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Kim Junkoo, CEO of Webtoon Entertaiment, a division of South Korean tech giant Naver, recently said that rivals such as Amazon and Apple will struggle to compete with his company in the short-form comic sector. Ahead of a potential U.S. listing, Kim told Reuters that if ‘Big Tech’ is serious, “they’d have to buy us out.” In parallel, Webtoon appears to be quietly laying the groundwork to tackle less-discussed competition; hundreds of pirate sites offering the company’s content for free. 
Launched by South Korean tech giant Naver Corporation in 2004, Webtoon gained popularity as a hosting platform for a specific type of short-form digital comic, known locally as ‘webtoons’
Almost two decades later, Webtoon Entertainment has over 85 million active users per month across more than 100 countries. In the United States, where the company now boasts 12.5 million active users, Webtoon seems destined for a public listing, potentially as soon as 2024 according to information shared by Naver during a recent earnings call.
In an August interview with Reuters, Webtoon Entertainment founder and CEO Kim Junkoo was certainly bullish on the company’s future. Rivals moving in on the short-form comic market, which include both Amazon and Apple, will struggle to build a viable business, Kim predicted.
“To build a (webtoon) store, you need knowledge about serial services, user targeting, a fitting business model, educating users,” Kim told Reuters. “This takes time. But even if you put in time, you can’t recreate the creator economy we’ve built.”
Webtoon believes its artists and depth of content libraries will present significant challenges for potential Silicon Valley competitors. “If big tech is serious about this IP-creating business, they’d have to buy us out,” the company’s CEO explained.
Of course, online competition can take many forms. Unconventional market participants that have no interest in acquisition, respond differently to traditional market forces. As such, they present novel challenges that require a specialist approach.
Webtoon fully understands what it’s up against and is already considering a response. The sheer scale of the initial groundwork appears unprecedented.
On an unspecified date in August 2023, in its capacity as agent for Webtoon Entertainment Inc., Texas-based anti-piracy company Remove Your Media, LLC, sent a complaint to CDN company Cloudflare.
DMCA notices can be unremarkable but here the undated document stands out as unusual. It begins with a “representative list” of copyrighted works owned by Webtoon, titles 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 overall number of allegedly infringed works that really catches the eye.
According to Remove Your Media, these titles and around 80 others like them were being made available for download by pirate sites, all of them utilizing Cloudflare’s services.
“The works primarily consist of animated motion pictures and digital comics published by WEBTOON,” Cloudflare was advised. “Please act expeditiously to remove or disable access to the infringing material.”
Each block in the image above represents one of the 390+ URLs listed in the Webtoon infringement notice. The blank spaces indicate URLs that no longer exist at the time of writing, wouldn’t load for unspecified reasons, or in some cases link to sites that appear to have shifted to new or alternative domains. The majority of those containing an image remain online; the question is for how long.
Over a decade ago, then-junior attorney Evan Stone made headlines when he used four-letter expletives to slam ISPs and the adult industry, while revealing his personal vendetta against pirates, or “smarmy entitled little brats” to use the attorney’s terminology.
While much has changed since then, the appearance of Stone’s name on a declaration in support of DMCA subpoena application filed at a district court in Texas, shows that his pirate-fighting days are not yet over.
With Stone representing Remove Your Media, and both acting as agents of Webtoon Entertainment, the DMCA subpoena application filed in August but only now being reported, is a strong indication that reducing illicit competition is a priority matter for the webtoon company.
The primary purpose of a DMCA subpoena is to compel a service provider, in this case Cloudflare, to hand over the personal details of an alleged infringer to allow copyright holders to enforce their rights. Here, the application demands 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 Exhibit A, or control the domains themselves.
What separates this application from most is the scale of the request and the sheer volume of site operators that face being caught up in the dragnet. It’s inevitable that some domains in the list will share the same owner but over 350 domains in a single subpoena is still unprecedented, and would remain so even if reduced by half.
Strictly there’s no requirement for the clerk of the court to conduct a detailed examination of a DMCA application before issuing the stamp of approval. Given that the application was filed August 22, marked as terminated on August 22, and then issued two days later on August 24, it seems likely that no further examination took place.
The list of domains targeted in the subpoena, for which Cloudflare was required to hand over full operator details, is available below. What happens next is almost entirely down to the quality of information handed over by Cloudflare before the deadline expired on October 5. It’s likely that the information received is already undergoing evaluation.
Webtoon’s overall goal likely entails the removal of illicit competition from the market but the means remain unknown. In practical terms, not even the largest corporate entertainment giants see value in mass litigation. Even if Webtoon decided otherwise, balancing the books to make the exercise worthwhile would be complex and unpredictable at best; messy, unproductive, even counterproductive at worst.
Threats of possible litigation to encourage settlements may be considered a viable option, at least if any of the operators left any usable identifying information in Cloudflare’s hands, which most try to avoid.
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The individual domains listed in the subpoena are shown below to illustrate scale. Due to the potential for errors following OCR and the extraction of domains from the full-content URLs in the subpoena, the list is not definitive. The DMCA takedown notice sent to Cloudflare, which contains full unedited URLs, is available here (pdf)
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