April 19, 2011 email from Mozilla to US Department of Homeland Security Special

Agent
To help us evaluate the Department of Homeland Security's request to take-down/r
emove the MAFIAAfire.com add-on from Mozilla's websites, can you please provide
the following additional information:
1. Have any courts determined that MAFIAAfire.com is unlawful or illegal in
any way? If so, on what basis? (Please provide any relevant rulings)
2. Have any courts determined that the seized domains related to MAFIAAfire
.com are unlawful, illegal or liable for infringement in any way? (please provid
e relevant rulings)
3. Is Mozilla legally obligated to disable the add-on or is this request ba
sed on other reasons? If other reasons, can you please specify.
4. Has DHS, or any copyright owners involved in this matter, taken any lega
l action against MAFIAAfire.com or the seized domains, including DMCA requests?
5. What protections are in place for MAFIAAfire.com or the seized domain o
wners if eventually a court decides they were not unlawful?
6. Can you please provide copies of any briefs that accompanied the affidav
it considered by the court that issued the relevant seizure orders?
7. Can you please provide a copy of the relevant seizure order upon which y
our request to Mozilla to take down MAFIAAfire.com is based?
8. Please identify exactly what the infringements by the owners of the domai
ns consisted of, with reference to the substantive standards of Section 106 and
to any case law establishing that the actions of the seized domain owners consti
tuted civil or criminal copyright infringement.
9. Did any copyright owners furnish affidavits in connection with the domai
n seizures? Had any copyright owners served DMCA takedown notices on the seized
domains or MAFIAAfire.com? (if so please provide us with a copy)
10. Has the Government furnished the domain owners with formal notice of the s
eizures, triggering the time period for a response by the owners? If so, when,
and have there been any responses yet by owners?
11. Has the Government communicated its concerns directly with MAFIAAfire.com?
If so, what response, if any, did MAFIAAfire.com make?