Maureen Harrington, et al. v. Pinterest, Inc.

Summary

The United States District Court for the Northern District of California grants Pinterest’s motion for summary judgment in a copyright infringement action concerning Pinterest notifications that linked users to images stored on Pinterest’s servers. The court holds that Pinterest’s conduct falls within the DMCA safe harbor under 17 U.S.C. § 512(c), finding that the alleged infringement occurred by reason of storage at the direction of a user and that the record lacked evidence of Pinterest’s actual or red-flag knowledge. The excerpt does not include the court’s analysis of all remaining issues or the order’s date.

Holdings

1. Pinterest established that the alleged infringement occurred by reason of storage at the direction of a user because its automatic file-format standardization, creation of image variants, algorithmic presentation, and hyperlink-based notifications were narrowly directed toward facilitating access to user-uploaded content.
2. Pinterest established that the record lacked evidence that it had actual or red-flag knowledge of the alleged infringing display.
3. Pinterest did not have the right and ability to control the alleged infringing display within the meaning of Section 512(c)(1)(B).
4. Pinterest did not receive a financial benefit directly attributable to the display of Harrington's copyrighted photograph.

Questions Presented

1. Whether Pinterest's display of Harrington's copyrighted photograph through an email notification occurred by reason of storage at the direction of a user under 17 U.S.C. § 512(c)(1).
2. Whether Pinterest lacked actual or red-flag knowledge of the alleged infringement under 17 U.S.C. § 512(c)(1)(A).
3. Whether Pinterest had the right and ability to control the alleged infringement or received a financial benefit directly attributable to it under 17 U.S.C. § 512(c)(1)(B).
4. Whether any genuine dispute of material fact precluded summary judgment on Pinterest's Section 512(c) DMCA safe-harbor defense.

Disposition

other