Lenz v. Universal Music Corp., 801 F.3d 1126 (9th Cir. 2015), is a decision by the United States Court of Appeals for the Ninth Circuit, holding that copyright owners must consider fair use defenses and good faith activities by alleged copyright infringers before issuing takedown notices for content posted on the Internet.
Background
In February 2007, Stephanie Lenz posted on YouTube a 29-second clip of her 13-month-old son dancing to the Prince song "Let's Go Crazy". The audio was of poor quality, and the song was audible for about 20 of the 29 seconds.[1] The total length of the original song is more than four minutes. In June 2007, Universal Music Corp., the copyright holder for "Let's Go Crazy", sent YouTube a takedown notice as enabled by the Digital Millennium Copyright Act (DMCA), claiming that the video was a copyright violation built upon an unauthorized copy of the song.[1]
YouTube removed the video, and notified Lenz of the removal and the infringement accusation. Lenz in turn sent YouTube a counter-notification, claiming fair use and requesting that the video be reposted. Six weeks later, YouTube reposted the video.