Universal City Studios LLC v Telstra Limited (No 2)

Universal City Studios LLC v Telstra Limited (No 2) [2025] FCA 1485 is an urgent Federal Court copyright decision about extending the practical effect of earlier site-blocking orders to new technical access points. The applicants were major film and entertainment companies. The respondents were Australian telecommunications and internet service providers.

The Court had already made site-blocking and ancillary orders on 12 November 2025 under s 115A of the Copyright Act 1968 (Cth) in relation to 52 target online locations. After those orders were implemented, the applicants said some of the targeted locations were still reachable through different domain names, URLs and IP addresses. The Court accepted evidence that waiting for the ordinary process under the earlier orders would likely leave those access points available for most of the theatrical release period of the film “Wicked: For Good”, and it made urgent orders requiring respondents to take reasonable steps to disable access.

This decision sits inside a larger copyright enforcement proceeding. On 12 November 2025, the Court had already made site-blocking and ancillary orders with respect to 52 target online locations. Those earlier orders were made under s 115A of the Copyright Act. The present application was brought only days later, after the applicants reviewed how those orders were working in practice.

The review was organised by Andrew Gavin Stewart, who instructed Jackson Ion Moir, a summer clerk employed by the applicants’ solicitors, to check implementation of the earlier orders on 18 and 19 November 2025. According to Mr Stewart’s evidence, the respondents had substantially complied with the earlier orders, subject to relatively minor exceptions. But the review also identified a number of urgent and standard target online locations that were being made available from different domain names, URLs and IP addresses.

The Court recorded evidence that these new access points appeared to have the same or substantially the same name, branding and content as the already-targeted locations and appeared to make available the film “Wicked: For Good”. The Court also recorded evidence that all of the additional urgent access means were outside Australia, had substantially the same means of contacting the owners or operators, and had substantially the same registrant and or registrar details and contact details as the original target online locations. That evidence mattered because it supported the applicants’ position that these were not unrelated new sites, but alternative routes to the same or substantially the same infringing locations.

The commercial setting was important. Mr Stewart gave evidence that “Wicked: For Good” had its initial Australian release on 20 November 2025 and was likely to remain in theatres for approximately 30 to 45 calendar days, likely for the remainder of the 2025 calendar year. The applicants argued that if they had to use the ordinary process under the earlier orders, the new access points might remain available until 24 December 2025. The Court accepted that this would leave the sites accessible for the majority of the theatrical release period and would likely reduce the film’s commercial success because infringing copies would be available without charge.

One useful point in the judgment is the Court’s clarification of terminology. The applicants’ notifications to respondents on 24 November 2025 described the new access points as “Additional Target Online Locations”. At the hearing, counsel clarified that “Additional Urgent Access Means” was the better description.

The reason is practical. The Court treated the new domain names, URLs and IP addresses as alternative routes by which users could access urgent target online locations and standard target online locations that were already the subject of the 12 November orders. In other words, the issue was not that a completely separate new website ecosystem had appeared. The issue was that access to already-targeted locations appeared to be continuing through replacement technical pathways.

The Court held that the wording difference did not materially detract from the relevance of the notifications given to respondents. That matters because urgent applications often turn on whether respondents had fair notice of what was being sought. Here, the Court was satisfied that the notifications remained relevant despite the less precise label.

For business readers, this distinction is worth understanding. A “target online location” is the online location the earlier orders were directed at. An “access means” is the route by which users can still get there, such as a replacement domain name, URL or IP address. In a dynamic infringement setting, that distinction can affect how quickly a rights holder can seek follow-up relief and how a respondent understands the technical work it is being asked to perform.

The immediate legal issue was narrow but commercially important. The Court was not revisiting the original basis for making site-blocking orders under s 115A. Instead, it had to decide whether it should make urgent orders requiring respondents to disable access to additional domain names, URLs and IP addresses that were said to provide new means of access to already-targeted online locations.

The earlier 12 November orders already contained procedures for dealing with new domain names. The Court explained that, in the usual course, those procedures involved the applicants giving notice to respondents, seven working days for response, and then, if the matter was not relisted, a further 15 working days for respondents to take reasonable steps to disable access. That meant at least 22 working days before the new access points would be disabled.

