Secondary Liability and Web 2.0 Businesses The potential for secondary liability is especially present with Web 2.0 service providers, which may host millions of items uploaded by individual users. The term “Web 2.0,” which is not a legal term, has been used to refer to online activities involving interactions between large numbers of users. MySpace, YouTube, and Wikipedia are examples of Web 2.0 service providers. Another example is eBay, a giant online marketplace that facilitates transactions between millions of individual buyers and sellers. In 2004, the famous jewelry store Tiffany brought suit against eBay, alleging that hundreds of thousands of items sold on eBay infringed Tiffany’s rights under the Lanham Act. Even though eBay was not itself the origin of the allegedly infringing goods, Tiffany argued that eBay should be contributorily liable for the infringement of eBay users. The court had to decide whether eBay had intentionally induced the infringement or continued to supply its services to primary infringers with knowledge of their infringing activities. TIFFANY, INC. V. EBAY, INC. 576 F. Supp. 2d 463 (S.D.N.Y. 2008), aff’d, 600 F.3d 93 (2d Cir. 2010), cert. denied, 2010 WL 3416635 (Nov. 29, 2010) RICHARD J. SULLIVAN, DISTRICT JUDGE [FACTS] Tiffany, the famous jeweler with the coveted blue boxes, brings this action against eBay, the prominent online marketplace, for the sale of counterfeit Tiffany silver jewelry on its website. Specifically, Tiffany alleges that hundreds of thousands of counterfeit silver jewelry items were offered for sale on eBay’s website from 2003 to 2006. Tiffany seeks to hold eBay liable for direct and contributory trademark infringement, unfair competition, false advertising, and direct and contributory trademark dilution, on the grounds that eBay facilitated and allowed these counterfeit items to be sold on its website…. Over its 170-year history, Tiffany has achieved great renown as a purveyor of high quality and luxury goods under the TIFFANY Marks, including jewelry, watches, and home items such as china, crystal, and clocks. The TIFFANY Marks are indisputably famous, and are a valuable asset owned by Tiffany…. eBay is a wellknown online marketplace, located at www.ebay.com, that allows eBay sellers to sell goods directly to eBay buyers. The listings are created and posted by third-party users, who register with eBay and agree to abide by a User Agreement. While users often go by descriptive user names instead of their real names, users are required to supply identifying information to eBay when registering…. [THE PARTIES’ ARGUMENTS] Tiffany acknowledges that individual sellers, rather than eBay, are responsible for listing and selling counterfeit Tiffany items. Nevertheless, Tiffany argues that eBay was on notice that a problem existed and accordingly, that eBay had the obligation to investigate and control the illegal activities of these sellers—specifically, by preemptively refusing to post any listing offering five or more Tiffany items and by immediately suspending sellers upon learning of Tiffany’s belief that the seller had engaged in potentially infringing activity. In response, eBay contends that it is Tiffany’s burden, not eBay’s, to monitor the eBay website for counterfeits and to bring counterfeits to eBay’s attention. eBay claims that in practice, when potentially infringing listings were reported to eBay, eBay immediately removed the offending listings…. [CONTRIBUTORY INFRINGEMENT] It is well established that “liability for trademark infringement can extend beyond those who actually mislabel goods with the mark of another.” … Contributory trademark infringement is a judicially constructed doctrine articulated by the Supreme Court in Inwood [Labs. v. Ives Labs., 456 U.S. 844, 854 (1982)]. In that opinion, the Supreme Court held that: [I]f a manufacturer or distributor intentionally induces another to infringe a trademark, or if it continues to supply its product to one whom it knows or has reason to know is engaging in trademark infringement, the manufacturer or distributor is contributorially responsible for any harm done as a result of the deceit. [Emphasis added.] [INTENTIONAL INDUCEMENT] The first prong of the Inwood standard for contributory trademark infringement … is inapplicable here, because Tiffany has not alleged that eBay intentionally induced infringement of Tiffany’s marks…. [PRODUCT VERSUS SERVICE] eBay argues that its website is not a “product,” as defined by Inwood. Rather, eBay characterizes its website as a “service [that] does not trade in the products at issue.” … Nevertheless, cases decided after Inwood have expanded the concept of contributory trademark infringement beyond the facts identified in Inwood, and have not limited liability for contributory infringement to situations involving misuse of a manufacturer’s product. First, in Hard Rock Café [v. Concession Services, 955 F.2d 1143 (7th Cir. 1992)], the Seventh Circuit considered the question of whether the owner of a flea market could be held liable for contributory trademark infringement on the grounds that vendors in the flea market were selling shirts that infringed the Hard Rock Café trademark…. [D]espite the fact that the flea market was clearly not a “product,” the Hard Rock Café