Does Anyone Still Care About NFTs? (Yuga Labs, LLC v. Ripps) — Guest Blog Post
By Guest Blogger Tyler Ochoa
Four years ago, NFTs were the hottest collectibles on the market and were being touted as the NBT (Next Big Thing). People were paying tens of thousands, or in some cases millions, of dollars (or the equivalent in highly volatile crypto-currencies) to have some bytes of digital code added to a blockchain — essentially, a permanent digital ledger. What did it get them? At best, the contract accompanying an NFT sometimes gives the buyer an ownership interest in or a license to use some piece of digital art (that could easily, if not always lawfully, be replicated by others for free). At worst, it gives the buyer, well, NFT — Not a F***ing Thing.
It was a speculative bubble that had to burst, and it did. In 2022, the NFT market fell more than 90% from its peak sales volume. The vast majority of all NFTs are now essentially worthless.
Anytime people are making or losing large amounts of money, lawsuits are inevitable. But law moves very slowly. Last week, we got the first published (precedential) appellate opinion in a federal lawsuit concerning NFTs: Yuga Labs, LLC v. Ryder Ripps, No. 24-879, 2025 WL 2056060 (9th Cir. July 23, 2025).
As I explained in my article Non-Fungible Tokens (NFTs) and Copyright Law, there is nothing in U.S. copyright law that prevents someone from minting and selling an NFT that links to a work of art that they did not create and do not own. That is essentially what happened here, which is why the plaintiff had to resort to trademark law instead.
The Facts
Ryder Ripps, a self-described conceptual artist, began criticizing Yuga Labs for allegedly using “neo-Nazi symbolism, alt-right dog whistles, and racist imagery” in their NFTs. In May 2022, he minted and sold a parallel series of 10,000 NFTs, each pointing to the same Bored Ape digital images as their authorized counterparts. He called his collection the Ryder Ripps Bored Ape Yacht Club (RR/BAYC). The NFTs themselves did not contain any kind of disclaimer; but Ripps’s website (where they were sold) provided the following “artist’s statement”:
By purchasing this Ryder Ripps artwork in the form of an NFT, you understand that this is a new mint of BAYC imagery, re-contextualizing it for educational purposes, as protest and satirical commentary.
Ripps’s NFT collection also sold out, earning him about $1.36 million in initial sales, and about $100,000 in royalties on secondary sales. In June 2022, Yuga Labs sent a series of takedown notices, and all of Ripps’s NFTs were removed from secondary marketplaces.
Yuga Labs sued Ripps for trademark infringement, false advertising, and cybersquatting under federal law, plus eight state-law claims. Ripps counterclaimed for knowing misrepresentation of infringing activity under 17 U.S.C. § 512(f), a declaratory judgment that Yuga Labs did not own any valid copyrights, and three state-law claims. Ripps also filed an anti-SLAPP (Strategic Lawsuit Against Public Participation) motion to strike. The district court denied the motion, and the Ninth Circuit affirmed in an unpublished three-paragraph opinion.
Yuga Labs moved for summary judgment. The district court granted the motion in favor of Yuga’s trademark infringement and cybersquatting claims, and against Ripps’s defenses and counterclaims. Yuga dismissed its state-law claims and its claim for damages, and it went to trial seeking equitable remedies only (an injunction and disgorgement of profits) on its two successful claims, which the district court granted. Ripps appealed.
Trademark Law: Are NFTs “goods”?
A trademark is “any word, name, symbol, or device” that is “used by a person … to identify and distinguish his or her goods … from those manufactured or sold by others and to indicate the source of the goods.” 15 U.S.C. § 1127. (There is a similar definition for service marks for services.) The first question was whether NFTs are “goods” for purposes of trademark law. The Ninth Circuit held that they are. [Slip op. at 22] It quoted from a joint report of the U.S. Patent and Trademark Office (PTO) and the U.S. Copyright Office, which actually drew a more subtle distinction:
Trademarks perform the same functions in NFT markets as they do in other markets…. For example, trademarks can be used to indicate the source of underlying assets associated with NFTs, such as digital art…. Trademarks can also indicate the source of services, such as unique entertainment experiences or club memberships, access to which is represented by NFTs.
Non-Fungible Tokens and Intellectual Property: A Report to Congress 45 (Mar. 2024) (emphasis added).
