United States v. Julius Chow Lieh Liu

OPINION

NGUYEN, Circuit Judge:

Julius Liu appeals his convictions and sentence for criminal copyright infringement and trafficking in counterfeit labels. Liu’s company, Super DVD, commercially replicated CDs and DVDs for various clients on a scale that subjects him to substantial criminal liability if a client— and, by extension, Liu — lacked permission from the copyright holder to make the copies.

Under the relevant criminal statutes, Liu’s guilt turns on whether he acted “willfully” and “knowingly.” We hold that the term “willfully” requires the government to prove that a defendant knew he was…