court determined that the common law imposed “the same duty on landlords and licensors that the Supreme Court has imposed on manufacturers and distributors.” In reaching this conclusion, the court noted that the flea market operator was not merely a landlord, but advertised and promoted the activity on its premises, sold admission tickets to buyers, and supervised the premises. [EBAY’S CONTROL OVER EBAY USERS] In Lockheed Martin Corporation v. Network Solutions, Inc. [194 F.3d 980 (9th Cir. 1999)], the Ninth Circuit, synthesizing the holdings of Hard Rock Café and [another case], determined that whether the venue is online or in brick and mortar is immaterial. The relevant inquiry is, instead, “the extent of control exercised by the defendant over the third party’s means of infringement.” The court further noted that “[d]irect control and monitoring of the instrumentality used by a third party to infringe the plaintiff’s mark permits the expansion of Inwood Lab.’s ‘supplies a product’ requirement for contributory infringement.” Because the facts in Lockheed Martin demonstrated that the defendant was a service that did not have “direct control and monitoring” over those who infringed the plaintiff’s mark, the court determined that the defendant, a contractor in charge of registering Internet domain names, was not contributorily liable as a matter of law. Several courts have followed Lockheed Martin and assessed the extent of control exercised by the defendant over the actual infringer’s means of infringement in determining whether a defendant may be contributorily liable. See Perfect 10, Inc. v. Visa Int’l Serv. Ass’n, 494 F.3d 788 (9th Cir. 2007)…. [T]he Court first notes that while eBay itself does not sell or possess the items available on its website, eBay retains significant control over the transactions conducted through eBay…. Second, eBay has actively promoted the sale of Tiffany jewelry items. eBay advertises merchandise on its own website as well as through other websites, including until 2003, Google and Yahoo!. eBay also actively works with sellers and PowerSellers to help them grow their jewelry business…. Third, eBay profits from the listing of items and successful completion of sales, through insertion fees and final value fees…. Fourth, eBay maintains significant control over the listings on its website. Certain categories of items are entirely barred from the website, including drugs, firearms, and alcohol products. The fraud engine screens listings and removes items that use specific terms in the listing description, for example, “counterfeit” or “fake.” Through eBay’s User Agreements, users are required to abide by the terms of use, and eBay retains the right to suspend those users who fail to do so…. Despite the fact that eBay never takes physical custody of the items sold on its website, eBay nevertheless exerts sufficient control over the listings on its website such that it cannot qualify as a mere online version of a newspaper or a magazine that publishes classified ads…. [KNOWLEDGE OR REASON TO KNOW] Under the Inwood test, Tiffany must prove that eBay continued to supply its services “to one whom it knows or has reason to know is engaging in trademark infringement.” The evidence produced at trial demonstrated that eBay had generalized notice that some portion of the Tiffany goods sold on its website might be counterfeit…. Tiffany has not alleged, nor does the evidence support a conclusion, that all of the Tiffany merchandise sold through eBay is counterfeit. Rather, a substantial number of authentic Tiffany goods are sold on eBay…. Were Tiffany to prevail on its argument that generalized statements of infringement were sufficient to impute knowledge to eBay of any and all infringing acts, Tiffany’s rights in its mark would dramatically expand, potentially stifling legitimate sales of Tiffany goods on eBay…. Instead, courts have required a much higher showing that a defendant knew or had reason to know of specific instances of actual infringement…. [T]he Court finds that eBay responded appropriately to notice of specific infringing items, and that evidence of eBay’s general knowledge of infringement is insufficient to impute knowledge to eBay of specific infringing listings. [WILLFUL BLINDNESS] However, the “reason to know” standard can be satisfied by a showing that the defendant was willfully blind to the infringing activity. Willful blindness means a person must suspect wrongdoing and deliberately fail to investigate…. [W]ithout specific knowledge or reason to know, eBay is under no affirmative duty to ferret out potential infringement. Willful blindness requires “more than mere negligence or mistake” and does not lie unless the defendant knew of a high probability of illegal conduct and purposefully contrived to avoid learning of it, for example, by failing to inquire further out of fear of the result of the inquiry. Put simply, it cannot be said that eBay purposefully contrived to avoid learning of counterfeiting on its website, or that eBay failed to investigate once it learned of such counterfeiting. To the contrary, in the face of such general awareness, eBay took significant steps to prevent counterfeiting…. Accordingly, the Court concludes that eBay was not willfully blind to the