Lenz v. Universal Music Corp.

Universal (defendant) issued a takedown notice against Stephanie Lenz's (plaintiff) home video, using a computer algorithm to identify potentially infringing YouTube content without any explicit fair-use consideration in its guidelines, though Universal argued its automated process was the functional equivalent of a subjective fair-use analysis. Lenz sued under the DMCA, and the case reached the Ninth Circuit on the question of whether Universal's process satisfied the good-faith fair-use consideration requirement.