The Ninth Circuit, sitting en banc, has reversed an earlier ruling by a three-judge panel that had dramatically expanded copyright protection for individual performances in a film and required Google to remove an anti-Muslim YouTube video from YouTube.  The panel decision had recognized plaintiff Cindy Lee Garcia’s copyright interest in her five-second performance in “The Innocence of Muslims” and, due to death threats Garcia received as a result of the film, ordered Google to take it down from YouTube.  But the en banc court found that Garcia was not entitled to a preliminary injunction because she had not shown that she had a copyright interest in her performance in the film and the potential harm to her had nothing to do with any copyright interest, anyway.