Appeals Court Gives Big Loss To Record Labels In Their Quixotic Lawsuit Against Vimeo For Lipdubs

from the let-it-go,-guys dept

The record labels basically will find no innovation that's not worth suing, and so back in 2013 they sued the online video hosting/streaming site Vimeo, in part because the site had created a popular genre of videos known as "lipdubs" where people would lip sync to a song in a video. In the fall of 2013, the district court rejected most, but not all, of the record labels' arguments about the DMCA. The labels had argued that Vimeo lost its DMCA safe harbors for a variety of reasons, including not having a reasonable repeat infringer policy (and by "reasonable" the labels claimed it had to be the same as YouTube's), red flag knowledge, and the fact that because Vimeo lets people download videos there's no safe harbor. The court rejected basically all of those arguments -- but did leave open the possibility that red flag knowledge might apply if Vimeo employees had watched some of the videos at play in the case. There was also one very problematic part of the ruling, which is that the court said that pre-1972 sound recordings do not qualify for the DMCA's safe harbors because of the weird quirk of copyright law history by which pre-1972 sound recordings are not actually covered by federal copyright law (but, instead, various state laws and common law).

It's taken quite some time, but on appeal the 2nd Circuit has finally released a ruling that trashes every single of of the record labels' arguments and sides with Vimeo across the board. That is, it upholds all of the stuff the district court had about Vimeo not losing its safe harbors and goes one step further in overturning the lower court's ruling concerning pre-1972 music. The decision was written by Judge Pierre Leval, who tends to be awesome on copyright issues.

In overturning the district court on whether or not the DMCA applies to pre-1972 recordings, the ruling is pretty clear, even going against the Copyright Office's views that argued against the DMCA covering such works.
While we unhesitatingly acknowledge the Copyright Office’s superior expertise on the Copyright Act, we cannot accept its reading of § 512(c). It is based in major part on a misreading of the statute. The Report’s main argument—that § 501(a) defines the words “infringement of copyright” as meaning infringement of the rights granted by the federal statute—misreads this provision. And as for the arguments based on canons of statutory construction, a subject not within the special expertise of the Copyright Office, we respectfully conclude that the pertinent canons were misunderstood and misapplied.
To get to this conclusion, the court just reads the actual law:
A literal and natural reading of the text of § 512(c) leads to the conclusion that its use of the phrase “infringement of copyright” does include infringement of state laws of copyright. One who has been found liable for infringement of copyright under state laws has indisputably been found “liable for infringement of copyright.” In this instance, Congress did not qualify the phrase “infringement of copyright” by adding, as it did in other circumstances, the words, “under this title.” See, e.g., § 106 (“Subject to sections 107 through 122, the owner of copyright under this title has the exclusive rights to do and to authorize any of the following . . . .); § 201(a) (“Copyright in a work protected under this title vests initially in the author or authors of the work.”). To interpret § 512(c)’s guarantee that service providers “shall not be liable . . . for infringement of copyright” to mean that they may nonetheless be liable for infringement of copyright under state laws would be, at the very least, a strained interpretation—one that could be justified only by concluding that Congress must have meant something different from what it said.

In contrast, there is every reason to believe that Congress meant exactly what it said. As explained above, what Congress intended in passing § 512(c) was to strike a compromise under which, in return for the obligation to take down infringing works promptly on receipt of notice of infringement from the owner, Internet service providers would be relieved of liability for user-posted infringements of which they were unaware, as well as of the obligation to scour matter posted on their services to ensure against copyright infringement. The purpose of the compromise was to make economically feasible the provision of valuable Internet services while expanding protections of the interests of copyright owners through the new notice-and-takedown provision. To construe § 512(c) as leaving service providers subject to liability under state copyright laws for postings by users of infringements of which the service providers were unaware would defeat the very purpose Congress sought to achieve in passing the statute. Service providers would be compelled either to incur heavy costs of monitoring every posting to be sure it did not contain infringing pre-1972 recordings, or incurring potentially crushing liabilities under state copyright laws. It is not as if pre-1972 sound recordings were sufficiently outdated as to render the potential liabilities insignificant. Some of the most popular recorded music of all time was recorded before 1972, including work of The Beatles, The Supremes, Elvis Presley, Aretha Franklin, Barbra Streisand, and Marvin Gaye.

