He likens online piracy to issues faced in the early 20th century by stationers in England, who tried and failed to prevent the large scale printing and distribution of illicit sheet music. Grokster, Ltd., he notes that there have historically been a number of technologies which have had a "dual effect" of facilitating legitimate sharing of information, but which also facilitate the ease with which copyright can be violated. Quoting from legal standards in MGM Studios, Inc. Nathan Fisk traces the origins of modern online piracy back to similar problems posed by the advent of the printing press. LimeWire's paid version of their app was frequently pirated by users using the free version
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