erroneous. Courts must practice constitutional avoidance: the practice of first arguing or reasoning a point based upon common law before turning to use the constitution. Bibliography for (Sony BMG Music Entertainment v. Tenenbaum (1st Cir. 2011) Mass. District Court Opinion Mass. District court opinion Rhode Island district court memorandum First district court of appeals opinion First district court of appeals supplement First district court of appeals documentation Collection of industry versus people files Random summary article on 1st district court decision US Court PDF DMCA Joel Tenenbaum and lawyers website Copyhype article Rights of copyright owner Definitions Damages References United States file sharing case law United States copyright case law 2011 in United States case law Sony litigation Sony BMG United States Court of Appeals for the First Circuit cases