WEBVTT 00:00:03.637 --> 00:00:12.497 It's entertainment law update episode 180 R to believe 180 of these here we are on May 28 2020. 00:00:14.000 --> 00:00:19.600 Music. 00:00:19.934 --> 00:00:26.774 Hi everybody and welcome to another episode of Entertainment Law update from Los Angeles California I am Gordon Firemark, 00:00:27.585 --> 00:00:30.645 And from the Dallas Fort Worth Metroplex I'm Tamara Bennett. 00:00:32.765 --> 00:00:37.725 This is our podcast. Buy entertainment lawyers about entertainment law where you can 00:00:37.605 --> 00:00:45.225 Each month will you take the time to round up the notable cases news and information keep you informed and hopefully a little bit entertained, 00:00:45.716 --> 00:00:50.336 We love feedback from our audience so please if you have suggestions or input or 00:00:50.523 --> 00:00:57.183 Telling us we're wrong about something. Send us send us a voice note. You can go to entertainment law update. 00:00:57.266 --> 00:01:06.266 Dot com and use the little widget on the side of the screen or just send us an email. It's entertainment law update@Gmail. Com. Camera, 00:01:06.718 --> 00:01:09.838 How are things? Things are good. 00:01:10.634 --> 00:01:20.114 Just it's been a had a nice long Memorial Day weekend with with really great friends attended out of town wedding and just had a fun 00:01:20.366 --> 00:01:26.366 Fun weekend. How about you? Actually, we had a busy weekend. We had, 00:01:26.856 --> 00:01:36.216 We decided it was time to buy a new mattress and and oh my gosh. I have to say I saw the coolest. They had the smart bed mattress now that 00:01:36.543 --> 00:01:37.803 Measures every, 00:01:38.888 --> 00:01:48.168 Activators everywhere and just you shouldn't need an app to run your bed but oh I know. It was pretty cool. We did not buy the smart bed but. 00:01:49.731 --> 00:01:55.131 You know, it's an investment in our health and comfort. So, anyway, that was that and then and then I'll 00:01:55.520 --> 00:02:02.300 Whenever my mom's and did the Memorial Day grilling thing and had a nice time. Good to see everybody. So 00:02:02.567 --> 00:02:10.467 Fine. That sounds great. Yeah. Good good. Yeah. Well, we have a big rundown so I say we just jump right in and, 00:02:10.913 --> 00:02:24.533 And get started with the stories for the month we'll start off with a kind of an anomalous thing happening in the Supreme Court five justices recused themselves in the case of Baker versus Coats 00:02:24.733 --> 00:02:26.753 and they had to, 00:02:28.288 --> 00:02:40.408 Recuse themselves here would they hear the situation a copyright infringement coming from the second circuit having the accused infringement where the planet was suing, 00:02:40.873 --> 00:02:49.753 The parent company of penguin house burlesman notably penguin house is the publisher of books authored by five of the supreme court 00:02:49.830 --> 00:02:55.650 Justices. So those justice is all recused themselves. Leaving the court without a quarum. 00:02:55.943 --> 00:03:07.463 And thus the lower cords decision that there had been no infringement nor any commonality with with the topics covered. Anyway, so that a non-infringment ruling stands. 00:03:09.986 --> 00:03:18.026 Because the justice is recused themselves. So, nice to see that they're doing what they're supposed to do under those new ethics rules. And I. 00:03:18.593 --> 00:03:26.633 It may be somebody else can confirm it. I think I saw that there's been three cases maybe where they've not been able to take it because of recusals. 00:03:28.306 --> 00:03:36.466 Oh, in history, okay, okay. Because so many had to repeat themselves. So, this is not happened much and, 00:03:38.007 --> 00:03:41.007 Anyway, this sort of just an interesting wrinkle in in the 00:03:41.332 --> 00:03:49.672 Well it's and it's interesting for us because it's also deals with copyrights so anyway but for that so. 00:03:51.531 --> 00:03:58.051 Sticking around the the while the the DC Environs anyway. Let's talk about this Isaac. 00:03:59.696 --> 00:04:06.996 Yeah so Isaac hey Wall St was found in the US District Court in Georgia by Hayes Hayes 00:04:07.061 --> 00:04:20.981 Hey enterprises the company representing the estate of legendary soul singer Isaac hey sweet talked about this a couple of times in the past it's a suit against Donald Trump and his presidential campaign, 00:04:21.500 --> 00:04:27.320 Around the election, authorized use of the song Hold On. I'm coming at political rallies. 00:04:28.220 --> 00:04:38.540 This suit really does raise significant and interesting issues regarding copyright law, trademark law, rights of publicity, in the context of political events, 00:04:38.673 --> 00:04:46.933 And the limits that may be imposed in the blanket public performance music like I can sing that's available so. 00:04:48.156 --> 00:04:51.816 Then mister Trump I guess he would now President Trump. 00:04:52.711 --> 00:05:04.471 Begin using hold on I'm coming co written by Isaac Hayes and David Porter at rallies in 2020 under a blanket license in place at that time with broadcast music inc BMI, 00:05:05.425 --> 00:05:19.585 That generally permitted the use of the every song in the catalog at any public event as long as it was licensed but then BMI as well as the other public performance rights organizations started to allow their members to opt out of police 00:05:19.457 --> 00:05:22.577 Political licensing and that's what Hayes, 00:05:23.112 --> 00:05:34.392 The Hazel State and his co-road reporter did formally withdrawing their song from the political licensing game but Trump continue to use the song triggering the copyright refringment claim, 00:05:35.472 --> 00:05:45.192 And separately and very even more interesting to me is the fact that this case also centered around 00:05:45.510 --> 00:05:55.470 The proper execution of termination rights by the estate under section 17 USC section 203 to reclaim, 00:05:56.573 --> 00:06:02.573 The portion related to Isaac hey used to reclaim the copyright in the song from his publisher warner chapel, 00:06:03.162 --> 00:06:14.842 And whether or not those rights did who they reverted to who had the ability to exercise those rights in relationship to this lawsuit so the estate originally. 00:06:16.027 --> 00:06:21.127 Started three main legal claims against Trump which was copyright infringement 00:06:21.402 --> 00:06:34.062 False endorsement under the land of act and then Tamara's just going to put in front of this because we don't have a federal right of publicity act and that's the closest thing to it. And violation of right of publicity law under Georgia. 00:06:34.338 --> 00:06:41.358 State law. And there was a claim brought against a youth organization for hosting some of the events. 00:06:41.522 --> 00:06:45.962 In the court looked at the falls indoors argument under the lanimac, 00:06:46.905 --> 00:06:57.825 Saying that Trump's playing of the song created the false impression that Isaac Hayes or his estate endorsed Donald Trump they claimed to hold a trademark in Hays's name 00:06:58.158 --> 00:07:10.758 And argued the use of the composition in a political setting without permission would miss lead the public into assuming into assuming you'll affiliation or endorsement and the court rejected that argument calling it quote. 