evidence of counterfeiting on its website. [CONTINUED SUPPLY OF PRODUCT] The Inwood test requires a plaintiff to prove that the defendant continued to supply its product to an infringer once it had knowledge of the infringement…. [T]he record is clear that once Tiffany notified eBay of a listing it believed to contain infringing merchandise, eBay promptly removed that listing from its website …. [Although] eBay, as a rule, declined to automatically or permanently suspend a seller [when notified by Tiffany of alleged infringement] [t]he Court finds that this policy was appropriate. As noted in the Findings of Fact, given the consequences of an eBay suspension, eBay reasonably proceeded with caution in suspending sellers based on [Tiffany’s notices] because [these notices] were a good faith determination of infringement, not an exact finding of infringement…. [CONCLUSION] The rapid development of the Internet and websites like eBay have created new ways for sellers and buyers to connect to each other and to expand their businesses beyond geographical limits. These new markets have also, however, given counterfeiters new opportunities to expand their reach. The Court is not unsympathetic to Tiffany and other rights owners who have invested enormous resources in developing their brands, only to see them illicitly and efficiently exploited by others on the Internet. Nevertheless, the law is clear: it is the trademark owner’s burden to police its mark, and companies like eBay cannot be held liable for trademark infringement based solely on their generalized knowledge that trademark infringement might be occurring on their websites. CASE QUESTIONS 1. Why wasn’t eBay held liable for the infringing sales made by users? [Hint: Describe how the elements of the Inwood test apply to eBay’s actions.] 2. Can online providers of services (as opposed to suppliers of products) ever be held liable for contributory trademark infringement? What steps might a business take to reduce liability exposure? 3. Ethical Consideration: As an online service provider, to whom do you owe the greater duty? To your customers who wish to knowingly (i.e., without confusion) buy cheaper, imitation products? Or to unrelated businesses whose valuable intellectual property is being flagrantly violated on your site? Would you take precautions beyond what the law requires to reduce infringing sales? Secondary Liability on the Internet: A Difficult Case to Make As seen in eBay, it may be difficult to succeed on the basis of a contributory trademark liability claim in the Internet context. Suits brought against Google and other search engines for contributory liability based on the key word purchases of its customers have generally also been unsuccessful. Vicarious trademark claims involving online businesses may be equally challenging to win. In Perfect 10, Inc. v. Visa Int’l Serv. Ass’n,22 plaintiff Perfect 10 alleged that Visa was vicariously infringing its trademarks by continuing to process credit card payments of individuals who subscribed to websites that infringed Perfect 10’s trademarks. Perfect 10 operated a subscription website featuring images of nude models, which images appeared without authorization on the alleged primary infringer’s websites. Although Visa had been notified of the activities occurring at the offending websites, it continued to process payments associated with these sites. The Ninth Circuit held that Visa did not exercise direct control over the websites and could therefore not be held vicariously liable. Nevertheless, the potential for secondary liability remains, and businesses must be careful not to induce or contribute to infringement by individual users. Aware of the potential for secondary liability, Twitter, a popular social networking site that allows users to display short online status reports, has adopted a policy under which trademark violations that create consumer confusion may result in permanent account suspension. Conversely, trademark owners who believe that online service providers are inducing or benefiting from the infringing activity of users may wish to include as defendants the alleged secondary infringer in addition to the direct infringer and pursue claims for secondary liability in the lawsuit despite the apparent obstacles to success. Domain Names Domain names present special problems for businesses that may not be adequately addressed under the Lanham Act. Difficulties arise in part because there is imperfect overlap between domain names and trademarks. While a domain name may contain a trademark within it, and while it is possible to trademark a domain name, each is governed by different rules that are administered by different organizations. When disputes over domain names arise, plaintiffs may seek to resolve them in either of two parallel adjudicative systems. The Structure of a Domain Name An Internet address includes a top level domain name (TLD), a second-level domain name, and possibly third- or lower-level domain names. See Exhibit 4.10. The TLD is the portion of the domain name furthest to the right. (The portion of the address appearing to the right of the TLD, if any, is called the “post domain path.”) For example, common TLDs include .com, .org, .edu, .net, and .gov. These are called generic