Nothing Filed in the GTA 6 Subpoena Cases Since 31 August

Nothing has been filed in any of Take-Two Interactive's four DMCA subpoena cases since 31 August. The subpoena return dates of 4 and 8 September have both passed with no return of service, no affidavit of compliance, no motion to quash, no motion for an extension and no letter from any recipient. No new Take-Two docket has opened anywhere in the federal system since 1 September. One of the four matters, the X Corp. one, is still open. That is the whole of the news, and the honest reading of it is that it tells you very little. What the empty dockets do allow is a re-verification, so we went back and checked our own four-case map against the record. The state of the four dockets CONFIRMED as a statement about the public RECAP mirror at our snapshot time. All four docket pages were fetched at 2026-09-10T03:08:52Z, all HTTP 200, at 89,952, 119,879, 92,541 and 88,222 bytes respectively. Each carries the header values below, verbatim. 1:26-mc-00421: Date Filed Aug. 20, 2026 · Date Terminated Aug. 21, 2026 · Date of Last Known Filing Aug. 21, 2026 · Assigned To Jennifer L. Rochon. 1:26-mc-00422: Date Filed Aug. 20, 2026 · Date Terminated Aug. 21, 2026 · Date of Last Known Filing Aug. 31, 2026 · Assigned To Andrew Lamar Carter Jr. 1:26-mc-00425: Date Filed Aug. 21, 2026 · Date Terminated Aug. 31, 2026 · Date of Last Known Filing Aug. 31, 2026 · Assigned To John Peter Cronan. 1:26-mc-00426: Date Filed Aug. 21, 2026 · no Date Terminated field · Date of Last Known Filing Aug. 24, 2026 · Assigned To Analisa Nadine Torres. Four search-level checks back the negative up. A RECAP document search for "Take-Two" with an entry date on or after 1 September 2026 across all courts, run at 2026-09-10T03:05:08Z, HTTP 200, 3,156 bytes, returned two hits and both are false positives, an unrelated motion to intervene filed 5 September and an unrelated complaint filed 4 September. Dockets captioned "Take-Two Interactive" filed anywhere on or after 1 September: 0 Result, fetched 2026-09-10T03:10:13Z, HTTP 200, 118,625 bytes. The same caption in the Southern District of New York on or after 25 August: 0 Result, 115,266 bytes. Dockets matching "DMCA Subpoena" in that district over the same period, fetched 03:10:01Z, 115,178 bytes: 0 Result. RECAP mirrors PACER and it lags, so all of that is as of the snapshot and no further. CourtListener's own per-docket freshness stamps are 3 September 10:39 p.m. for the Microsoft matter, 8 September 2:26 a.m. for Discord, 3 September 12:42 a.m. for Google and 9 September 1 a.m. for X Corp. Anything filed in PACER after those stamps would not be visible to us. Live PACER was not accessed. The silence is genuinely ambiguous, and we are not going to resolve it. In section 512(h) practice a return of service is frequently never docketed at all, because the whole mechanism is designed to run outside the court once the clerk issues the paper. "Nothing filed" is equally consistent with recipients quietly complying, recipients quietly not complying, negotiations happening off the docket, and nothing happening at all. It is evidence of none of those four. Anyone telling you the silence means compliance, or means resistance, is reading a blank page. The frame, because it goes missing in almost every retelling A section 512(h) subpoena is an ex parte identity-disclosure mechanism. It is not a lawsuit. No adversary was served, heard or given a chance to respond before the clerk issued paper. "Granted" means only that the clerk will issue the subpoena. No judge has found infringement, weighed evidence or decided anything on the merits. "Withdrawn" is not "denied", and "closed" is not "rejected". The recipients are custodians of records. They are not defendants and are accused of nothing. Microsoft Corporation, Discord, Inc., Google LLC and X Corp. received subpoenas as third parties. None has been sued and none is alleged by anyone to have done anything wrong. Take-Two has sued nobody. There is no complaint, no cause of action and no named defendant on any of the four dockets. The cause code on all four is M 08-86 Internet Infringement, a miscellaneous classification rather than a claim. A Rule 45 return date is counsel's demand date printed on a form. It is not a court order and not a deadline any court set. The 4, 8 and 14 September dates were read off the subpoena forms, and a recipient missing one is not in contempt of anything by that fact alone. Allegations in a brief or a declaration are not court findings. Nothing Take-Two has asserted has been tested. We re-checked our own map against the dockets, and it holds This desk has published a four-case map several times since 24 August. Before writing anything about the silence we put that map back against