The Court therefore had to assess whether the evidence justified an abridged timetable. The key evidence was that the film was in its theatrical release window, that the additional urgent access means appeared to provide access to infringing copies of the film, and that waiting until 24 December 2025 would likely leave those copies available for most of the release period. The Court accepted that this would likely reduce the commercial success of the film.

The Court also considered the procedural fairness point created by the wording used in the notifications and the respondents’ position on consent. Each respondent confirmed consent to the proposed orders. TPG Telecom noted that it would use reasonable endeavours to meet the timeframe because its blocking services were provided by a third-party vendor. The Court treated that, in substance, as consent to the orders sought.

Justice Halley made the urgent orders. The Court ordered each respondent to take reasonable steps to disable access to the Additional Urgent Access Means by 4.00 pm on Friday, 28 November 2025. The orders also provided that, after that point, respondents were to take reasonable steps within 15 business days of an obligation to disable access to a domain name, IP address or URL arising under Order 13 of the 12 November orders.

The Court further ordered that Orders 21 to 37 and 39 of the 12 November orders would apply to the Additional Urgent Access Means in the same manner as the Urgent Target Online Locations. The published orders also identified the additional urgent target domain names, URLs and IP addresses in Schedule 2, including entries associated with cineby, Hydrahd, hurawatch, andyday, myflixer, flixbaba, hdtoday and 123movies.

In reaching that result, the Court accepted Mr Stewart’s evidence that some target online locations shift to similar but not identical domain names after s 115A orders are made, which can subvert those orders because the locations remain accessible in Australia through a respondent’s carriage service. The Court also accepted the evidence about the likely commercial effect of delay during the theatrical release period of “Wicked: For Good”.

The Court was satisfied that the notifications given to respondents remained relevant despite the use of the phrase “Additional Target Online Locations”, and it placed weight on the fact that each respondent had confirmed consent to the proposed orders within a very short time period. On that basis, the Court concluded that the urgent orders sought by the applicants should be made.

For copyright owners, the case shows that enforcement may need to be staged. A first order can be effective and still leave room for circumvention if operators redirect users to replacement domains, URLs or IP addresses. The practical lesson is not simply to obtain an order, but to monitor what happens after implementation and to preserve evidence showing how users are still reaching the content.

The judgment also shows the value of linking technical evidence to commercial timing. The applicants did not rely only on a general complaint that infringement was continuing. They put forward evidence about what had changed, how the new access means resembled the original targets, where those access means appeared to be located, and why delay mattered during a theatrical release window. For a business owner, that means screenshots, redirect paths, domain details, dates of discovery and evidence of release timing can all matter.

For ISPs and carriage service providers, the case highlights operational readiness. The Court required each respondent to take reasonable steps within a short timeframe. One respondent noted that implementation depended on a third-party vendor, which is a useful reminder that outsourced technical arrangements do not remove the need for a workable compliance process. Businesses in this position should understand who receives legal notices, who assesses them, who instructs technical teams or vendors, and how timing commitments can realistically be met.

For other businesses that distribute or license digital content, the broader point is that online infringement often changes form rather than disappearing. A domain may be blocked, but traffic may move to a similar domain, a new URL path or a different IP address. This case is a practical example of the Court responding to that reality where the evidence was specific and the commercial urgency was clear.

The hearing took place on 25 November 2025. The orders were made the same day. The reasons were published on 28 November 2025 and were revised from the transcript. The Court expressly said that the reasons, and the defined terms used in them, are to be read together with the earlier 12 November 2025 judgment in Universal City Studios LLC v Telstra Limited [2025] FCA 1390.

That context matters because this is a short urgent ruling focused on additional access means and timing. It is best read as part of the broader site-blocking proceeding rather than as a standalone explanation of the entire dispute history.

This explainer is based on the published Federal Court reasons and orders in Universal City Studios LLC v Telstra Limited (No 2) [2025] FCA 1485. The Court’s own reasons say they should be read in conjunction with the earlier 12 November 2025 judgment referred to in the decision.

Because this is a short urgent follow-on ruling, it does not set out the full background of the earlier proceeding or the full detail of the original 52 target online locations. The discussion here stays within what the Court recorded in [2025] FCA 1485.