Schneider v. YouTube, LLC

CourtDistrict Court, N.D. California
DecidedJanuary 5, 2023
Docket3:20-cv-04423
StatusUnknown

This text of Schneider v. YouTube, LLC (Schneider v. YouTube, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schneider v. YouTube, LLC, (N.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 10 MARIA SCHNEIDER, et al., Case No. 20-cv-04423-JD

11 Plaintiffs, ORDER RE SUMMARY JUDGMENT v. 12

13 YOUTUBE, LLC, et al., Defendants. 14

15 16 Maria Schneider is one of three named plaintiffs in a putative copyright class action against 17 YouTube and Google (together, YouTube). Dkt. No. 99 ¶ 16. Schneider alleges in a first 18 amended complaint (FAC) that YouTube and its users infringed her copyrighted musical 19 compositions and sound recordings, and that YouTube facilitated infringement by removing 20 copyright management information (CMI) from her works in violation of the Digital Millennium 21 Copyright Act (DMCA), 17 U.S.C. § 1202(b). Dkt. No. 99 ¶¶ 112-152. 22 YouTube has asked for summary judgment on the grounds that: (1) Schneider licensed her 23 works to YouTube; (2) Schneider did not present evidence of a DMCA violation; and (3) the 24 claims are untimely. Dkt. No. 163-10. The parties’ familiarity with the record is assumed, and 25 summary judgment is granted and denied in part. 26 27 1 LEGAL STANDARD 2 Summary judgment, or more aptly judgement without a trial, may be granted under Federal 3 Rule of Civil Procedure 56 when the moving party establishes that there is no genuine issue of 4 material fact and that it is entitled to judgment as a matter of law. Yates v. Adams, No. 15-cv- 5 04912-JD, 2017 WL 783520, at *1 (N.D. Cal. Mar. 1, 2017); see also Brickman v. Fitbit, Inc., No. 6 15-cv-02077-JD, 2017 WL 6209307, at *2 (N.D. Cal. Dec. 8, 2017) (quoting Celotex Corp. v. 7 Catrett, 477 U.S. 218, 323-24 (1986)). When a party asks for summary judgement on a contested 8 factual record, the motion will be denied in short order. See FTC v. D-Link Sys., Inc., No. 17-cv- 9 00039-JD, 2018 WL 6040192, at *2 (N.D. Cal. Nov. 5, 2018). This principle is particularly 10 germane here because the parties filed a mountain of conflicting declarations and other evidence. 11 Material facts are facts that may affect the outcome of the case, and a dispute over a 12 material fact is genuine if there is sufficient evidence for a reasonable jury to return a verdict for 13 either party. Yates, 2017 WL 783520, at *1 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 14 248 (1986)). To determine if there is a genuine dispute as to any material fact, the Court will view 15 the evidence in the light most favorable to the nonmoving party and draw all justifiable inferences 16 in that party’s favor. Id. The Court will not independently “scour the record in search of a 17 genuine issue of triable fact,” and will rely on the nonmoving party to “identify with reasonable 18 particularity the evidence that precludes summary judgment.” Keenan v. Allan, 91 F.3d 1275, 19 1279 (9th Cir. 1996) (internal quotation omitted). 20 “The Court may dispose of less than the entire case and just portions of a claim or defense” 21 on a motion for summary judgment. Brickman, 2017 WL 6209307, at *2. “A principal purpose of 22 summary judgment ‘is to isolate and dispose of factually unsupported claims.’” Id. (quoting 23 Celotex, 477 U.S. at 323-24). 24 DISCUSSION 25 I. COPYRIGHT INFRINGEMENT CLAIMS 26 For a claim of direct copyright infringement, a plaintiff must demonstrate: “(1) ownership 27 of a valid copyright, and (2) copying of constituent elements of the work that are original.” Feist 1 783520, at *1. This entails proof of “causation, which is commonly referred to as the ‘volitional- 2 conduct requirement.’” VHT, Inc. v. Zillow Group, Inc., 918 F.3d 723, 731 (9th Cir. 2019) 3 (citation omitted). When, as here, the defendant operates an online website, volitional conduct 4 may be established through “evidence showing [the alleged infringer] exercised control (other than 5 by general operation of [its website]); selected any material for upload, download, transmission, or 6 storage; or instigated any copying, storage, or distribution” of copyrighted works. Id. at 732 7 (internal quotation omitted). The key concept is that “direct copyright liability for website owners 8 arises when they are actively involved in the infringement,” and not passive handlers of content 9 supplied by others. Id. (emphasis in original). 10 For a claim of contributory copyright infringement, a plaintiff “must establish that there 11 has been direct infringement by third parties” as a threshold matter. Perfect 10, Inc. v. 12 Amazon.com, Inc., 508 F.3d 1146, 1169 (9th Cir. 2007). Liability for contributory copyright 13 infringement requires proof that a defendant: “‘(1) has knowledge of another’s infringement and 14 (2) either (a) materially contributes to or (b) induces that infringement.’” VHT, 918 F.3d at 745 15 (quoting Perfect 10, Inc. v. Visa Int’l Serv. Ass’n, 494 F.3d 788,795 (9th Cir. 2007)). In the online 16 context, material contribution means the defendant “‘has actual knowledge that specific infringing 17 material is available using its system, and can take simple measures to prevent further damage to 18 copyrighted works, yet continues to provide access to infringing works.’” Id. (quoting Perfect 10, 19 Inc. v. Giganews, Inc., 847 F.3d 657, 671 (9th Cir. 2017)) (emphasis in original). “Inducement 20 liability requires evidence of ‘active steps … taken to encourage direct infringement,” such as 21 “‘advertising an infringing use or instructing how to engage in an infringing use.’” Id. (quoting 22 Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 936 (2005)). 23 For a claim of vicarious copyright infringement, a plaintiff must prove that a defendant: 24 “‘has (1) the right and ability to supervise the infringing conduct and (2) a direct financial interest 25 in the infringing activity.’” Id. at 746 (quoting Giganews, 847 F.3d at 673). A key component of 26 vicarious liability is evidence that the defendant had the practical and technical ability to identify 27 or screen out infringing material, but did not do so. Id. A failure to change operations to avoid 1 distribution of infringing content “‘is not the same as declining to exercise a right and ability’” to 2 stop direct infringement by others. Id. (quoting Amazon, 508 F.3d at 1175). 3 A. The 27 Works Not Infringed 4 The FAC alleges direct and indirect copyright infringement claims for 76 copyrighted 5 musical compositions and two sound recordings owned by Schneider. Dkt. No. 99 ¶ 60 n.7.1 6 Now that fact discovery has closed, Schneider acknowledges that there is no evidence of 7 infringement for 27 of her works. See Dkt. No. 195 at 13:20-25, 14:10-14; Dkt. No. 163-10 at 22 8 n.8 (identifying the 27 works). Consequently, summary judgment is granted in favor of YouTube 9 for those 27 works.2 10 B. The PLA License 11 A defendant licensee is not liable for copyright infringement “if the challenged use of the 12 work falls within the scope of a valid license.” Great Minds v. Office Depot, Inc., 945 F.3d 1106, 13 1109 (9th Cir. 2019). The scope of the license is a critical factor because a licensee may still be 14 liable for infringement if it acted beyond the grant of a license. See MDY Indus. v. Blizzard Ent., 15 Inc., 629 F.3d 928, 939 (9th Cir. 2010); see also Sun Microsystems, Inc. v. Microsoft Corp., 188 16 F.3d 1115, 1121 (9th Cir. 1999). In addition, a license granted without authority will not insulate 17 the licensee from an infringement claim.

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