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Note - And They Sayin’ It’s Because of the Internet: Applying the De Minimis Exception to Digital Sound Sampling in the Wake of VMG Salsoul, LLC v. Ciccone


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.