00:07:11.094 --> 00:07:17.754 Senseless the high will tell you I always include that argument in it. 00:07:19.169 --> 00:07:26.729 The estate never alleged that Trump or his campaign used haze name or likeness only the musical composition which 00:07:26.920 --> 00:07:36.640 I'm going to add in this case was insufficient to support a false endorsement claims. I think there could be situations where it could support it but that's just, 00:07:37.624 --> 00:07:40.324 Judge Tamara the 00:07:40.315 --> 00:07:54.535 Court said that this would be a dangerous president allowing any artist to sue over a properly licensed public performance undermining the utility of blanket licenses. The mere use of a song even at repeated public events does not. 00:07:54.512 --> 00:08:02.972 Plausibly implying endorsement without further association or explicit approval. The core also went on to dismiss the 00:08:03.172 --> 00:08:15.532 Third part the right of publicity claim under George a law again because Trump never used haze his name or image the claim failed but then let's talk about, 00:08:16.208 --> 00:08:16.928 The. 00:08:19.304 --> 00:08:26.924 Sorry this is what I do at my pages it messed up the copyright infinite claim only only because I had extra stuff to say today, 00:08:28.550 --> 00:08:31.070 In the court person 00:08:31.151 --> 00:08:42.431 The court said they can proceed on their copyright infringement claim but it was really interesting because the defense raised a couple of issues that I think if you're interested in how copyright, 00:08:43.214 --> 00:08:47.594 Notices of termination work. This was a good case to go. 00:08:47.850 --> 00:09:00.690 Take a read because the court walked through what you need to do to properly execute termination rights that they had a majority the widow plus one child qualified, 00:09:02.245 --> 00:09:11.245 So I think that was just a good read. They also made an interesting claim. I guess that haze enterprises was an improper party. So once the rights were 00:09:11.636 --> 00:09:15.516 Terminated and reclaimed from warner chapel they vested in 00:09:15.902 --> 00:09:24.542 The appropriate stash story airs under the copyright act and then those rights were assigned into haze enterprises and Indianity, 00:09:25.984 --> 00:09:34.624 And clear if there was a written assignment or not and that's what the defense was kind of hanging on and the court said under, 00:09:35.490 --> 00:09:41.190 17 USC 204 A which requires the assignment to be an assigned writing. 00:09:42.950 --> 00:09:48.710 You know what this is not for a third party to challenge that that's only between the assignee and the aspen, 00:09:49.273 --> 00:09:57.553 Oh, I know. I thought that was. So, at least for purposes of this portion of the proceeding the court said ownership 00:09:57.582 --> 00:10:04.602 What is sufficiently at Laj to proceed so the court dismissed the Boston endorsement publicity rights and the 00:10:04.622 --> 00:10:09.842 Briefly mentioned third party liability claims but again it should be 00:10:09.933 --> 00:10:22.413 Taking the next steps in litigation and possibly proceeding to trial as to they cooperate infringement claim because the public performance rights were not licensed to under the blanket license so, 00:10:23.769 --> 00:10:29.169 I think it's yeah a little bit of a road map for future cases of this sort if if they, 00:10:29.630 --> 00:10:33.290 Persist to make sure they will. Yeah, right, right. 00:10:34.239 --> 00:10:42.399 So good. Alright. Well, we have several quick cases dealing with photocopy right through those sort of cars. 00:10:42.404 --> 00:10:48.224 Quickly we've had picture three different photographers each wake up one morning to find their work wondering the internet without them. 00:10:49.243 --> 00:11:02.503 Their journeys through the court illustrate the three main hurdles that creators now face timing access and fair use defenses so the first one is a discovery rule case basically Michael Greco versus Ruthie Davis 00:11:02.523 --> 00:11:06.103 centers on a copright infringement claim that raises a 00:11:06.323 --> 00:11:09.203 Pivotal legal question when does the statue 00:11:09.222 --> 00:11:22.362 Of limitations begin to run Greco alleges that the designer Ruthie Davis and her company are a designs used his copyrighted photos of a model named Amber Rose from 2017 without his permission 00:11:22.473 --> 00:11:32.193 Davis posted the images on her website and social media but Greco didn't sue until 2021 4 years later prompting a debate over whether that claim is timebar 00:11:32.363 --> 00:11:39.123 So the key issue here is whether the claims a crew when the infringement occurs which is the injury rule or 00:11:39.281 --> 00:11:46.961 When the plane of discovers it to the discovery rule Davis are used the copper that contains no support for the discovery rule and urges the court to adopt. 00:11:47.356 --> 00:11:55.636 The injury rule. Greco defends on the on the basis of the discovery rule. Citing it's necessity in an age of hidden digital infringement. 00:11:55.845 --> 00:12:00.765 An interesting argument. Just record dismiss the case as untimely finding that greco 00:12:01.102 --> 00:12:14.122 Being an experienced photographer with a prior history of litigation should have discovered the infringement sooner but the second circuit reverse saying no the discovery rule plies equally to all planets regardless of sophistication in it. 00:12:14.122 --> 00:12:17.902 It's a binding president unless it's overturned by congress or the Supreme Court. 00:12:18.214 --> 00:12:22.634 So, in January, Davis petitioned the Supreme Court to resolve the 00:12:22.879 --> 00:12:31.399 The split to over these accrual of the case rules and to reject the discovery rule Greco opposed and the court has now acknowledged this issue. 00:12:32.691 --> 00:12:37.491 In that nearly case the one or chapel versus Neely from last year but they left it unresolved. 00:12:37.912 --> 00:12:45.712 And so if the court takes the case and and here's it next term then we may get an answer on this for once and for all we'll see, 00:12:46.924 --> 00:12:55.984 I mean I just feel like it has to be the discovery rule yeah I I think the the argument about you know the the possibility of these, 00:12:56.691 --> 00:13:05.331 Hidden digital infringements going unnoticed for years and years. You just, we have to do something to sort of address that. If there's no recourse, just because it remain hidden then, 00:13:06.692 --> 00:13:08.672 You know, it just doesn't seem right. 