Kulick said the Ninth Circuit wanted to rewrite its December 2011 opinion to incorporate specific arguments UMG made.

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UMG's catalog is marketed through two distinct divisions, Universal Music Enterprises (in the U.S.) and Universal Strategic Marketing (outside the U.S.).

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YouTube has since responded, stating that UMG only has the power to do this in limited circumstances, and that UMG overstepped its authority in the Megaupload case.

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