§ 1202(b)
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DMCA requirements for CMI removal not always met in AI code writing

The US Court of Appeals for the Ninth Circuit affirmed the dismissal of Digital Millennium Copyright Act (DMCA) claims that alleged artificial intelligence (AI) tools removed or altered copyright management information (CMI) from the programmers’ protected works. Doe et al. v. GitHub, Inc., et al., Case No. 24-7700 (9th Cir. Sept. 16, 2026) (Thomas, Miller, Blumenfeld, JJ.)

GitHub operates a platform where developers can store, manage, and share software code. GitHub Copilot and OpenAI Codex are generative AI tools trained on millions of software projects available on GitHub. Copilot uses statistical patterns learned from its training data to generate code in response to user prompts. The plaintiffs are programmers who published copyrighted code in public GitHub repositories under open-source licenses that generally required attribution, including the author’s name and copyright notice.

The plaintiffs sued GitHub, Microsoft, and OpenAI, alleging that Copilot sometimes reproduced their code without the attribution, copyright notices, or license terms accompanying the code in the GitHub repositories. The plaintiffs asserted that these omissions violated § 1202(b) of the DMCA.

The district court dismissed the DMCA claim, reasoning that § 1202(b) required the allegedly infringing work to be identical to the original work from which the CMI had been removed. Because the plaintiffs alleged that Copilot generated near-identical, modified, or functionally equivalent versions of their code, the district court concluded that they had failed to state a claim. It certified for interlocutory appeal the question of whether § 1202(b) imposes an identicality requirement.

Removal or alteration of CMI

Section 1202(b) prohibits intentionally removing or altering CMI, and distributing works or copies of works knowing that CMI has been removed or altered without authority.

The plaintiffs argued that § 1202(b) does not require the defendant’s output to be literally identical to the copyrighted work. They contended that a literal-identicality rule would allow a defendant to evade the DMCA simply by making a trivial change to a copied work after removing its CMI – for example, changing one word on a page. The defendants, while conceding that literal identicality was not required, argued that § 1202(b) requires CMI to have been removed or altered from a copy of the plaintiff’s existing work. If Copilot instead generates a new or derivative work that never contained the plaintiff’s CMI, there is nothing from which CMI was “removed” or “altered.”

The Ninth Circuit rejected a literal identicality requirement and characterized “identicality” as a “misnomer.” The relevant inquiry is not whether the works are identical, but whether CMI was actually removed or altered from a copy of an existing protected work. Identicality may be evidence of removal where two works are otherwise identical, but the allegedly infringing version omits CMI contained in the original. Under those circumstances, a factfinder may reasonably infer that the CMI was removed. But literal identity is not required. Minor cosmetic changes will not necessarily defeat a claim where a defendant substantially or entirely reproduces an existing work and removes its CMI.

Applying that standard, the Ninth Circuit concluded that [...]

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DMCA Scienter Requirement Not Satisfied without Evidence of Knowledge of Inducement or Concealment

Interpreting a provision of the Digital Millennium Copyright Act (DMCA), 17 U.S.C. § 1202(b), for the first time, the US Court of Appeals for the Eleventh Circuit affirmed a summary judgment ruling that the plaintiff failed to satisfy the second scienter requirement of § 1202(b) by not showing that the defendant knew, or had reasonable grounds to know, that its actions would induce, enable, facilitate or conceal a copyright claim. Victor Elias Photography, LLC v. Ice Portal, Inc., Case No. 21-11892 (11th Cir. Aug. 12, 2022) (Newsom, Marcus, JJ; Covington, Distr. J.)

Victor Elias is a professional photographer who takes photographs for hotels and resorts throughout the United States, Mexico and the Caribbean. Between 2013 and 2017, Elias took pictures for Starwood Hotels & Resorts and Wyndham Hotel & Resorts. As part of his process, Elias embedded copyright management information (CMI) into the image files.

During this period and into 2018, Starwood and Wyndham contracted with Ice Portal (a division of Shiji at the time of the appeal) to process thousands of images, including 220 images taken by Elias, and make them available to online travel agents. This processing included converting the images to JPEG format, making copies in various industry-standards sizes and optimizing the files for faster display. The processing sometimes resulted in the loss of an image file’s metadata. In 2016, Elias discovered infringing online uses of his images that lacked the embedded CMI. He filed suit against Ice Portal, contending that the stripping of metadata resulted in loss of his embedded CMI, which violated two sections of the DMCA: 17 U.S.C. §§ 1202(a) and 1202(b).

Following discovery, the district found that Elias could not “satisfy the ‘second scienter requirement’ of the statute” and granted Shiji’s motion for summary judgment. Relying on the 2018 Ninth Circuit case Stevens v. Corelogic, the district court found that Elias had not established that Shiji “knew or had reason to know that its action would induce, enable, facilitate, or conceal infringement.” The court determined that Elias failed to demonstrate that the removal of CMI “is the reason, or even the likely reason, for the infringing use of the images,” or that “Shiji was even aware that searching for terms embedded in the extended attributes was a method used by copyright holders to find infringement on the internet.” Elias appealed.

Because this was a novel issue for the Eleventh Circuit, the Court interpreted § 1202(b) as an issue of first impression. After considering the plain terms of the statute and the opinions of sister circuits, the Court agreed with its sister circuits that to satisfy the scienter requirement of §1202(b), a plaintiff “must make an affirmative showing . . . [that] the defendant was aware [of] or had reasonable grounds to be aware of the probable future impact of its actions.”

Elias urged the Eleventh Circuit to adopt a standard that would only require a plaintiff to demonstrate that CMI was knowingly removed without consent and that the defendant either “knows, or has [...]

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