00:13:10.519 --> 00:13:23.959 Yeah. Okay. Well, we'll see. Oh, okay. Well, let's talk about Woodland V Hill. In this case, where the plan of photographer failed to alleged sufficient access on basis of his postings on Instagram 00:13:24.087 --> 00:13:28.387 Freelance artist Rodney Woodland sued Montero Lamar Hall. 00:13:28.586 --> 00:13:34.946 Hey little no it's a X for cooperating fringing every infringement or ledging that hill, 00:13:35.788 --> 00:13:45.028 No I think I said help properly alleging that he'll post photos on Instagram that unlawfully copied Woodlands original photographs, 00:13:46.614 --> 00:13:53.754 Woodland the planet posted these photographs between 2018 and 2021 they received minimal engagement 00:13:54.189 --> 00:14:08.169 Sounds like my Instagram page. But I'm not posting what he was posting. But in between eight and 75 likes. While hills allegedly similar post again, little Naza X. 00:14:09.006 --> 00:14:10.086 Rapper countries. 00:14:12.266 --> 00:14:18.786 Anyway, similar post in 2021 attractive, attractive, massive intention 00:14:18.882 --> 00:14:25.902 Attention the subject matter of these photographs were African American man, 00:14:26.462 --> 00:14:34.742 With no clothes on with something covering their parts. So, at first, I was thought 00:14:34.942 --> 00:14:44.062 Little Nozz x reposted the exact picture of this gentleman. No, it that he didn't copy. He didn't post his picture. It's just. 00:14:44.871 --> 00:14:46.671 Two people posing, 00:14:47.428 --> 00:15:00.748 Naked. Anyway, so there we go. Woodland claimed heal appropriated the original expression in his photos. Starting claims of copyright infringement, requesting declaratory relief accounting and unjust in Richmond 00:15:00.733 --> 00:15:13.393 But US district court for the central district of California this Woodland failed to plazably alleged that hill had access to his photos one oh 00:15:13.229 --> 00:15:18.389 Or that the images were substantially similar and protected expression. 00:15:18.981 --> 00:15:26.001 Woodland was given the opportunity to amend his filings but failed to state available claim the ninth circuit affirmed 00:15:26.075 --> 00:15:34.115 The dismissal. The appellate court ruled that simply posting photos on a public Instagram account with limited engagement 00:15:34.420 --> 00:15:44.140 Does not establish a reasonable possibility of access especially when there was no tagging or dissemination directly to Hill 00:15:44.133 --> 00:15:56.673 The court emphasize that copyright law protects only the selection and arrangement I created elements not general ideas or poses applying the extremic test for substantial similarity 00:15:56.772 --> 00:16:00.972 The court found the photos liked legally protectable similarities 00:16:01.391 --> 00:16:15.551 Are they excited vice publications first versus rule telephone the Supreme Court decision that reiterated that copyright does not extend to unoriginal or general content because woodland could not show either access 00:16:15.596 --> 00:16:24.656 Or substantial similarity the court upheld the dismissal law claims concluding there is no copyright infringement under the law and again these are 00:16:24.644 --> 00:16:28.604 Two different people in different photographs posing. 00:16:29.469 --> 00:16:40.029 And they just said no access and even I guess even if there was. It was just no substantial similarity. That access thing is the is the thing that caught my eye right off the bat and and, 00:16:41.469 --> 00:16:46.809 I would think now what was how was this disposal? Was this an after a trial? It must have been an early motion, right? 00:16:48.382 --> 00:16:54.682 It was a dismissal. So, yes, it seems to me that there might be a way to prove through forensic 00:16:54.990 --> 00:17:09.270 Computer technology logs evidence those kinds of things that little nausea's account did in fact see those images for access purposes so it seems I mean maybe there was no briefing on that issue or or I don't know, 00:17:10.159 --> 00:17:17.959 Seems like that might have been a jury question. The access part of it. So yeah, but they if you don't get to substantial similarity, then, doesn't make a difference. So, right. 00:17:18.891 --> 00:17:22.791 Kinda interesting for district court well I don't know, 00:17:23.460 --> 00:17:34.960 Judicial economy, my matters too. So, yeah. Well, the third of these photo cases is a second circuit saying that the trial court misunderstood 00:17:35.221 --> 00:17:40.681 Fair use. The case is ramenova versus amylus. Ink. 00:17:41.574 --> 00:17:47.814 Coming out of the second circuit professional photographer Jana Romanova sued amyla sinkin online publisher for 00:17:48.004 --> 00:17:56.644 Willful copyright infringement after they allegedly published one of her photos without permission credit or payment. They failed to respond to the lawsuit 00:17:56.737 --> 00:18:06.217 So she moves for summer excuse me a default judgement and instead of granting the default the district court raise the fair use defense on its own, 00:18:06.863 --> 00:18:08.763 Suicponte fair used defense. 00:18:09.822 --> 00:18:24.682 That's a exciting maybe. I don't know. That's weird. Yeah. For the court to bring up an affirmative defense. You know, so anyway, they asked for a woman over to justify why the use wasn't fair. And then eventually dismissed the complaint with prejudice. 00:18:25.058 --> 00:18:33.038 Concluding that the the it was a fair use and reasoning that it conveyed a different message and therefore qualified as transformative use under, 00:18:33.736 --> 00:18:42.916 The fairest doctrine. They said defendance article showed 10 photographs of people with pets. The article declared that it was published and continuation of the 00:18:43.152 --> 00:18:57.852 Websites semi regular series focusing on the ever increasing amount of pet photography we find online so she appeals and the second circuit reversed saying the appellate court found the disrecord had both procedurally and substantively aired. 00:18:59.202 --> 00:19:05.782 First it ruled the the fair uses a defense is an affirmative defense that must be raised and proved by the defendant not the court 00:19:06.207 --> 00:19:14.907 Especially in a case of default and the court found that the use was not transformative it republished the photo without alteration commentary or new purpose, 00:19:15.705 --> 00:19:20.205 And said the test for transformativeness turns on whether the copying of the original 00:19:20.568 --> 00:19:27.808 Communicates a message that differs from the message of the original not whether the copier separately declares such a message 00:19:27.998 --> 00:19:33.498 So because it like transformed character and valid justification it failed on the first end 00:19:33.592 --> 00:19:44.692 Critical prong of the fair used tests so they said she's entitled to the default judgement on her unchallenged claims and remanded the case with instructions to enter that judgement in her favor, 00:19:45.385 --> 00:19:53.185 And there's a key quote fair use cannot be conjured up by a court to excuse a defaulting parties infringement took, 00:19:55.009 --> 00:19:57.349 Could the appellate court because, 00:19:58.393 --> 00:20:07.033 Then why does the appellate court get to make a opinion about transformative if they're going to say district court you didn't have the authority to do this. 00:20:09.142 --> 00:20:10.642 Why didn't they just stop there? 