Filed an amicus brief in the U.S. Supreme Court asking the Court to hear Kienitz v. Sconnie Nation LLC, involving an errant expansion of the fair use doctrine. The brief argues that the Court could thereby: (1) Reaffirm the fundamental distinction between parody and satire. (2) Maintain the Copyright Act’s protection of derivative works by curbing expansion of the fair use doctrine. (3) Limit fair use to keep “lazy appropriators” from exploiting existing copyrighted photographs. (4) Preserve the rights of copyright holders by invoking statutory remedies rather than the blunt instrument of fair use. The brief was written by Prof. Rod Smolla, visiting professor, University of Georgia Law School.