This Note argues that the Ninth Circuit’s approach in VMG
Salsoul should be adopted and the de minimis exception should be applied
to copyright infringement cases involving sound sampling. Additionally,
in light of the VMG Salsoul decision, this Note revisits the
Sixth Circuit’s opinion in Bridgeport and the subsequent commentary. It provides a new perspective on the Sixth Circuit’s analysis, unpacks
Judge Silverman’s dissent, and discusses the underlying policy
need to adopt the Ninth Circuit’s decision in VMG Salsoul.