Law & jurisdiction

Does the DMCA apply to offshore hosting?

Short answer

The DMCA is United States copyright statute. Its notice-and-takedown procedure and safe harbour apply to service providers situated in the United States. A server in Panama, Moldova or Seychelles is governed by that country's copyright law instead — which in most cases requires a court order rather than a private notice.

This is often described as "DMCA ignored", which is misleading. The accurate statement is that the DMCA procedure has no application outside the US, so a notice sent to a non-US host is a letter rather than a legal instrument. It is not that the notice is defied; it is that it has no procedural effect.

Copyright itself is near-universal through the Berne Convention. Infringement remains unlawful in every jurisdiction we operate in. What differs is the enforcement mechanism: notice-and-takedown in the US, judicial process almost everywhere else.

  • DMCA notices to non-US locations: no procedural effect, forwarded for information
  • Valid court orders from a competent court: acted on
  • US locations (New York, Ashburn, Miami, Dallas, Chicago, Los Angeles and others): DMCA applies fully
  • Content that is illegal in the host jurisdiction: removed regardless of who complains

See also: DMCA