The main counter-argument was the U.S. Supreme Court’s opinion in Dastar Corp. v. Twentieth Century Fox Film Corp., which stated that “the ‘origin’ of ‘goods’ … is the producer of the tangible product sold in the marketplace.” 539 U.S. 23, 31 (2003) (emphasis added). The Court elaborated: “as used in the Lanham Act, the phrase ‘origin of goods’ is in our view incapable of connoting the person or entity that originated the ideas or communications that ‘goods’ embody or contain.” Id. at 32. The Ninth Circuit thought those sentences were taken out of context, noting that in Dastar, the “tangible goods” were videocassettes:
[T]he Supreme Court did not adopt a bright-line rule delineating tangible and intangible goods. Rather, it recognized a distinction between the tangible good and the intangible aspects of that same good. In so doing, it concluded that “the author of any idea, concept, or communication embodied in [tangible] goods” is not afforded trademark protection separate and distinct from the protection afforded to the producer of the tangible cassette housing the author’s content.
Slip op. at 23 (emphasis in original). “Unlike the intangible content at issue in [Dastar], NFTs are not contained in or even associated with tangible goods that are sold in the marketplace…. [However,] NFTs are marketed and actively traded in commerce … in online marketplaces specifically curated for NFTs.” [Slip. op. at 24] “Thus, we conclude that Yuga’s NFTs are ‘goods’ under the Lanham Act.” [Slip op. at 25]
Trademark Law: Validity
Assuming NFTs are goods, there was no credible argument that the Bored Ape Yacht Club marks were invalid. The marks are inherently distinctive (arbitrary) for NFTs; and even if the marks were considered descriptive (the artwork depicts “bored apes” after all), there is little doubt that the marks have acquired distinctiveness, or secondary meaning, from their use to identify and distinguish these NFTs (and associated entertainment services) from others in the marketplace. And it was uncontested that BAYC was the first to use the marks in commerce. Ripps did not even try to argue lack of distinctiveness or priority.
Instead, Ripps argued that the NFTs are unregistered securities that were being sold in violation of the securities laws, so they should be ineligible for trademark protection. The Ninth Circuit rejected the argument: “we conclude that there is an insufficient nexus between Yuga’s alleged securities violation and its use of the BAYC Marks in commerce to warrant withholding trademark protection.” [Slip op. at 28]
Next, Ripps argued that Yuga lost its trademark rights when it sold the Bored Apes to buyers. Selling a mark by itself, without an accompanying business (or at least the “goodwill” of the business) is an invalid “assignment in gross.” The court noted that Yuga’s terms and conditions “undoubtedly gave buyers … an unlimited, royalty-free right to use its associated artwork (i.e., the Bored Ape image).” [Slip op. at 29-30] “But the BAYC Marks are distinct from the artwork, and the T&Cs are silent as to trademark rights.” [Slip op. at 30]
Because the T&Cs did not grant any trademark licenses, the court also rejected Ripps’s argument that Yuga had “abandoned” its trademark rights through so-called “naked licensing,” granting a license while failing to exercise quality control over the licensee. [Slip. op. at 31]
Ripps also argued that Yuga had abandoned its trademark rights by “failing to adequately police ‘unlicensed, commercial uses of the asserted marks.’” [Slip op. at 32] Despite trademark owners’ commonly expressed fears, this defense almost never works, and it didn’t work here. “Yuga did police its marks by sending takedown notices for unlicensed uses of its trademarks to NFT marketplaces.” [Slip op. at 33]
Trademark Law: Infringement
Trademark infringement requires a showing that the defendant’s use has caused a likelihood of confusion among an appreciable number of reasonably prudent consumers. This usually is analyzed using a multi-factor test (in the Ninth Circuit, the eight Sleekcraft factors). But where a defendant alleges a nominative fair use (where the use lawfully refers to the trademark owner or the trademark owner’s goods or services), the Ninth Circuit instead applies the three-factor test that originated in New Kids on the Block v. News America Pub. Co., 971 F.2d 302 (9th Cir. 1992), and was applied in Toyota Motor Sales U.S.A., Inc. v. Tabari, 610 F.3d 1171 (9th Cir. 2010). “A common example is where one ‘deliberately uses another’s trademark or trade dress for the purposes of comparison, criticism, or point of reference.’” [Slip op. at 34 (citation omitted)]
Ripps claimed he made a nominative fair use of the BAYC marks. But in Jack Daniel’s Properties, Inc. v. VIP Prods. LLC, 599 U.S. 140 (2023) (the Bad Spaniels case), the Supreme Court held that there was no First Amendment defense to trademark infringement “when the accused infringer has used a trademark to designate the source of its own goods — in other words, has used a trademark as a trademark.” The Ninth Circuit held that the same was true when the defendant is claiming a nominative fair use:
If Ripps had solely depicted the BAYC Marks in the context of critiquing the Bored Ape images as racist, that may have been nominative fair use. But Defendants went well beyond criticism: they used the BAYC Marks to create, promote, and sell their own NFTs associated with the same artwork as Yuga’s NFT collection.
