than liability for contributory infringement of a copyright. See Sony Corp. v. Universal City Studios, 464 U.S. 417, 439 n. 19, 104 S.Ct. 774, 78 L.Ed.2d 574 (1984); Perfect 10, 494 F.3d at 806; Fonovisa, 76 F.3d at 265 (noting that "trademark infringement liability is more narrowly circumscribed than copyright infringement”). Under copyright law, generalized knowledge that copyright infringement may take place in an Internet venue is insufficient to impose contributory liability. See, e.g., A & M Records, Inc. v. Napster, Inc., 239 F.3d 1004, 1027 (9th Cir.2001) ("The mere existence of the Napster system, absent actual notice and Napster’s demonstrated failure to remove the offending material, is insufficient to impose contributory liability.”); Hendrickson, 165 F.Supp.2d at 1088-90 (<HOLDING>). 38 . Of course, a NOCI was not a notice of
holding that generalized notice of copyright infringements was insufficient to establish knowledge for the purpose of contributory liability holding that notice of judgment was insufficient holding that mere authorization and approval of copyright infringements taking place outside the united states is not a copyright violation and does not create jurisdiction over those extraterritorial acts holding that while the computer program at issue was within the subject matter of copyright the right sought under state law pursuant to a license was not equivalent to the exclusive rights under copyright as such copyright preemption did not apply holding manufacturers generalized knowledge of concerns insufficient to meet ucc notice requirement