Universal Music Group v. Malkin [1]

Michelle Malkin, a political commentator and columnist, publishes a daily video podcast called "Vent with Michelle Malkin." The video podcast appears on Malkin's conservative Internet broadcast network Hot Air [2] and is also regularly posted on YouTube. In the May 2, 2007 edition of Vent [3], entitled "Akon's Assault," Malkin criticized hip hop artist Akon for being a mysogynist and supported her arguments with excerpts from Akon's music videos and video footage from a concert in Trinidad.

On May 3, 2007, YouTube removed "Akon's Assault" in response to a claim of copyright infringement by Universal Music Group (UMG), the company that distributes Akon's albums and other content.

Malkin, with the help of the Electronic Frontier Foundation, responded by sending a counternotice to YouTube, asserting that the video did not infringe UMG's copyright and was protected under the fair use doctrine. Youtube restored the video, and UMG retracted its claim of copyright infringement.