Take-Two Filed Four GTA 6 DMCA Subpoena Cases, Not Two

Take-Two Interactive did not open two federal proceedings over the Grand Theft Auto VI leak in August. It opened four. This desk reported two: the Discord matter and the Google matter. Both were read from primary filings and both remain accurate as far as they go. They were half the campaign. On 20 and 21 August, in the same courthouse and within roughly 48 hours, Take-Two also opened proceedings against Microsoft Corporation and X Corp. Both were granted. Neither has appeared in our coverage until this article, so the correction comes first and gets its own heading. Correction: we reported two proceedings when there were four Our count of Take-Two's August identity-discovery campaign was short by two. We wrote about 1:26-mc-00422-ALC, the Discord matter, and 1:26-mc-00425-JPC, the Google matter. We did not write about 1:26-mc-00421-JLR against Microsoft Corporation, filed 20 August and granted 21 August, or 1:26-mc-00426-AT against X Corp., filed 21 August and granted 24 August. Both were on the public docket the entire time. There is no access problem to blame and no ambiguity in the filings. We looked at two dockets when we should have run the search that returns all four, and the shape of the story is different at four than at two: a campaign against four service providers, run by two law firms in parallel, rather than a pair of one-off requests. The full four-case map CONFIRMED, from docket text and signed orders read at source through RECAP. All four are miscellaneous proceedings in the Southern District of New York, opened within 48 hours of each other. 1:26-mc-00421-JLR, In re DMCA Subpoena to Microsoft Corporation. Filed 20 August 2026 before Judge Jennifer L. Rochon, cause code M 08-86 Internet Infringement, counsel Dale M. Cendali, Kirkland and Ellis LLP. Granted 21 August. 1:26-mc-00422-ALC, In re DMCA Subpoena to Discord, Inc. Filed 20 August 2026 before Judge Andrew L. Carter, Jr., counsel Dale M. Cendali. Granted 21 August, and a second request granted 31 August with its target schedule under seal. 1:26-mc-00425-JPC, In re DMCA Subpoena to Google LLC. Filed 21 August 2026 before Judge John P. Cronan, counsel Rachel Bandli, Ruttenberg IP Law. Withdrawn by Take-Two on 28 August, endorsed and closed by Judge Cronan on 31 August. 1:26-mc-00426-AT, In re DMCA Subpoena to X Corp. Filed 21 August 2026 before Judge Analisa Torres, counsel Rachel Bandli. Granted 24 August. The split between the firms is clean. Kirkland and Ellis filed the two 20 August petitions through Dale M. Cendali; Ruttenberg IP Law filed the two 21 August petitions through Rachel Bandli. All four carried the same Rule 7.1 corporate disclosure identifying BlackRock, Inc. as an "Other Affiliate" of Take-Two. What happened in the Microsoft proceeding The initiating document was docketed on 20 August. Its docket text, verbatim: MISCELLANEOUS CASE INITIATING DOCUMENT - REQUEST FOR ISSUANCE OF DIGITAL MILLENNIUM COPYRIGHT ACT SUBPOENA as to Microsoft Corporation. (Filing Fee $ 52.00, Receipt Number ANYSDC-33319726)Document filed by Take-Two Interactive Software, Inc.. ...(Cendali, Dale) (Entered: 08/20/2026) A declaration from Dale M. Cendali followed the same day, attaching an exhibit the docket describes as a GitHub DMCA notice. Judge Rochon signed on 21 August. Her operative line, verbatim: ORDERED that the clerk of this Court shall issue the Subpoena for Microsoft Corporation as sought by the petitioner. The subpoena runs to Microsoft rather than GitHub for a structural reason: GitHub is a Microsoft subsidiary, so a section 512(h) subpoena founded on a notice sent to GitHub is served on Microsoft Corporation as the service provider. That notice was filed publicly as an exhibit. It was sent on Wednesday, 19 August 2026 at 11:28 from Take-Two's in-house intellectual property enforcement address to GitHub's copyright address, signed by a Take-Two paralegal at the company's West 44th Street office in New York. It reads, in part: We are writing to submit a takedown request regarding leaked content being hosted on GitHub that infringes on Take-Two's copyrights. ... The entire repository must be completely disabled, there are no remedies to rectify this clear case of infringement. A redaction, flagged rather than hidden. The notice names a single repository and its URL appears three times in the exhibit. We removed it. This desk does not print routes to unauthorised material, and a document on a public docket containing one does not change that rule. The phrase "clear case of infringement" is Take-Two's own allegation, sworn