Sony Corp of America vs. Universal City Studios
In a 1984 Supreme Court hearing, defendant, Sony Corporation of America was being sued by Universal City Studios, Inc. The case was known as the "Betamax" case and ruled that the creation of copied television shows for purposes of time-shifting is in fact fair use. This included the manufacturers of home video recording equipment such as Betamax and other video tape recorders to not be held liable for any infringement. The courts came to this conclusion to form a general test to assist in determining whether or not a device with recording capabilities is infringing the law of copyright. This test has caused some disputes with other courts throughout the nation in utilizing the case to challenge more recent infringement activities with sharing files on the internet. To form some background for the case, Sony created a video tape format called Betamax in the 1970's. Universal and Disney were not too sure of this innovation and its outcomes, but were aware of revisions to the copyright law being in their final stages with Congress. With that being said they knew Congress would be hesitant to undertake any new protections for the film industry. Instead both companies decided to sue Sony in the U.S. District Court of the Ninth Circuit in 1976 for making a device that can record and be used for copyright infringement as well as anyone who purchased such a device. Included in the complaint was an attempt to include a competition claim which fell under the Lanham Act of 1946 and was later dismissed. The District Court ruled for Sony two years later in 1978. Non-commercial home only use recordings were considered fair use and impacts the First Amendment served by its use. A home user basically didn’t publically mass produce copies and attempt to make a profit, so they weren’t a threat at the time. The ruling was quickly reversed by the U.S. Court of Appeals and held Sony accountable for contributory...
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