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Webtoon: A booming online comic platform
Webtoon, launched in 2004 by South Korea's Naver Corporation, has become popular as a hosting platform for a specific type of short-format digital comic, known locally as 'webtoons'.
Nearly two decades later, Webtoon Entertainment boasts over 85 million monthly active users in more than 100 countries. In the U.S., where the company now boasts 12.5 million active users, Webtoon seems destined for an IPO, potentially as early as 2024 according to information shared by Naver on a recent earnings call.
In an August interview with Reuters, Webtoon Entertainment founder and CEO Kim Junkoo was optimistic about the company's future. According to Kim, competitors entering the short-form comic book market, such as Amazon and Apple, will find it difficult to build a viable business.
Competitors face an uphill battle
"To create a webtoon store, you need knowledge of serial services, user targeting, a suitable business model, as well as user training," Kim told Reuters. "This takes time. But even if you put in the time, you can't recreate the creator economy we've built."
Webtoon believes that its artists and wealth of content libraries will present significant challenges to potential Silicon Valley competitors. "If the big tech companies are serious about this business of creating intellectual property, they'll have to buy us out," explained the company's CEO.
Of course, online competition can take many forms. Unconventional market participants, who are not interested in acquisition, react differently to traditional market forces. They therefore present new challenges that require a specialized approach.
Webtoon understands exactly what it's up against, and is already planning a response. The scale of the preliminary work seems unprecedented.
The calm before the storm
On an unspecified date in August 2023, as agent for Webtoon Entertainment Inc, Texas-based anti-piracy company Remove Your Media, LLC sent a complaint to CDN company Cloudflare.
DMCA takedown notices can be mundane, but here the undated document stands out for its unusual nature. It begins with a "representative list" of copyrighted works belonging to Webtoon, such as How To Tame My Beastly Husband, I Raised The Beast Well, Jungle Juice and I'm Not That Kind Of Talent. However, it's the sheer number of allegedly infringing works that really catches the eye.
According to Remove Your Media, these titles and around 80 others of the same genre were made available for download by pirate sites, all using Cloudflare services.
"The works are mainly animated films and digital comics published by WEBTOON," Cloudflare said. "Please act quickly to remove or disable access to the infringing material."
Each block in the image above represents one of the more than 390 URLs listed in Webtoon's breach notification. Blank spaces indicate URLs that no longer exist at the time of writing, fail to load for unspecified reasons, or in some cases link to sites that appear to have migrated to new or alternative domains. The majority of those containing an image are still online; the question is, for how long?
A silent trip to Texas
More than a decade ago, junior lawyer Evan Stone made headlines when he used profanity to criticize Internet service providers and the adult industry, while revealing his personal vendetta against pirates, or "snotty little brats", as the lawyer put it.
Much has changed since then, but the appearance of Stone's name on a declaration in support of a DMCA subpoena filed in a Texas district court shows that his days of fighting pirates are not yet over.
With Stone representing Remove Your Media, and both acting as agents for Webtoon Entertainment, the DMCA subpoena application filed in August but only now reported is a clear indication that reducing illicit competition is a priority for the webtoon company.
Webtoon demands identification of hundreds of pirate site operators
The main purpose of a DMCA subpoena is to compel a service provider, in this case Cloudflare, to provide the personal details of an alleged infringer so that copyright owners can enforce their rights. Here, the request requires the following:
Identifying information, including name, e-mail address, physical address, billing information and any other relevant contact information for the alleged infringer(s) who control the sites at the domains listed in Appendix A, or who control the domains themselves.
What sets this subpoena apart from most others is the sheer size of the request and the sheer number of site operators likely to be caught in the net. It's inevitable that some domains on the list will have the same owner, but over 350 domains in a single subpoena remains unprecedented, even if that number were halved.
Strictly speaking, there is no need for the court clerk to review a DMCA application in detail before affixing his approval. Given that the application was filed on August 22, marked as complete on August 22, and issued two days later, on August 24, it seems unlikely that any further review took place.
The list of domains targeted by the subpoena, for which Cloudflare had to provide full operator contact details, is available below. What happens next will depend mainly on the quality of the information provided by Cloudflare before the deadline expires on October 5. It is likely that the information received is already being assessed.
Webtoon's overall aim is probably to eliminate illegal competition from the market, but the means remain unknown. In practical terms, even the largest entertainment companies see no point in pursuing a massive lawsuit. Even if Webtoon were to decide otherwise, balancing the books to make the exercise profitable would be complex and unpredictable at best; messy, unproductive or even counterproductive at worst.
Threats of potential lawsuits to encourage settlements could be considered a viable option, at least if one of the operators has left exploitable credentials in Cloudflare's hands, which most are trying to avoid.
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The individual domains listed in the subpoena are shown below to illustrate the scale. Due to the risk of errors following optical character recognition and domain extraction from the full URLs in the subpoena, the list is not exhaustive. The DMCA takedown notice sent to Cloudflare, which contains the full unedited URLs, is available here (pdf).
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