TLDs, or gTLDs, because they are not associated with any particular country. In addition to gTLDs, more than 240 country-code TLDs (ccTLDs) exist, such as .uk (United Kingdom), .mx (Mexico), and .us (United States). The regional TLD .eu (European Union) was established in 2006. A listing of gTLDs and ccTLDs can be found on the website of the Internet Assigned Numbers Authority (IANA), www.iana.org. IANA is operated by the Internet Corporation for Assigned Names and Numbers (ICANN), a nonprofit organization established in 1998 that is not directly affiliated with the USPTO. EXHIBIT 4.10: Domain Name Components Second-level domain names appear to the left of the TLD and frequently include the name of the organization associated with the website. For example, “plymouth” is the secondlevel domain in www.plymouth.edu, the website of Plymouth State University. Registering a Domain Name While trademarks are registered with the USPTO, domain name registration is a separate and independent process. Domain names may be registered for a small fee through any of the hundreds of registrars accredited by ICANN. A list of registrars is available at www.icann.org. When an application for a domain name registration is received, registrars do not inquire into the trademark status of the requested domain name. So long as the identical domain name has not already been registered by another party, the registrar will process the request. Domain Names and Opportunistic Behavior The ease with which domain names can be acquired led to a virtual land grab on domain names in the early days of the Internet that continues to the present. By registering key domain names before others appreciate their value, individuals can acquire Internet “real estate” that can be later sold for a profit. This type of opportunistic behavior is known as cybersquatting. Trademark CyberSquatting: Panavision v. Toeppen In the landmark case of Panavision v. Toeppen,23 the tension between domain name registration and trademark rights came to a head. In 1995, an individual named Dennis Toeppen registered a number of domain names based on wellknown trademarks, including panavision.com, deltaairlines.com, eddiebauer.com, and yankeestadium.com. At the time of Toeppen’s domain name registration, businesses were only beginning to utilize the Internet, and Toeppen realized that businesses might pay substantial amounts in order to acquire a preferred domain name. He offered to give up the domain name panavision.com if Panavision, a well-known manufacturer of film and television camera equipment and owner of the trademark “Panavision,” would pay him $13,000. Instead, Panavision brought suit. In finding for Panavision, the court concluded that Toeppen’s conduct diluted Panavision’s marks in violation of the FTDA and prevented Panavision from using its marks within an important new business medium. The court enjoined Toeppen from further use of the Panavision mark in a domain name. Nontrademark CyberSquatting Panavision was ultimately successful because it was the owner a valid trademark that Toeppen had used as part of a domain name. Some cybersquatters, however, register domain names that are unrelated to any trademarks. These cybersquatters have been able to command thousands or even millions of dollars for domain names such as wiki.com and Bhutan.com. • Not Have Knowledge of Infringing Activity. OSPs seeking to benefit from the content hosting and information location tool safe harbors must not be aware of infringement, or must remove infringing content expeditiously once infringing activity becomes known. This requirement incorporates one of the elements of contributory liability. • Not Receive a Direct Financial Benefit. OSPs seeking to benefit from the content hosting and information location tool safe harbors must not receive a financial benefit directly attributable to the infringing activity where the OSP has the right and ability to control the activity. This requirement incorporates the elements of vicarious liability. In the following case, the court had to determine whether Amazon.com’s zShops platform for third party vendors fell within the content-hosting safe harbor. CORBIS CORP. v. AMAZON.COM, INC.: 351 F.Supp.2d 1090 (W.D. Wash. 2004) LASNIK, CHIEF JUDGE [FACTS] Amazon is a company specializing in electronic commerce. It is most widely known for selling books over the Internet at its website, Amazon.com. The Amazon.com website also hosts several third party vendor platforms, including a platform entitled “zShops.” … The zShops platform allows individuals and retailers (referred to as “vendors”) to showcase their products and sell them directly to online consumers. Amazon, however, does not sell any of its own inventory on the zShops platform. To sell on zShops, a vendor creates a web page on the zShops platform that includes information regarding the product being sold. These web pages are referred to as “listings,” and are created by using tools and forms provided by Amazon. The forms allow the vendor to describe the product, list the price, and provide an image of the product. A vendor can include a product image in the listing in one of two ways. The vendor either creates a link to an image stored on the vendor’s computer or server, or uploads an image to