Here is another video of a Ninth Circuit oral argument. The case is VMG SALSOUL, LLC v. Ciccone, 824 F.3d 871 (9th Cir. 2016). One of the issues in the case was whether Madonna Ciccone’s (aka Madonna) use of a 0.23 second horn recording from another artist’s song in Madonna’s song Vogue constituted “de minimis” use under copyright law. In a split from the Sixth Circuit, the Ninth Circuit said that Madonna’s use was “de minimis” use. This is believed to be the first time that the Ninth Circuit has applied the “de minimis” use exception to sound recordings. You can read the Ninth Circuit opinion [here].