The RIAA believes it is on the cusp of victory in its lawsuit against Limewire, thanks mainly to its large selection of damaging charts. However, it seems to be expecting the worst, if these leaked documents are any indication. All evidence below indicates that the RIAA will be willing to settle for only $15 billion (out of a possible $55 billion). Not only that, but it already has plans in place for the dispersal of the Limewire settlement.

Explanatory Notes

First and foremost, the legal war chest must be refilled. It never sleeps and it is always hungry. Copyright won't protect itself and every battle to secure these rights has become long, uphill and against the wind.

A $15 billion payout doesn't come around every day and our executives are justly entitled to a large chunk of that ($3.15 bil.). As an added bonus (to the bonuses), all executives will be treated to a celebratory blimp ride ($2.25 bil.). This dollar amount seems high until you consider that each executive will be requiring their own blimp. Previously, the executives had shared one blimp, but in the post-Napster environment, "sharing" is obviously no longer a legal option.

Other line items include the ongoing efforts in Washington to impose the RIAA's will on the internet, research and development and the opaquely-named "Other Expenditures."

(1) Other Expenditures
Having run the "Stealing a Song = Stealing a Car" analogy into the ground, we need a new "go to" catchphrase. Hence, $1.05 billion should be earmarked for development of a new anti-piracy metaphor. Suggestions include:

• Stealing a song is like stealing a yacht.
• You wouldn't steal popcorn, would you?
• There's no such thing as a free lunch, free song or an infinite good.
• File sharing is as un-American as immigration, outsourcing and opium production.
• You wouldn't steal a blimp, would you?
• Stealing a song is like kidnapping an artist's children and is punishable by a sentence of 25 years to life.

Other incidental expenditures include a much-needed re-upholstering of the executive suites and a celebratory hot tub full of money to splash around in with various members of the escort community, each of whom will be paid in full for their services, including any fees due for public performance.

(2) Research and Development
A lion's share of the payout will go towards the ongoing development of a time machine/wormhole to 1991 ($450 million). Many recent efforts have come close but the RIAA has yet to reach the pre-Napster days and develop a parallel timeline in which CD sales increase forever. On the plus side, it did manage to get our mom to hook up with our dad, thus ensuring our continued existence.

Other products/services on the way:

• A computer-unfriendly music delivery system, much needed in this time of digital theft. Wax cylinders have been discussed as well as a partnership with RealPlayer, whose clumsy, bug-ridden software would likely prevent music from being enjoyed on a wide variety of operating systems.
• "Lost Sales" calculation improvements, which should allow the RIAA to seek even larger damages from various file sharing services. It is hoped that we will finally reach the trillion dollar mark within the next decade. In addition, breakthroughs should also be sought in the "Shocking Graph" field, what with the recent success of the "Napster Ruined Everything" line graphs.
• A partnership with the developers of The Club to prevent music from being stolen. A possible route would be some sort of clamp that could be tightened around an ethernet cable to prevent uploading. In other words, not so much "throttling" as "strangling."
• Domain seizure technology, via the RIAA's partnership with ICE, which has already proven its ability to take thousands of sites offline despite lack of evidence or proper investigative techniques. On the front burner: cooperating with ICE's takedown of many large pharmaceutical companies who continue to make themselves rich off various anti-seizure remedies, including the weirdly-named Antivan and Dilantin.

Royalty Payments

Royalty disbursements, as expected, will be delivered in a "top down" fashion. Those artists with the most sales will receive a disproportionately large share of the proceeds. After the "Big 3" are taken care of (and a chunk of money thrown towards Paul McGuiness in hopes that some of it lands in his mouth), the remaining funds will be dispersed to yet more lawyers and an appreciable amount ($300,000 ) put towards the ongoing health of Jon Bon Jovi's remaining hair. It is hoped that he will be able to put off his eventual "Trump Hair" for another 7-10 years, thus ensuring his continued success in the field of "fairly attractive frontmen." See footnotes for royalty dispersals.

*Charting Artists

$300,000 will be divided evenly among those artists currently in the Top 40 at the point of dispersal. If said artist happen to include any of the "Big 3," well, I suppose the rest of you should just write better hits, right? There's no crying in the music industry, especially if you're unrecouped.

*Non-Charting Artists

The remainder of the RIAA's roster will split $150,000. To qualify for payment, bands/musicians must have a viable Wikipedia page (stubs and pages slated for deletion do not count) and a web presence that includes more than just a long-abandoned MySpace page. (Try Facebook.)

The benefits of Google's book project are many. Books will become more accessible. Libraries, schools, researchers, and disadvantaged populations will gain access to far more books. Digitization will facilitate the conversion of books to Braille and audio formats, increasing access for individuals with disabilities. Authors and publishers will benefit as well, as new audiences will be generated and new sources of income created. Older books -- particularly out-of-print books, many of which are falling apart buried in library stacks -- will be preserved and given new life.

While Plaintiffs do not believe that either verdict was improper under the law, or that the second verdict should be remitted, they would have considered accepting a remittitur simply so that this case could finally come to an end. However, any remittitur must otherwise be consistent with the law and be guided by what actual juries have awarded under similar circumstances. Unfortunately, Plaintiffs find it impossible to accept a remittitur that could be read to set a new standard for statutory damages -- essentially capping those damages at three times the minimum statutory amount of $750 (or $2,250) for any "noncommercial individuals who illegally download and upload music." (Id. at 2, 25.) This far-reaching determination is contrary to the law and creates a statutory scheme that Congress did not intend or enact.

Indeed, Congress has spoken on this very topic. Congress deliberately and purposefully established a range of statutory damages that applies without regard to the commercial motivation of the defendant.

A rule that the maximum permissible award in cases involving so-called "noncommercial" infringers is three times minimum statutory damages also ignores the harm caused by such infringers. From an economic perspective, individuals who give away copyrighted works illegally can cause as much harm as those who sell those works illegally, particularly when the so-called "non-commercial" infringer uses a P2P service. The notion that an infringer who does not make a profit should automatically be entitled to better treatment than an infringer who does make a profit is found nowhere in the law. The "not for profit" infringer is hardly entitled to special protection, which is why Congress conferred no such protection.

The Court's cap would set a new ceiling such that no copyright owner could effectively enforce their rights unless they could and did sue on numerous works. No copyright owner would be motivated to enforce its rights where it could only sue on a handful of works because the potential recovery would be too limited. Congress set a wide range of statutory damages for copyright cases precisely because plaintiffs need to be incentivized to bring appropriate cases to enforce their rights -- even those who own a small number of copyrights or those who only have a limited number of works infringed. Conversely, the Court's artificially depressed cap compels parties with a large number of copyrights at stake to sue on all of them, rather than a more modest number. This serves only to increase the discovery and trial burdens on parties and courts. Yet the Court's inflexible "three times" cap would invariably penalize plaintiffs with a small number of works at issue, and would force those with a lot of works to add to their complaints unnecessarily.