The United States District Court for the Southern District of Indiana dismissed with prejudice all claims brought by plaintiff author Keith Bell against Bartholomew Consolidated School Corporation and one of its teachers and allowed them to seek attorneys’ fees. Bell, the author of the book Winning Isn’t Normal and the owner of the copyright in the work, filed suit after a March 2022 social media repost involving a passage from his work.

The parties

The dispute centered on the conduct of one Timothy Bless, a high school teacher and football coach employed by the school system. Bless was not acting on behalf of the school in any official capacity when the events occurred. Instead, he used his personal X account, which he controlled independently. On that account, Bless reposted a post originally made by a college football coach. The post contained an image of one of Bell’s well-known motivational passages. Bless did not add any commentary or attempt to connect the repost to the school or any official activity.

Bell alleged that this repost violated copyright law and a prior settlement agreement between the parties. He also brought claims for vicarious liability against the school and for violations of the Digital Millennium Copyright Act. He sought damages and a finding that the defendants had used his copyrighted work without authorization.

The court’s decision – fair use

The court rejected all of Bell’s claims. The central issue was whether Bless’s repost constituted copyright infringement. The court concluded that it did not because the repost qualified as fair use. In reaching this conclusion, the court focused heavily on the purpose and context of Bless’s actions. It found that Bless shared the passage to motivate or inspire student athletes, not for any commercial purpose. There was no evidence that he profited from the repost or used it in connection with any business activity. This noncommercial and educational context weighed strongly in favor of fair use.

The court also considered the nature of the work and the amount used. While the passage had some creative elements, it largely consisted of familiar motivational ideas. Although Bless reposted the entire passage, the court found that copying the whole excerpt was reasonable because its full text was necessary to convey its inspirational message. The fact that the passage was already widely available online further supported this conclusion.

Most importantly, the court found no plausible harm to the market for Bell’s work. There was no indication that the repost reduced sales of the book or related merchandise. If anything, the court suggested that widespread sharing of the passage could increase interest in Bell’s work rather than diminish it. Because market harm is often the most significant factor in fair use analysis, this finding strongly supported the court’s conclusion.

Other claims failed as well

The claims against the school also failed because Bell did not plausibly allege that the school itself copied the work or controlled Bless’s personal social media activity. The repost occurred on Bless’s private account, and there were no facts linking the school to that decision. The vicarious liability claim was dismissed as conclusory, and the DMCA claim failed because Bell did not adequately allege that copyright information had been knowingly removed. The breach of contract claim was also dismissed because Bell did not plausibly allege actionable use or damages.

Given Bell’s litigation history and the weakness of the claims, the court determined that any amendment would be futile and dismissed the case with prejudice. It also concluded that an award of attorneys’ fees was appropriate, in part to deter similar claims in the future.

Bell v. Bartholomew Consolidated School Corporation, 2026 WL 828677 (S.D. Ind. Mar. 26, 2026).

The United States District Court for the District of New Jersey transferred OKLegal.com’s lawsuit against Meta Platforms, Inc. and Mark Zuckerberg to the Northern District of California under Instagram’s forum-selection clause.

Plaintiff OKLegal.com sued defendant Meta Platforms, Inc. and defendant Mark Zuckerberg after Instagram indefinitely banned its account, (1) alleging the ban violated the First Amendment, (2) seeking a declaration that Section 230 is unconstitutional, and (3) asserting tortious interference with an advantageous business relationship.

Plaintiff asked court to keep the case in New Jersey and deny defendants’ request to enforce the Instagram Terms of Use forum-selection clause, while also opposing defendants’ alternative request to dismiss the complaint.

The court’s ruling

The court granted defendants’ motion in part by transferring the case to the United States District Court for the Northern District of California under 28 U.S.C. § 1404(a). It denied the remainder of the motion without prejudice, allowing defendants to raise their dismissal arguments in California.

Reasoning for the transfer

The court found plaintiff could have brought the action in the Northern District of California because Meta’s principal place of business and Zuckerberg’s residence are located there. It also found plaintiff agreed to Instagram’s Terms of Use when creating and using the account, and that those terms required non-arbitrated claims to be litigated exclusively in the Northern District of California or a state court in San Mateo County. The court rejected plaintiff’s arguments that the clause was unenforceable as clickwrap, adhesive, unconscionable, or contrary to public policy, concluding plaintiff failed to show that relevant public-interest factors overwhelmingly disfavored transfer.

