9th Circuit Creates Circuit Split Over De Minimis Copying Exception

(June 6, 2016, 11:32 AM EDT) -- SAN FRANCISCO — A California federal judge properly granted pop star Madonna Louise Ciccone — commonly known as Madonna — and others summary judgment on allegations a modified version of a horn segment in the song “Vogue” infringed the copyrighted song “Love Break,” a divided Ninth Circuit U.S. Court of Appeals concluded June 2 in a decision that creates a circuit split (VMG Salsoul LLC v. Madonna Louise Ciccone, et al., Nos. 13-57104, 14-55837, 9th Cir.; 2016 U.S. App. LEXIS 10017)....