00:20:11.043 --> 00:20:21.283 Instead of giving their own opinion on why it wasn't very used. Well, that is an interesting question, isn't it? I mean, I guess if the. I mean, it sounds got like what's you can't do it but we can. 00:20:22.797 --> 00:20:27.397 Yeah, little, yeah. On the other hand, they are allowed to, 00:20:28.335 --> 00:20:37.155 Correct a miss statement of the law of you know what is transformativeness I think so they were addressing probably something that the trial judge, 00:20:46.597 --> 00:20:49.337 We think you got that wrong put it to the jury, 00:20:50.633 --> 00:20:51.173 Not. 00:20:51.354 --> 00:21:00.294 You got it wrong. Here's why. You know, and and too bad you're dealing with it. So, we'll see. Yeah. But you know, in a default judgement situation, 00:21:01.607 --> 00:21:10.067 There is no jury you know it's it's never going to go there they're the the findings of fact all go in favor of the planet and then that's the procedural point they were making so, 00:21:11.852 --> 00:21:20.372 So the the commentary on this is you know with digital platforms making infringement easy and discovery random, 00:21:21.367 --> 00:21:32.827 And proof is complicated. So, here are these cases that show you got three gates to get through. To to bring a case. First off, if if the court decides with date of the Supreme Court sides with Davis on that case. 00:21:34.320 --> 00:21:37.480 The clock ticking from the day the photo is first, 00:21:38.723 --> 00:21:50.003 Infringed that maybe a thing so you gotta get the timing file on time you've gotta actually show there was access the opportunity to make the copy and then you know 00:21:50.067 --> 00:21:57.987 Relying on fair use is risky and and the best of cases. So, but it's a defense not a. Not a, 00:21:58.709 --> 00:22:06.929 To a sponte thing. Not for that, not for the judge to say, hey, what about this? Anyway, 00:22:07.683 --> 00:22:16.723 Let's move on. We have another case over with the ruling is the jury should be just the ones to decide about similarities. So, let's talk about 00:22:17.118 --> 00:22:23.778 Dancing with a stranger? Yeah. Yeah. So a new development in the case involving Sam Smith hit 00:22:23.969 --> 00:22:31.169 Song and dancing with a stranger just lets month the ninth circuit court of appeals reversed a summary judgement 00:22:31.441 --> 00:22:38.281 That was awarded in favor of Smith back in 2023 in 2015 Jordan Vincent and Christopher, 00:22:38.724 --> 00:22:41.664 My rend co wrote and released a song entitled 00:22:41.749 --> 00:22:52.849 Dancing with strangers. There are music publisher and party to this case is sounding color LLC and in 2019, Sam Smith road and as the artist released 00:22:52.947 --> 00:22:56.427 Pop a song that was also entitled Dancing with Strangers. 00:22:57.368 --> 00:23:07.928 There were also other songwriters, co writers. Sounding colors copyright infringement claims are based on their allegations that the Smith's song copied 00:23:08.107 --> 00:23:16.267 Their lyrics key pitch sequence melodic contour rhythm and metric placement core progressions and other musical elements. 00:23:17.703 --> 00:23:23.943 In 2023 Smith and the other defendants that are co-writers brought emotion for some rejuvenate have the case 00:23:24.095 --> 00:23:29.915 Dismissed on the basis that there's no substantial similarity between their songs chorus and melody. 00:23:30.235 --> 00:23:33.655 Versus the 2015 song owned by the plaintiffs. 00:23:33.980 --> 00:23:48.980 In asserting the summary judgment motion the district court zoned in on using the extremic test to determine where the weather there was substantial similarity in musical elements between the two songs and so when the court uses the extremic test they rely on 00:23:49.192 --> 00:23:56.612 Report reports and testimony of many experts that break down the two songs to determine any similarities in musical elements. 00:23:58.322 --> 00:24:06.302 In the Smith case several experts testified regarding the similar lyrics quote dancing with a stranger and compared the two songs in terms of 00:24:06.640 --> 00:24:13.240 The musical elements key pitch sequence of a lot of contour and metric placement as well as chord progressions, 00:24:13.697 --> 00:24:25.077 Sounding claims sounding colors main claim is that the musical elements in their 2015 song are not protected by copyright and visually as individual components but rather 00:24:25.337 --> 00:24:32.517 based on their original selection and arrangement and arrangement of all of these elements that make the ballotic phrase, 00:24:32.980 --> 00:24:35.120 There are starting that Smith. 00:24:35.438 --> 00:24:44.558 And his co-writers melodic phrase is substantially similar to the arrangement in their melody phrase the court also addressed the lyric issues 00:24:44.962 --> 00:24:53.722 Basically stated that the phrasing dancing with a stranger is unprotectable under copyright law because it's in so many different musical works. 00:24:54.001 --> 00:24:55.981 They looked at the musical elements. 00:24:57.098 --> 00:25:07.958 Again determining all these different things related pitch rhythm so on and so forth and when it came to the plane of slam that it selected an arrangement of these elements has copyright projection 00:25:08.315 --> 00:25:12.695 The district court decided that the musical elements in Sam Smith 00:25:12.915 --> 00:25:19.935 Melodic phrase did not quote share in substantial amounts the same arrangement as that from the sound in color song 00:25:20.151 --> 00:25:23.551 So Smith succeeded in his summer motion judgement. 00:25:23.942 --> 00:25:36.302 On appeal the court of appeals made a decision just a few weeks ago that a jury would actually likely find there is a substantial salon there to selection in rage of musical elements in both songs, 00:25:37.032 --> 00:25:40.152 Interesting not as to the lyric but as the musical element. 00:25:41.533 --> 00:25:49.153 Sam Smith and other defendants tried to argue that the sound and color song had only thin copyright protection which would raise the bar, 00:25:49.770 --> 00:25:52.470 And they would have to prove that the songs are identical, 00:25:53.641 --> 00:26:00.301 I don't think that's the standard. Sam Smith arguments failed in this case and instead the pill appeals court decided that the hawk 00:26:00.564 --> 00:26:08.424 So that chorus in sound and color song was uniquely selected and arranged and thus maybe protected, 00:26:09.089 --> 00:26:19.769 So it's moving forward going down that road toward jury trial which will be following and will be updating who knows if it'll go if it'll settle or what will happen on that so, 00:26:20.540 --> 00:26:24.440 Yeah. Lots of great music. Copyright cases we've got going on. 00:26:26.740 --> 00:26:27.740 And. 00:26:27.967 --> 00:26:32.407 Keeping things interesting did you know there was a restatement of copyright in the works. 00:26:33.998 --> 00:26:40.658 Okay I did not and I no but okay so let me tell you what I remember from law school. 