[Slip op. at 36 (emphasis in original)] For the same reason, Ripps had no First Amendment or expressive use defense. Ripps tried to argue that his “constant criticism and public protest of the Bored Ape Images’ racism and the business practices associated with the Bored Ape NFT collection was intended to undermine Yuga’s good will, not to trade on it.” [Slip op. at 40 (emphasis in original)] But the court rejected any “intent” inquiry in determining whether defendants were making a trademark use of the mark. Thus, it held the proper analysis was the eight-factor Sleekcraft test:
- Strength of the Mark. The Bored Ape marks are conceptually strong because they are arbitrary: “There is no obvious conceptual link between NFTs and Apes, Bored Apes, or Yacht Clubs.” [Slip op. at 44]
- (2) Relatedness of the Goods. The court acknowledged that “it would be reductive to suggest that all NFTs are the same and be done.” [Slip op. at 45] But here, “the two products are nearly identical,” because both sets of NFTs link “to the exact same Bored Ape images and corresponding Ape ID numbers.” [Slip op. at 46]
- (3) Similarity of the Marks. Although there were obvious similarities, defendants almost always used “RR” as a prefix when using the BAYC marks, which pointed to Ryder Ripps at the origin of the defendants’ NFTs. “Despite the similarities between the marks at issue, the differences discussed above are sufficient for a reasonable juror to conclude that these marks are not similar.” [Slip op, at 49]
- (4) Actual Confusion. Yuga presented some evidence of actual confusion, but Ripps presented evidence that users understood the difference between the two series of NFTs. Thus, this factor was neutral. [Slip op. at 49-50]
- (5) Marketing Channels. Although some secondary NFT marketplaces were the same, the primary markets were two different websites: the original bayc.com and defendants’ rrbayc.com. Giving defendants the benefit of favorable inferences, this factor “heavily favors them.” [Slip op. at 51]
- (6) Degree of Purchaser Care. “Given the nature of NFTs, their relative novelty, and that they remain a mystery to most consumers, they are inherently sophisticated goods” that “can also be expensive” and “are non-essential and virtual.” [Slip op. at 52] At the time defendants sold their NFTs (for between $100 and $200), the original Bored Apes were only available in secondary markets at highly inflated prices (up to $24 million in one case), undercutting a likelihood of confusion. [Id.] Because sophisticated purchasers are less likely to be confused, this factor also weighed in defendants’ favor.
- (7) Defendants’ Intent. “Defendants could have been fueled by dual motives. Their intent to criticize and satirize Yuga is not incompatible with an intent to confuse consumers. Indeed, these two motives necessarily may be intertwined in accomplishing Ripps’s overall artistic goal of exposing the vacuity of NFTs.” [Slip op. at 55] Resolving the relative weight of these motives was improper on summary judgment.
- (8) Likelihood of Expansion. Since the parties already compete directly, this factor was unimportant.
Overall, the court believed that there were genuine issues of material fact that made summary judgment on the issue of likelihood of confusion improper. [Slip op. at 56]
Cybersquatting
In the 1990s, Congress passed a law prohibiting cybersquatting, where “the defendant registered, trafficked in, or used a domain name … identical or confusingly similar to a protected mark owned by the plaintiff; and … the defendant acted ‘with bad faith intent to profit from that mark.’” [Slip op. at 57] Here, the contested domain names were rrbayc.com (compared to the plaintiff’s BAYC mark and bayc.com domain name) and apemarket.com (alleged to be similar to “Bored Ape”). The Ninth Circuit held it was improper to grant summary judgment to the plaintiff on this claim, because “Yuga has not established as a matter of law that these domains are ‘confusingly similar.’” [Slip op. at 59]
DMCA Counterclaim
The Digital Millennium Copyright Act created four “safe harbors” for internet service providers, three of which are conditioned on complying with a “notice-and-takedown” system for material alleged to be infringing. 17 U.S.C. § 512. Subsection 512(f) imposes liability on “[a]ny person who knowingly materially misrepresents … that material or activity is infringing” in a takedown notice, if “the service provider relying upon such misrepresentation in removing or disabling access to the material or activity claimed to be infringing.”
