Law School Case Brief
Sony Corp. of Am. v. Universal City Studios, Inc. - 464 U.S. 417, 104 S. Ct. 774 (1984)
Copyright protection has never accorded the copyright owner complete control over all possible uses of his work. Rather, it grants the copyright holder exclusive rights to use and to authorize the use of his work in five qualified ways, including reproduction of the copyrighted work in copies pursuant to 17 U.S.C.S. § 106. All reproductions of the work, however, are not within the exclusive domain of the copyright owner; some are in the public domain. Any individual may reproduce a copyrighted work for a fair use.
Petitioner Sony Corp manufactured and sold home video tape recorders. Respondents owned the copyrights to television programs broadcast on public airwaves. Some members of the general public use video tape recorders sold by petitioners to record some of these broadcasts, as well as a large number of other broadcasts. Respondents sued petitioners for copyright infringement, alleging that because consumers used petitioners' recorders to record respondents' copyrighted works, petitioners were liable for the copyright infringement allegedly committed by those consumers in violation of the Copyright Act. The district court held in favor of petitioners. The appellate court reversed.
Is the sale of petitioners' copying equipment to the general public violative of the rights conferred upon respondents by the Copyright Act?
The U.S. Supreme Court held that the sale of home video tape recorders to the general public did not constitute contributory infringement of copyrights on television programs because there was a significant likelihood that substantial numbers of copyright holders who license their works for broadcast on free television would not object to having their broadcasts time-shifted by private viewers, and the plaintiff copyright holders did not demonstrate that time-shifting would cause any likelihood of non-minimal harm to the potential market for, or the value of, their copyrighted works.
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