Lenz v. Universal Music Corp.
United States Court of Appeals for the Ninth Circuit
815 F.3d 1145 (2016)
- Written by Rose VanHofwegen, JD
Facts
Stephanie Lenz (plaintiff) uploaded a YouTube video of her children dancing to Prince’s “Let’s Go Crazy.” Universal Music Corporation (Universal) (defendant) held responsibility for enforcing Prince’s copyrights and had an assistant in its legal department review YouTube videos for infringing content on a daily basis. The assistant reviewed the video, decided it focused on the Prince song, and Universal issued a takedown notification claiming copyright infringement. Lenz sued Universal under the Digital Millennium Copyright Act (DMCA), arguing that Universal abused the DMCA’s takedown procedures by not first considering whether her video constituted a fair use. Both sides moved for summary judgment. The trial court denied both motions, reasoning that a triable issue of fact remained as to whether Universal had a subjective good-faith belief that Lenz’s video was lawful, which precluded summary judgment. The court also held that Lenz could proceed under a willful blindness theory by proving only that Universal deliberately ignored whether the video was a fair use, instead of having to show actual knowledge. Both parties appealed.
Rule of Law
Issue
Holding and Reasoning (Tallman, J.)
Concurrence/Dissent (Smith, J.)
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