First Post-Viacom 512(c) Opinion Doesn’t Look Much Different–Obodai v. Demand Media

20 06 2012

By Eric Goldman

Obodai v. Demand Media, Inc., 2012 WL 2189740 (SDNY June 13, 2012)

This is the first substantive ruling I’ve seen interpreting the Second Circuit’s Viacom v. YouTube ruling. (The Viacom ruling was also discussed in the Ouellette case, but that was tangential to its main discussion). The good news is that the opinion looks pretty much like it would have looked before Viacom v. YouTube. The bad news is that the case was a layup victory against an outgunned pro se plaintiff (who is also unsuccessfully sued YouTube), so we don’t really learn much we didn’t know. The ugly news is that even at a comparatively svelte 17 pages, the opinion remains an unfortunately long read compared to brief and to-the-point Section 230 opinions.

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