Each year, the Office of the US Trade Representative produces two major reports about counterfeiting and piracy. One of them is the Review of Notorious Markets for Counterfeiting and Piracy (Notorious Markets List), which identifies examples of online and physical markets that reportedly engage in or facilitate substantial copyright piracy or trademark counterfeiting.
The `issue focus’ for the 2025 Notorious Markets List is piracy of sports broadcasts. USTR began the report process in August, when it called for public comments that identify candidates for inclusion in the report. 77 comments were submitted. The final round of the comment period ended on October 15. The final report is usually published in January.
The other is the Special 301 report, which is an annual review of the state of intellectual property rights protection and enforcement. The 2024 Special 301 report was released in April 2025.
AI as an anti-piracy tool
Looking across the submissions, few of them identified AI as a tool that aids in identifying piracy operations. The use of AI may be more widespread than is apparent here, as stakeholders may wish to keep their operational details secret so as not to tip off pirates to their anti-piracy methods.
In its submission, Amazon noted:
“In 2024, we improved our infringement detection capabilities by leveraging multimodal large language models (MLLMs) to look more holistically across multiple signals to identify infringing content. What sets this approach apart is its comprehensiveness. Instead of focusing separately on individual aspects of the listing data such as textual attributes, visual attributes, and pricing patterns, we are now able to look at these inputs collectively and all at once, allowing us to detect even subtle manipulations designed to evade detection. By processing billions of listings through this sophisticated lens and continuously learning new risk signals, our system keeps getting better at protecting customers and brands from infringing content. In 2024, Amazon’s proactive controls blocked more than 99% of suspected infringing listings before a brand ever had to find and report them.”
Interestingly, while the company operates one of the world’s largest video streaming platforms, Amazon’s entry made no reference to video piracy.
Sports piracy
The Spanish professional football league, LaLiga provided a good representative example of comments made about sports piracy, and has been particularly proactive in its anti-piracy efforts, due to the sheer volume of copyright infringement for its sports programming.
LaLiga segmented pirate operations into three categories: Infringing streaming Web sites, mobile apps and APKs (e.g. Android), and the illegal pay TV-like ‘IPTV’ ecosystem which includes CDNs (notably, Cloudflare) and offshore hosts. LaLiga identified “top ten” piracy operations in each of these categories.
“(Just ten streaming pirate sites) collectively generated over 266 million global visits per month… They systematically monetize stolen broadcasts through intrusive advertising, affiliate malware, and subscription-based “VIP” access tiers. Their promotion and visibility rely heavily on search engine optimization (SEO) strategies, social media marketing, and dissemination through specialized messaging groups, which drive traffic and user acquisition while masking the illicit nature of their activity.
“Many are hosted through non-cooperative infrastructure providers located in jurisdictions with limited enforcement cooperation, including the Russian Federation, Eastern Europe, and offshore entities in the Caribbean.”
LaLiga’s second nemesis, APKs, are “deliberately engineered to operate within Android environments, allowing users to install them easily … often bypassing official app store controls.”
While LaLiga says it has made numerous attempts to engage with Google to mitigate this persistent issue, Google’s use of enforcement mechanisms such as Google Play Protect and better monitoring for recurring offenders remain insufficient, they said.
The top IPTV site identified by LaLiga was Magis TV, based primarily in Shenzhen, China, and serving millions of users throughout Latin America and Europe.
Magis TV
In addition to the comment from LaLiga, Magis TV was noted by a number of other submissions to the USTR. This article singles out Magis TV as a classic example of an ‘IPTV’ piracy operation.
For example, the entire 9-page submission by Galaxy Entertainment of Venezuela’s streaming video operator Simple TV (which previously operated under the DirecTV brand) also detailed Magis TV. Galaxy Entertainment partners with the MPA’s Alliance for Creativity and Entertainment (ACE) to counter pirates in Latin America.
Galaxy Entertainment say that Magis TV offers more than 1,000 TV channels of all genres, premium content, events, 10,000 movies, and 6,000 TV series programs. This includes series and content from Netflix, Amazon Prime, Apple TV, Disney +, and Paramount Plus. It delivers to consumers via branded illicit streaming devices made in China, and via the Web and through apps.
Magis TV has re-branded as Flujo TV, whose Android APK application replaces the Magis TV application on the user’s phone by default and automatically prompts the user to update the application. The rebranding move is likely a reaction to judicial blockades of Magis TV in multiple countries.
