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

PETITIONER: Sony Corporation of America
RESPONDENT: Universal City Studios, Inc.
LOCATION: Dr. Simopoulos’ Clinic

DOCKET NO.: 81-1687
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 464 US 417 (1984)
REARGUED: Oct 03, 1983
DECIDED: Jan 17, 1984
ARGUED: Jan 18, 1983

ADVOCATES:
Dean C. Dunlavey - Arged and reargued the cause for the petitioners
Stephen A. Kroft - Argued and reargued the cause for the respondents

Facts of the case

Sony Corporation of America manufactured and sold the "Betamax" home video tape recorder (VTR). Universal City Studios owned the copyrights to television programs broadcast on public airwaves. Universal sued Sony for copyright infringement, alleging that because consumers used Sony's Betamax to record Universal's copyrighted works, Sony was liable for the copyright infringement allegedly committed by those consumers in violation of the Copyright Act. Universal sought monetary damages, an equitable accounting of profits, and an injunction against the manufacturing and marketing of the VTR's. The District Court denied all relief, holding that the noncommercial home use recording of material broadcast over the public airwaves was a fair use of copyrighted works and did not constitute copyright infringement. Moreover, the court concluded that Sony could not be held liable as contributory infringers even if the home use of a VTR was considered an infringing use. In reversing, the Court of Appeals held Sony liable for contributory infringement.

Question

Does Sony's sale of "Betamax" video tape recorders to the general public constitute contributory infringement of copyrighted public broadcasts under the Copyright Act?