00:26:42.046 --> 00:26:55.666 The restatement is just a restatement. It is not the authority. Right. Cuz I always remember, I mean it restament of torts. You know, so much of law school seemed to be, 00:26:56.162 --> 00:27:03.542 Right rounding crosser and the restatement of torch but yet you know it wasn't the end all to be all so so I 00:27:03.877 --> 00:27:10.117 It's a secondary source. That's right. So, what's happening around the restatement of copyright? Well, 00:27:11.501 --> 00:27:25.301 There's been this move toward a restatement going on for I think about 10 maybe a little longer than 10 years and several copyright experts professor Jane Ginsburg and Sham Balganish of Columbia Law School Peter Manella, 00:27:25.896 --> 00:27:29.196 You see Berkeley School of Law and Attorney David Nimmer from, 00:27:30.136 --> 00:27:37.156 They have formally disassociated themselves from the ALI the American Lion Institute's restatement of the copyright law. 00:27:37.554 --> 00:27:43.674 On May 12 that they sent a letter to ALI members urging the council to veto the draft. 00:27:44.882 --> 00:27:58.142 Restatement when it came up for a vote arguing that the project's unprecedented move to restate a comprehensive federal statute without treating the acted self as the black letter baseline is a threat to the institutes 00:27:58.223 --> 00:27:59.483 Scholarly credibility. 00:27:59.736 --> 00:28:12.096 Their core objection is to the methodology the restatement has proceeded they say without adequate peer review or substance to feedback from these advisors including calls to preserve 00:28:12.357 --> 00:28:20.937 Robust fair use protections that's been sideland they warn that the draft's paraphrasing of statutory text risks creating a shadow statute 00:28:21.278 --> 00:28:24.038 That diverges from what congress and acted. 00:28:24.204 --> 00:28:34.524 And confuses rather than clarifies the law for lawyers in court. This isn't merely an academic quibble about a but it's actually a fundamental breach. 00:28:34.998 --> 00:28:47.898 Of the restatement's mission to synthesize not to supplant existing law. So, the ALI council will will decide on this and if they heal heed the plea, then the vote could be delayed or defeated 00:28:48.240 --> 00:28:53.400 And that would be a rare rebuke of the project at the 11th hour but even if there were statements survives 00:28:53.821 --> 00:29:02.221 There's a lot of confusing spotlighting the delicacy of balancing statue strength against the desire to guide the judicial interpretation. The background here is that 00:29:02.436 --> 00:29:08.316 The the people who were driving the move toward the restatement in the first place are. 00:29:11.371 --> 00:29:17.051 Information wants to be free types I guess you could say that the more libertarian approach to 00:29:17.380 --> 00:29:28.840 Ownership of intellectual property and in particular connected with the tech industry which of course with the AI and and other things there there are some interests there that these folks feel are being, 00:29:29.674 --> 00:29:32.974 Disproportionately represented in the way the restatement is being 00:29:33.188 --> 00:29:41.528 Crafted so as to maybe undermine thoughts about fair use and and where the boundaries for infringement line things so, 00:29:43.609 --> 00:29:48.149 Politics at the ALI I guess you could say it's economic politics 00:29:48.564 --> 00:29:49.164 Really? 00:29:54.464 --> 00:29:58.284 Yeah, what do you think about it? So, 00:29:59.673 --> 00:30:04.053 So right as well as other other excellence sources, 00:30:05.659 --> 00:30:14.119 Yeah. But it does make you think about here are these things that in law school we learned or you could sort of rely on them and, 00:30:15.265 --> 00:30:23.065 You know to see that now that we're seeing how the sausage is made so to speak we're maybe not as thrilled about eating it or consuming it. 00:30:25.788 --> 00:30:29.388 No because it's been a long time since I've been in law school. How old are you? 00:30:30.704 --> 00:30:37.244 I always think of the restatement relating to common law not statutory law. It's 00:30:37.419 --> 00:30:38.199 Am I wrong? 00:30:41.699 --> 00:30:48.519 Well, I think there's probably, you know, property, well, that's also goes back to common law but there have been. Yeah. Yeah. So, 00:30:50.561 --> 00:30:54.921 Anyway, it'd be interesting to see what happens with the vote of the community and and, 00:30:56.162 --> 00:31:05.762 And what's next but it's sort of just took me by surprise that they're even was going to be a restatement of copyright and that it I'd never would have thought that it would be something that would be sort of. 00:31:11.707 --> 00:31:17.387 Something to to pay attention to when you're reading when you're doing research is you know you have to, 00:31:18.146 --> 00:31:20.426 Look at the source a little more carefully than we thought 00:31:20.603 --> 00:31:30.623 I guess. Yeah, while students don't forget the rest statement is a secondary source. So, whatever people that might be opinions and points of view that may or may not be 00:31:31.019 --> 00:31:38.039 Completely in line with the actual law. So, that's yeah. Interesting. Yeah. So, 00:31:39.328 --> 00:31:47.908 Mixed feelings about this next revenge porn law. The president signed into law 00:31:48.177 --> 00:31:58.557 On May 19 he signed the take it down act this is the first federal legislation in the US specifically targeting distribution of non consensual intimate images, 00:31:59.133 --> 00:32:04.113 Including AI generated deep fake pornography. Sounds great. 00:32:04.381 --> 00:32:16.921 Sounds like of the right thing and in fact the way it you know it was a sort of bipartisan bill. So the key provisions here are makes criminal it makes non consect nonconsensual content. 00:32:18.227 --> 00:32:25.307 Published a criminal. The act makes it a federal crime to publish her distribute sexually explicit images or videos of individuals without their consent, 00:32:26.005 --> 00:32:39.505 And that covers both real and AI generated content I have a little bit of a point to to make there in a second but also it puts on the social media platforms and websites a mandate that they need to remove the content 00:32:39.634 --> 00:32:44.074 This kind of content within 48 hours of a victims request, 00:32:44.928 --> 00:32:50.868 The penalties are up to 2 years in prison for publishing adult content and 3 years 00:32:51.049 --> 00:32:59.329 If the content involves minors and the FTC will be tasked within forcing the law and using its authority over, 00:33:00.390 --> 00:33:01.770 Deceptive trade practices. 00:33:02.509 --> 00:33:14.869 So the first lady played a big role in advocating for the bill aligning it with one of her initiatives on Youth Wellbeing and online safety and she was lobbying and made a lot of public appearances to garner support. 00:33:15.445 --> 00:33:19.825 And it did receive bipartisan support in the congress passing the house 409 to two 00:33:20.189 --> 00:33:31.109 And the senate was unanimous companies like Meta TikTok and Snapchat endorsed the legislation recognizing the need for clear guidelines and handling non-consensual explicit content. 