today's snapshot, line by line. It is accurate. The pieces re-verified are our report on the four cases and the undercount, which names Judge Rochon on the Microsoft matter and Judge Torres on X Corp. and already describes the Microsoft exhibit as a GitHub DMCA notice, and our report on the Google withdrawal, which places Judge Cronan on 1:26-mc-00425 throughout. CONFIRMED, from the four docket pages read at 2026-09-10T03:08:52Z. DocketRecipient named on the initiating documentJudgeCounselStatus at snapshot 1:26-mc-00421Microsoft Corporation, supporting exhibit a GitHub DMCA noticeJennifer L. RochonDale M. Cendali, Kirkland & Ellis LLPTerminated 21 Aug 2026, nothing since 1:26-mc-00422Discord, Inc.Andrew Lamar Carter Jr.Dale M. Cendali, Kirkland & Ellis LLPTerminated 21 Aug 2026, last filing 31 Aug 1:26-mc-00425Google LLC, supporting exhibit a YouTube takedown noticeJohn Peter CronanRachel Mae Bandli, Ruttenberg IP Law, P.C.Withdrawn and closed 31 Aug 2026 1:26-mc-00426X Corp.Analisa Nadine TorresRachel Mae Bandli, Ruttenberg IP Law, P.C.No termination date, still open On the GitHub point specifically, docket entry 4 in 1:26-mc-00421, filed 20 August 2026, reads verbatim: DECLARATION of Dale M. Cendali in Support re: 1 Request for Issuance of Digital Millennium Copyright Act Subpoena,. Document filed by Take-Two Interactive Software, Inc.. (Attachments: # 1 Exhibit 1 - Github DMCA Notice).(Cendali, Dale) (Entered: 08/20/2026) The declaration runs to 2 pages and the exhibit to 2 pages. Microsoft owns GitHub, and the exhibit Take-Two put in front of Judge Rochon is a GitHub takedown notice, which points at a code repository rather than a video or a chat server. We did not open the exhibit, so we cannot say what the repository was. A RECAP full-archive search for "Rockstar Games" across all federal courts for dockets filed on or after 1 August 2026, fetched at 2026-09-10T03:10:13Z, HTTP 200, 123,617 bytes, returns exactly 1 Result, and it is this docket. Two federal judges signed an order that says it grants the wrong thing CONFIRMED, from entry 5 in each of two cases, both one page. Take-Two's counsel submitted a proposed order whose body correctly grants a DMCA subpoena but whose title says the court is granting the petitioner's Rule 7.1 corporate disclosure statement, which is not a thing a court grants. Two different judges, in two separate cases, on the same day, signed it as drafted. 1:26-mc-00421, entry 5, filed 21 August 2026, verbatim: ORDER GRANTING PETITIONER TAKE-TWO INTERACTIVE SOFTWARE, INC.'S RULE 7.1 DISCLOSURE STATEMENT: Having considered the Declaration and all documents submitted in support of the instant application, the Court finds good reason to issue an order directing the clerk to issue said subpoena and it is therefore: ORDERED that the clerk of this Court shall issue the Subpoena for Microsoft Corporation as sought by the petitioner. (And as further set forth herein.) (Signed by Judge Jennifer L. Rochon on 8/21/2026) (jca) Transmission to Finance Unit (Cashiers) for processing. (Entered: 08/21/2026) Entry 5 at 1:26-mc-00422, filed the same day, is the same text word for word, with "Discord, Inc." in place of "Microsoft Corporation" and signed by Judge Andrew L. Carter, Jr. Entry 3 in each case is the actual Rule 7.1 corporate disclosure statement, a routine one-page form. Entry 5 is a different document doing a different job with the wrong name on it. Read the docket alone and it looks as though a judge granted a disclosure form. Read the body and a subpoena was authorised. By the 24th and the 31st the caption was fixed. The Torres order at 1:26-mc-00426, entry 5, filed 24 August, is correctly headed as a request for issuance of a subpoena to X Corp., and the Carter order at 1:26-mc-00422, entry 10, filed 31 August, correctly grants the subpoena to Discord. The Torres order carries its own typographical fingerprint, the run-together strings INC.'SREQUEST and CORP.:This on its face, another sign these captions came off a party-supplied template rather than out of chambers. This is a documentary artefact and not misconduct by anybody. A judge signing a party's proposed order with a bad caption is unremarkable in itself. What it evidences is speed and templating: four filings, two firms, two days, boilerplate orders, all four granted. Why this file is genuinely easy to get wrong Worth setting out, because mis-attributions in this story keep appearing and the reason is structural rather than careless. Four near-identical matters. All four carry the same cause code, M 08-86 Internet Infringement, the same $52.00 filing fee, the same one-party caption, and initiating documents that differ only in the recipient's name. Near-consecutive docket numbers across two days. 421 and 422 on 20 