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Strike 3 Holdings filing lawsuits for "Pure Bill of Discovery" in Florida County Courts

Posted by Steve Vondran | Oct 31, 2019

2019 Strike 3 Holdings, LLC Updates (Filing Lawsuits in Miami-Dade County Court) - What's this?  Now they are trying a litigation "unmask" method in Florida?  Are they trying to avoid federal court?  Trying to circumvent the federal rules of civil procedure?

Strike 3 Bill of Discovery Florida County Court



You never know what new is going to happen in BitTorrent litigation.  Our firm is a leader in defending persons (internet subscribers) in defending cases of peer to peer (p2p) file sharing of adult porn movies.  With regard to Strike 3 Holdings, and Malibu Media, LLC these companies have filed well over 5,000 federal court copyright infringement lawsuits.  My take is the federal courts are getting tired of their using the court as a "collection arm" of their business as one federal judge called it.  In short, they clog the court with lawsuits seeking to extract large settlements from unsuspecting torrent users who believe that torrenting is legal just like it was believed to be with Napster.  Now, federal judges in my opinion are getting tired of these cases that don't really even turn into cases.  To my knowledge, only one case has ever gone to trial (Malibu Media), and the lead attorney for Bandlow Law Firm told me Strike 3 Holdings has not went to trial but "it is the same technology" I was informed.  Now, we have to ask the honest question, are they filing in Miami-Dade "County Court" seeking to unmask subscribers to get their name and identity, and what is this "Pure Bill of Discovery" lawsuit all about?  Seems to be the the next move in internet file sharing litigation.

LAW FIRMS WHO MAY BE FILING FLOIDA UNMASK LAWSUITS:  Tyler Mamome Law Firm | Rachel Walker Firm  The case may be transferred to Bandlow Law Firm (LA CA) for "settlement" purpose and "litigation" (threat) if in California.  Bandlow Law Firm files lawsuits in CA Northern District, CA Central District and CA Southern District.  We are admitted and have handled cases in all three areas.

We have seen the following cases filed: 


What to do if you get notice of a subpoena from Florida?

Plaintiff Attorneys are VULTURES.  Do not make any mistake about that.  They do not care about your sob stories, and they will try to take you for everything they can.  There are some mitigating factors they will look at (ex. military duty, financials, medicals, etc.) but outside of that, they will likely run an asset search to see if you have a good job and own a house (something they can really intimidate you with).  This is just the way it is.  We have handled hundreds of these cases with multiple regional lawyers from around the United States including Los Angeles, New York, Texas, Arizona, etc.  They will spare very little mercy.  One lawyer chastised me for "begging" for my client.  Others have said they will force a sale of the home if they have to.  Still others asserted that they would "get a judgment and garnish wages."  Since this is the true nature of things, calling them up on your own and trying to apologize (which some try to do) generally is not a winning strategy.  Here is what I suggest:

1.  Make sure you have shut down your Torrent client.  I would not delete evidence, but shut it down.  Stop sharing videos like Strike 3 Tushy, Vixen, Blacked and Blacked Raw.

2.  Do not talk to your friends, neighbors or roommates (they may end up being witnesses against you)

3. Call our copyright infringement law firm to discuss your rights.  This is even more important if you are being sued in California or Arizona - we are licensed in these states and it is important to have a local attorney here to help).  The opposing counsel know if the attorneys are local and this can effect the settlement.  Some attorneys will claim "we have a nationwide network of attorneys" but this is normally just a bogus marketing tactic.

4.  Start putting aside settlement money.  We can discuss settling out of court vs. the litigation option (they are not always right and we have had cases DISMISSED outright).

Call us for a free consultation at (877) 276-5084 if you have received a subpoena notice seeking to "unmask" your identity.


NOTE:  I am not a lawyer licensed in Florida and this is not Florida legal advice. But I read this on the Florida State Bar website, and I really think the Strike 3 Complaints need to be closely reviewed for abuse of the rules.  Here is what I read:

"Considering the foregoing, a complaint for a pure bill of discovery should conform to general rules of pleading at the outset, contain a standard caption, and be entitled as a “complaint for a pure bill of discovery.” It should contain separate allegations regarding the following:

1) the complaint is for a pure bill of discovery;

2) the basis for the court's jurisdiction lies in equity;

3) the identity of the parties and their interests in the case;

4) the specific facts giving rise to a cause of action or defense by the plaintiff, and that the plaintiff is an actual party and not a mere witness or other third party;

5) the matters which give rise to the need for discovery;

6) the nature and content of matters or items specifically sought to be discovered which are in the possession of the defendant;

7) the plaintiff's right to the relief sought (i.e., identification of a) possible defendants, b) conditions precedent to maintaining a cause of action,11and/or c) additional causes of action or defenses);

8) the plaintiff's title, interest, and relationship to the items of discovery sought;


9) the discovery sought is material to the action at law for which it is sought. Forms for a complaint for discovery are set forth in Trawick, Fla. Prac. and Proced. Forms §4-38 (2003 ed.) and 2 La Coe's Fla. R. Civ. P. Forms R 1.280(102) (2003 ed.).