Here, Yuga Labs did not even attempt to allege that Ripps had infringed any copyrights. As I wrote in my article:
There are likely several reasons why Yuga Labs chose not to rely on copyright. First, it had not yet registered any copyrights in its cartoon images, a precondition to filing a lawsuit for “United States works.” See 17 U.S.C. § 411(a)…. Second, there is at least a serious legal question whether algorithmically generated images are entitled to copyright protection. See … Thaler v. Perlmutter [130 F.4th 1039 (D.C. Cir. 2025)] (affirming denial of registration to an AI-generated work “autonomously created by a computer algorithm running on a machine” without any human involvement). Third, as explained above, minting and selling NFTs of images created by others likely is not a copyright infringement under U.S. law.
40 Santa Clara High Tech. L.J. at 32 n.173.
Only three takedown notices resulted “in removing or disabling access to the material,” all of which expressly were based on trademark law, despite being labelled “Notice Under DMCA.” The court affirmed the dismissal of the section 512(f) claim: “Referencing a copyright statute to enforce trademark rights may have been sloppy, but we discern no evidence of any ‘actual knowledge of misrepresentation,’ particularly where the notices exclusively referenced trademark infringement.” [Slip op. at 62] Moreover, the court found no evidence that any service provider relied on the improper references to the DMCA. [Slip op. at 61]
Declaratory Judgment Counterclaim
Ripps also sought a declaratory judgment that Yuga did not have any valid copyrights in its Bored Apes images. The district court dismissed this claim for lack of a “case or controversy” under Article III, because Yuga had not asserted any copyright claims or even registered any copyrights. Ripps did not challenge that ruling on appeal; but he argued that the counterclaim should have been dismissed without prejudice, rather than with prejudice. The court agreed with Yuga’s argument that a dismissal with prejudice only resolved the question of whether a case or controversy existed at the time of dismissal. “[I]f [Yuga] were to successfully register a copyright and subsequently threaten litigation, the district court’s dismissal with prejudice would not bar Defendants from reasserting their declaratory-judgment claims.” [Slip op. at 63]
The court summarized its holdings:
Yuga is not entitled to prevail on its trademark-infringement and cybersquatting claims at this stage because it has not proven as a matter of law that Defendants’ RR/BAYC project is likely to cause consumer confusion in the marketplace. Yuga may ultimately prevail on these claims, but to do so it must convince a factfinder at trial. But we affirm the district court’s grant of summary judgment for Yuga on Defendants’ DMCA counterclaim and the district court’s dismissal of Defendants’ declaratory-judgment counterclaims. [Slip op. at 63]
Commentary
In the imaginary world of classical economics, where all people are rational actors, this case would settle quite easily. Now that the market for NFTs has crashed, there simply isn’t enough money at stake to justify continuing to litigate. And it’s hard to see what an injunction would accomplish; neither the buyers of Ripps’s NFTs nor any NFT marketplaces are parties to the lawsuit, so they wouldn’t be bound by any injunction. Nonetheless, in the real world, I suspect this case will be hard to settle for two reasons: first, the obvious animosity between the parties; and second, the prospect that the prevailing party may be able to recover its attorneys’ fees.
The ruling that NFTs are “goods” for purposes of trademark law establishes a precedent, but it is hard to know whether anyone still cares. Trademark defendants will be encouraged by the reversal of summary judgment on likelihood of confusion, and they will cite this case in support of their oppositions. Ultimately, however, I predict this case will be forgotten relatively quickly, just as the NFT craze itself has largely faded from memory.
