Last month, in Garcia v. Google, Inc., the U.S. Court of Appeals for the Ninth Circuit issued a preliminary injunction ordering Google to take down an anti-Islamic film from YouTube and to prevent further uploads of the film.  The court concluded that the plaintiff, an actress who appears in the film, likely has a valid copyright interest in her performance in the film and that leaving the film on YouTube could cause the most irreparable sort of harm – the plaintiff’s death.  The key part of the decision is the court’s conclusion that an actor can retain an independent copyright interest in her performance in a film, even if she is not a “joint author” of the entire film.  This is an issue that is of concern not just to Google and other operators of video platforms – since it will broaden the range of parties entitled to require such operators to remove videos based on alleged copyright infringement – but also to the producers and other “joint authors” of films, who might have thought that they had the exclusive copyright interests in their work.  Google has indicated it will petition for rehearing en banc.