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The July 2025 Cloudflare DMCA subpoena marks another escalation in the decades-long battle between academic publishers and shadow libraries.

The subpoena seeks to force Cloudflare to disclose identifying information about the operators of multiple domains associated with these shadow libraries, as well as several other websites.

Author

Pascal Hetzscholdt
August 09, 2025

by ChatGPT-5

1. Background

A coalition of major academic publishers — including Elsevier, Springer Nature, the American Chemical Society, and Taylor & Francis — has escalated its long-running battle against so-called “shadow libraries” such as Anna’s Archive, Z-Library, Library Genesis (LibGen), and Sci-Hub. These platforms, well-known in academic circles, provide unauthorized access to millions of scholarly articles, textbooks, and research monographs.

In July 2025, the group filed a Digital Millennium Copyright Act (DMCA) subpoena request in the U.S. District Court for the District of Columbia. The target was Cloudflare, a U.S.-based internet infrastructure company that provides content delivery network (CDN), DNS, and security services to a vast number of websites — including, allegedly, several pirate sites.

The subpoena seeks to force Cloudflare to disclose identifying information about the operators of multiple domains associated with these shadow libraries, as well as several other websites accused of linking to pirated works. This move follows years of escalating enforcement tactics, including takedown notices to Google, blocking orders in multiple jurisdictions, and direct litigation against infringing platforms.

2. Scope of the Subpoena

According to the filings, the subpoena demands that Cloudflare hand over all available subscriber and account data for the listed domains. This includes:

  • Names

  • Physical addresses

  • Telephone numbers

  • Email addresses

  • Billing and account records

The domains identified in the request are extensive, covering both major piracy portals and smaller sites allegedly serving infringing content. Examples include:

  • Anna’s Archive: annas-archive.org, annas-archive.se

  • Library Genesis: libgen.gl, libgen.la, libgenesis.co

  • Z-Library: z-lib.fm, z-lib.fo, z-lib.gd, z-lib.gl

  • Sci-Hub: sci-hub.vkif.top

  • Additional alleged piracy portals: collegepdf.com, ebookmass.com, dl4all.org, letmeread.net, limetorrents.lol

Notably, the subpoena also targets SLUM (Shadow Library Uptime Monitor), a site that does not host infringing material but provides status updates and historical uptime data for shadow libraries. The publishers allege SLUM “redirects” to Anna’s Archive; however, at present, it merely contains a standard hyperlink.

Under 17 U.S.C. § 512(h), copyright holders can request a clerk-issued DMCA subpoena compelling service providers to reveal identifying information about alleged infringers.
Key features of this process:

  • No judicial review: A judge does not evaluate the merits — a court clerk signs the subpoena if formal requirements are met.

  • Expedited process: The subpoena in this case was issued the day after filing.

  • Third-party leverage: Since pirate site operators often conceal their identities and host outside U.S. jurisdiction, targeting intermediaries like Cloudflare offers a path to obtaining actionable intelligence.

Publishers also paired the subpoena with a prior takedown notice asking Cloudflare to disable access to the domains in question. That request was not honored — likely because Cloudflare does not host the sites and tends to require a legal obligation before terminating service.

For Publishers

  • Identification for litigation: If Cloudflare holds billing or registration data, publishers could pursue direct lawsuits or criminal referrals against operators.

  • Deterrence effect: Broad subpoenas signal an aggressive enforcement posture, potentially discouraging others from operating similar services.

  • Collateral enforcement: Even if key sites remain operational, some secondary targets may shut down under pressure.

For Cloudflare and Intermediaries

  • Precedent for disclosure: Compliance could reinforce expectations that infrastructure providers will cooperate with rights holders without a court’s substantive review.

  • Due diligence challenge: Distinguishing between sites that directly infringe and those that merely link or monitor (like SLUM) raises legal and reputational concerns.

For Internet Freedom and Neutrality Advocates

  • Expansion of DMCA reach: The subpoena process sidesteps judicial oversight, raising questions about due process and potential overreach.