under the notice provisions of section 512 and untested by any court. What happened in the X Corp. proceeding The X Corp. petition was docketed on 21 August under the same $52.00 filing fee, receipt number ANYSDC-33326685, filed by Take-Two Interactive Software, Inc. through Rachel Bandli. Judge Torres signed on 24 August. Her order, verbatim: This matter comes before the Court upon the ex parte application of petitioner Take-Two Interactive Software, Inc. along with the Declaration of Rachel Bandli and supporting documents for the signing of a Subpoena directing X Corp. to produce the identity of entities or persons believed to be infringing on the copyright of Take-Two Interactive Software, Inc. ... ORDERED that the clerk of this Court shall issue the Subpoena for X Corp. as sought by the petitioner. A second redaction, also flagged. An exhibit in that proceeding reproduces X ticket forms containing a third-party brand-protection vendor employee's personal email address, home-format street address and mobile number. We are not republishing any of it. Those details belong to somebody who is not a party to anything here. What does the Microsoft subpoena actually demand? Where the second Discord request was sealed, the Microsoft subpoena's Attachment A was filed in the clear, making it the most detailed public artefact of the investigation so far. Verbatim, it demands: All internal Microsoft business records and investigative records associated with Microsoft's internal investigation of the "cyberleek" persona sufficient to identify the user(s), person(s) and/or entity/ies associated with that persona. All identifying information associated with all user accounts that are/were members communicating with the Discord server(s) listed below during the time period from June 1, 2026 to present; and for those accounts, provide any associated device/telemetry records where one or more of the tool/file artifacts below were present on the system. For each returned account, provide: the account ID, registration email, registration and last-login IP addresses, phone number, linked connections (Google/Xbox/etc.), any associated device identifiers (MachineGuid/MSA), and content related to Grand Theft Auto ("GTA"), Rockstar or Cyberleek from their OneDrive account. Read what that reaches for: registration and last-login addresses, a phone number, linked platform connections, machine identifiers, device telemetry and the contents of a cloud storage account. Those are things Take-Two has asked for. They are not things Microsoft has produced. Nothing on the docket shows any response, and a subpoena recipient retains its objection and motion-to-quash rights. Whether a statute whose text is about identifying an alleged infringer stretches this far has never been argued here, because the proceeding is ex parte and Microsoft has not appeared. What we are not printing from that attachment, and why Under the two paragraphs quoted above, the attachment tabulates three Discord servers with their guild identifiers and three account handles with numeric identifiers. We have read that table. We are not reproducing any of it: no guild identifier, no handle, no account name, and no description of the communities involved that would let a reader work out which they are. That is this desk's decision, and the reason is straightforward. The demand covers identifying information on all accounts that communicated with those servers over a three-month window, so it sweeps in ordinary members who did nothing at all. Appearing in a subpoena attachment is not an accusation. Nobody named there has been sued, charged or accused of anything in any filed complaint, and a section 512(h) subpoena adjudicates nothing whatsoever. Publishing the table would attach a criminal-sounding association to real names on no evidence, and the filing's own premise is that Take-Two does not know who these personas are. What does "granted" mean here? Considerably less than the word suggests. Three limits are routinely collapsed. This is not a lawsuit. A subpoena under section 512(h) of the Digital Millennium Copyright Act is an ex parte identity-disclosure mechanism, with no defendant, no complaint, no adversarial hearing and no opposing party. Microsoft, X Corp., Discord and Google are recipients of process rather than defendants: service providers being asked for records. Granted means the clerk will issue the subpoena, and nothing more. It is not a finding of infringement and not a ruling on scope. Both orders recite only that the court finds good reason to direct the clerk to issue the subpoena. The Microsoft