Intellectual Property Law

New Matter SPRING 2021, Volume 46, Number 1

Copyright News

Jo Ardalan

One LLP

SECOND CIRCUIT CLARIFIES THE STANDARD FOR REMOVAL OF COPYRIGHT MANAGEMENT INFORMATION CLAIMS

A unanimous Second Circuit Court of Appeals panel affirmed a judgment against BuzzFeed, Inc. that turned on "a relatively novel issue" concerning the interpretation of Section 1202(b)(3) of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 1202(b) (3).1 At issue was whether plaintiff Gregory Mango was required to prove that Buzzfeed knew, or had reasonable grounds to know, that removing Mango’s copyright management information ("CMI") in conjunction with a photograph it made publicly accessible would lead to third-party infringements. In holding that the DMCA does not impose such a requirement,2 the Second Circuit distinguished the Ninth Circuit’s 2018 decision in Stevens v. Corelogic, Inc.3

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