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New York Times lawsuit against Brave over paywall blocker

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The New York Times Company sued Brave Software, Inc.[1] on November 2, 2026,[2] in part under Section 1201 of the Digital Millennium Copyright Act, a 1998 law that amended US copyright law,[3][4][5] over the Brave browser's "Paywall blocker" setting,[6][7] which in a test by technology news site Ars Technica "made it possible to read a paywalled New York Times article",[8] which the complaint says Brave describes as allowing users to "Bypass Paywalls",[6] & which takes its rules from an "Adblocker list".[7][9] The complaint says the Times generally lets registered users read "a limited number of articles" before requiring a subscription,[10] & alleges that Brave delivers the Times's "paywalled content to its users without a subscription".[11]

Section 1201, as the Copyright Office describes it, prohibits circumventing technological protection measures that copyright owners use to control access to their works;[4] the complaint alleges that the Times's paywalls are such measures[12] & that Brave "circumvented" them, including with the browser's "Paywall bypass feature".[13] Three other publishers filed a similar suit that day,[8][14][15] & Ars Technica summarized both suits as alleging that Brave "illegally bypasses paywalls and sells stolen news content to AI companies";[8] each complaint also brings copyright infringement counts,[5][16] & in each, the count under 17 U.S.C. § 1201 claims remedies including "the destruction of any device involved in the violation";[3][17][18][19] both complaints ask the court to permanently enjoin Brave "from engaging in the unlawful conduct alleged herein".[20][21]

Background

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Filter lists, such as EasyList, are sets of rules for ad blockers; EasyList describes its lists as "sets of rules originally designed for Adblock" that remove "annoying adverts, bothersome banners and troublesome tracking".[22] Brave's filter-list catalog, a data file in the company's public adblock-resources repository on GitHub, a code-hosting site, has an entry titled "Paywall blocker" with the description "Bypass Paywalls Clean Filters", which takes its rules from a list published under the name magnolia1234.[7] The list's own header titles it "Bypass Paywalls Clean filter" & describes it as "Filters for news sites (supports less sites than the extension/add-on)".[23] The list's description file, its README, calls it an "Adblocker list which allows you to read articles from (supported) sites that implement a paywall" & adds that for a lot of sites a separate script also has to be installed.[9]

A change titled "Add Bypass Paywall Clean filters" added the entry to Brave's repository on March 29, 2023,[24] & a February 2026 change renamed it from "Bypass Paywalls Clean Filters" to "Paywall blocker".[25] The New York Times Company's complaint alleges that the setting, "when activated", causes the browser to "go behind website paywalls and deliver the shielded content to the user".[6]

According to the complaint, The Times launched its metered paywall in 2011.[26] The complaint says The Times "does not require payment for all access to Times Content" & "generally offers access to a limited number of articles" to users who create registered accounts "before requiring them to subscribe for access to additional content".[10] One subscription price it prints is "$1/week for your first six months", on a Times banner ad that the complaint says Brave had stripped from the page.[27]

Complaints filed in the Southern District of New York

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The New York Times Company sued Brave Software, Inc. in the United States District Court for the Southern District of New York[1] on November 2, 2026, under docket number 1:26-cv-09549.[2] The complaint names Rothwell, Figg, Ernst & Manbeck, P.C. as the Times's attorneys,[28] & Steven Lieberman signed it.[29] On the same day, Daily News, LP, Chicago Tribune Company, LLC & Orlando Sentinel Communications Company, LLC filed a complaint against Brave in the same court under docket number 1:26-cv-09554,[14][15] through the same law firm.[30] Ars Technica described it as a similar lawsuit by the New York Daily News, Chicago Tribune & Orlando Sentinel companies.[8]

The Times complaint says that as of September 30, 2026, the Brave Browser had "close to 130 million monthly users and over 50 million daily users".[31]

Section 1201 count

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Count IV of each complaint is headed "Violation of the Digital Millennium Copyright Act, 17 U.S.C. § 1201(a)(1)(A) and § 1201(a)(2)".[3][17] Section 1201(a)(1)(A) of Title 17 of the United States Code provides:

No person shall circumvent a technological measure that effectively controls access to a work protected under this title.

