2015), is an ongoing dispute that arose when Cindy Lee Garcia sued Google and its video-sharing website, YouTube, to have the controversial film, Innocence of Muslims, taken down from the site.

While the protests began at the diplomatic mission in Cairo, Egypt, unrest quickly spread to several other countries with significant Muslim populations, including Yemen, Greece, Sudan, Tunisia, India, Indonesia, and Pakistan.

The court denied the application "because Garcia had delayed in bringing the action, had failed to demonstrate 'that the requested preliminary relief would prevent any alleged harm' and was unlikely to succeed on the merits because she'd granted Youssef an implied license to use her performance in the film.

Specifically, the court explained that Garcia's performance was "fixed" and that her "body language, facial expression and reactions to other actors and elements of a scene" constituted sufficient originality, both requirements of the Copyright Act of 1976.

Additionally, the court determined that Garcia was not an "employee" for purposes of transferring her ownership interest in her performance under the Copyright Act.

According to the court, because "Youssef hired Garcia for a specific task, she only worked for three days and she claims she received no health or other traditional employment benefits" suggests that she was not an "employee" under the statute.

[citation needed] In May 2015, in an en banc opinion, the Ninth Circuit reversed the panel's decision, vacating the order for the preliminary injunction.

[10][11][12] Prior to its reversal in an en banc opinion, the Ninth Circuit's decision sparked criticism from the legal community, as well as those who produce, distribute, or host copyrighted content.

[3] Stefan M. Mentzer, a partner at White & Case, LLP, argues that the court misinterpreted certain provisions of the Copyright Act.