August, 425 and 426 on 21 August. A single transposed digit swaps the recipient and the judge at once. Four different judges. Rochon, Carter, Cronan and Torres, one per matter, no two matters sharing a judge. Two law firms. Kirkland & Ellis, through Dale M. Cendali, filed 421 and 422. Ruttenberg IP Law, through Rachel Mae Bandli, filed 425 and 426. No filing on any docket explains the split, and we are not going to guess at one. Orders whose own captions misdescribe them. When two of the four signed orders are titled as granting something they do not grant, a docket-text scrape reads a false label straight off the source. Recipient names that invite substitution. The respondent on 421 is Microsoft Corporation, but the exhibit is a GitHub notice, so both are defensible shorthand and only one is the name on the docket. We are describing the shape of the trap rather than pointing at anybody who fell into it. We have not audited other outlets' copy on these four cases and we are not asserting that any named publication got it wrong. The Google matter, closed and not denied The one case that went the other way is worth restating, because closure is routinely reported as defeat. Its RECAP document listing was fetched at 2026-09-10T03:03:24Z, HTTP 200, 14,702 bytes, showing 13 documents. Entry 4, filed 21 August, attaches Exhibit 1, a DMCA takedown notice to YouTube, declaration 2 pages and exhibit 4 pages. Not opened. Entry 5, Judge Cronan's memo endorsement of 24 August, 3 pages, verbatim with one elision: MEMO ENDORSEMENT on re: 1 Request for Issuance of Digital Millennium Copyright Act Subpoena, filed by Take-Two Interactive Software, Inc. ENDORSEMENT: Petitioner has not provided any information as to how it identified the online personas that it seeks to subpoena from Google, including its basis for believing that those users are associated with the posting of [URL removed by us] The elision is ours and it is deliberate. The docket text prints a specific YouTube video identifier on its face. We removed it, we did not follow it, and we are telling you we did. Take-Two responded on 28 August. Entry 7, Judge Cronan's endorsement of 31 August, one page, verbatim: MEMO ENDORSEMENT on re: 6 Response filed by Take-Two Interactive Software, Inc. ENDORSEMENT: The Clerk of Court is respectfully directed to terminate all pending motions and to close this case. SO ORDERED. (Signed by Judge John P. Cronan on 8/31/2026) (jca) (Entered: 08/31/2026) That is housekeeping following a withdrawal. It is not a rejection, not a rebuke and not a ruling against Take-Two. No court in any of these four cases has ruled on the merits of anything, because there are no merits before it. What we did not look at No exhibit attachment in any of the four cases was opened. We recorded only the docket-text descriptions and page counts. No repository name, account name, handle, email or URL from any exhibit appears anywhere in this article, and the one YouTube identifier printed on a docket face has been elided as described. What is and is not established CONFIRMED as of the RECAP snapshot at 2026-09-10T03:08:52Z: nothing filed in any of the four cases since 31 August, no Take-Two docket opened anywhere since 1 September, and the 4 and 8 September return dates passed with no return of service. The 14 September date has not yet arrived. CONFIRMED, and re-verified against this desk's own back catalogue: 1:26-mc-00421 names Microsoft Corporation before Judge Rochon with a GitHub DMCA notice as its exhibit; 1:26-mc-00422 names Discord, Inc. before Judge Carter; 1:26-mc-00425 names Google LLC before Judge Cronan and is closed; 1:26-mc-00426 names X Corp. before Judge Torres and is the only matter still open. CONFIRMED: two federal judges signed proposed orders captioned as granting a Rule 7.1 disclosure statement, whose bodies grant subpoenas to Microsoft Corporation and Discord, Inc. Later orders in the campaign carry correct captions. Explicitly ambiguous: the silence. Quiet compliance, quiet non-compliance, off-docket negotiation and nothing happening at all are all equally consistent with an empty docket. Explicitly not claimed: that any recipient has been served or produced anything, that any court has found anyone infringed anything, or that anything improper occurred in the drafting or signing of the orders. Explicitly not claimed: that any named outlet has mis-attributed any of these four matters. We set out why the file is easy to get wrong without auditing anyone else's copy. Method limits: RECAP mirrors PACER and lags, the four freshness stamps run from 3 to 9 September, live PACER was not accessed, and no exhibit was opened. The rest of today's reporting is on the news desk, and the servers list and leaderboards are open for the next 70 days.