Under the Copyright law, it has always been accepted and understood that the work product of actors in films and television do not have a copyright in their performances. That changed in a highly unusual case in 2014 when the federal appeals court in California (the 9th Circuit) held that a film actress owned the copyright in her performance. The situation was highly unusual – she thought she was appearing in a minor role in an adventure film only to find out that her performance was included in a very anti-Islamic film. Death threats followed and she demanded that Google remove the film from YouTube. Google refused and she sued, and ultimately the 9th Circuit held that she had a copyright interest and was entitled to an order requiring Google to take the film down.