(January 5, 2016, 12:09 PM EST) -- SAN FRANCISCO — Affirming findings by a Nevada federal judge, the Ninth Circuit U.S. Court of Appeals on Dec. 30 clarified that after a copyright defendant who invokes the doctrine of first sale meets its initial burden, the burden then shifts to a copyright holder to demonstrate that a first sale never took place (Adobe Systems Inc. v. Joshua Christenson, et al., No. 12-17371, 9th Cir.; 2015 U.S. App. LEXIS 22818)....