NOTE:  in one complaint for "pure bill of discovery" involving a California resident, the complaint said the "amount in controversy does not exceed $15,000" . (oh really?  Why do I routinely get demands of 30-50k)?  Perhaps they should be held to their own representations.  If not, they are pulling a fraud on the Court if they seek more are they not?

Watch Attorney Steve® explain ISP subpoena law in this episode of Vondran Legal Hour

Bill of Pure Discovery Explained

Click on the image to hear this great legal podcast.  Learn more about the Florida lawsuit "in equity" - what happened to their great GEOLOCATION technology?  Why sue Californians in Florida?  

Miami-Dade County Court - Local and State Case Numbers

These are believed to be the relevant case numbers for some of the cases filed:

Local Case Numbers: 











State Case Numbers: 











December 2019 Update:

Here are a list of the cases we have seen filed. Now it seems (from what we can tell in at least one case) that Malibu Media and Strike 3 may be "jointly" filing cases with subpoenas being served on Altice ISP a/ CSC Holdings by Yaana Technologies, LLC. 2019-027599-CC-05

















ISP's believed to be involved

Here are some of the ISP's (Internet Service Providers) that we believe may be involved in unmasking subscribers so companies like Strike 3 and Malibu can pursue them for an "out-of-court" settlement:

1. Century Link

2. Hotwire Communications


4. San Bruno Cable

5.  Webpass

6.  US Internet (some of these are "fiber" companies making me wonder if they are targeting wealthier businesses or just minorities and immigrants to this country - which we see many times).  People who know NOTHING about the copyright laws.


8.  Consolidated Smart Systems, LLC

9.  Windstream Communications

10.  Atlantic Broadband

11.  Altice USA (with service in New York)

If you have received a notice of subpoena telling you that you have a limited time to file a MOTION TO QUASH SUBPOENA or to file a protective order, give us a call.  We have seen a recent case of a California resident being exposed by an ISP and they never set foot in Florida.  Does this tell you something about Strike 3 and their claimed accuracy in their GEOLOCATION TECHNOLOGY?  It appears they want to unmask the subscriber in Florida, threaten them with copyright infringement (in whatever state the subscriber lives in - ex. California), and if the case does not settle out of court they will threaten to sue you in your home state.  Nice guys right?  Are the Florida courts now being used as mere PUPPETS in this IP enforcement routine?  Other scholars have noted that pursuing the Bill of Discovery is something that Prenda Law firm used to pursue.  Following this, certain lawyers faced disbarment and loss of their legal license.  Before you CAVE into these types of demands, it would make sense to have an experienced internet copyright law firm review your case.  We have helped hundreds of clients deal with these trolls. 

Contact a United States Torrent Defense Law Firm

Our law firm has appeared in over 150 federal court copyright infringement defense cases.  This surpasses virtually all of our "serious" competition.  They may tell you all kinds of things, but they cannot match our experience handling Torrent movie download cases.  In addition, before you ever hire an IP copyright law firm, you should ask to see references.  Here are ours from our Avvo review website.  Call us to discuss your case at (877) 276-5084.  There is no cost if you are facing the need to respond to these vultures.  If you received notice from Florida Courts and you live in California or other states, call us to discuss this new strategy they are employing. 

We think it's WRONG to use the Florida court system like this when they claim their GEOLOCATION TECHNOLOGY is flawless.  If so, why are lawsuits being filed in Florida when the alleged perpetrator lives in California for example.  Time to answer up guys.  We are going to hold your feet to the fire at this law firm. 

Also, no other law firm in BitTorrent litigation puts out a free legal YouTube channel with over 16,000 subscribers.  We are not afraid to subject ourselves to peer review.  What about the so-called "experienced copyright attorneys."  THINK before you INK.

Email us through our contact form below or call us at (877) 276-5084.

We are not licensed to practice law in Florida including Miami-Dade County and do not seek to solicit clients in this state nor can we provide legal advice on Florida state law.  We have partnered with a local firm that can file a motion to quash.


About the Author

Steve Vondran

Thank you for viewing our blogs, videos and podcasts. As noted, all information on this website is Attorney Advertising. Decisions to hire an attorney should never be based on advertising alone. Any past results discussed herein do not guarantee or predict any future results. All blogs are written by Steve Vondran, Esq. unless otherwise indicated. Our firm handles a wide variety of intellectual property and entertainment law cases from music and video law, Youtube disputes, DMCA litigation, copyright infringement cases involving software licensing disputes (ex. BSA, SIIA, Siemens, Autodesk, Vero, CNC, VB Conversion and others), torrent internet file-sharing (Strike 3 and Malibu Media), California right of publicity, TV Signal Piracy, and many other types of IP, piracy, technology, and social media disputes. Call us at (877) 276-5084. AZ Bar Lic. #025911 CA. Bar Lic. #232337

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