The U.S. District Court for the Southern District of California recently decided that it could not hold as a matter of law that CafePress, an e-commerce vendor that allows individuals to upload images of their artwork and designs for printing on items such as shirts, bags, and mugs, was entitled to DMCA safe-harbor protection. See Gardner v. CafePress, Inc., No. 3:13-cv-1108-GPC-JMA (S.D. Cal. Feb. 26, 2014).