Whether we confine our examination to the plain meaning of the text, or consider in addition the purpose the text was intended to achieve, we find no reason to doubt that § 512(c), as it states, protects service providers from all liability for infringement of copyright, and not merely from liability under the federal statute.
Later the court doubles down on the idea that pretending the DMCA's safe harbors don't apply to pre-1972 sound recordings would basically undermine the entire DMCA:
Finally, construing the safe harbor of § 512(c) as not granting protection to service providers from liability for state-law-based copyright infringements would substantially defeat the statute’s purposes. Internet service providers that allow the public to post works on their sites would either need to incur enormous expenses to monitor all postings to ensure the absence of infringing material (contravening the provision of § 512(m) excusing them from such obligation), or would incur state law-based liabilities for copyright infringement by reason of user-posted infringements of which they were unaware. The financial burdens in either case would be substantial and would likely either dissuade service providers from making large investments in the expansion of the growth and speed of the Internet (which Congress sought to encourage) or perhaps cause them to charge so much for the service as to undermine substantially the public usefulness of the service Congress undertook to promote.
On the infamous question of "red flag knowledge" the court notes that the Viacom v. YouTube case settled this a while ago. And this includes the fact that employees of Vimeo may have seen copyright-covered music on Vimeo, so the lower court was wrong to say that just because an employee watched a video, the "red flag" knowledge question could go to trial:
The mere fact that an employee of the service provider has viewed a video posted by a user (absent specific information regarding how much of the video the employee saw or the reason for which it was viewed), and that the video contains all or nearly all of a copyrighted song that is “recognizable,” would be insufficient for many reasons to make infringement obvious to an ordinary reasonable person, who is not an expert in music or the law of copyright.
This is a useful point. Over and over again we see people who support the current copyright system (or who want it expanded) insist that it's "obvious" to everyone when there's infringement happening. We've tried to explain repeatedly why that's not necessarily the case. There are all sorts of factors that make it difficult -- from the fact that the songs may be authorized to questions around fair use to a variety of other issues. So it's good to see the court make such a clear statement on this point and to overturn the lower court ruling that would have made life difficult for a number of platform companies. The court clearly understands this issue that so many copyright maximalists miss:
First, the employee’s viewing might have been brief. The fact that an employee viewed enough of a video to post a brief comment, add it to a channel (such as kitten videos) or hit the “like” button, would not show that she had ascertained that its audio track contains all or virtually all of a piece of music. Second, the insufficiency of some viewing by a service provider’s employee to prove the viewer’s awareness that a video contains all or virtually all of a song is all the more true in contemplation of the many different business purposes for which the employee might have viewed the video. The purpose of the viewing might include application of technical elements of computer expertise, classification by subject matter, sampling to detect inappropriate obscenity or bigotry, and innumerable other objectives having nothing to do with recognition of infringing music in the soundtrack. Furthermore, the fact that music is “recognizable” (which, in its dictionary definition of “capable of being recognized” would seem to apply to all music that is original and thus distinguishable from other music), or even famous (which is perhaps what the district court meant by “recognizable”), is insufficient to demonstrate that the music was in fact recognized by a hypothetical ordinary individual who has no specialized knowledge of the field of music. Some ordinary people know little or nothing of music. Lovers of one style or category of music may have no familiarity with other categories. For example, 60-year-olds, 40-year-olds, and 20-year-olds, even those who are music lovers, may know and love entirely different bodies of music, so that music intimately familiar to some may be entirely unfamiliar to others.

