What is the current state of the law on criminal copyright infringement?

In reviewing a conviction for criminal copyright infringement, we, and numerous other circuits, have assumed that proof of the defendant's specific intent to violate someone's copyright is required. See United States v. Beltran, 503 F.3d 1, 2 (1st Cir. 2007); United States v. Manzer, 69 F.3d 222, 227 (8th Cir. 1995); United States v. Minor, 756 F.2d 731, 734 (9th Cir. 1985); United States v. Gottesman, 724 F.2d 1517, 1522 (11th Cir. 1984); United States v. Whetzel, 589 F.2d 707, 712 (D.C. Cir. 1978);³ see also United States v. Heilman, 614 F.2d 1133, 1137 (7th Cir.

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