Garcia v. Google, Inc., 743 F. 3d 1258 (9th Cir. 2014)

The footage of an actress' minor role in an unreleased adventure film titled “Desert Warrior”, was modified and incorporated into an anti-Islamic film titled the "Innocence of the Muslims", which was later uploaded to Youtube. The actress then received death threats from an Egyptian cleric. After Google refused to take it down from Youtube, plaintiff actress sought a restraining order seeking removal and that posting of the video infringed the copyright in her performance. 9^th Circuit Judge Kozinski ruled for the actress, holding that she had an independent copyright interest in her performance (although filmmaker had an implied license to use her performance, the filmmaker exceeded the bounds of the license); and that the actress faced irreparable harm absent an injunction.