Furthermore, employees of service providers cannot be assumed to have expertise in the laws of copyright. Even assuming awareness that a user posting contains copyrighted music, the service provider’s employee cannot be expected to know how to distinguish, for example, between infringements and parodies that may qualify as fair use. Nor can every employee of a service provider be automatically expected to know how likely or unlikely it may be that the user who posted the material had authorization to use the copyrighted music. Even an employee who was a copyright expert cannot be expected to know when use of a copyrighted song has been licensed. Additionally, the service provider is under no legal obligation to have its employees investigate to determine the answers to these questions.
The court does allow that, during discovery, a copyright plaintiff may work to establish that employees who did view the videos were able to understand that it was infringing, but merely having employees view a video is not evidence of red flag knowledge. The court also rejects the idea -- as many copyright maximalists insist -- that this interpretation of red flag knowledge writes it out of the statute. Not so, the court points out:
This argument has no merit. While the difference between actual knowledge of infringement under § 512(c)(1)(A)(i) and red flag knowledge under § 512(c)(1)(A)(ii) may not be vast, it is nonetheless a real difference. If the facts actually known by an employee of the service provider make infringement obvious, the service provider cannot escape liability through the mechanism of the safe harbor on the ground that the person with knowledge of those facts never thought of the obvious significance of what she knew in relation to infringement. Plaintiffs further argue that this understanding of red flag knowledge reduces it to a very small category. Assuming this is so, it is of no significance. The fact that Congress was unwilling to extend the safe harbor to circumstances where the service provider did not subjectively know that the posted material infringed, but did know facts that made infringement objectively obvious, does not compel the conclusion that Congress expected this extension to cover a large number of instances. That is especially so in view of the fact that the purpose of § 512(c) was to give service providers immunity, in exchange for augmenting the arsenal of copyright owners by creating the notice and-takedown mechanism.
The court goes into detail about the different burdens that each party needs to carry in trying to establish red flag knowledge:
A significant aspect of our ruling relates to the burdens of proof on the question of the defendant’s entitlement to the safe harbor—particularly with respect to the issue of red flag knowledge. The issue is potentially confusing because of the large numbers of factual questions that can arise in connection with a claim of the safe harbor. A service provider’s entitlement to the safe harbor is properly seen as an affirmative defense, and therefore must be raised by the defendant. The defendant undoubtedly bears the burden of raising entitlement to the safe harbor and of demonstrating that it has the status of service provider, as defined, and has taken the steps necessary for eligibility. On the other hand, on the question whether the service provider should be disqualified based on the copyright owner’s accusations of misconduct—i.e., by reason of the service provider’s failure to act as the statute requires after receiving the copyright owner’s notification or otherwise acquiring actual or red flag knowledge—the burden of proof more appropriately shifts to the plaintiff. The service provider cannot reasonably be expected to prove broad negatives, providing affidavits of every person who was in its employ during the time the video was on its site, attesting that they did not know of the infringement and did not know of the innumerable facts that might make infringement obvious. And to read the statute as requiring a trial whenever the plaintiff contests the credibility of such attestations would largely destroy the benefit of the safe harbor Congress intended to create.
Finally the court is fine with the lower court rejecting the argument of "willful blindness." The court points out that the law is clear that services have no proactive duty to monitor sites for infringement, no matter how many times copyright holders insist they must. And this holds true even if they monitor for other stuff:
We see no reason why Vimeo’s voluntary undertaking to monitor videos for infringement of visual material should deprive it of the statutory privilege not to monitor for infringement of music.
The court also rejects the related claim that once Vimeo had some info suggesting some music may be infringing, it had a duty to further investigate -- and the failure to do that was willful blindness. Not so, says the court:
Section 512(c) specifies the consequences of a service provider’s knowledge of facts that might show infringement. If the service provider knows of the infringement, or learns of facts and circumstances that make infringement obvious, it must act expeditiously to take down the infringing matter, or lose the protection of the safe harbor. But we can see no reason to construe the statute as vitiating the protection of § 512(m) and requiring investigation merely because the service provider learns facts raising a suspicion of infringement (as opposed to facts making infringement obvious). Protecting service providers from the expense of monitoring was an important part of the compromise embodied in the safe harbor. Congress’s objective was to serve the public interest by encouraging Internet service providers to make expensive investments in the expansion of the speed and capacity of the Internet by relieving them of burdensome expenses and liabilities to copyright owners, while granting to the latter compensating protections in the service providers’ takedown obligations. If service providers were compelled constantly to take stock of all information their employees may have acquired that might suggest the presence of infringements in user postings, and to undertake monitoring investigations whenever some level of suspicion was surpassed, these obligations would largely undo the value of § 512(m). We see no merit in this argument.
Finally, the labels had tried to argue that Vimeo employees encouraging users to create lipdubs constituted a form of willful blindness because they then refused to recognize that this encouraged infringement. The court isn't buying it:
The evidence cited to us by Plaintiffs, consisting of a handful of sporadic instances (amongst the millions of posted videos) in which Vimeo employees inappropriately encouraged users to post videos that infringed music cannot support a finding of the sort of generalized encouragement of infringement supposed by their legal theory. It therefore cannot suffice to justify stripping Vimeo completely of the protection of § 512(m).
In short, just because some employees may have encouraged lipdub videos it most certainly does not remove all of Vimeo's safe harbors.

