[opendtv] News: Justices Reinstate Suits on Internet File Sharing
- From: Craig Birkmaier <craig@xxxxxxxxx>
- To: OpenDTV Mail List <opendtv@xxxxxxxxxxxxx>
- Date: Tue, 28 Jun 2005 07:27:40 -0400
http://www.nytimes.com/2005/06/28/technology/28grokster.html?th=&emc=th&pagewanted=all
Justices Reinstate Suits on Internet File Sharing
By LINDA GREENHOUSE and LORNE MANLY
Published: June 28, 2005
WASHINGTON, June 27 - The Supreme Court handed a major victory to the
entertainment and recording industries on Monday by reinstating a
copyright-infringement suit against two file-sharing services.
In a unanimous opinion, the court strongly suggested that the
services, Grokster and StreamCast Networks, should be found liable
for the vast copyright infringement committed by those using their
software to download music and movies.
Two lower federal courts in California had ruled in favor of the two
companies, dismissing the lawsuit without a trial on the basis of a
legal analysis that the Supreme Court found seriously flawed.
In his opinion for the court on Monday, Justice David H. Souter
suggested that when properly evaluated, the evidence against Grokster
and StreamCast was, in fact, so strong that the
entertainment-industry plaintiffs might be entitled to summary
judgment.
At the least, he said, MGM Studios and the other plaintiffs -
including the Recording Industry Association of America, the Motion
Picture Association of America and a class of 27,000 music publishers
and songwriters - were entitled to a trial to prove their accusations
that the file-sharing companies were in business primarily to enable
and induce computer users to find and download copyrighted material.
In the Supreme Court's view, the plaintiffs have effectively made
that case already. Justice Souter called the record "replete with
evidence" that the companies "acted with a purpose to cause copyright
violations by use of software suitable for illegal use." The opinion
referred to "evidence of infringement on a gigantic scale" and said
that "the probable scope of copyright infringement is staggering."
[Excerpts, Page C5.]
The movie and music industries, even armed with a decision affirming
their legal recourse, have a long way to go to capitalize on it, and
they plan new efforts to persuade or force those actually doing the
downloading to desist.
Digital rights advocates, while somewhat relieved that the court did
not go further, were concerned that the ruling could invite a deluge
of lawsuits and a risk that they would inhibit innovation.
There is no dispute that individual users violate copyright law when
they share files of copyrighted material, and the industry has had
some modest success in seeking fines from college students and
others. But with millions of users downloading billions of files each
month, retail prosecution proved inefficient, so the music and
entertainment industries turned their attention several years ago to
the commercial services that make the file sharing possible.
That effort led to the Supreme Court's most important copyright case
since its ruling in 1984 that shielded the manufacturers of the
videocassette recorder from copyright liability for possibly
infringing use by home consumers.
The court based its decision then, in Sony v. Universal City
Studios, on a finding that the VCR was "capable of substantial
noninfringing uses," like time-shifting, in which home users simply
recorded programs for viewing later.
In ruling last year for Grokster and StreamCast, the United States
Court of Appeals for the Ninth Circuit in San Francisco relied on the
Sony decision, finding that the file-sharing software had possible
noninfringing uses. Because the software operates in a decentralized
way without using a central computer, the appeals court found,
Grokster and StreamCast could not track users and had no direct
knowledge of any specific instance of infringement.
The Supreme Court on Monday held that the appeals court had
misapplied the Sony decision by focusing only on the technology,
without regard to the business model that the technology served.
"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, is liable for the resulting acts
of infringement by third parties," Justice Souter wrote.
Movie and music industry executives hailed the decision. "If you
build a business that aids and abets theft, you will be held
accountable," said Dan Glickman, chief executive of the Motion
Picture Association of America, the lobbying organization for the
major Hollywood studios. BMI, representing more than 300,000
songwriters and composers, called the decision "good news indeed for
the creative community whose work has been blatantly infringed."
The movie and music industries had warned that file sharing was
hurting them financially, and could ultimately inhibit the creation
of content. The music industry has blamed song-swapping over the
Internet for its decade-long sales slump.
While movies and television shows are more difficult to trade online
because of the size of their files, technological advances are making
that easier and threatening the rich source of cash that DVD sales
have become for the studios.
On the other hand, groups including the American Civil Liberties
Union, Consumers Union, the Consumer Electronics Association and
other elements of the computer and technology industries warned the
court that too broad a rule of contributory copyright infringement
would stifle innovation if there was a possibility that consumers
might put a product to an infringing use.
It was clear from the opinion, Metro-Goldwyn-Mayer Studios Inv. v.
Grokster Ltd., No. 04-480, that the justices had taken note of that
argument and tried to draw a line that would protect both copyright
holders and innovators. The court identified the line as "inducement"
- deliberately urging consumers to make illicit use of the product or
showing them how it could be done.
"Mere knowledge of infringing potential or of actual infringing uses
would not be enough here to subject a distributor to liability,"
Justice Souter said. He added: "Nor would ordinary acts incident to
product distribution, such as offering customers technical support or
product updates, support liability in themselves. The inducement
rule, instead, premises liability on purposeful, culpable expression
and conduct, and thus does nothing to compromise legitimate commerce
or discourage innovation having a lawful promise."
James Gibson, a professor of intellectual property and computer law
at the University of Richmond School of Law, applauded what he called
a balancing act between artistic creators and technological
innovators.
By putting so much weight on proving companies' bad behavior, he
said, the decision could create more legal expenses and
unpredictability for technology companies. At the same time, he
added, it should provide peace of mind to creators of technology that
could be used for both legitimate and infringing uses.
But several technology advocates expressed concern, saying innovators
would now be saddled with the befuddling notion of "intent." Matthew
Neco, StreamCast's general counsel, said the ruling turned Hollywood
and the recording industry into "thought police."
Michael Petricone, vice president for technology policy at the
Consumer Electronics Association, said that without clear guidelines
from the court on what a company must do to avoid being held liable
for contributing to copyright infringement, "the legal clarity has
decreased and the risk of litigation has increased."
Attorney General Alberto R. Gonzales said he was pleased the court
had "determined that those who intentionally induce or encourage the
theft of copyrighted music, movies, software or other protected works
may be held liable for their actions." The Bush administration joined
the argument in support of the studios.
While the court's judgment was unanimous, the justices did not share
the same view of how useful the Sony precedent remained after more
than 20 years of changing technology. A concurring opinion by Justice
Ruth Bader Ginsburg, which Chief Justice William H. Rehnquist and
Justice Anthony M. Kennedy joined, suggested that the Sony case's
reference to "substantial noninfringing use" was too easily
misunderstood by lower courts and might have to be tailored for
different types of technology.
The file-sharing software might be used to swap large numbers of
noninfringing files, Justice Ginsburg said, but even a big number
would be "dwarfed by the huge total volume of files shared."
Justice Stephen G. Breyer, in a concurring opinion also signed by
Justices John Paul Stevens and Sandra Day O'Connor, said the Sony
decision had basically achieved its "innovation-protecting objective"
and struck the right balance between protecting copyrights and
technology. It should be retained, he said.
Linda Greenhouse reported from Washington for this article and Lorne
Manly from New York. Jeff Leeds and Tom Zeller Jr. contributed
reporting.
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