For those who are still interested in NFTs, however (i.e., those who have identified themselves by reading this far), there is another NFT appeal to watch. Last October, the Second Circuit heard oral arguments in Hermès Int’l v. Rothschild, 678 F. Supp. 3d 475 (S.D.N.Y. 2023), appeal pending, No. 23-1081 (2d Cir. filed July 24 ,2023). That case involves NFTs of digital artworks that Rothschild dubbed “MetaBirkins,” because the artworks depict fictional fur-covered handbags that are similar in appearance to the registered trade dress of Hermès Birkin handbags. The district court held a trial, ostensibly using the defendant-favorable Rogers test (a test that was rejected in the Jack Daniels case under those circumstances), and the jury found Rothschild liable for trademark infringement and awarded $133,000 in damages. “While the Court instructed the jury that even the modest elements of artistic expression contained in Rothschild’s works entitled him to total First Amendment protection against Hermès’ claims unless Hermès proved that Rothschild intentionally misled consumers into believing that Hermès was backing its products, the jury had no difficulty in concluding that Hermès had so proved.” 678 F. Supp. 3d at 481.
In 2023, the Second Circuit had a median time of just over one month from oral argument to final decision. It has already been nine months since oral argument in the Hermès v. Rothschild case. That likely indicates either that the panel is having difficulty resolving the issue, or that there will be a dissenting opinion. But unless the jury instructions were materially incorrect, well beyond the possibility of harmless error, the jury’s finding of intentional misrepresentation makes it extremely unlikely that the jury verdict will be overturned.
* * *
Eric’s Comments
The entire NFT industry sketches me out. In this case, I’m unsure if Ripps’ commentary on the BAYC NFTs crossed from being an artistic statement into a hanger-on-er cash grab/grift. At the same time, I’m not a fan of alt-right dog whistles either. As a result, this is one of those cases where I want both parties to lose. In a sense, I think that’s the outcome of this opinion–it’s daring each side to spend maybe up to $1M each to get a trial that almost certainly will not produce a result worth that investment. As Prof. Ochoa indicates, this ruling should force both sides to the settlement table to avoid the trial costs. If they each decide to spend another mil on attorneys’ fees to get a trial, well, I have no sympathy for whoever loses at trial.
I had previously blogged the district court’s 512(f) ruling. The district court rejected Ripps’ 512(f) claims because BAYC’s takedown notices made trademark demands (despite expressly invoking the DMCA), not copyright demands, and therefore are outside 512(f)’s scope. I wrote in my prior post:
It’s a neat parlor trick to avoid 512(f) liability: make claims that are SO bogus that they evade the statutory scope….Apparently, a takedown notice only becomes a DMCA takedown notice when the sender adds a screaming neon label flashing “DMCA TAKEDOWN NOTICE SUBJECT TO 512(F).”
The Ninth Circuit’s response to my concern: ¯\_(ツ)_/¯
As you can tell, I was already done with this case the first time I blogged it. I have to imagine the district court judge was bummed to see that this case is coming back to his docket. 😢
Prior Posts on Section 512(f)
* Viral DRM Awarded Damages for Its 512(f) Claims, But At What Cost?
* Big YouTube Channel Gets TRO Against Being Targeted by DMCA Copyright Takedown Notices–Invisible Narratives v. Next Level Apps
* The Competition Between Temu and Shein Moves Into a Courtroom–Whaleco v. Shein
* Copyright Battles Over City Council Videos
* Record Label Sends Bogus Takedown Notice, Defeats 512(f) Claim Anyway–White v. UMG
* Plaintiffs Make Some Progress in 512(f) Cases
* 512(f) Doesn’t Restrict Competitive Gaming of Search Results–Source Capital v. Barrett Financial
* 512(f) Once Again Ensnared in an Employment Ownership Dispute–Shande v. Zoox
* Surprise! Another 512(f) Claim Fails–Bored Ape Yacht Club v. Ripps
* You’re a Fool if You Think You Can Win a 512(f) Case–Security Police and Fire Professionals v. Maritas
* 512(f) Plaintiff Must Pay $91k to the Defense–Digital Marketing v. McCandless
* Anti-Circumvention Takedowns Aren’t Covered by 512(f)–Yout v. RIAA
* 11th Circuit UPHOLDS a 512(f) Plaintiff Win on Appeal–Alper Automotive v. Day to Day Imports
* Court Mistakenly Thinks Copyright Owners Have a Duty to Police Infringement–Sunny Factory v. Chen
* Another 512(f) Claim Fails–Moonbug v. Babybus
* A 512(f) Plaintiff Wins at Trial! 
