The United States Court of Appeals for the District of Columbia Circuit recently issued its decision in Matthew Green v. DOJ, rejecting a First Amendment challenge to section 1201 of the Digital Millenium Copyright Act (“DMCA”). Section 1201 prohibits the circumvention of technological protections on copyrighted works and the distribution of the means to circumvent. Section 1201 also gives the Librarian of Congress the authority to conduct a triennial rulemaking to grant temporary exemptions to the general prohibition on circumvention in certain instances.