When Satire Stands Its Ground
By Matthew B. Harrison
TALKERS, VP/Associate Publisher
Harrison Legal Group, Senior Partner
Goodphone Communications, Executive Producer
When we first covered this case, it felt like only 2024 could invent it – a disgraced congressman, George Santos, selling Cameos and a late-night host, Jimmy Kimmel, buying them under fake names to make a point about truth and ego. A year later, the Second Circuit turned that punchline into precedent. (Read story here: https://talkers.com/2024/12/19/jimmy-kimmels-fair-use-victory-what-it-means-for-content-creators/)
And just to clear the record: this has nothing to do with Jimmy Kimmel’s unrelated dust-up with FCC Commissioner Brendan Carr. Different story, different planet. This one’s about copyright and commentary – and it’s a clear win for both.
The Set-Up
After his expulsion from Congress, George Santos began offering paid video shout-outs on Cameo. Kimmel’s writers sent absurd requests under pseudonyms for a segment called “Will Santos Say It?” – and he did. The show aired those clips to highlight how easily a public figure would say anything for a fee.
(If you want a taste, look up “Jimmy Kimmel Pranks George Santos on Cameo” on YouTube. That’s the kind of transformative satire the court later called “sarcastic criticism and commentary.”)
Santos sued Kimmel, ABC, and Disney for copyright infringement, fraud, and breach of contract, claiming the videos were sold for “personal use.” The district court tossed it; Santos appealed.
The Ruling
On September 15, 2025, the Second Circuit unanimously affirmed the dismissal. The panel said Kimmel’s use was transformative: he turned Santos’s self-promotion into political satire. Even Santos’s complaint described the bit as sarcastic commentary.
Claims of “market harm” fell flat. Airing a few clips on network TV doesn’t compete with Cameo. Embarrassment isn’t economic loss.
And the supposed bad faith – using fake names to order the clips – didn’t undo fair use. The court stuck to the statutory factors: purpose, nature, amount, and effect. Mischief isn’t a fifth one.
The rest of the claims – fraud, contract, enrichment – stayed dismissed as pre-empted or too thin to matter.
Why It Matters
This decision lands as courts wrestle with whether AI’s use of copyrighted works can ever be “transformative.” Santos v. Kimmel shows what that word really means: a human taking existing material and using it to say something new.
Fair use protects meaning, not mimicry. That’s why satire, commentary, and criticism still stand when they have a point.
For media creators, the lesson is simple: transformation beats permission. If you use third-party material, make sure you’re adding perspective – not just recycling content. That, more than any fine print, is what keeps you on the right side of the line.
Matthew B. Harrison is a media and intellectual property attorney who advises radio hosts, content creators, and creative entrepreneurs. He has written extensively on fair use, AI law, and the future of digital rights. Reach him at Matthew@HarrisonLegalGroup.com or read more at TALKERS.com.
company’s WRNW-FM, Milwaukee “97.3 The Game,” and KBME-AM, Houston “SportsTalk 790” morning host Sean Salisbury. Salisbury tweeted, “It’s been a hell of a run the last 8 years [at] SportsTalk 790. I fully understand the financial decisions that corporate has to make. I appreciate the great bosses at iHeart that I got to work with and here in Houston, who have become friends too. Very grateful for good coworkers and the talent you hear daily on the SportsTalk 790 lineup. I’m so blessed to have worked with special teammates/friends on my show every morning, you know my love for you guys!” Also, a victim of this latest round of cuts is Salt Lake City market manager Joyce Wirthlin. 
successful political and cultural programs.” The new Megyn Kelly channel will also feature brand-new programming, including the debut of an exclusive daily after-show program. Additional series, shows, and specials will be announced in the coming weeks. Kelly comments, “Linear television news is dead. People can’t stand those stilted, censored conversations anymore, which is exactly why this medium is thriving. I’m thrilled to deliver our bold brand of no-BS news live on SiriusXM and to be expanding my relationship with such a stellar, blue-chip brand and great partner. Soon our listeners will have the Megyn Kelly Channel to enjoy and trust for the conversations and content they love.”
cluster that was recently acquired from Alpha Media. Handwerger, who assumes his new role on October 16, will take over for current market manager Robert Dove, who is retiring at the end of the year and will transition to an advisory role until then. Connoisseur Media CEO Jeff Warshaw states, “Portland is a major part of who we are. It’s a great market with incredible talent and strong brands. Mark’s the right person to lead this next chapter. He understands how to connect with the community and drive results, and that’s exactly what we want in a local leader.”
operations manager for the station group that includes news/talk WERE-AM. Urban One SVP of programming Colby Tyner comments, “These leadership changes reflect the incredible depth of talent within Radio One. It’s exciting to see so many of our team members grow within the company and take on new challenges across markets. By empowering our brightest minds to share fresh ideas and perspectives, we ensure our stations remain dynamic, creative, and deeply connected to the communities we serve.”
of NBC and Hubbard Radio president and general manager Joel Oxley. The Media Mixer series is designed to “celebrate the camaraderie of the broadcasting community and bring to light the charitable mission of the BFOA to provide a lifeline to colleagues in acute need from illness or disaster.” BFoA chair Scott Herman says, “We thank the NAB for providing this impressive event space at their headquarters, and we’re grateful to Curtis, Kelly, and Joel for their support in making this event a success for all attendees. Our Media Mixers bring together junior and senior level broadcast professionals and on-air celebrities, while raising the profile of our mission to help every broadcaster who qualifies for aid.” 
company’s four stations that includes sports talk KKSE-AM/FM. Clary most recently served with Salem Media Group as regional multimedia sales manager and takes over for Dave Fleck who left the company to start up his own company. Clary comments, “I am incredibly excited to join an organization with such a passionate fan base and an unparalleled portfolio of teams and venues. I look forward to contributing to the continued success and growth of the KSE family.”