OkLegal.com v. Meta Platforms, Inc., 2026 WL 850812 (D.N.J. Mar. 27, 2026)

The U.S. District Court for the Southern District of New York largely trimmed a content creators’ suit over alleged affiliate commission hijacking by a browser extension, but let the tortious interference with contract claim proceed.

Plaintiffs, a group of online content creators, sued defendants RetailMeNot, Inc. and Ziff Davis, Inc., alleging that defendant’s browser extension wrongfully overwrote plaintiffs’ affiliate tracking codes and diverted sales commissions that plaintiffs otherwise would have received from merchants.

Motion to dismiss

Defendants asked the court to dismiss the case, arguing that plaintiffs lacked Article III standing and that the complaint failed to state any viable claims, including common law, computer fraud, and consumer protection claims.

The court ruled that plaintiffs had standing to sue and denied dismissal on that ground, but it otherwise granted the motion in substantial part and dismissed all claims except plaintiffs’ claim for intentional interference with contractual relations.

Why the tortious interference claim survived

The court found that the complaint plausibly alleged an actual and traceable injury through test purchases and statistical evidence, and that plaintiffs adequately pleaded that defendants knew of plaintiffs’ affiliate contracts and intentionally caused merchants to breach those contracts by crediting commissions to defendants instead of plaintiffs. But the court found the remaining claims deficient for reasons including failure to allege that plaintiff conferred a benefit on defendant, failure to plead interference with a prospective relationship rather than an existing contract, failure to identify convertible property, failure to show unauthorized computer access, and failure to allege the consumer harm required under the cited state statutes.

In re RetailMeNot Browser Extension Litigation, No. 25-CV-783, 2026 WL 820585 (S.D.N.Y., March 25, 2026)

The United States District Court for the District of Colorado left a jury’s verdict intact by denying defendants’ bid for judgment as a matter of law and denying plaintiff’s request to increase punitive damages.

Plaintiff Eric Coomer sued defendant Michael J. Lindell, defendant Frankspeech LLC, and defendant My Pillow, Inc. for defamation and related claims based on statements accusing Coomer of helping rig the 2020 presidential election while he worked for Dominion Voting Systems. After trial, the jury found defendant Lindell and defendant Frankspeech liable on certain defamation claims, found defendant Frankspeech liable for intentional infliction of emotional distress and punitive damages, and found defendant My Pillow not liable.

Frankspeech was a streaming and broadcasting platform that Lindell created, that aired interviews, hosted shows such as “The Lindell Report,” and livestreamed events like the Cyber Symposium, rather than simply operating as a passive message board or social media site.

Post-trial requests

Defendant Lindell and defendant Frankspeech asked the court to enter judgment as a matter of law in their favor on several grounds, including that Frankspeech was immune under 47 U.S.C. § 230, that plaintiff had not proved economic damages, and that the evidence did not support actual malice. Plaintiff asked the court to amend the final judgment to increase the punitive damages award against defendant Frankspeech based on alleged continuing misconduct during the case.

Motions denied

The court ruled that both post-trial motions should be denied. It refused to overturn the jury’s findings against defendant Lindell and defendant Frankspeech, and it also refused to enlarge the punitive damages award against defendant Frankspeech.

Why the court ruled the way it did

The court concluded that there was sufficient evidence for a reasonable jury to find that Frankspeech was not entitled to Section 230 immunity because it was not merely hosting third-party content. Instead, Lindell, acting as Frankspeech’s agent, made defamatory statements on its broadcasts, and the company also promoted, sponsored, and livestreamed the Cyber Symposium where additional statements were made. This allowed the jury to find that Frankspeech participated in the development and dissemination of the content, rather than acting as a neutral intermediary. The court also found sufficient evidence of economic harm and actual malice, and it determined that plaintiff had not met the high burden required to justify increasing punitive damages under Colorado law. Finally, the court ordered defendants to show cause why additional Rule 11 sanctions should not be imposed for another inaccurate citation in their briefing.

Coomer v. Lindell, 2026 WL 817370 (D. Colo. Mar. 25, 2026)

The United States District Court for the Northern District of California granted Anthropic’s motion for a preliminary injunction, finding it likely to succeed in challenging federal actions that barred it from government work and that labeled it a national security supply chain risk.

Plaintiff AI company Anthropic PBC sued defendant U.S. Department of War and other federal defendants after the government moved to cut it off from federal contracts, pressure defense-related companies to stop working with it, and designate it a supply chain risk. Plaintiff alleged the measures were unlawful retaliation for its public criticism of defendant’s demand that Claude be available for all lawful military uses, including mass surveillance of Americans and lethal autonomous warfare.