[32]

Section 1201(a)(2) bars any person from manufacturing, importing, offering to the public, providing or otherwise trafficking in any technology, product, service, device, component or part that is "primarily designed or produced for the purpose of circumventing" such a measure, that has "only limited commercially significant purpose or use other than to circumvent" one, or that "is marketed by that person or another acting in concert with that person" with that person's knowledge for use in circumventing one.[33] The statute defines circumventing a technological measure as "to descramble a scrambled work, to decrypt an encrypted work" or otherwise to avoid, bypass, remove, deactivate or impair one, "without the authority of the copyright owner".[34] A measure "effectively controls access to a work" if, "in the ordinary course of its operation", it requires the application of information, or a process or a treatment, with the authority of the copyright owner, to gain access to the work.[34]

Section 1201, as the federal Copyright Office describes it, prohibits two types of activities: circumventing technological protection measures (TPMs) that copyright owners use to control access to their works, such as bypassing a password system used to prevent unauthorized access to a streaming service, & trafficking in certain circumvention technologies, products, services, devices or components.[4]

The Times complaint alleges that the Times "employs paywalls and other technological protection measures" that "effectively control access" to its copyrighted works on its websites "within the meaning of 17 U.S.C. § 1201(a)(3)(B)".[12] The Daily News complaint makes the same allegation about the three publishers' paywalls.[35] Paragraph 149 of the Times complaint alleges that Brave "knowingly and intentionally circumvented The Times’s TPMs" by deploying automated systems, "including the Paywall bypass feature of the Brave Browser".[13] It further alleges that Brave "trafficked in" & "offered to the public" measures, including the paywall bypass feature, that are "primarily designed or produced" for circumvention, have "only limited commercially significant purpose or use" other than circumvention, & are "marketed for use in circumventing" a technological measure that effectively controls access to a copyrighted work.[13] Paragraph 124 of the Daily News complaint makes the same two allegations on behalf of the three publishers.[36]

The Times complaint also alleges that Brave's conduct "constitutes circumvention" because it involved "the avoidance and bypassing of technological measures" that control access to copyrighted works without the copyright owner's authority,[37] & that the circumvention "has facilitated Brave’s ongoing and massive copyright infringement" through its "unauthorized and uncompensated use of Times Content".[38]

Paywall tests and posts cited in the complaints

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Paragraph 99 of the Times complaint says that "Brave’s paywall blocker is effective" & shows two images: one of "an effort to retrieve an article from The Times on another major browser", & one of the Brave Browser retrieving the same article "without a login and bypassing The Times’s paywall".[39] The Daily News complaint makes the same claim about a Daily News article, says the paywall blocker "is similarly effective for the Chicago Tribune’s paywalls" & says "Brave’s activities with respect to the Orlando Sentinel are no different".[40] It says a user who opens an article on the three papers' websites "will typically encounter a paywall", & continues:

But when using the Brave Browser configured to disable paywalls, the Brave Browser will copy the requested article and render the article text and other content for display to the user without the paywall.

[41]

Paragraph 100 of the Times complaint says the same about articles at nytimes.com.[42] The Times complaint alleges that "Brave has made unauthorized copies of The Times’s copyrighted works" through "retrieving and displaying the text of an article" that would otherwise be shielded behind its paywall.[43]

The Times complaint says Brave's employees call its requirement that visitors register or subscribe "paywall nag", & that a Brave engineer advertised on social media that Brave users could employ its Adblock feature to circumvent the "paywall nag".[44] It quotes a Reddit user who wrote, in a thread titled "Paywall Blocker in Brave":

Today I scrolled down a bit and noticed a Paywall Blocker filter. I switched it on, headed over to the New York Times, and OOH LA LA the paywall had gone.

[45]

The complaint also cites posts on the Brave Community Forum & on X by people it describes as Brave employees, one of whom suggested that users "just enable the paywall list in Brave filters" to "remove the nag".[46]

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In both complaints, Count I alleges direct copyright infringement under 17 U.S.C. § 501, Count II contributory copyright infringement & Count III vicarious copyright infringement.[5][16] The Times complaint calls Brave "the supplier, dealer, and distributor of stolen copyrighted content" for its own users & "many of the most prominent GenAI companies, including Anthropic, Perplexity, Mistral, xAI, and Cohere".[47] Citing third-party revenue estimates,[8] it alleges that Brave "has made more than $100 million" by copying & reselling publishers' work without consent or permission while "publishers have received nothing".[48] Count III alleges that Brave controls all updates to the Brave Browser's software, "including the software for the paywall blocking feature".[49]

