employees interact with users. (...); Although it may be difficult, streaming media startups should resist uploading initial content in order to populate and popularize their services. (...); As a general matter, tolerating “gray areas” will cost money. (...); 'Red flag' knowledge and willful blindness are significant expansions on actual knowledge." Evan Sheres has stated: "Judge Abrams failed to establish a reasonable precedent regarding 'red flag' knowledge, further eroding the 'red flag' standard. Actual employee interaction with the infringing material, especially where the employees make it harder for copyright owners to issue takedown notices, should be sufficient to constitute infringement which is ‘objectively’ obvious to a reasonable person." Others are particularly interested in the implications of applying the safe harbor protection to recordings made before February 1972. References External links 2013 in United States case law United States District Court for the Southern District of New York cases United States copyright case law Capitol Records litigation