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Use of the Internet to traffic counterfeit goods is a global problem. “A study published in 2008 by the Organisation for Economic Co operation and Development ( entitled The Economic Impact of Counterfeiting and Piracy estimated that the value of counterfeited and pirated goods moving through international trade alone in 2005 amounted to up to US$200 billion,” according to the court document. “In 2011 Frontier Economics Ltd published a report entitled Estimating the Global Economic and Social Impacts of Counterfeiting and Piracy which estimated that the value of internationally traded counterfeit and pirated goods would increase to US$960 billion by 2015.”.

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