Perjury may or may not be the right term here, but it's definitely bad faith. EU and German legal definitions hold no weight on a US law. The repo contains no copyrighted material.
More importantly: they are not the copyright owners of the content being removed.
The DMCA doesn't magically give you the right to file "takedown requests" for circumvention devices: as stated elsewhere in this thread, they must sue in an appropriate United States venue.
This filing is absolutely in bad faith and the preparing attorney should actually face professional censure.
Perjury?
> Under penalty of perjury, we submit that the RIAA is authorized to act on behalf of its member companies on matters involving the infringement of their sound recordings, audiovisual works and images, including enforcing their copyrights and common law rights on the Internet.
Absolutely none of these things are applicable to this case.
