Murphy v. Millennium Radio Group, LLC

Murphy (plaintiff), a photographer hired by New Jersey Monthly, took a promotional photo of two radio hosts that ran in the magazine with a photo credit to Murphy in the page's gutter; an employee of radio station WKXW, owned by Millennium Radio Group (defendants), copied the image without the photo credit and posted it on the station's website without Murphy's permission. Murphy sued under 17 U.S.C. section 1202 for removing his copyright-management information, and the defendants argued the statute, properly read together with a related provision, only protects copyright-management information conveyed as part of an automated digital management system; the district court agreed and granted the defendants summary judgment.