nah, all she has to do is squeeze cloudflare's balls tight enough
90% of pirate sites using CF
send 3 cease/desist to CF and if it ain't gone, hit em
she needs a better lawyer though, RICO is wack and she left out the ad program crakrevenue, they're the ones who put the ads there.
the question is, did she send a cease/desist to bangbros and chaturbate?
civil suits are expensive, that's why you have DMCA, cease/desist
civil suit should be the final step
the correct attack would've been to attack them for 2257, copyright, trademark and add xvideos boss since he owns bangbros, add crakrevue and their boss, add CF ceo, add registrar for .tv domain
sue everyone
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i'm very skeptical about that assertion since The MPAA, RIAA, BREIN and et cetera haven't been able to take down the piratebay which uses cloudflare.