* Satirical Depiction in YouTube Video Gets Rough Treatment in Court
* 512(f) Preempts Tortious Interference Claim–Copy Me That v. This Old Gal
* 512(f) Claim Against Robo-Notice Sender Can Proceed–Enttech v. Okularity
* Copyright Plaintiffs Can’t Figure Out What Copyrights They Own, Court Says ¯\_(ツ)_/¯
* A 512(f) Case Leads to a Rare Damages Award (on a Default Judgment)–California Beach v. Du
* 512(f) Claim Survives Motion to Dismiss–Brandyn Love v. Nuclear Blast America
* 512(f) Claim Fails in the 11th Circuit–Johnson v. New Destiny Christian Center
* Court Orders Rightsowner to Withdraw DMCA Takedown Notices Sent to Amazon–Beyond Blond v. Heldman
* Another 512(f) Claim Fails–Ningbo Mizhihe v Doe
* Video Excerpts Qualify as Fair Use (and Another 512(f) Claim Fails)–Hughes v. Benjamin
* How Have Section 512(f) Cases Fared Since 2017? (Spoiler: Not Well)
* Another Section 512(f) Case Fails–ISE v. Longarzo
* Another 512(f) Case Fails–Handshoe v. Perret
* A DMCA Section 512(f) Case Survives Dismissal–ISE v. Longarzo
* DMCA’s Unhelpful 512(f) Preempts Helpful State Law Claims–Stevens v. Vodka and Milk
* Section 512(f) Complaint Survives Motion to Dismiss–Johnson v. New Destiny Church
* ‘Reaction’ Video Protected By Fair Use–Hosseinzadeh v. Klein
* 9th Circuit Sides With Fair Use in Dancing Baby Takedown Case–Lenz v. Universal
* Two 512(f) Rulings Where The Litigants Dispute Copyright Ownership
* It Takes a Default Judgment to Win a 17 USC 512(f) Case–Automattic v. Steiner
* Vague Takedown Notice Targeting Facebook Page Results in Possible Liability–CrossFit v. Alvies
* Another 512(f) Claim Fails–Tuteur v. Crosley-Corcoran
* 17 USC 512(f) Is Dead–Lenz v. Universal Music
* 512(f) Plaintiff Can’t Get Discovery to Back Up His Allegations of Bogus Takedowns–Ouellette v. Viacom
* Updates on Transborder Copyright Enforcement Over “Grandma Got Run Over by a Reindeer”–Shropshire v. Canning
* 17 USC 512(f) Preempts State Law Claims Over Bogus Copyright Takedown Notices–Amaretto v. Ozimals
* 17 USC 512(f) Claim Against “Twilight” Studio Survives Motion to Dismiss–Smith v. Summit Entertainment
* Cease & Desist Letter to iTunes Isn’t Covered by 17 USC 512(f)–Red Rock v. UMG
* Copyright Takedown Notice Isn’t Actionable Unless There’s an Actual Takedown–Amaretto v. Ozimals
* Second Life Ordered to Stop Honoring a Copyright Owner’s Takedown Notices–Amaretto Ranch Breedables v. Ozimals
* Another Copyright Owner Sent a Defective Takedown Notice and Faced 512(f) Liability–Rosen v. HSI
* Furniture Retailer Enjoined from Sending eBay VeRO Notices–Design Furnishings v. Zen Path
* Disclosure of the Substance of Privileged Communications via Email, Blog, and Chat Results in Waiver — Lenz v. Universal
* YouTube Uploader Can’t Sue Sender of Mistaken Takedown Notice–Cabell v. Zimmerman
* Rare Ruling on Damages for Sending Bogus Copyright Takedown Notice–Lenz v. Universal
* 512(f) Claim Dismissed on Jurisdictional Grounds–Project DoD v. Federici
* Biosafe-One v. Hawks Dismissed
* Michael Savage Takedown Letter Might Violate 512(f)–Brave New Media v. Weiner
* Fair Use – It’s the Law (for what it’s worth)–Lenz v. Universal
* Copyright Owner Enjoined from Sending DMCA Takedown Notices–Biosafe-One v. Hawks
* New(ish) Report on 512 Takedown Notices
* Can 512(f) Support an Injunction? Novotny v. Chapman
* Allegedly Wrong VeRO Notice of Claimed Infringement Not Actionable–Dudnikov v. MGA Entertainment
