was translated into Arabic and sparked death threats against her. But that proves the point: the gravamen of Garcia's harm is untethered from her commercial interests as a performer, and instead focuses on the personal pain caused by her association with the film.
The district court did not abuse its discretion in determining that Garcia failed to muster a clear showing of irreparable harm. See Flexible Lifeline Sys., Inc. v. Precision Lift, Inc., 654 F.3d 989, 999–1000 (9th Cir. 2011) ("Harm must be proved, not presumed." (quoting 4 Nimmer on Copyright § 14.06[A][5])).
In the face of a doubtful copyright claim and the absence of irreparable harm to Garcia's interests as an author, we need not consider the final two Winter factors, the balance of equities and public interest.
II. The Panel's Injunction
In February 2014, the panel majority issued the following injunction: "Google, Inc. shall take down all copies of 'Innocence of Muslims' from YouTube.com and from any other platforms under Google's control, and take all reasonable steps to prevent further uploads of 'Innocence of Muslims' to those platforms." Soon after, the panel amended the order to state that the prohibition did "not preclude the posting or display of any version of 'Innocence of Muslims' that does not include Cindy Lee Garcia's performance."
Although the first order was more sweeping, the second cast the court in the uneasy role of film editor. The amendment only mattered if Google assumed authority to change the content of someone else's copyrighted film. To