Requested relief

Plaintiff asked the court to preliminarily enjoin defendant from implementing or enforcing three challenged actions: (1) a presidential directive ordering agencies to stop using Anthropic technology, (2) a directive from Secretary Pete Hegseth cutting Anthropic off from military-related commercial relationships, and (3) the Department of War’s supply chain risk designation. Plaintiff argued these actions violated the First Amendment, the Fifth Amendment, and the Administrative Procedure Act.

Court’s ruling

The court granted the preliminary injunction in a modified form (that varied from what Anthropic had proposed). It concluded plaintiff was likely to succeed on its First Amendment retaliation claim, its procedural due process claim, and its APA claims that the supply chain risk designation and Hegseth directive were contrary to law, exceeded statutory authority, and were arbitrary and capricious. The court also found plaintiff had shown irreparable harm, that the equities and public interest favored relief, and that a nominal $100 bond was sufficient.

Why it ruled

The court found the record supported an inference that defendant acted to punish plaintiff for speaking publicly about AI safety and for criticizing the government’s contracting position, rather than to address a genuine national security threat. It said the broad federal ban and supply chain risk label went far beyond simply stopping use of Claude, and it emphasized that the Department of War had previously praised Anthropic and raised no comparable security concerns until the public dispute. The court also found serious procedural flaws, including lack of notice and opportunity to respond, and held that the statutory supply chain risk framework did not fit plaintiff’s conduct because the record did not show sabotage, subversion, or any reasoned determination that less intrusive measures were unavailable.

Anthropic PBC v. U.S. Department of War, et al., Case No. 26-cv-01996-RFL (N.D. Cal. Mar. 26, 2026)

[Read the full opinion]

The United States District Court for the Western District of Oklahoma refused to dismiss Paycom trademark and cybersquatting suit against Pay.com entities, finding that the case could proceed in Oklahoma. Plaintiff sued defendants for trademark infringement, false designation of origin, trademark dilution, cybersquatting, common-law trademark infringement, unfair competition, and violation of the Oklahoma Deceptive Trade Practices Act. Plaintiff alleged that defendants used Pay.com and Paycom-related branding in a way that confused consumers, suggested an affiliation with plaintiff, and harmed plaintiff’s PAYCOM marks.

Dismissal request

Defendants asked the court to dismiss the case for lack of personal jurisdiction and also asked it to dismiss the cybersquatting claim for failure to state a claim. They argued that their online activity did not create sufficient Oklahoma contacts and that plaintiff had not adequately pleaded the elements of an Anti-Cybersquatting Protection Act (ACPA) claim.

Jurisdiction ruling

The court ruled that dismissal was not warranted. It held that plaintiff made a prima facie showing of specific personal jurisdiction in Oklahoma and also held that the amended complaint plausibly stated a cybersquatting claim, so defendants’ motion to dismiss was denied in full.

Why the court rejected dismissal

The court found that defendants had sent follow-up marketing emails directly to prospective Oklahoma merchants after those businesses began account applications through the pay.com website, and those contacts were enough to show purposeful direction toward Oklahoma that related to plaintiff’s alleged injuries. The court also found that defendants had not shown jurisdiction in Oklahoma would be unreasonable, and it concluded that the cybersquatting arguments turned on factual disputes and matters outside the pleadings that could not be resolved on a Rule 12(b)(6) motion.

Paycom Payroll, LLC v. Pay.com US, Inc., 2026 WL 810559 (W.D. Oklahoma, March 24, 2026) 

Plaintiffs sued Defendant for secondary copyright infringement, alleging that Defendant, an internet service provider, was liable because it continued to provide internet access to subscribers whose accounts were associated with music piracy. Plaintiffs won a jury verdict for $1 billion, and the Fourth Circuit Court of Appeals agreed in part, concluding that Defendant could be contributorily liable for continuing to serve known infringers.

Defendant asked the U.S. Supreme Court to reverse the contributory infringement ruling, arguing that merely providing internet service to subscribers suspected of infringement does not make a service provider liable under the Copyright Act. It contended that secondary liability requires proof that Defendant induced infringement or provided a service designed for infringement, not just knowledge that some subscribers used the service unlawfully.

The Court ruled that Defendant was not contributorily liable and reversed the Fourth Circuit’s decision on that issue. It held that supplying internet access to the general public, even with knowledge that some users may infringe copyrights, is not enough by itself to establish contributory copyright infringement.

