Khanh

BACKGROUND

20 Synopsys designs copyrighted and trademarked software for the semiconductor industry. 21 Dkt. No. 1 ¶ 21. Synopsys customers purchase licenses which grant them rights to install 22 Synopsys software and use specific Synopsys programs subject to control by Synopsys’ “License 23 Key” security system. Id. ¶ 24. Synopsys software cannot be used without the appropriate license 24 key, and Synopsys itself “is the sole source of legitimate license key files, which it provides only 25 to licensed users of its software.” Id. ¶ 25. 26 As alleged in the complaint, Khánh resides in Vietnam and operated the website 27 distributed without the owner’s authorization and with modifications that circumvent access controls. Id. ¶¶ 2, 26, 29. Synopsys alleged that ShareAppsCrack.com allowed for unauthorized downloads of its software using counterfeit license keys, and advertised “cracked” versions of Synopsys software using Synopsys’ protected trademarks. Id. ¶¶ 26, 29, 44-48. Synopsys filed suit on April 26, 2022, and served Khánh on April 29, 2022. Dkt Nos. 1, 8- 6 1. On May 9, 2022, the Court entered a temporary restraining order (TRO) and an order…