In Gwinn v. City of Chicago, the United States District Court for the Northern District of Illinois held, in a matter of first impression, that a Twitter post containing a work qualifies as copyright management information (CMI) under Section 1202(c) of the Digital Millennium Copyright Act (DMCA), and further held that Section 1202(b) has a double scienter requirement (17 U.S.C. § 1202).
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