defamation of character against Millennium Radio Group, Carton, and Rossi. On March 31, 2010, New Jersey District Court ruled in favor of the radio station on all counts in a summary judgment without oral arguments. Opinion of the Court On June 14, 2011, the Third Circuit Court of Appeals reversed the district court's decision, vacating the previous ruling on all counts. Violation of the DMCA Murphy claimed that WKXW's removal of his photographer's credit when copying the picture constituted a violation of the DMCA under 17 U.S.C. §1202(b), which states in part: Copyright management information (CMI) is defined in 17 U.S.C. §1202(c), quoted in part as follows: The district court relied on the decision from IQ Group v. Wiesner, which stated that due to the legislative history of the DMCA, CMI should be interpreted as "a component of an automated copyright protection or management system." Using this analysis, the district court concluded that a print credit in a magazine is not CMI under the DMCA, and removing the credit is not a violation of §1202. The Third Circuit disagreed with the district court's interpretation, holding that the wording of §1202 did not limit its scope to copyright management information only as part of automated systems. As this was the first appellate court to address the scope of CMI in the DMCA, the Third Circuit relied primarily on a plain reading of §1202 to make its decision. The court also addressed the intention of §1202, and found that there was no obvious contradiction between the plain wording and the goal of the legislation. The Third Circuit therefore held that the actions of the radio station and talk show hosts did constitute removal of CMI under the DMCA. Copyright Infringement Murphy alleged direct infringement for the station's use of the unaltered picture, and contributory and vicarious infringement for the user-modified pictures. The defendants claimed that the station's actions qualified as fair use under the Copyright Act. The district court held that both the user-modified and the unaltered copies of Murphy's picture had transformative purposes from the original, with the former being parody and the latter being news reporting, both of which qualify as fair use. The court also noted that Murphy suffered no adverse economic impact from WKXW's copying, bolstering the fair use defense. The district court therefore found the defendants' use of Murphy's picture to be fair use. Murphy did not