one of Amazon.com’s servers for display in the listing. Amazon does not actively participate or supervise the uploading or linking of images, nor does Amazon preview the images before the link is created or the upload completed. Vendors must register with Amazon before they list items on zShops. Amazon charges a fee of $39.99 to all vendors, which allows a vendor to use the zShops platform and Amazon’s credit card processing services. Vendors also pay Amazon a percentage of the price of any products sold. The percentage ranges from 2.5% to 5%, depending on the price of the item…. Amazon also owns and operates the Internet Movie Database (IMDb), a website located at www.IMDb.com. IMDb is an information database regarding movies, actors, and entertainment in general…. Although the IMDb site is independent from the Amazon.com site and its third party selling platforms, IMDb contains links to items available on the Amazon.com site. For instance, IMDb contained a banner advertisement with celebrity photos including two photos in which Corbis claims a copyright interest. IMDb users who clicked on the banner were linked to zShops and provided with information regarding vendors selling celebrity images. Corbis is in the business of licensing art images and photographs, including photographs of celebrities. As part of its business, Corbis enters into contracts with photographers who take celebrity photos. Under these contracts, Corbis represents and distributes a photographer’s work and, in exchange, is paid a royalty based on the fees charged for licensing the photos. Corbis also owns exclusive rights to a number of individual photographs and photographic collections…. Corbis has identified a total of 232 images (the “Corbis Images”) in which it claims a copyright interest. Two of the images appeared on the IMDb website. The remaining 230 images have been copied, displayed, and sold by vendor defendants through their zShops sites. [DMCA] In 1998, Congress enacted the DMCA in an effort to resolve the unique copyright enforcement problems caused by the widespread use of the Internet…. The DMCA “safe harbors provide protection from liability for: (1) transitory digital network communications; (2) system caching; (3) information residing on systems or networks at the direction of users; and (4) information location tools.” … To be eligible for any of the safe harbors, a service provider must meet a series of threshold conditions. At the outset, a party seeking safe harbor must, in fact, be a “service provider” as that term is defined under the DMCA. If it fits within that definition, the service provider must then show that it (A) has adopted and reasonably implemented, and informs subscribers and account holders of the service provider’s system or network of a policy that provides for the termination in appropriate circumstances of subscribers and account holders of the service provider’s system or network who are repeat infringers; and (B) accommodates and does not interfere with standard technical measures. Amazon asserts that it is entitled to protection for information residing on systems or networks at the direction of users. See 17 U.S.C. § 512(c). The § 512(c) safe harbor protects a service provider from liability for “infringement of copyright by reason of the storage at the direction of a user of material that resides on a system or network controlled or operated by or for the service provider.” To qualify for the § 512(c) safe harbor, a service provider must show that: (1) it has neither actual knowledge that its system contains infringing materials nor an awareness of facts or circumstances from which infringement is apparent, or it has expeditiously removed or disabled access to infringing material upon obtaining actual knowledge of infringement; (2) and it receives no financial benefit directly attributable to infringing activity; (3) it responded expeditiously to remove or disable access to material claimed to be infringing after receiving from the copyright holder a notification conforming with requirements of § 512(c)(3). [TERMINATION POLICY FOR REPEAT INFRINGERS] It is undisputed that Amazon requires each zShops vendor to accept a Participation Agreement that sets forth guidelines for the use of the zShops platform…. The Participation Agreement prohibits the listing, linking, or posting of any material that violates copyright laws, and makes it clear that those who violate Amazon’s policies may face a variety of penalties, including restricting access to Amazon’s sites and suspension or termination of service. Finally, and perhaps most importantly, those accused of copyright infringement are informed that repeated violations could result in “permanent suspension” from Amazon sites. Although Amazon does not use the term “repeat infringer” or precisely track the language of the DMCA, the evidence shows that Amazon has adopted a termination policy as required …. [STANDARD TECHNICAL MEASURES] Corbis has not challenged Amazon’s assertion that it accommodates and does not interfere with standard technical measures used to identify and protect copyrighted works. Accordingly, this Court finds that this threshold condition has been met. [KNOWLEDGE OF INFRINGEMENT] To enjoy the § 512(c) safe harbor Amazon must show that