[opendtv] Betamax decision citations and views
- From: John Willkie <johnwillkie@xxxxxxxxxxxxx>
- To: opendtv@xxxxxxxxxxxxx
- Date: Sat, 28 Jun 2008 19:10:31 -0400 (EDT)
To try to shed some light and not heat (aside from 'responding" to bert on the
Betamax decision, I decided to see how "the decision has survived the test of
time." In legal research, this involves seeing what subsequent decisions have
rested upon a holding or holdings in the Betamax decision, and how courts have
drawn distinctions in cases that cited Betamax yet held differently.
It's easiest to do this with Nexus/Lexus. Lacking an account at this time, the
next best is to use Sheppard's Citations, but I don't have time today to visit
the County Law Library. So, I have to use online sources.
Here's the full text of the decision, from an authoritative source
http://www.law.cornell.edu/copyright/cases/464_US_417.htm
Here's the Cornel Law School's Legal Information Institute main page on
Copyright http://topics.law.cornell.edu/wex/Copyright
Here's a good precis:
"A copyright gives the owner the exclusive right to reproduce, distribute,
perform, display, or license his work. See § 106 of the act. The owner
also receives the exclusive right to produce or license derivatives of
his
or her work. See § 201(d) of the act. Limited exceptions to this
exclusivity exist for types of "fair use", such as book reviews.
See § 107 of the act. To be covered by copyright a work must be
original and in a concrete "medium of expression." See § 102
of the act. Under current law, works are covered whether or not
a copyright notice is attached and whether or not the work is
registered."
Here's the page LII comes up with in response to a search for copyright cases
http://www.law.cornell.edu/supct/search/index.html?query=copyright
This case, which I alluded to previously, cites Betamax
http://www.law.cornell.edu/supct/search/display.html?terms=copyright&url=/supct/html/04-480.ZS.html
This is a U.S. Supreme Court decision; it's subsequent to Betamax, and it
draws some distinctions.
This holding in that case is really bad for bert.
Held: One who distributes a device with the object of promoting its use to
infringe copyright, as shown by clear expression or other affirmative steps
taken to foster infringement, going beyond mere distribution with knowledge of
third-party action, is liable for the resulting acts of infringement by third
parties using the device, regardless of the device’s lawful uses. Pp. 10—24.
And this is even worse: "The doctrine [in Betamax] absolves the equivocal
conduct of selling an item with lawful and unlawful uses and limits liability
to instances of more acute fault."
I found no other cases on findlaw or LII that addressed Betamax, but that's not
an exhaustive search; for that, I will have to refer to Shepard's.
Marci Hamilton opines on why the Betamax decision should be overturned. (I
gave some modern distinctions 'in another thread.'
)http://writ.news.findlaw.com/hamilton/20070419.html
Hope this helps non-fools.
John Willkie
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