Sony Corporation of America v. Universal City Studios, Inc

Citation. Sony Corp. of Am. v. Universal City Studios, Inc., 464 U.S. 417, 104 S. Ct. 774, 78 L. Ed. 2d 574, 1984 U.S. LEXIS 19, 220 U.S.P.Q. (BNA) 665, 224 U.S.P.Q. (BNA) 736, 52 U.S.L.W. 4090, 55 Rad. Reg. 2d (P & F) 156 (U.S. Jan. 17, 1984)

Brief Fact Summary. Movie studios (Plaintiff) that owned copyrights in movies and other television programming argued that Sony (Defendant) contributed to copyright infringement of their copyrighted works by marketing videocassette recorders (VCRs or VTRs) that enabled users to record the programs.

Synopsis of Rule of Law. One who supplies the way to accomplish an infringing activity and encourages that activity through advertisement is not liable for copyright infringement.

Facts. Sony Corp. (Sony) (Defendant) marketed Betamax videocassette recorders (VCRs or VTRs), which allowed home recording of televised programs.  Several movie studios (Plaintiff), holders of copyrights on televised movies and other televised programs, brought an action for contributory copyright infringement on the theory that Defendant was contributorily liable for infringement by consumers of VTRs of the studios’ (Plaintiff) copyrighted works on the basis of Sony’s (Defendant) marketing and distribution of the VTRs.  The district court, finding, inter alia, that no Sony (Defendant) employee had either direct involvement with the allegedly infringing activity or direct contact with purchasers of Betamax who recorded copyrighted works off-the-air, and that there was no evidence that any of the copies made by individuals were influenced or encouraged by Defendant’s advertisements, held that Defendant was not liable for direct or contributory copyright infringement.  The court of appeals reversed.  The United States Supreme Court granted certeriori.

Issue. Is one who supplies the way to accomplish an infringing activity and encourages that activity through advertisement liable for copyright infringement?