Sony Corp. of America v. Universal City Studios, Inc.

Sony Corp. of America v. Universal City Studios, Inc.
Supreme Court of the United States
Argued January 18, 1983 Reargued October 3, 1983 Decided January 17, 1984
Full case name	Sony Corporation of America et al. v. Universal City Studios, Inc., et al.
Citations	464 U.S. 417 (more) 104 S. Ct. 774; 78 L. Ed. 2d 574; 1984 U.S. LEXIS 19; 52 U.S.L.W. 4090; 220 U.S.P.Q. (BNA) 665; 224 U.S.P.Q. (BNA) 736; 55 Rad. Reg. 2d (P & F) 156
Prior history	Unfair competition claims dismissed, 429 F. Supp. 407 (C.D. Cal. 1977); judgment for defendants, 480 F. Supp. 429 (C.D. Cal. 1979); affirmed in part, reversed in part and remanded, 659 F.2d 963 (9th Cir. 1981); rehearing denied, 9th Circuit, 1982; cert. granted, 457 U.S. 1116 (1982); reargument scheduled, 463 U.S. 1226 (1983)
Subsequent history	Rehearing denied, 465 U.S. 1112 (1984)
Holding
Manufacturers of home video recording machines could not be liable for contributory copyright infringement for the potential uses by its purchasers, because the devices were sold for legitimate purposes and had substantial non-infringing uses. Personal use of the machines to record broadcast television programs for later viewing constituted fair use. Ninth Circuit Court of Appeals reversed.
Court membership
Case opinions
Majority	Stevens, joined by Burger, Brennan, White, O'Connor
Dissent	Blackmun, joined by Marshall, Powell, Rehnquist
Laws applied
17 U.S.C. § 101 et seq. (Copyright Act of 1976)

Sony Corp. of America v. Universal City Studios, Inc., 464 U.S. 417 (1984), also known as the “Betamax case”, is a decision by the Supreme Court of the United States which ruled that the making of individual copies of complete television shows for purposes of time shifting does not constitute copyright infringement, but is fair use. The Court also ruled that the manufacturers of home video recording devices, such as Betamax or other VCRs (referred to as VTRs in the case), cannot be liable for infringement. The case was a boon to the home video market as it created a legal safe haven for the technology.

The broader legal consequence of the Court's decision was its establishment of a general test for determining whether a device with copying or recording capabilities ran afoul of copyright law. This test has created some interpretative challenges to courts in applying the case to more recent file sharing technologies available for use on home computers and over the Internet.

In the 1970s, Sony developed the Betamax video tape recording format. Universal Studios and the Walt Disney Company were among the film industry members who were wary of this development, but were also aware the U.S. Congress was in the final stages of a major revision of copyright law and would likely be hesitant to undertake any new protections for the film industry. The companies therefore opted to sue Sony and its distributors in California District Court in 1976, alleging that because Sony was manufacturing a device that could be used for copyright infringement, they were thus liable for any infringement committed by its purchasers. The complaint additionally included an unfair competition claim under the Lanham Act, but this was dismissed early in the course of the lawsuit.