection with copies of [the plaintiffs] work” was connected, linked or associated in some identifiable way to known instances of infringement, even though the plain language of the statute contains no such requirement. : . ii