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Lenz v. Universal Music Corp.

United States Court of Appeals for the Ninth Circuit
801 F.3d. 1126 (2015)


Facts

Stephanie Lenz (plaintiff) uploaded a home video of her children dancing to YouTube. The video showed the children dancing to the song “Let’s Go Crazy” by Prince. Universal Music Corporation (Universal) (defendant) was responsible for enforcing Prince’s copyrights. Universal issued a takedown notification to Lenz, stating that the video constituted an infringing use of Prince’s copyright. Lenz sued Universal under the Digital Millennium Copyright Act (DMCA). Lenz argued that Universal abused the DMCA’s takedown procedures by not first considering whether her video was a fair use. Universal responded that it used a computer algorithm to search for possible copyright infringement in YouTube videos. Although none of the computer guidelines explicitly considered fair use, Universal claimed that its computer algorithm and procedures were the equivalent of a subjective consideration of fair use.

Rule of Law

Issue

Holding and Reasoning (Tallman, J.)

Concurrence/Dissent (Smith, J.)

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