The Times complaint says its intellectual property counsel, Carl Mazurek, sent a letter to Brave's chief executive, Brendan Eich, on August 11, 2025, stating that without the Times's permission, Brave's products & services output "summaries of, and verbatim language from" Times content.[50] It says the Times's outside counsel sent Eich a second letter on April 13, 2026, & that "Brave ignored" each one.[50] It says Brave's infringements "were and are willful", citing among other things Brave's "failure to respond to The Times’s cease and desist letters" & its "deployment of paywall bypass measures".[51] The Daily News complaint's willfulness paragraph also cites, among other things, the "deployment of paywall bypass measures", but names no letters.[52]

Ad substitution count

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The Times complaint says the Brave Browser "blocks advertising by default" & strips the Times's advertising from its pages, "including advertising that prompts the user to subscribe".[53] Brave's own website says its "easy-to-use browser blocks ads by default".[54] The complaint alleges that through "Brave Ads", Brave "replaces the ads that appear on the content owners’ websites with its own",[55] offering its users "a cut of the revenue".[56]

Count V, for unjust enrichment under New York law,[5] alleges that Brave "unjustly reaped a financial benefit" from the revenue it receives "by blocking the advertising that accompanies Times Content and showing advertising of its own".[57] The complaint states that Count V "does not depend on any copying, reproduction, or distribution of Times Content",[58] & both complaints seek "restitution and disgorgement of all revenue and profits Brave obtained through its ad-substitution scheme", plus interest.[59][60]

Relief sought

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Both complaints ask the court to award statutory damages, actual damages & restitution of profits, to permanently enjoin Brave "from engaging in the unlawful conduct alleged herein", & to award costs, expenses and attorneys' fees.[20][21] Both also demand a jury trial, & neither prayer for relief names a dollar amount.[20][21]

Count IV of each complaint says the plaintiffs are entitled to "all remedies available under 17 U.S.C. § 1203", including "the destruction of any device involved in the violation", & that "Each act of circumvention constitutes a separate violation of § 1201".[18][19]

Default state of the setting

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Paragraph 6 of each complaint describes the Paywall blocker as "a default setting that, when activated, causes the browser to go behind website paywalls".[61][62] Paragraph 70 of the Times complaint & paragraph 45 of the Daily News complaint call it "a setting that, when activated" causes the browser to go behind website paywalls, without the word "default".[6][63] Advertising-industry news site PPC Land reported that the settings view reproduced in the Times complaint shows the Paywall blocker "among dozens of optional filter lists", & that the complaints do not say whether it is switched on for new installations.[64]

Ars Technica reported that when it tested the Brave browser for Mac on November 3, 2026, the optional paywall blocker feature made it possible to read a paywalled New York Times article, & that the feature "was enabled in the default settings and can be turned off".[8]

Filter rules for nytimes.com

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Version 4.4.7.4 of the Bypass Paywalls Clean filter list contains five rules that name nytimes.com or nyt.com:[23]

||meter-svc.nytimes.com/meter.js$xmlhttprequest,~third-party
||nytimes.com/svc/onsite-messaging/query$xmlhttprequest,~third-party
||mwcm.nyt.com/$script,domain=nytimes.com
nytimes.com##div#dock-container
||cooking.nytimes.com/api/*/access$xmlhttprequest,~third-party

The list's README says that for some sites the list will log users out or block them from logging in, "caused by removing cookies or blocking general paywall-scripts".[9]

User-written filters in Brave and uBlock Origin

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Brave's Help Center says users can turn on additional filter lists, which "may provide more comprehensive blocking of annoying or distracting elements, or ads on regional websites", & can "create and apply your own custom adblock filters" with its Block elements feature or by writing filters manually.[65] The same page says "Brave is broadly compatible" with the filter rule syntax of uBlock Origin, an ad-blocker extension.[65]