This ruling is a complete and total victory for Vimeo against the labels -- and an important win for the safe harbors of the DMCA (and for the ability for websites that create useful services for the public to protect themselves). I'm sure the labels will try to challenge this decision, but it's a very strong and useful ruling as it stands.

Reader Comments

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  • icon
    Nate (profile), 16 Jun 2016 @ 12:02pm

    Lipsync is not the same as lipdub. They are almost the inverse in that lipsync has a person moving their lips in sync with a song, while lipdub has a new audio dubbed over the top of an existing video

    Here's a lipdub:
    https://www.youtube.com/watch?v=YjaZNYSt7o0

    Here's a lipsync:
    https://www.youtube.com/user/LipSyncBattle

    reply to this | link to this | view in chronology ]

    • identicon
      Anonymous Coward, 16 Jun 2016 @ 3:28pm

      Re:

      Sorry, but Jake Lodwick, the co-founder of Vimeo, coined the term "lip dubbing" on December 14, 2006, in a video entitled Lip Dubbing: Endless Dream. He winds up with the original song synchronized to new video.

      reply to this | link to this | view in chronology ]

      • icon
        Nate (profile), 16 Jun 2016 @ 5:49pm

        Re: Re:

        So he dubbed a song on top of another video?

        Yes, that is lipdub, just as I described.

        reply to this | link to this | view in chronology ]

        • identicon
          Anonymous Coward, 17 Jun 2016 @ 9:13am

          Re: Re: Re:

          Yeah, the easiest way to make a lipdub is to take take a lipsync replace the audio something else (doesn't really matter what, noise or even silence will do). Now you have a lipsync with the sound stripped out. Now put the original song back. Voilà! Now you have something that you can deny is a lipsync. It's called a lipdub!

          reply to this | link to this | view in chronology ]

  • icon
    That One Guy (profile), 16 Jun 2016 @ 3:32pm

    A welcome breath of fresh air

    Given how many courts seem to bend over backwards to grant anything and everything the prosecution demands the second the magic words 'Copyright infringement' are uttered, it's nice to see one actually look at the details, consider the consequences of their ruling beyond just the case at hand and rule on the side of sanity.

    Here's hoping the ruling stands and isn't overturned by a judge or judges more easily impressed by the magic words that they just accept any claim put forward by those uttering the words.

    reply to this | link to this | view in chronology ]

  • identicon
    Anonymous Coward, 16 Jun 2016 @ 3:36pm

    And then he cashed his check and went out for a round of golf.

    reply to this | link to this | view in chronology ]

    • identicon
      Anonymous Coward, 16 Jun 2016 @ 3:48pm

      Re:

      Check from whom?

      reply to this | link to this | view in chronology ]

      • identicon
        Anonymous Coward, 16 Jun 2016 @ 4:13pm

        Re: Re:

        pinko commie liberals. who else?

        reply to this | link to this | view in chronology ]

        • identicon
          Anonymous Coward, 16 Jun 2016 @ 4:36pm

          Re: Re: Re:

          That is some weak ass trolling son. I mean damn, I've seen shit trolls around here but that is just garbage. You could at least compare TOG to Hitler. Fucking hell, ever since we started offshoring the trolls to Russia quality has gone downhill.

          reply to this | link to this | view in chronology ]

    • icon
      That One Guy (profile), 16 Jun 2016 @ 4:09pm

      Before lobbing a stone make sure to check it can't be thrown right back at you

      Funny thing about implying that the judge had to be bribed to rule this way, it's beyond easy to turn that right around and say the same of any judge that does the opposite.

