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
Argument	Oral argument
Case history
Prior	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	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
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist John P. Stevens · Sandra Day O'Connor
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 can instead be defended as fair use.^[1][2] 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 contributory infringement. The case was a boon to the home video market, as it created a legal safe harbor for the technology.^[3]

The broader legal consequence of the Supreme 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 for courts when applying the precedent to more recent file sharing technologies available for use on home computers and over the Internet.^[3]