On February 26, 2014, the Northern District of California issued
its opinion in
Dhillon v. Does 1-10. Judge Susan Illston held that
the use of a political campaign photograph by one's political
enemies is fair use.
The Munger
Games is a political blog run by anonymous California
conservatives who are not fans of socially liberal California
Republican politics, exemplified in their eyes by businessman Charlie Munger. On February 12, 2013, the blog
set its sights on Harmeet Dhillon, Vice Chair of the California
Republican Party, by publishing "Meet Harmeet," an article criticizing
Dhillon's involvement with the ACLU. To illustrate the article,
the Munger Games published an official headshot from Dhillon's
prior campaign for State Assembly. Dhillon quickly registered the
photograph with the Copyright Office and then, on April 1, 2013,
sued the "John Does" behind the site for copyright
infringement. In January 2014, prior to discovery, Messrs. Doe
moved for summary