Brave wrote in a September 21, 2021 blog post that it would support custom filter list subscriptions "Starting in version 1.31.x" & that the feature "brings Brave to parity with other blocking tools like uBlock Origin, AdblockPlus, and AdGuard".[66]

uBlock Origin's interface includes a dashboard tab named "My filters", with a checkbox labeled "Enable my custom filters" & a button labeled "Import and append…".[67] Brave's developer documentation for its filter-list catalog says the format of each source list is either "ABP/uBO-style format", labeled Standard & described as the most common, or a list of IP addresses & hostnames, labeled Hosts.[68]

The paywall list's maintainer, magnolia1234, tells readers in its README to use "a browser which supports extensions/add-ons and install an adblocker (like uBlock Origin or AdGuard)".[9] The maintainer writes in the same README:

Brave browser has also incorporated the filterlist ... but some filter rules don't work in Brave's buit-in adblocker or are actively deactivated. Better add the filterlist to an extension like uBlock Origin.

[9]

Statements on the lawsuits

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Steven Lieberman, an attorney representing the Daily News, Chicago Tribune and Orlando Sentinel, said in a statement:[69]

AI giants are now desperate to avoid getting caught red-handed stealing news from publishers, so Brave Software is selling them a back door to the journalism they know they have no right to.

[8][70]

Lieberman also said that "Brave must be held responsible for laundering pirated reporting for the AI industry".[8]

Technology news site The Next Web reported:

New York Times spokesperson Graham James told Reuters that the company had repeatedly asked Brave to stop using its journalism, but the browser maker had ignored those requests.

[70]

Perplexity, an artificial intelligence company, is not a defendant in the Brave lawsuit, though The New York Times has sued it in a separate case.[8] In a statement given to Ars Technica and other news outlets, Perplexity accused the Times of "disinformation".[8] Ars Technica reported that Perplexity's statement did not identify any specific inaccuracies in the lawsuit against Brave.[8]

Publisher disputes with Brave since 2016

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On April 7, 2016, the Newspaper Association of America announced that 17 of its member companies had sent a letter to Brave Software, Inc., which the association said notified Brave that its plan to replace publishers' ads on the publishers' own websites & mobile applications with Brave's own advertising was "blatantly illegal".[71] Technology news site InfoWorld reported that the signatories included The New York Times & Tribune Publishing.[72] Brave said the letter asserted that any browser that blocks & replaces ads performs "unauthorized republication" of web content, & InfoWorld quoted the company's reply:

This is false on its face, since browsers do not 'republish,' serve, syndicate, or distribute content across the Internet or to any computer other than the one on which they run.

[72]

In March 2025, Brave sued News Corp, the parent company of The Wall Street Journal & New York Post, in San Francisco federal court.[73][69][74] Reuters reported that in its complaint Brave said News Corp had sent a cease-and-desist letter threatening litigation & demanding compensation for the alleged misappropriation of copyrighted articles by "scraping" its websites & indexing their content.[73] According to Reuters, the suit sought a declaration that using copyrighted News Corp articles that can be bundled into search indexes that can be licensed and sold is not copyright infringement.[73] Legal news service Bloomberg Law reported that in June 2025 the parties filed a joint stipulation of dismissal to end Brave's suit, & that the requested dismissal was without prejudice, "meaning the claims could be refiled at a later date".[75]

Bloomberg Law reported that in May 2026 Brave sued News Corp in the US District Court for the Northern District of California.[76] Reuters reported that in July 2026 News Corp filed a countersuit accusing Brave of "flagrant theft" in distributing & selling versions of articles from The Wall Street Journal & New York Post to AI companies.[74] According to Reuters, News Corp said in that filing that Brave's unauthorized "covert scraping" & resale of its copyrighted articles fall "nowhere near the bounds" of legally acceptable conduct known as fair use.[74] Media news site TheWrap reported that Brave "has previously defended its search practices as fair use".[69]

