We would also like to note that consensus lastyear grossly underestimated the impact of a pause and inventory drawdown ahead of the iPhone 4S refresh where estimates were significantly off.
For instance, a customer might get an e-mail reminding him that it is his mother-in-law's birthday next week, along with a suggestion for a present, plus a note of what he sent lastyear.
Instead, Universal argued, state common law applies. (As a side note, at the end of lastyear, the U.S. Copyright Office performed a study at the request of Congress and recommended that pre-72 sound recordings be placed under federal jurisdiction).