and Discord dockets carry a termination date of 21 August, which is housekeeping: miscellaneous 512(h) matters terminate on issuance, so termination means the mechanism ran. Withdrawn is not denied. The Google matter closed because Take-Two pulled it, not because Judge Cronan refused it. He had asked Take-Two to explain how it identified the personas it wanted to unmask. Take-Two's answer, filed 28 August, was that it "no longer needs the particular information requested", with an express reservation of the right to file again. No court has ruled on the merits. A different Discord subpoena that is not this one One anti-conflation flag, because the timing invites the error. A separate section 512(h) proceeding against Discord, 3:26-mc-80272 in the Northern District of California, was filed on 26 August 2026 before Magistrate Judge Ajay S. Krishnan, with a subpoena issued on 27 August and the case terminated the same day. Its petitioner is the Motion Picture Association, Inc. Take-Two is not a party to it. Different petitioner, different district, different matter, and a coincidence of timing and target. How current is any of this? A limit on our own method, printed because it matters to how the story ages. Everything quoted here was read through RECAP, a crowd-sourced mirror of PACER rather than PACER itself. A document appears only once somebody with the browser extension has pulled it, so a filing made on 1 September, or an unindexed one from 31 August, would not necessarily show up. "Nothing newer in RECAP" is not "nothing newer on PACER". As read at 03:02 UTC on 1 September, a RECAP search for Take-Two proceedings filed since 1 August returns these four and no fifth. One further method note. Judge Carter's 31 August order granting the second Discord subpoena has no usable text layer: it is a scanned image with a handwritten signature. It was read visually from a page rendered at two and a half times scale, not extracted as text. That is a weaker read, and we are recording it rather than smoothing it over. What is and is not established CONFIRMED, from docket text and signed orders read at source: Take-Two opened four miscellaneous DMCA proceedings in the Southern District of New York on 20 and 21 August 2026, against Microsoft Corporation, Discord, Google and X Corp. Judge Jennifer L. Rochon granted the Microsoft subpoena on 21 August; Judge Analisa Torres granted the X Corp. subpoena on 24 August. Our own error, stated plainly: we reported two of the four. The undercount was ours and there is no access excuse for it. CONFIRMED, verbatim: the Microsoft Attachment A seeks account identifiers, registration and last-login IP addresses, phone numbers, linked platform connections, device identifiers, telemetry records and cloud storage content for all accounts communicating with three named Discord servers from 1 June 2026 onward. Explicitly withheld by us: the three guild identifiers, the three handles and every account name in that attachment. Nobody named there has been sued, charged or accused of anything in any filed complaint, and a section 512(h) subpoena adjudicates nothing. Redactions disclosed: we removed the GitHub repository URL from the quoted takedown notice, and we are not republishing the personal contact details of a third-party vendor employee in an exhibit to the X Corp. filing. Not a lawsuit, and withdrawn is not denied: all four proceedings are ex parte identity-disclosure applications with no defendant and no complaint. Granted means the clerk will issue the subpoena and nothing beyond it. The Google matter closed on Take-Two's own withdrawal with an express reservation of the right to refile, and no court has ruled on the merits of any of the four. Explicitly not claimed: that any provider has produced anything, that any individual has been identified, or that litigation will follow. Explicitly not speculated on: the identity behind any persona in these filings, and the contents of the sealed Discord schedule. Anti-conflation: the Motion Picture Association's separate Discord subpoena in the Northern District of California is a different matter and Take-Two is not a party to it. Method limits printed as limits: RECAP mirrors PACER and lags, and the 31 August Discord order was read visually from a scanned image rather than extracted as text. Our ledger of what is established about this game, as opposed to what is circulating, is on the wiki, and the rest of today's filings coverage is on the news desk. If you would rather spend the next 79 days playing than reading court records, the servers list and the leaderboards are open.