In Perfect 10, Inc. v. Google, Inc., Case No. CV 04-9484 (C.D. Cal. July 26, 2010), the court issued a decision consistent with a recent line of cases1 that generally favors online service providers that establish and implement effective policies under the Digital Millennium Copyright Act (“DMCA”), keeps the burden to police infringement on content owners, and strictly construes the DMCA in determining whether content owners meet the DMCA notice requirements.2