Lenz v. Universal Music Corp. (2008 / 2015)

“Copyright holders must assess fair use before issuing takedown notices — automation is not a free pass.”

This landmark case clarified the responsibilities of copyright owners under the DMCA, especially regarding user-generated content, balancing copyright protection with free expression.

Short Description :

Stephanie Lenz uploaded a 29-second home video of her toddler dancing to Prince’s song “Let’s Go Crazy” on YouTube. Universal Music issued a DMCA takedown notice, claiming infringement. The court held that copyright owners must consider fair use in good faith before issuing takedowns. The ruling protected small creators and emphasized careful enforcement of copyright.

Facts :

Lenz’s video was non-commercial, brief, and intended as a humorous, personal clip. Universal Music, the copyright owner of Prince’s music, issued a takedown notice without evaluating whether the use qualified as fair use. Lenz argued that the DMCA requires copyright holders to consider fair use before removing content. The case highlighted conflicts between automated enforcement systems, large-scale content platforms, and individual creators’ rights.

Findings / Reasoning :

The Ninth Circuit emphasized that copyright owners cannot ignore fair use. Even automated or mass takedown procedures require a good-faith evaluation. The court held that takedown notices sent without assessing fair use could expose copyright holders to liability under the DMCA. This decision reinforced that transformative, non-commercial, or educational uses might qualify as fair use, and platforms should respect these principles when processing takedown requests.

Suggestions / Observations :

Content creators are now better protected from overreach in takedown notices. Copyright holders must implement reasonable procedures for evaluating fair use, and platforms should provide mechanisms for dispute resolution. The ruling underscores the importance of balancing copyright enforcement with freedom of expression, especially in the era of user-generated digital content.

Judgment & Date :

Court ruled that copyright holders must consider fair use before issuing takedown notices. Case remanded for further proceedings.

Date : Original filing 2008, Ninth Circuit decision 2015.