It seems we may be having another Grokster moment in the law. Just as in the pre-Grokster era,when the staple article of ocmmerce doctrine of Sony Corporation v.Universal City Studios, Inc. was expanding beyond the realm of legitimate innovation to protect purposefully infringing activity-ultimately necessitating corrective action by the Supreme Court-so, too, the DMCA safe harbors, as construed in Viacom International, Inc. v. YouTube, Inc. and by some other courts, are threatening to swallow the very principles of secondary liability they were meant to incorporate.