      Judge agree with the prosecution that copyright is 'easy' to spot and therefore a site should have known and was responsible? Must have been paid off.

      Judge rule that fair use doesn't apply in a case? Let's check their bank account for recent deposits shall we?

      Judge accept the idea that sites have a duty to pro-actively do the impossible, that is look for and determine infringement? Best see if they received any 'retirement' offers from the prosecution during the case.

      If you wouldn't accept the insinuation that any judge that rules one way could only have been paid to do so, then you don't get to lob those insinuations against judges that rule the other way and not expect to get called out on it.

      reply to this | link to this | view in chronology ]

    • identicon
      Anonymous Coward, 21 Jun 2016 @ 2:23am

      Re:

      Look, you get what you pay for. If you don't let the judge put it in raw when he clearly does not want to use a condom, obviously he's not going to reciprocate favorably.

      Remember that the next time you tug open your asscheeks.

      reply to this | link to this | view in chronology ]

  • identicon
    Anonymous Coward, 16 Jun 2016 @ 5:53pm

    That sound you hear is antidirt and Whatever angrily grinding their teeth.

    reply to this | link to this | view in chronology ]

  • identicon
    Pixelation, 16 Jun 2016 @ 7:52pm

    Didn't George Bush Sr. have prior art? Read my lips...

    reply to this | link to this | view in chronology ]

  • icon
    Whatever (profile), 16 Jun 2016 @ 9:00pm

    I think the judge may have erred here:

    "The mere fact that an employee of the service provider has viewed a video posted by a user (absent specific information regarding how much of the video the employee saw or the reason for which it was viewed), and that the video contains all or nearly all of a copyrighted song that is “recognizable,” would be insufficient for many reasons to make infringement obvious to an ordinary reasonable person, who is not an expert in music or the law of copyright."

    For me the judge is allowing way too much latitude here. If an employee recognizes a work as being less than 70 years old, then it's very likely that it is copyright to someone else other than the user posting it. It's one of the great benefits of a system where copyright is assigned automatically, there is little or no doubt that anything relatively recent if covered.

    Also, a title of a video (lipdub of Popular Song by Popular Artist) might also be a clue.

    Now some might say "what happens if it's been release with a CC license?". It's pretty simple: The user should just provide a link or information related to the license. It's not very complicated at all.

    So when you consider the the judge potentially made an error here by being way too generous is allowing willful blindness, then you can understand where the rest of the judgement that in no small part needs this point to work could fall down.

    Further, "Furthermore, employees of service providers cannot be assumed to have expertise in the laws of copyright. Even assuming awareness that a user posting contains copyrighted music, the service provider’s employee cannot be expected to know how to distinguish, for example, between infringements and parodies that may qualify as fair use. "

    The problem is that this logic butts up against section 230 to create an impenetrable legal wall. By this judgement, the employee is to assume that EVERYTHING is fair use (an affirmative defense) but at the same time the company allows for anonymous posting and generally will not be liable for the works being on their site. They also would likely NOT in any manner help in locating the user or provide any information that would help. It creates the perfect position for the company to encourage such videos and to profit from them while providing 100% perfect legal protection.

    My guess is that this decision will get appealed, and will get in part over turned.

    reply to this | link to this | view in chronology ]

    • icon
      Ninja (profile), 17 Jun 2016 @ 12:14pm

      Re:

      I'll leave this here

      the service provider’s employee cannot be expected to know how to distinguish, for example, between infringements and parodies that may qualify as fair use

      Fair use is a right, not a defense. And these videos are mostly fair use. If even you, a long time shill, can't tell what is infringing or not, the average worker can't be expected to tell the distinction. That's why there are courts if the copyright holder believes there's any harm.

      By this judgement, the employee is to assume that EVERYTHING is fair use

      Or rather assume they don't know the copyright status of anything and either take down when requested OR let it go to the courts to be decided. There's nothing in the article saying that Vimeo doesn't have its DMCA mechanisms and there's nothing in the DMCA saying that it cannot dispute the copyright status of something if they believe it's, say, fair use. The only way they can be liable is if they don't remove something after scoring a defeat through the courts. Have they done that? No.

      They also would likely NOT in any manner help in locating the user or provide any information that would help.