00:33:32.522 --> 00:33:39.122 But there are some digital rights organizations that have expressed concerns about the overreach and suppression of lawful speech. 00:33:39.435 --> 00:33:49.735 So critics argue that the laws language might be vague and leads could lead to intended consequences like removal of legitimate content or challenges to privacy tools like encryption 00:33:50.040 --> 00:33:57.940 So also apprehensions about the use of the the potential or misuse of the law for politics purposes especially given, 00:33:58.611 --> 00:34:11.271 The current administration in its relationship with certain agencies and things like that. So, significant step forward in addressing some challenges, you know, that are that have come up in this last few decades. And especially with AI. 00:34:13.159 --> 00:34:26.659 But it it's trying to protect privacy and dignity but it also poses risks for free speech and things like that. So, the point I wanted to make was that I the case of ashcroft versus free speech coalition, 00:34:27.733 --> 00:34:34.633 Ruled the child pornography protection act unconstitutional as applied to, 00:34:35.349 --> 00:34:42.069 Fake child pornography where they weren't really kids or it wasn't a real person at all. Like cartoons and things like that. 00:34:43.388 --> 00:34:49.448 Seems to me that A. I. Generated deep fake can look to the law like that and say well it doesn't apply to us either, 00:34:50.851 --> 00:34:59.431 Although if it looks like a real person so I I just you know I do worry it's hard it's hard because I think we as, 00:34:59.952 --> 00:35:08.712 Humans we as having children you know the last thing we want is someone we love to be a victim 00:35:08.964 --> 00:35:21.984 Of something horrible like this. So, I I went back and I didn't, I just didn't remember Ashcroft. Everything about it and so, I proved it quickly. It was from 2002 hard to believe. It's been over 20 years ago. 00:35:22.863 --> 00:35:27.183 And I thought it was interesting request descented 00:35:27.419 --> 00:35:37.079 That maybe wasn't interesting but he sent it and he said in 2002 this is a rapid technology. 00:35:39.112 --> 00:35:39.832 End 00:35:39.950 --> 00:35:49.910 We're going to I'm summarizing we're going to get to the point where we can't distinguish between real versus fake and I think in 2002, 00:35:51.184 --> 00:36:00.064 It was easier to distinguish. Now, it wouldn't be easier to distinguish between a real person who was over 18, who was pretending to be under 18, but, 00:36:01.726 --> 00:36:07.606 You know some the wrong person's head attached to the wrong body maybe in 2002 that was, 00:36:08.379 --> 00:36:17.499 Not as much of an issue as it is today. So, I I did not have an opportunity to look to see if any claims have been brought yet. 00:36:18.776 --> 00:36:29.696 And I guess if it's is it a personal claim I mean if you have if you can file a take down notice I guess it is yeah and I mean it's only been in you know what 10 day effect yeah I mean, 00:36:31.568 --> 00:36:45.368 I know Texas when I was at the Texas Capitol earlier this year advocating we were had a pending AI deep fake bill on the books and it looks like it did not 00:36:45.621 --> 00:36:50.001 It passed one side but didn't never got to the other side. So, 00:36:51.743 --> 00:36:55.583 A lot of states as well are trying to, 00:36:56.640 --> 00:37:00.960 There are the fray to protect their their citizens now, 00:37:02.653 --> 00:37:05.233 Federalism. Yeah. 00:37:07.773 --> 00:37:10.153 You know, look, positive that that, 00:37:11.043 --> 00:37:13.443 The congress was almost unanimous and, 00:37:15.013 --> 00:37:28.753 And the technology industry mostly got on board but you know, yeah, I think I do worry about victim just being able to say, hey, take it down. In Allah DMCA. If there isn't a guardrail and a, 00:37:29.561 --> 00:37:36.941 A responsive way of of addressing it to say wait a minute you're wrong here you know something like that 00:37:37.258 --> 00:37:40.498 It right and like the DMCA how long is it 00:37:40.526 --> 00:37:54.386 You know, there's going to have to be some kind of response and procedures and I don't know when all that has to be implemented by. So, it'll be interesting to watch and I think it's overall positive but I do worry about 00:37:54.489 --> 00:38:02.289 Folks getting caught up in either false accusations of this stuff or expressive content that isn't, 00:38:03.176 --> 00:38:09.416 A particular person, for example, being taken down in you know, certain amount of bridgement of of free 00:38:09.729 --> 00:38:14.709 Expression rights and things like that too. So, we'll have to watch what happens. I'm sure it'll be, 00:38:15.401 --> 00:38:20.081 Years and years ahead for now we'll still be seeing challenges to this kind of if it remains okay. 00:38:22.158 --> 00:38:29.298 But now that there's a great transition into our AR corner where we have a fair lead large bit to talk about first off, 00:38:31.172 --> 00:38:33.632 Sort of striking comment from the bench. 00:38:34.170 --> 00:38:44.910 In the case against Meta this is Cadri versus Meta that's the case brought by author Sarah Silverman and Richard Cadry and others, 00:38:46.009 --> 00:38:58.549 It's closely watched infringement case and the judge in the case is Vince Chabria who expressed pointed criticism over a claim by meta that using copyrighted books to train it's, 00:38:59.329 --> 00:39:12.889 Large language model llama AI tool qualifies fair use during a hearing the judge interrupted me as legal team to say i just don't understand how that can be fair use. 00:39:14.904 --> 00:39:19.204 Oh, sorry. I love it. You don't care about judges saying things like that. 00:39:19.452 --> 00:39:31.932 Quite as black as as directly. So he he elaborate. He questioned me. How American claim for you some AI system that is quote capable of spitting out an infinite number of works that are going to compete with the original works. 00:39:32.559 --> 00:39:40.359 Provide oh compensation to the authors and he warned that this kind of a model could obliterate the market for the original works 00:39:40.787 --> 00:39:45.167 Highlighting a key factor courts have to consider in fair use that that fourth element right? 00:39:46.078 --> 00:39:57.238 For factor. His comments suggest a deep concern that the AI generate outputs could replace human created works in the marketplace and that calling that fair use might be legally untenable 00:39:57.469 --> 00:40:06.349 So, no ruling yet. He indicated the outcome might hinge on whether the planets can prove actual market harm from the AI training and output, 00:40:06.804 --> 00:40:07.764 But this 00:40:07.848 --> 00:40:21.288 Rare kind of on the bench gives authors creators and AI companies a preview of how the courts may be looking at some of these cases as they stand for and maybe some doubt on the the breadth of the fair used defense in these cases. So. 00:40:22.981 --> 00:40:30.061 We'll be watching but it could be a turning point so we'll see what happens there. Yeah. What, 00:40:31.074 --> 00:40:44.694 What about the cupright office report that by now everybody's alright so that's yeah been a lot going on the copyright office report in pre-publication part three on January of AI training was released, 00:40:45.891 --> 00:40:48.051 Feels 2 weeks ago maybe. 