  • Impact on lawful services: Sites that are not themselves infringing but are swept into subpoenas risk chilling effects on legitimate speech and information services.

5. Controversies

  1. Inclusion of SLUM — This appears to push the boundaries of infringement theory by treating a status-monitoring service as an infringing party. This could broaden liability concepts for “linking” or “referring” to alleged infringers.

  2. Opacity of Operator Data — Pirate site operators often use privacy-protected domain registration and cryptocurrency for payments, meaning the subpoena might yield little actionable intelligence.

  3. No Judicial Scrutiny — The absence of a judge’s review in DMCA subpoenas leaves room for questionable or overly broad requests.

6. Outlook

Given Cloudflare’s history of complying with properly issued DMCA subpoenas, it is likely to provide at least some of the requested data. Whether that data leads to real-world enforcement success depends on:

  • The accuracy and completeness of the operator information.

  • The willingness of publishers to pursue costly litigation in multiple jurisdictions.

  • The resilience and adaptability of shadow libraries, which have historically evaded shutdowns through mirror sites, decentralized hosting, and anonymous operations.

This case may also embolden publishers to target other intermediaries — such as hosting providers, DNS registrars, and payment processors — in a coordinated campaign against academic piracy.

7. Conclusion

The July 2025 Cloudflare DMCA subpoena marks another escalation in the decades-long battle between academic publishers and shadow libraries. While the move may yield valuable investigative leads, it also raises significant due process and free-speech concerns, particularly when applied to ancillary or non-infringing services like SLUM.

The broader strategic question remains whether such enforcement efforts can meaningfully disrupt deeply entrenched piracy ecosystems — or whether publishers will need to pair legal pressure with more accessible, affordable, and legitimate distribution models to reduce demand for illicit alternatives.

·

10 JAN

Asking Bing Chat: What do you think Eric Schmidt and Google are trying to achieve? Explain what role Shadow Libraries play in the context of this conversation

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25 SEPTEMBER 2023

Question 1 of 20 for Bing Chat: Please read ‘Google's Former CEO Is Leveraging His $27 Billion Fortune to Shape AI Policy’ https://www.bloomberg.com/news/articles/2023-09-08/google-ex-ceo-eric-schmidt-influences-ai-policy-with-27-billion-fortune#xj4y7vzkg

GPT-4o: The report highlights that major AI companies (e.g., Meta, OpenAI, Microsoft, Apple, and others) have used pirated content to train their generative AI models.

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5 MAR

Asking ChatGPT-4o: Please read the “Report on Pirated Content Used in the Training of Generative AI” and the associated LinkedIn post and tell me what the key messages are and how AI makers should be responding to these issues.

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26 SEPTEMBER 2024

Question 1 of 2 for ChatGPT-4o: Please read the article “U.S. Court Orders LibGen to Pay $30m to Publishers, Issues Broad Injunction” and the associated judgment and tell me what the key messages (and key grievances) are.

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20 JUL

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7 FEB

Asking AI Services: Please read the articles "“Torrenting from a corporate laptop doesn’t feel right”: Meta emails unsealed" and "‘Meta Torrented over 81 TB of Data Through Anna’s Archive, Despite Few Seeders’" and explain what happened, whether this is bad behaviour or not and what a) the judge should do and b) what the AI maker(s) should do to prevent…

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14 APR

Asking AI services: Please analyze the TorrentFreak article “Meta AI ‘Piracy’ Lawsuit: Publishers and Professors Challenge Fair Use Defense” and the associated Amicus Brief from the International Association of Scientific, Technical and Medical Publishers

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5 JANUARY 2024

Question 1 of 4 for Google Bard: Please analyze the TorrentFreak article "Silenzio! ‘Anna’s Archive’ Shadow Library Blocked Following Publishers’ Complaint" and tell me what it says.

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7 FEB

Asking ChatGPT-4o: List every surprising, controversial and valuable detail (for copyright owners) you can find in the newly unsealed emails from META as published by Ars Technica