Several weeks have now passed since the news was published, just before the Champions League semi-final, that the streaming platform livetv.sx had been blocked following a court ruling. While this block cannot ultimately prevent such platforms from emerging repeatedly, it was a significant measure at that time.

Germany’s largest illegal sports streaming platform, livetv.sx, was no longer reachable through German internet connections. The block followed a decision of the Cologne Regional Court, secured by DAZN and the DFL (German Football League) through CUII, Germany’s industry clearing house for internet piracy. However, within days, reports emerged that the site had resurfaced under an alternative domain, serving as a reminder of the limitations of DNS blocking.

Nevertheless, the case is a useful snapshot of where German site-blocking practice now stands: the legal test is well established, but the procedural route has just changed, and the technical limits of DNS blocking are more visible than ever.

Background: a well-known and costly problem

DAZN and the DFL describe livetv.sx as the largest illegal sports streaming platform in Germany, active for many years and offering free access to football and other sport that would otherwise sit behind a paywall on services such as DAZN or Sky. The site reportedly relied on uncooperative hosting providers and domain registrars to withstand earlier enforcement attempts.

The stakes for rights holders are considerable. The DFL’s national Bundesliga media rights alone are reported to bring in around €1.1 billion per season through to 2029, and the number of people in Germany who use illegal sports streams may be in the millions each year. Piracy at that scale is a direct threat to the value of those rights.

Against that backdrop, it’s unsurprising that DAZN and the DFL have made blocking a central plank of their enforcement strategy, and that they went after livetv.sx specifically ahead of a major fixture. The block took effect just before the Champions League semi-final match between FC Bayern München and Paris Saint-Germain in which DAZN held exclusive German rights.

The CUII mechanism — and why this went to court

CUII (Clearingstelle Urheberrecht im Internet, “Clearing Body for Copyright on the Internet”) is a voluntary self-regulatory body set up in 2021 by German internet access providers and rights holders, including the DFL, Sky, the Motion Picture Association and the German music industry association. Its job is to coordinate the blocking of “structurally copyright-infringing websites”, meaning sites whose business model is built on mass, deliberate infringement.

Until mid-2025, CUII operated an internal review process: a rights holder would apply, a three-person independent panel (chaired by a retired judge of the Federal Court of Justice) would examine the application. If the panel agreed unanimously it would recommend a DNS block. Germany’s telecoms regulator, the Bundesnetzagentur (BNetzA), would then check the recommendation against EU net neutrality rules before participating Internet Service Providers (ISP) implemented the block. No court was involved at that stage.

That process changed on 1 July 2025, when CUII introduced a revised code of conduct. The trigger was BNetzA telling CUII it needed to focus on its core statutory duties, including its role under the EU Digital Services Act, and could no longer resource the oversight role it had played. The change followed sustained criticism of the old system, including reporting that some blocks had been left in place after the underlying sites had gone offline, and that some of the underlying court rulings CUII relied on were default judgments issued because the ISP defendant simply didn’t appear.

Under the new “Code 2.0”, CUII no longer makes its own blocking recommendation. Instead, a rights holder must obtain a court decision confirming that a site is structurally infringing and that blocking is appropriate. In practice court action is brought against one CUII-member ISP at a time, on a rotating basis. Once that judgment exists, CUII coordinates its implementation across all participating access providers, without each of them having to be sued separately.

This is exactly the route DAZN and the DFL used against livetv.sx. The underlying judgment was handed down by the Cologne Regional Court on 22 April 2026 (case reference 14 O 68/26), and the resulting DNS block was rolled out via CUII in early May 2026. The case therefore illustrates the new model in action: judicial confirmation first, CUII-coordinated implementation second.

The legal basis for blocking orders

German law allows rights holders to seek blocking measures against access providers under Section 8 of the Digital Services Act implementation law (Digitale-Dienste-Gesetz, DDG). This sits within a broader European framework, most notably the Court of Justice’s 2014 ruling in UPC Telekabel Wien (C-314/12), which confirmed that access providers can be required to block infringing websites even without a direct contractual relationship with the infringer, provided the measure is proportionate and doesn’t unduly restrict lawful internet use.

German courts, including the Federal Court of Justice (BGH), have developed this into a structured test, historically discussed under the “Störerhaftung” (interferer liability) line of case law, most notably the BGH's 2015 decision on access-provider liability (26 November 2015 – I ZR 174/14, GRUR 2016, 268). The more directly relevant modern authority, and the one CUII’s position relies on for this case, is the BGH’s 2022 “DNS-Sperre” decision (13 October 2022 – I ZR 111/21, GRUR 2022, 1812), which confirms that an access provider can be required to implement a DNS block once a work has been made available without authorization via a service the provider connects its users to.

