Filed an amicus brief in the U.S. Court of Appeals for the Ninth Circuit urging the court to overturn a district court decision in Fox Television Stations, Inc. v. Aereokiller, LLC, which would allow FilmOnX (Aereokiller) to qualify for a compulsory license under Section 111 of the Copyright Act. The brief noted that Congress intended Section 111 to cover only traditional cable systems; that the Copyright Office has said for decades that Internet transmissions do not qualify under Section 111; and that the Supreme Court’s decision in Aereo III does not support treating Internet transmissions as a cable system under Section 111. The brief was written by Rodney A. Smolla, Dean of the Delaware Law School at Widener University. [2016]