it (1) does not have actual knowledge that the material or an activity using the material on the system or network is infringing, and (2) is not aware of facts or circumstances from which infringing activity is apparent. If a service provider does obtain either actual or apparent knowledge, it may still invoke the § 512(c) safe harbor if it acts expeditiously to remove or disable access to the infringing material…. Congress’s discussion of apparent knowledge … is instructive. Absent evidence of its own efforts to notify a service provider, a copyright owner could establish apparent knowledge if she could show that an online location at which her copyrighted material was available was clearly a “pirate site.” … Congress described the advertisement of illegal copyright activity through such slang words [as “bootleg”] as a “ ‘red flag’ of obvious infringement,” and indicated that the infringing nature of sites containing such red flags would be apparent from even a “brief and casual viewing.” … Outside of the fact that the zShop vendors sold pictures of celebrities, Corbis is silent regarding the content of the complained of listings. There is simply nothing to suggest that the vendor listings contained evidence of blatant copyright infringement. As a result … Corbis has failed to [show] that those sites contained the type of blatant infringing activity that would have sent up a red flag for Amazon. [RIGHT AND ABILITY TO CONTROL INFRINGING ACTIVITY] Outside of providing the zShops platform, Amazon did not have the right or ability to control vendor sales. Amazon is never in possession of the products sold by zShops vendors. Furthermore, Amazon does not preview the products prior to their listing, does not edit the product descriptions, does not suggest prices, or otherwise involve itself in the sale…. Because Amazon does not have the right and ability to control the infringing material, it is not necessary for this Court to inquire as to whether Amazon receives a direct financial benefit from the allegedly infringing conduct. [CONCLUSION] Amazon has satisfied all of the threshold conditions for DMCA protection and all of the requirements for protection under the § 512(c) safe harbor. As a result, Amazon is immune from all monetary relief…. CASE QUESTIONS 1. How did the copyrighted images at issue in Corbis come to be displayed to Internet users? 2. Given that Amazon reserved the right to terminate account holders from further activity on the zShops platform (as it must to benefit from the DMCA safe harbors), why doesn’t Amazon have the “right or ability to control vendor sales,” according to the court? 3. Ethical Consideration: What duty should OSPs such as Amazon that host content uploaded by others owe to copyright holders? Should such OSPs be required to “police” their websites to detect and prevent copyright infringement? Summary A great deal of online content is protected under the Copyright Act, including web pages, music, movies, and software. Indeed, because notice and registration are not required in order to secure copyright protection, it is prudent to assume that any content a business did not itself create is subject to the exclusive rights of others, unless the business has a particular reason to believe otherwise. These exclusive rights include the right to reproduce, prepare derivative works, distribute, publicly display, and publicly perform a copyrighted work. The broad reach of the exclusive rights is tempered by the limited duration of copyrights, the ability of the public to make fair use of copyrighted works without the permission of the copyright owner, and the ability to sell particular copies of works under the first sale doctrine. These and numerous other complex and detailed exceptions to the exclusive rights are provided in Sections 107–122 of the Copyright Act. A nonprofit organization known as Creative Commons offers a simple licensing scheme that copyright owners may use to give permission to others to use their copyrighted works. The Internet has dramatically expanded the ability of the public to copy and distribute copyrighted works. Congress responded by enacting the Digital Millennium Copyright Act (DMCA), which prohibits the circumvention of technological measures that copyright owners use to prevent unauthorized access to copyrighted works. In addition, the DMCA’s antitrafficking provisions prohibit the manufacture or distribution of devices designed to facilitate unauthorized access to or use of copyrighted works. In order to reduce uncertainty and promote the development of online businesses, the DMCA includes four safe harbor provisions that protect businesses from liability for certain online activities, such as passive routing and transmission, system caching, hosting of third party content, and providing information location services. In order to benefit from these safe harbors, OSPs must meet the detailed requirements of Section 512, which generally require good faith efforts to cooperate with copyright owners to reduce third party infringement. (Ferrera 164-167) Ferrera, Gerald R., Margo E. Reder, Stephen Lichtenstein, Robert Bird, Jonathan Darrow, Jeff. CyberLaw: Text and Cases. Cengage Learning, 01/2011. VitalBook file.
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