RIAA gets shut-down in a recent case.

A federal district judge has delivered a pretty resounding blow to a theory the RIAA has been using to win verdicts in its copyright-infringement lawsuit campaign. In Atlantic Records v. Howell, Judge Neil Wake refused the RIAA’s motion for summary judgment based on the “making available” theory.
The theory is that merely by making available to the public a copyrighted work the defendant “distributes” the work – regardless of whether the plaintiff can show actual distribution or if any distribution ever took place