CEG TEK International—also known as Copyright Enforcement Group and operating through the website copyrightsettlements.com—launched an aggressive new copyright enforcement campaign targeting website owners who display images owned by AKM Images and GSI Media. Unlike CEG TEK’s previous campaigns targeting BitTorrent downloaders of adult films, this campaign focuses on photos appearing on commercial websites and demands $500 per image in settlement. The problem: many of these notices have been sent to owners of licensed content who have done nothing wrong.
CEG TEK sent a wave of copyright infringement notices under the subject line “Notice of Unauthorized Use of Copyrights Owned by AKM Images / GSI Media.” Recipients of these notices were instructed to “remit settlement in the amount of $500.00” or face escalation to higher penalties once the matter was referred to litigation. The notices typically include a screenshot of the allegedly infringing use and identify the specific image at issue.
AKM Images and GSI Media are celebrity and entertainment photo agencies that license photographs to news organizations, publishers, and websites. Their images appear on millions of websites, many of which have obtained valid licenses through standard stock photo platforms or syndication agreements. CEG TEK’s automated identification process has flagged many of these legitimately licensed uses as infringing—a fundamental error that does not excuse the demand but does create strong defenses for recipients.
Not without consulting an attorney. The $500 figure is chosen deliberately: it is large enough to generate significant revenue when multiplied across thousands of recipients, but small enough that many recipients will pay rather than fight. CEG TEK’s business model depends on recipients making that calculation.
Before paying any copyright settlement demand, an experienced copyright attorney will assess several critical questions:
Not every photograph qualifies for copyright protection. A photograph must embody at least minimal creative expression to be protected. More importantly, to recover statutory damages—the large figures CEG TEK threatens—the copyright holder must have registered the work with the U.S. Copyright Office before the infringement or within three months of first publication. 17 U.S.C. § 412. If AKM Images or GSI Media did not timely register the specific photograph at issue, CEG TEK’s threat of large statutory damages is largely hollow.
If you obtained the image through Getty Images, Shutterstock, a WordPress theme, a content aggregation platform, or any other channel that provided a license, you may have a complete defense. CEG TEK’s campaign has been plagued by demands sent to licensees—people who paid for and properly used the images. Your license documentation is your most important piece of evidence.
Only the copyright holder or its authorized agent can assert copyright infringement claims. CEG TEK’s authority to collect on behalf of AKM Images and GSI Media should be verified. If CEG TEK lacks a valid written assignment or exclusive license to enforce the copyrights, its standing to bring or threaten suit may be compromised.
Commentary, criticism, news reporting, and other transformative uses of copyrighted photographs may qualify as fair use under 17 U.S.C. § 107. The analysis is fact-specific, but many editorial uses of celebrity images—particularly when the photograph is used to illustrate a news article or commentary about the subject—are strong fair use candidates.
First, do not panic. These notices are designed to generate fear and urgency. Take the following steps:
Revision Legal’s copyright attorneys have handled numerous CEG TEK demand letters and understand the company’s enforcement tactics, negotiating patterns, and litigation record. We can help you assess whether you have a valid defense, respond to the demand effectively, and avoid paying more than you legally owe—which in many cases is nothing at all. Contact us today for a confidential consultation.
CEG-TEK International has sent hundreds of thousands of copyright settlement demand notifications on behalf of adult film studios, independent music labels, and software publishers. Each notification invites the recipient to visit a settlement portal and pay a specified amount — typically ranging from $200 to $600 per title — to resolve alleged BitTorrent infringement. Before visiting that portal, making any payment, or contacting CEG-TEK directly, the recipient should understand what the notification establishes, what it does not establish, and what legal options are available.
The ISP account holder is not necessarily the infringer. CEG-TEK’s monitoring captures the IP address of the internet connection from which a torrent was allegedly downloaded. The ISP then routes the notification to the account holder of record. But the account holder is legally distinct from whoever actually operated the device and initiated the download. In households with multiple residents, guests, or an unsecured WiFi network, any number of individuals may have had access to the connection. Courts have consistently held that this identification gap precludes a strong inference of infringement by the account holder alone.
No lawsuit has been filed. CEG-TEK’s notification process is pre-litigation. The recipient’s ISP has not been subpoenaed, and the recipient’s name is not known to CEG-TEK unless the recipient visits the settlement portal and provides it. Visiting the portal, entering identifying information, and engaging with the settlement process can create a record that the copyright owner uses if it later decides to file suit. An attorney can make contact on the client’s behalf without the client’s identity being disclosed to the claimant at that stage.
The vast majority of CEG-TEK notifications are not followed by individual lawsuits. The economics of mass BitTorrent litigation have become less favorable following judicial pushback on joinder and personal jurisdiction, the three-year statute of limitations has run on many older claims, and individual lawsuits against anonymous John Doe defendants are expensive relative to the settlement amounts collected.
However, certain copyright holders — particularly those with a demonstrated history of individual litigation — do follow through. If the copyright holder has filed John Doe suits in your district within the past two years, treats the works as high-value, or if the notification involves multiple titles, the risk of a lawsuit is elevated. An attorney familiar with the specific copyright holder’s litigation history can provide a realistic litigation risk assessment and help weigh the cost-benefit of settlement against the probability and cost of litigation.
One frequently overlooked issue in CEG-TEK matters is the availability of declaratory relief. Where a recipient has received multiple notifications, or where the copyright holder has threatened litigation without following through, counsel can evaluate whether a declaratory judgment action — seeking a court ruling that no infringement occurred or that the asserted copyright is invalid — would be appropriate to force a resolution rather than leaving the recipient in indefinite uncertainty. Declaratory relief requires an actual controversy, but when a copyright holder has made repeated demands without filing suit, the threshold for ripeness may be satisfied. This option is rarely the first resort, but it is a legitimate tactical tool when other avenues have been exhausted and the recipient needs finality.
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