Hosting providers
In addition to CDNs, hosting providers were also identified by various commenters. For example, the International Broadcaster Coalition Against Piracy (IBCAP) collects data related to a number of hosting companies and CDNs used by pirates offering unauthorized streaming services through STBs, IPTV services, websites, and other streaming platforms. A number of them facilitate piracy by providing services that support large-scale infringements and ignore requests to take down streams of infringing material or to terminate accounts of repeat infringers.
IBCAP again identified Ukraine-based Virtual Systems, which touts its “DMCA Ignored” services, and UK-based Innetra PC which offers nearly 57,000 unauthorized assets and 2,800 unlicensed linear streams. Another was Extoxy OÜ, an Estonian hosting company that had been responsive to takedown requests in the past. None of them have been responsive recently.
Virtual Systems and Extoxy were also identified by the Motion Picture Association in its own submission.
Cloudflare
The Motion Picture Association described CDN and reverse proxy service provider Cloudflare as being widely used by notorious markets to avoid detection and enforcement. “Cloudflare’s customers include some of the most notorious, long-standing pirate websites in the world, including the massively popular streaming sites vegamovie.gmbh, cuevana.biz, and The Pirate Bay, whose current domain, thepiratebay.org, has been identified as infringing rightsholders’ copyrights more than six million separate times,” said MPA.
Cloudflare was also detailed as a threat by LaLiga and others.
Physical counterfeits
Makers of physical products and their industry groups were concerned with physical counterfeits of global brands. One trade association, Information Technology and Innovation Foundation, singled out several China-based e-retailers. Others, like the Intellectual Property Owners Association, identified physical markets in Asia, Africa, the UK and elsewhere.
Removal for good behavior
China-based online retailer DHgate Group had been listed in previous Notorious Markets reports. For example, the 2018 report cited the International Anti-Counterfeiting Coalition, which reported concerns about the high volume of sales of counterfeit goods on DHgate.com, lax seller registration procedures that allow sellers to resume operations even after being removed from the platform, and limited means for right holders to enforce their rights.
For the 2025 Notorious Markets report, DHgate made two its own submissions to the USTR – one public and the other confidential – requesting that USTR remove DHgate from inclusion. DHgate’s 98-page public submission detailed the company’s extensive efforts to enhance its IPR protections:
“Since DHgate launched its artificial intelligence (“AI”) anti-counterfeit screening tools in 2021, the company has been continuously improving these tools to proactively remove a broad range of counterfeit goods from its platform.”
Call for standardization
Anonymous commenters tend to be somewhat frivolous but one of them called on the USTR to define standards for outside submissions and baseline standards to estimate impact and harm, and how to handle differences for estimates in the same situations. Good advice.
One example of a submitter that defined its own standards for severity was UNIFAB, the French association for the promotion and protection of intellectual property (IP) rights; which segmented online marketplaces by country and and defined “Priority 1: Blacklist,” “Priority 2: List,” and “Additional Listing: Monitor.”
Why it matters
The Office of the United States Trade Representative (USTR) requests comments that identify online and physical markets to be considered for inclusion in the 2025 Review of Notorious Markets for Counterfeiting and Piracy (Notorious Markets List). The Notorious Markets List identifies examples of online and physical markets that reportedly engage in or facilitate substantial copyright piracy or trademark counterfeiting. The `issue focus’ for the 2025 Notorious Markets List will examine copyright piracy of sports broadcasts.
The United States is concerned with trademark counterfeiting and copyright piracy on a commercial scale because these illicit activities cause significant financial losses for right holders, legitimate businesses, and governments. In addition, these illicit activities undermine critical U.S. comparative advantages in innovation and creativity to the detriment of American workers, and can pose significant risks to consumer health and safety and privacy and security. Conducted under the auspices of the Special 301 program and the authority of the U.S. Trade Representative to address practices that have significant adverse impact on the value of U.S. innovation, the Notorious Markets List identifies examples of online and physical markets that reportedly engage in or facilitate substantial copyright piracy or trademark counterfeiting that infringe on U.S. intellectual property (IP).
Further reading
2025 Review of Notorious Markets for Counterfeiting and Piracy: Comment Request. Official notice. August 18, 2025. US Federal Register
Comments received. 2025 Review of Notorious Markets for Counterfeiting and Piracy. Landing page, linking to 77 comments submitted. Regulations.gov (US Government Web site)
Past issues of the USTR Notorious Markets report through 2024.