These aren’t just bulletin boards. They’re extensions of your station, where listeners expect to be acknowledged and advertisers expect to see results.
but sources tell Reuters that it would likely be sometime after November. Senate Commerce Committee Chair Ted Cruz criticized Carr for comments he made on the Benny Johnson podcast about late night talk host Jimmy Kimmel’s joke that appeared to threaten ABC/Disney and promise FCC action against the company if it didn’t take action on its own. On his Premiere Networks distributed podcast, “The Verdict with Ted Cruz,” Cruz said of Carr’s comments, “I got to say that’s right out of ‘Goodfellas.’ That’s right out of a Mafioso coming into a bar going, ‘Nice bar you have here. It would be a shame if something happened to it.’” Carr recently said that’s not what he meant and stated, “We don’t want to see weaponization of government by any administration against any perspective – and that’s certainly not what we’re doing here.”
With topics ranging from Mars and UFOs to flying cars and ‘civilization starter kits,’ each episode blends science, technology, and imagination with the real choices shaping our world.” For example, on this week’s program Cirilli welcomes Harvard astrophysicist Dr. Avi Loeb for a conversation about comet 3I/ATLAS, alien tech, and the future of space exploration. He also chats with Rich Cooper, vice president of strategic communication and outreach for Space Foundation, about America’s $1 trillion space economy and why investing in space isn’t just about exploration – it’s about building America’s economic future. Premiere Networks president Julie Talbott states, “We’re thrilled to welcome ‘Hello Future’ to the network. With years of experience as a journalist covering global affairs, technology and policy, Kevin has the unique ability to connect the dots between science and the future for listeners who crave bold ideas and fresh perspectives on what’s ahead.”
unapologetically conservative, culturally aware, and authentically Black voices to the forefront – voices that have been ignored for far too long. This show is about faith, family, freedom, and fearless truth-telling. I’m proud to be part of a network that values bold ideas and real conversations, and I can’t wait to shake things up.” Separately, Cumulus announces that “The Next Role with Vernon Davis” also joins the Cumulus Podcast Network. Former NFL star and Super Bowl champion turned actor and producer Vernon Davis’ podcast focuses on career transition and reinvention. Davis says, “The Next Role is more than a podcast – it’s a movement. I created this show to highlight the courage it takes to reinvent yourself, especially after a career in the spotlight. Partnering with the Cumulus Podcast Network gives me the platform to amplify these powerful stories and connect with listeners who are navigating their own transitions. I’m excited to bring these conversations to life and inspire others to embrace their next chapter.” 
Beaumont region for over five decades known for his authenticity, passion, and a deep love for Beaumont and its people. Caldwell is now 89 yet he continues to wake up at 4:00 am to entertain and inform his long standing and loyal fan base. Chamber president Amy Lavoi says, “Al Caldwell is more than just a radio personality – he’s the voice of our community. Through decades of broadcasting and public service, Al has uplifted this city with his humor, insight, and compassion. We are honored to recognize him as our 2025 Man of the Year.” Caldwell comments, “This community has given me so much over the years and being recognized by the Chamber as ‘Man of the Year’ is truly humbling. I love telling stories, sharing laughs, connecting with listeners, and waking up before the sun to be part of their day.” The award will be presented at the Chamber’s Annual Meeting on October 7 at the Beaumont Civic Center.
entertainment & integrated marketing Jeff Meza says, “Cultural ROI is the vehicle for us at Urban One to further our mission to help educate the industry and brand partners alike on the importance that intentions must be rooted in strategy, and this new economy requires development of total market plans that are inclusive and representative of authentic experiences.” Urban One VP, television and digital research Audrey Cochran adds, “I am incredibly proud of the work we’ve done to quantify the undeniable impact that Black consumers have on U.S. culture. This study not only demonstrates their impact and influence on broader consumer behavior but also underscores the value of authentically connecting with this segment – and the business risks of failing to do so.” 
As a media consultant, my team has had the privilege of being engaged extensively by members of the C-Suite. Becoming a member of the C-Suite is a common goal. To get into any group, acceptance often depends on acting and appearing like established members. Here are some of the actions observed of business masters whom we consulted:
number of issues based on data from Edison Research’s ongoing Share of Ear study. One aspect of AM/FM radio’s strength is its ability to reach the country’s political segments. The post notes, “Among registered voters, AM/FM radio has a 67% share of ad-supported audio, followed by podcasts (20%). Whether the target is Independents, Republicans, or Democrats, AM/FM radio shares are in the mid-60s to low 70s.” 
licensed to Walton, New York – previously aired a country format and a news/talk format, respectively. Bold Gold Media Group president Vince Benedetto says, “We have a deep love and connection to the Catskill Mountains and Delaware County, and we are very much looking forward to bringing our programming to the wonderful community of Walton. For a long time, we have had the privilege serving the neighboring town of Hancock, and very much look forward to extending our local programming to include even more of the residents of Delaware County.”