Vault Corp. v. Quaid Software Ltd.
U.S. legal case / From Wikipedia, the free encyclopedia
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Vault Corporation v Quaid Software Ltd. 847 F.2d 255 (5th Cir. 1988) is a case heard by the United States Court of Appeals for the Fifth Circuit that tested the extent of software copyright. The court held that making RAM copies as an essential step in utilizing software was permissible under §117 of the Copyright Act even if they are used for a purpose that the copyright holder did not intend. It also applied the "substantial noninfringing uses" test from Sony Corp. of America v. Universal City Studios, Inc. to hold that Quaid's software, which defeated Vault's copy protection mechanism, did not make Quaid liable for contributory infringement. It held that Quaid's software was not a derivative work of Vault's software, despite having approximately 30 characters of source code in common. Finally, it held that the Louisiana Software License Enforcement Act clause permitting a copyright holder to prohibit software decompilation or disassembly was preempted by the Copyright Act, and was therefore unenforceable.
Vault Corporation v. Quaid Software Limited | |
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Court | United States Court of Appeals for the Fifth Circuit |
Full case name | Vault Corporation v. Quaid Software Limited |
Decided | June 20 1988 |
Citation(s) | 847 F.2d 255 (5th Cir. 1988) |
Case history | |
Prior history | 655 F.Supp. 750 (E.D.La.1987) |
Holding | |
Quaid's RAM copies are not infringing and Quaid's software is not a derivative work. Quaid is not liable for contributory infringement because its software can be used for making fair use archival copies of software. The Louisiana License Act's clause prohibiting decompilation or disassembly is unenforceable because it is preempted by federal copyright law. | |
Court membership | |
Judge(s) sitting | Thomas Morrow Reavley, Carolyn Dineen King, Jerry Edwin Smith |
Case opinions | |
Majority | Thomas Morrow Reavley |
Laws applied | |
17 U.S.C. §101 et seq. (Copyright Act of 1976) |