Court Opinions, yielded limited assistance. An adaptation of the law was needed to litigate this new computer technology involving unauthorized access to online consumer's data. Malley seized on an archaic law written concerning the technology of the 1980s involving video cassettes, VHS, and Betamax, the Video Privacy Protection Act ("VPPA"), 18 U.S. Code § 2710 - Wrongful disclosure of video tape rental or sale records, (1988), envisioning that the websites and any affiliated third-parties, which used the audio and/or video within its marketing ads were "video-providers"; moreover, this content, ads, and online games, merely a video; moreover, the essential functionality of the illegal transfer, a "wrongful disclosure", (core elements needed to prove-up a VPPA violation). The use of the VPPA law in regard to this new-age computer technology would set precedent, and become the new "blueprint" used in Federal privacy litigation. In December 2009, Joseph H. Malley representing an anonymous plaintiff, filed a lawsuit against the online DVD rental company Netflix over its release of data sets for the Netflix Prize, alleging that the company's release of the information constituted a violation of the VPPA. Netflix cited the VPPA in 2011 following the announcement of its global integration with Facebook. The company noted that the VPPA was the sole reason why the new feature was not immediately available in the United States, and it encouraged its customers to contact their representatives in support of legislation that would clarify the language of the law. In 2012, Netflix changed its privacy rules so that it no longer retains records for people who have left the site. This change was due directly to a lawsuit indicating violation of the act. Joseph H. Malley was contacted by the U.S. House of Representatives Chief Counsel of the Democratic Subcommittee on IP to provide legal assistance related to blocking the 2012 VPPA Amendment proposal. In January 2013, President Obama signed into law H.R. 6671 which amended the Video Privacy Protection Act to allow video rental companies to share rental information on social networking sites after obtaining customer permission. Netflix had lobbied for the change. While VPPA was amended, efforts to limit the extent of the VPPA amendments were successful. To date, when a Netflix consumer desires to share their viewing history to the accounts of their Facebook friends, an indicator on the Netflix site provides notice of the actual use by Netflix of their data. In