See also

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References

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  1. ↑ 1.0 1.1 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. Caption, p. 1.
  2. ↑ 2.0 2.1 "The New York Times Co. v. Brave Software, Inc., 1:26-cv-09549 (S.D.N.Y.)". CourtListener (Free Law Project). Retrieved 2026-11-04. Docket header and entries 1, 10 and 11.
  3. ↑ 3.0 3.1 3.2 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. Count IV heading, p. 68.
  4. ↑ 5.0 5.1 5.2 5.3 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. Count headings, pp. 62, 64, 67, 68 and 70.
  5. ↑ 6.0 6.1 6.2 6.3 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 70, p. 25.
  6. ↑ 7.0 7.1 7.2 "adblock-resources/filter_lists/list_catalog.json". Brave Software (GitHub). Archived from the original on 2026-11-05. Retrieved 2026-11-05. The entry is at lines 602–618 of the file at this commit.
  7. ↑ 8.00 8.01 8.02 8.03 8.04 8.05 8.06 8.07 8.08 8.09 8.10 Jon Brodkin (2026-11-03). "NYT demands Brave shut down its paywall blocker and end deals with AI firms". Ars Technica. Archived from the original on 2026-11-04. Retrieved 2026-11-04.
  8. ↑ 9.0 9.1 9.2 9.3 9.4 "Bypass Paywalls Clean filters (README)". magnolia1234 (GitFlic). Archived from the original on 2026-11-05. Retrieved 2026-11-05.
  9. ↑ 10.0 10.1 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 40, p. 14.
  10. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 69, p. 25.
  11. ↑ 12.0 12.1 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 147, p. 69.
  12. ↑ 13.0 13.1 13.2 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 149, pp. 69–70.
  13. ↑ 14.0 14.1 "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. Caption, p. 1.
  14. ↑ 15.0 15.1 "Daily News LP v. Brave Software, Inc., 1:26-cv-09554 (S.D.N.Y.)". CourtListener (Free Law Project). Retrieved 2026-11-04. Docket header and entries 1, 9, 11 and 13.
  15. ↑ 16.0 16.1 "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. Count headings, pp. 58, 60, 63, 64 and 67.
  16. ↑ 17.0 17.1 "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. Count IV heading, p. 64.
  17. ↑ 18.0 18.1 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 152, p. 70.
  18. ↑ 19.0 19.1 "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. ¶ 127, p. 66.
  19. ↑ 20.0 20.1 20.2 "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. Prayer for relief and jury demand, pp. 71–72.
  20. ↑ 21.0 21.1 21.2 "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. Prayer for relief and jury demand, p. 68.
  21. ↑ "EasyList - Overview". EasyList. Archived from the original on 2026-11-04. Retrieved 2026-11-04.
  22. ↑ 23.0 23.1 "Bypass Paywalls Clean filter". magnolia1234 (GitFlic). Archived from the original on 2026-11-05. Retrieved 2026-11-05.
  23. ↑ "Add Bypass Paywall Clean filters". Brave Software (GitHub). 2023-03-29. Retrieved 2026-11-05.
  24. ↑ "Initial commit for list titles and descriptions (#299)". Brave Software (GitHub). 2026-02-14. Retrieved 2026-11-05.
  25. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 35, p. 13.
  26. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 104, p. 59.
  27. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. Opening paragraph, p. 1.
  28. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. Signature block, p. 72.
  29. ↑ "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. Opening paragraph, p. 1.
  30. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶ 51, pp. 18–19.
  31. ↑ "17 U.S.C. 1201 - Circumvention of copyright protection systems". United States Code, 2024 Edition. U.S. Government Publishing Office. Archived from the original on 2026-10-11. Retrieved 2026-11-04. Subsection (a)(1)(A).
  32. ↑ "17 U.S.C. 1201 - Circumvention of copyright protection systems". United States Code, 2024 Edition. U.S. Government Publishing Office. Archived from the original on 2026-10-11. Retrieved 2026-11-04. Subsection (a)(2).
  33. ↑ 34.0 34.1 "17 U.S.C. 1201 - Circumvention of copyright protection systems". United States Code, 2024 Edition. U.S. Government Publishing Office. Archived from the original on 2026-10-11. Retrieved 2026-11-04. Subsection (a)(3).
  34. ↑ "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. ¶¶ 122–123, p. 65.
  35. ↑ "Complaint, Daily News, LP v. Brave Software, Inc., No. 1:26-cv-09554 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-03. Retrieved 2026-11-04. ¶ 124, p. 66.
  36. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶¶ 150–151, p. 70.
  37. ↑ "Complaint, The New York Times Company v. Brave Software, Inc., No. 1:26-cv-09549 (S.D.N.Y.), ECF No. 1" (PDF). United States District Court for the Southern District of New York, via CourtListener. 2026-11-02. Archived from the original (PDF) on 2026-11-04. Retrieved 2026-11-04. ¶¶ 153–154, p. 70.
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