      Thankfully. They can request removal and Vimeo can deny if they believe it is some sort of fair use. Then The holder can go to courts and force the removal and it's all right. At best they can go after the individual for damages and in that case IF the judge allows for such discovery then Vimeo would have to comply. Other than that they are in the right.

      It creates the perfect position for the company to encourage such videos and to profit from them while providing 100% perfect legal protection.

      If it is fair use and I believe it is, then that's awesome!

      reply to this | link to this | view in chronology ]

      • identicon
        Anonymous Coward, 17 Jun 2016 @ 4:59pm

        Re: Re:

        "Fair use is a right, not a defense."

        Nope. Wrong again.

        Fair use is a defense you have a right to.

        reply to this | link to this | view in chronology ]

        • identicon
          Anonymous Coward, 20 Jun 2016 @ 2:22am

          Re: Re: Re:

          Sounds like someone's pissed that this was one judge the RIAA didn't pay off.

          I hear SGAE's got a few coke-snorting hookers for you to soothe your butthurt in.

          reply to this | link to this | view in chronology ]

      • icon
        Whatever (profile), 18 Jun 2016 @ 11:02am

        Re: Re:

        "Fair use is a right, not a defense. "

        Nope. Fair use is "yes, I violated his copyright, but I have fair use because...". You start by admitting that you have violated copyright, but it's acceptable for a given reason.

        "Or rather assume they don't know the copyright status of anything and either take down when requested OR let it go to the courts to be decided. "

        If you don't know something, perhaps it's better to ask?

        "Thankfully. They can request removal and Vimeo can deny if they believe it is some sort of fair use. Then The holder can go to courts and force the removal and it's all right. At best they can go after the individual for damages and in that case IF the judge allows for such discovery then Vimeo would have to comply. Other than that they are in the right."

        That is a pretty delusional view of things. They can request removal (over and over again as the same work gets reposted every day), and if Vimeo decides (not anyone else) that it seems like fair use, then it's a court fight - yet Vimeo would be in the clear because they would claim DMCA safe harbor - yet they are the ones deciding if the work is fair use? Anyway, so the rights holder goes to court (every day, as the work is reposted daily!), and the judge says "who are you suing?" The rights holder says "some anonymous poster" and Vimeo trots out the section 230 defense. So they rights holder says "okay, then we are suing Vimeo", and they trot out the DMCA safe harbor. So the judge says "get lost rights holder, you have nobody to sue here".

        The laws butt up against each other in a manner that provides 100% protection to both the poster and the company, both of whom can profit from the infringement for as long as they like.

        "If it is fair use and I believe it is, then that's awesome!"

        Does it really sound fair that rights holders can't get any true legal action on this?

        reply to this | link to this | view in chronology ]

        • identicon
          Anonymous Coward, 20 Jun 2016 @ 4:32pm

          Re: Re: Re:

          "Nope. Fair use is "yes, I violated his copyright, but I have fair use because...". You start by admitting that you have violated copyright, but it's acceptable for a given reason."

          Actually, according to 17 U.S.C. § 107, fair use is by definition, "not an infringement of copyright", so the argument is not "yes, I violated his copyright, but I have fair use because", but "No, I did not violate his copyright, because my use is fair". This is black letter law.

          Also, you refer to it as just a defense, but that is only a procedural quirk. The Ninth circuit in Lenz v. Universal Music Corp included this bit in their ruling: "Copyright holders cannot shirk their duty to consider — in good faith and prior to sending a takedown notification — whether allegedly infringing material constitutes fair use, a use which the DMCA plainly contemplates as authorized by the law. That this step imposes responsibility on copyright holders is not a reason for us to reject it.". A duty, a responsibility to make fair use considerations. Regardless as to whether or not they actually do so (my money's on no, given all the automation), this strongly suggests that fair use is a right that must be taken into account.

          There is also 17 U.S.C. § 108(f)(4) "(4) in any way affects the right of fair use as provided by section 107, or any contractual obligations assumed at any time by the library or archives when it obtained a copy or phonorecord of a work in its collections.". Also black letter law.

          In other words, because an action is fair use, it is by definition "not an infringement of copyright", and ergo is something that they have every right to do.

          reply to this | link to this | view in chronology ]


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