There already has been. The relevant case law is LLC v ReDigi:
https://en.wikipedia.org/wiki/Capitol_Records,_LLC_v._ReDigi....
> On March 30, 2013, Judge Richard J. Sullivan ruled in favor of Capitol Records, explaining that the transfer of digital data from one storage medium to another constituted a violation of copyright, because the copy was ultimately an unauthorized reproduction, and therefore outside of the protection of the first-sale doctrine