00:40:48.745 --> 00:41:03.085 We we've got last week here but I think it was 2 weeks ago. Middle of May. The US copyright office released a preplication version of part three of its report on quote copyright and artificial intelligence focusing on the use of copyrighted materials. 00:41:03.527 --> 00:41:12.227 And what we just talked about training, generative AI systems. It's 108 page document. I have not read all 100 in age but eight pages. 00:41:13.690 --> 00:41:19.150 But I I think I will because these these reports are so, 00:41:20.091 --> 00:41:31.431 Detailed and comprehensive but on related to AI training fair use it gives us nuanced insights into how existing copyright laws apply to emerging technologies, 00:41:32.466 --> 00:41:39.846 It actually takes a firm stands against the owners and operators of AI platforms. The chiroprite office focused on fair use. 00:41:40.175 --> 00:41:44.795 The office teams at training may be a highly transformative use, 00:41:45.487 --> 00:41:57.967 Okay but that is tempered by what the AI algorithm is being trained to provide as output. The algorithms are trained to produce similar material to copyright at works. 00:41:58.351 --> 00:42:06.211 Dis favor. I train to help with moderation. Finding and blocking profanity say it's a document you're looking at 00:42:06.219 --> 00:42:16.839 That used to be more favored. The office has adopted the theory that AI poses are real market harm which is what we just heard the judge speaking about. 00:42:17.360 --> 00:42:29.240 For licensing works for training and for creating substitutes as to the factor of the amount and substantial substance reality of the work kind of a toss up the 00:42:29.328 --> 00:42:30.048 The, 00:42:30.786 --> 00:42:40.326 Document said. The nature of the works copied especially as it pertains to more expressive works dis favors of finding a fair use. 00:42:41.526 --> 00:42:47.046 So that's interesting. So if AI trained on news articles and cyclopedia entries. 00:42:47.449 --> 00:42:54.769 Those kinds of things are less protected. Even though I think it's like ladia botanica might disagree. 00:42:56.335 --> 00:43:01.855 But what about the impact on the market that's usually factor four in the analysis on fair use, 00:43:03.410 --> 00:43:13.550 And it's saying that's a major focus though it is based on more speculative measures I need delusion do the due to the creation of art or lost licenses. 00:43:15.734 --> 00:43:18.194 You know is there going to be market delusion, 00:43:18.849 --> 00:43:26.349 I don't know is AI going to flood the market that could harm potential market for original works even if there's not direct copying, 00:43:27.374 --> 00:43:41.174 I think that's where the controversy is kind of lying is in this market delusion theory the report also argues that AI should not be compared to human learning and that AI is capable of perfectly, 00:43:41.711 --> 00:43:49.791 Replicating any content it learns. It is the machine. So, 00:43:51.095 --> 00:43:56.855 It's the report sounds to me like it's saying look we can't separate out the ingestion. 00:43:57.514 --> 00:44:04.834 Of the the data the the training from the outputs that it's all one big infringement we have to look or one 00:44:05.058 --> 00:44:18.738 Integrated infringement we have to look at because the nature of the outputs and that market dilution and and how similar is the output to the original work those are really factors that have to be considered so we're not I think the 00:44:18.687 --> 00:44:23.787 It sounds like the office is saying we can't just look at the training it's more than that, 00:44:24.566 --> 00:44:25.226 Is that? 00:44:28.786 --> 00:44:33.266 Defendance in these cases are saying, well, all we've done is train. Yeah. 00:44:33.838 --> 00:44:41.578 We can't control what how someone might use this oh are we going to have a well 00:44:41.832 --> 00:44:50.832 Video tape case here just because we create the beaterbacks I mean we created the machine that doesn't mean we're responsible. 00:44:51.500 --> 00:44:59.940 Maybe there comes into questions that the nature of the design of the machine itself did we train the machine to copy or did we train it to adapt and transform, 00:45:02.204 --> 00:45:04.844 Oh they're training the machine toppy. 00:45:09.124 --> 00:45:10.124 So 00:45:11.675 --> 00:45:18.515 Yeah, interesting. Well, this is, you know, you're damned if you do, you're damned if you don't and you know, Congress says, hey, copyright office. 00:45:19.075 --> 00:45:26.215 Give us a report. Give us a report. We need, we need, oh, register of copyrights who serves at our pleasure. 00:45:26.186 --> 00:45:28.886 Segue give us a report. 00:45:34.186 --> 00:45:37.466 Interesting that it was published as a preliminary draft rather than 00:45:37.538 --> 00:45:41.858 Here it is. I don't know what's going on there. And I wasn't able to find much about it. 00:45:42.543 --> 00:45:46.083 Hi that we all know what was going on there but anyway go ahead. 00:45:50.283 --> 00:45:56.403 The president fires your promoter the register of copyrights. No specific reason given. 00:45:57.118 --> 00:46:07.858 Also back up so I just didn't interrupt also as well the library and of congress was fired and the position I believe of librarian of Congress is the one who, 00:46:08.362 --> 00:46:15.322 Has the authority to appoint the registrator of copyrights but both received an email saying see ya. I'm sorry. Go ahead. 00:46:17.769 --> 00:46:25.749 The librarian of Congress role the the White House did come out stating reasons for the firing including that they had. 00:46:26.552 --> 00:46:37.772 Chosen DEI and and other inappropriate books to include in the library for children and anybody who's been to the library of congress knows this is not a child friendly life and it is a, 00:46:38.573 --> 00:46:43.313 It is a what's the word an archive not a lending library so. 00:46:45.073 --> 00:46:53.713 Anyway, so that was a little little preposterous and the reasoning there but ultimately, no reason given for why permater was fired. The timing of the report of course, 00:46:54.427 --> 00:47:04.087 Has to be the the nexus there in this unfavorable stance toward the AI company point of view on fair use in training and so on. So, 00:47:04.374 --> 00:47:10.854 Broader tensions between tech and the actual property community and you know just to note, 00:47:11.657 --> 00:47:20.537 The president and his connections in particular to mask but also other tech folks definitely viewed as a probable, 00:47:21.376 --> 00:47:33.496 Motivation here. So per motor has filed suit against the White House for this termination arguing congress made this law congress made this office. Congress appoints you know and, 00:47:34.109 --> 00:47:36.569 The president doesn't have the power to fire, 00:47:37.178 --> 00:47:43.778 The director of the copyright office it's position under the library of congress and that's a legislative body and so. 00:47:47.819 --> 00:47:53.819 So we'll see. We'll see. It's going to be a while. But it's troubling. I think. To 00:47:54.201 --> 00:48:08.301 To see the what has again restating the copyright never really thought much about it never really thought much about the partisan politics affecting the copyright office and the library of congress it just doesn't seem like these are partisan organization agencies, 00:48:09.315 --> 00:48:15.175 So I found this somewhat fascinating and went down a lot of, 00:48:15.744 --> 00:48:22.104 Where I know that rabbit trails but just kind of more related to the appointment of the librarian of congress. 