The Recording Industry Association of America (RIAA) has once again come out swinging at Google, saying the company isn’t doing enough to fight copyright infringement online. But it may be that the RIAA itself is guilty of that charge.

In a blog post this week, RIAA Executive VP Brad Buckles shares what the organization calls “clear facts” about Google’s efforts to remove infringing pages from Google’s search results. A week ago, Google announced the addition of Copyright Removal Requests to its Transparency Report, but Buckles says “Google’s data misleads.”

In a series of five “facts,” the RIAA lays out what amounts to two primary complaints:

Google “places artificial limits on the number of queries that can be made by a copyright owner to identify infringements.”

Google “also limits the number of links we can ask them to remove per day.”

The RIAA says these limits keep it from finding and requesting removal of piracy-related web pages related to the Billboard Top 10 songs, let alone all pirated material on the web.

Piracy & Search Results: A Battleground

No one debates the fact that there’s a lot of piracy happening online and, a look at one query even shows how the search results have become a battleground of sorts. Consider a search for “katy perry fireworks mp3.” After Google’s 10 main search results, there are another 21 messages from Google explaining that a total of 36 pages have been removed from the page already. (In the screenshot below, the copyright removal notices take up about 1,000 vertical pixels while the search results take up about 500 pixels.)

RIAA & Limits

Ignoring the fact that the RIAA isn’t accusing Bing (where its search results for the same query seem just as bad) of not doing enough to prevent piracy, let’s look at the group’s two accusations against Google.

Query limits. Google will occasionally throttle suspicious search activity; this may happen, for example, at conferences or events where several hundred people (or more) are searching Google all from the same IP address. Google also explains that its Terms of Service don’t allow sending automated search queries without advance permission. Depending on how the RIAA is trying to find infringing material, it could be hitting the query limit and/or be in violation of Google’s TOS.

Takedown request limits. The RIAA accuses Google of limiting how many takedown requests it can send. A Google spokesperson denies that charge in a statement shared with Search Engine Land:

We have never imposed any limit on the number of DMCA notices that a copyright owner or reporting organization may send us, although we do have some technical safeguards in our trusted partner program (where submitters may be using automated mechanisms to send large volumes) as a safeguard against accidental flooding of the system.

What makes the RIAA’s claim questionable is Google’s list of most active copyright owners that have submitted removal requests. The RIAA is fifth with about 44,000 requests over the past month, but that’s less than 10 percent of the requests that Microsoft has submitted, and about one-fifth of the requests from NBC Universal.

Limit or not, it looks like the RIAA isn’t nearly as active as other organizations in asking Google to remove infringing URLs. It may believe that Google isn’t doing enough on this issue, but the numbers suggest that the RIAA can do more itself.