The Court ruled this way because contributory liability requires intent, which Plaintiffs could show only by proving that Defendant induced infringement or provided a service tailored to infringement. The Court concluded that Defendant did neither, since it did not encourage infringement and its internet service had substantial lawful uses. The Court also rejected Plaintiffs’ reliance on the DMCA, explaining that the statute creates safe harbors and does not itself impose liability on service providers that fail to qualify for them.

Cox Communications, Inc. v. Sony Music Entertainment, 607 U.S. ___, 2026 WL 815823 (Mar. 25, 2026).

Plaintiff sued defendant for unlawfully accessing plaintiff’s email account and publishing more than sixty private emails on social media. Defendant had repeatedly claimed credit for the hack in a Hulu documentary, on social media, and in podcast appearances. Plaintiff brought several claims in federal court, including claims under the Stored Communications Act, the Computer Fraud and Abuse Act, and invasion of privacy under Tennessee common law.

Plaintiff asked the court to enter summary judgment on liability, arguing that defendant’s own public statements confirmed every essential element of the Stored Communications Act and invasion of privacy tort claims.

The court ruled that defendant was liable under the Stored Communications Act and for public disclosure of private facts. It denied summary judgment on the Computer Fraud and Abuse Act claim because plaintiff had not presented sufficient evidence of economic loss. But that issue remains open for trial.

The court ruled this way because it found that defendant gave repeated, detailed accounts of how he accessed plaintiff’s email account, changed the password, and took control. Plaintiff submitted additional evidence that it lost access to the account during the same period. The court held that this conduct met the elements of unauthorized access under the Stored Communications Act and that the publication of dozens of personal emails, including intimate messages and communications from family members, qualified as highly offensive under Tennessee law.

McKamey v. Yerace, No. 3:21-CV-00132, 2024 WL 7147987 (M.D. Tenn. January 15, 2026)

A brazen and disruptive intrusion by anti-ICE activists during a Sunday worship service at Cities Church in St. Paul, Minnesota, has rightly drawn national outrage and sparked a federal investigation into potential violations of civil rights laws. The protesters, organized by various left wing groups, stormed the sanctuary, chanting slogans and effectively shutting down the service. This understandably left congregants, including children, very upset. The U.S. Department of Justice’s Civil Rights Division is now examining whether these actions violated the federal Freedom of Access to Clinic Entrances Act (FACE Act).

At first glance, applying the FACE Act (originally passed in the 1990s to combat violent blockades and threats at abortion clinics) might seem unexpected. But the law’s text is clear and broad. Congress deliberately extended protections to places of religious worship. It recognized that the same aggressive tactics used against medical facilities could be weaponized against houses of worship. The law exists to prevent raucous interference and other hostilities toward religious exercise.

What the FACE Act actually prohibits

Under 18 U.S.C. § 248(a)(2), it is unlawful for anyone to:

by force or threat of force or by physical obstruction, intentionally injure, intimidate or interfere with or attempts to injure, intimidate or interfere with any person lawfully exercising or seeking to exercise the First Amendment right of religious freedom at a place of religious worship.

This provision exists precisely because disruptions like the one in Minnesota threaten the fundamental right to peaceful worship. The activists did not simply express disagreement outside. They invaded the sanctuary mid-service, chanting demands and accusations. They turned a sacred space into a stage for their political theater.

Why the definitions are critical (and why this conduct looks troubling)

The FACE Act does not criminalize all protest or even offensive speech. It targets specific, harmful conduct with narrow definitions. Here are the key definitions for this situation:

• To “interfere with” means restricting a person’s freedom of movement.
• To “intimidate” means to place a person in reasonable apprehension of bodily harm to him- or herself or to another.
• A “physical obstruction” means rendering ingress to or egress from a place of religious worship impassable, or unreasonably difficult or hazardous.

Reports and video evidence suggest the protesters crowded the sanctuary, positioned themselves in the middle during the sermon, and caused congregants to be very upset. This was not peaceful picketing. It was a calculated invasion that terrified families and halted a Christian service. Given the current political climate and instances of violence, it seems the government should be able to prove that worshippers – who were clearly exercising a First Amendment right – were placed in reasonable apprehension that either they or their loved ones would be harmed.

Federal enforcement, civil options, and state inaction

The FACE Act allows not only criminal prosecution but also civil suits, including by state attorneys general. Minnesota’s AG could theoretically act to defend residents’ religious freedom. However, given the state’s political leadership (often sympathetic to disruptive protests), we have no reason to hold our breath awaiting enforcement from local or state officials.