Blocking against an access provider is treated as a last resort under this line of case law. Rights holders are generally expected to show that reasonable efforts against the site operator and its hosting provider have failed, or that such efforts plainly offer no prospect of success. Only then does a blocking claim against the access provider arise. CUII’s own procedural rules build in the same subsidiarity requirement, and CUII’s statement regarding this case confirms that the requirement was treated as satisfied here.

Courts must also be satisfied that the site in question is genuinely “structurally” infringing, i.e. that unlawful content dominates its offering. CUII’s statement about the livetv.sx case puts this on a precise footing: a quantitative and qualitative analysis of a representative sample found that between 85.28% and 96.72% of the site’s relevant content was unlawful, at a stated confidence level of 95.5%. On that basis, the Cologne court found the block both reasonable and proportionate.

How a DNS block actually works

For a non-technical reader, it helps to separate the three main ways a site can be blocked.

A DNS block targets the “phonebook” step of browsing. When you type a web address, your device asks a DNS server to translate it into the numerical IP address of the site’s server. An ISP-level DNS block simply makes the ISP’s own DNS servers refuse to answer, or redirect the query elsewhere — often to a CUII information page. The website itself is untouched; only the lookup, via that particular ISP’s DNS service, is blocked.

An IP block goes a step further, blocking traffic to the site’s actual server address regardless of how a user found it. A URL block is more granular still, targeting specific web addresses or pages rather than an entire domain or server. DNS blocking is the method CUII and German courts have generally required, partly because it is easier for participating ISPs to implement uniformly and partly because it is seen as a comparatively light-touch measure.

Why DNS blocking has real limits

The livetv.sx case illustrates both sides of this coin.

Technically, a DNS block only affects users who rely on their ISP’s default DNS service. It does nothing to stop anyone using:

• a different public DNS resolver (such as those offered by major tech companies);

• encrypted DNS protocols like DNS-over-HTTPS or DNS-over-TLS, now built into many browsers by default;

• a VPN, which reroutes traffic through a server outside Germany entirely; or

• the site’s raw IP address directly, bypassing the domain name lookup altogether.

Even DAZN and the DFL have acknowledged, in their own public statements, that the block can be circumvented fairly easily with a VPN. More strikingly, it quickly became apparent that livetv.sx had already become reachable again under a different domain within days of the block taking effect. This reaction is known as the “whack-a-mole” problem, where operators simply stand up a mirror site faster than rights holders can pursue a fresh blocking order against it.

Legally, this circumvention problem feeds directly into the proportionality debate. Critics have long argued that a measure so easily defeated struggles to meet the threshold of being genuinely “effective” and “proportionate”, and that the burden it places on ISPs, who must build, maintain and monitor blocking infrastructure for sites with no lawful connection to their service, needs to be weighed against real-world impact. There are also live freedom-of-information concerns. Overblocking (blocking sites that are not infringing, or continuing to block sites after they cease infringing) has been a recurring criticism of the CUII system, and was itself part of the reason BNetzA pushed for the shift to judicial oversight in the first place.

Rights holders’ counter-argument, echoed in DAZN and the DFL’s own statements, is that blocking still has a meaningful impact: according to CUII's own data, visits to targeted sites have dropped by up to 80% across the sites it has handled since 2021. On that view, the fact that a determined minority of users can circumvent a block doesn’t mean it fails for the wider audience.

Outlook: what this means in practice

For rights holders, the practical lesson is that DNS blocking remains a legitimate and available tool, but not a standalone solution. A few implications stand out:

• Expect to go to court, not just to CUII. Since July 2025, a blocking claim needs a court decision before CUII will coordinate implementation across its ISP members. Enforcement strategies should build in the time and evidential burden of a court process, including subsidiarity evidence showing genuine attempts against the operator and host first.

• Move fast on mirrors. Given how quickly livetv.sx reportedly reappeared under a new domain, a blocking strategy built around a single judgment against a single domain will likely need follow-up action, and ideally a mechanism for extending blocks to newly identified mirror domains without restarting the whole process from scratch.

• Treat blocking as one layer. The DFL and DAZN have signalled further legal steps against related domains and operators. Blocking sits alongside, not instead of, hosting and registrar takedown requests, payment processor pressure, and law enforcement referrals for the more serious criminal infrastructure behind these platforms.

For ISPs and their advisors, the shift to judicial oversight brings welcome clarity on process, but also puts a premium on how blocking claims are litigated. Given past criticism of default judgments obtained with no ISP appearing to contest them, providers should expect closer scrutiny from courts, regulators and civil society of how rigorously the underlying test is actually applied, not just whether a judgment technically exists.