00:48:24.422 --> 00:48:37.082 Prior to the last 2030 years it was a very political post and I had no idea yeah and often times it wasn't a librarian so I with the 00:48:37.385 --> 00:48:41.945 Library and of course who was just fired not only was she a, 00:48:43.111 --> 00:48:48.871 Yeah a library science educated person she was the 00:48:49.124 --> 00:49:00.404 I believe the first female and I know she was the first first person of color to surf in that role. But I had no idea that that was a political appointment. It never thought about it. But it clearly, 00:49:01.115 --> 00:49:08.135 Now we know when if you go back and look through history it was so political or just sort of patronage let's just find a job, 00:49:09.433 --> 00:49:14.713 Maybe that's the better term. Okay. Well, maybe that's better term. Interesting. 00:49:14.673 --> 00:49:26.433 Again Tamara's opinions nobody else's opinion just my opinion well it's not just the US that has to deal with these political questions and and fights over how to regulate these things you know, 00:49:27.033 --> 00:49:30.333 in the UK there's a big bruh ha ha going over, 00:49:31.593 --> 00:49:32.553 the government's, 00:49:34.006 --> 00:49:36.386 Move to set up some. 00:49:38.358 --> 00:49:51.618 What's the word I'm looking for is an AI regulation hundreds of leading figures from the UK's creative sectors Paul McCartney do a lipa in McAllen Royal Shakespeare company they have penned and open letter to the prime minister Kier Starmer 00:49:51.807 --> 00:49:58.707 Warning that the bill the data use and access bills proposed copyright exception for commercial AI training, 00:49:59.288 --> 00:50:03.608 Threatens the very life blood of their professions and the draft legislation would allow, 00:50:04.113 --> 00:50:12.693 AI developers to ingest protected works in less creators explicitly opt out effectively shifting the burden onto the rights holders to please usage. 00:50:13.421 --> 00:50:22.181 So opt out not opt in. Okay. So oppositions opponent to the bill urge the parliament to back an amendment requiring AI firms 00:50:22.604 --> 00:50:26.624 To disclose what works they've used and to negotiate fair licing terms. 00:50:26.916 --> 00:50:34.416 Rather than a free for all model that's just the default that endangers the UK as a creative a place for creativity 00:50:34.676 --> 00:50:42.336 so the critics resorts of course say the opt out proposal forces creators to rent back their work on unfavorable terms 00:50:42.382 --> 00:50:44.782 And they want it for a transparent framework that 00:50:44.948 --> 00:50:57.068 This disclosure so long. As of May 20, the House of Lords rejected so so the House of Commons passed at the the House of Lords has attached an amendment, 00:50:57.614 --> 00:51:09.794 That would mandate the disclosure of what materials were used in the training and so now the bill goes back to the commons where the debate continues and I don't know exactly how they arrive at a final answer in these things but. 00:51:10.595 --> 00:51:25.295 The yellow at each other a lot right yes so that's the fear or is that just TV okay it's okay yes the theater of of government is is a whole other thing I guess you could say so. 00:51:28.807 --> 00:51:36.247 I I think that's it for a rundown. Yeah, there we go. Sorry, I got distracted. And we should be more theatrical. 00:51:39.492 --> 00:51:47.472 So I thought we're going to go long but we're actually a little shorter than most reps so I guess something went right. That's okay. Yeah. Well, Wilson 00:51:47.666 --> 00:52:01.226 That does bring us to the end of this episode and I want to say thank you to all of our loyal listeners for spending your time with us. We would love it if you got in touch, gave us feedback just to tell us how we're doing, are we doing a good job? Are we doing a lousy job? 00:52:02.259 --> 00:52:07.239 What would you improve? What would you like to see as a stories or topics we're not covering that you think we should? 00:52:07.597 --> 00:52:22.057 Would love to hear from you. You can leave that for us using a voice widget over it, entertainment law, update. Com, little red flag on the side of the screen or you can Email us, entertainment law update@Gmail. Com and find us on social media 00:52:22.199 --> 00:52:25.439 As well. Tamara tell folks how to find you, 00:52:26.097 --> 00:52:38.577 Yes, you can find me at my new firm, Harper Bates. Com. You can also continue to find me at Create Protect. Com. That's where all of my historical information is housed. 00:52:38.877 --> 00:52:41.337 Social media on most sites at. 00:52:41.320 --> 00:52:49.240 Tamara Bennett T A M E R A B E N N E T T. And I'm going to ask folks so that we, 00:52:50.178 --> 00:52:55.818 Can be in the category of having lots of clicks in the case we get infringed come, 00:52:56.390 --> 00:53:00.350 One like a song wherever you listen to podcast but also, 00:53:01.197 --> 00:53:07.377 Go visit us on YouTube. Were there live edited person? If you ever wondered what Gordon and I look like. 00:53:09.551 --> 00:53:15.371 Maybe maybe not I don't know. Go check us out. We're how can people find us on YouTube Gordon? 00:53:15.475 --> 00:53:20.335 Type in the words entertainment law update or just you can search on my name G Firemark is my handle on 00:53:20.363 --> 00:53:26.543 Youtube and it's under my account. Okay. So, entertainment update. So, there you go. We're there. 00:53:26.556 --> 00:53:39.816 And from Los Angeles I'm Gordon Firemark and you can find my website@Firemark. Com there's another one at Gordon Firemark. Com Email address G Firemark@Firemark. Com and on most social media websites, 00:53:40.285 --> 00:53:45.085 G firemark and finally let's say thank you to our team of volunteer contributors, 00:53:45.533 --> 00:53:54.113 John Janiceek is our managing editor and to put in a valiant effort this week Charles Thorn Alexis Allen violet Jang Tasha Spear, 00:53:55.108 --> 00:54:07.708 Dawson Holder and Lewa Masetti all contributed to this episode and hey if you are interested in joining the fun as part of our little family of contributors reach out using that email address entertainment law update at Gmail. Com 00:54:08.129 --> 00:54:15.029 And let us know and we'll we'll try to get you into the team. So, that's going to wrap up this episode of Entertainment. 00:54:14.960 --> 00:54:43.521 Music.