Chamberlain Group, Inc. v. Skylink Technologies, Inc.
American legal case concerning the DMCA / From Wikipedia, the free encyclopedia
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The Chamberlain Group, Inc. v. Skylink Technologies, Inc., 381 F.3d 1178 (Fed. Cir. 2004)[1] is a legal case heard by the United States Court of Appeals for the Federal Circuit concerning the anti-trafficking provision of the Digital Millennium Copyright Act (DMCA), 17 U.S.C. § 1201(a)(2), in the context of two competing universal garage door opener companies. It discusses the statutory structure and legislative history of the DMCA to help clarify the intent of the anti-circumvention provisions and decide who holds the burden of proof. It expresses that the statute creates a cause of action for liability and does not create a property right, and holds that as Chamberlain had alleged that Skylink was in violation of the anti-trafficking provision, it had the burden to prove and failed to show that access was unauthorized and its rights were infringed under the Copyright Act. As Chamberlain incorrectly argued that Skylink had the burden of proof and failed to prove their claim, the court upheld summary judgment in favor of Skylink.
The Chamberlain Group, Inc. v. Skylink Technologies, Inc. | |
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Court | United States Court of Appeals for the Federal Circuit |
Decided | Aug. 31, 2004 |
Citation | 381 F.3d 1178 |
Court membership | |
Judges sitting | Arthur J. Gajarsa, Richard Linn, Sharon Prost |
Case opinions | |
Maker of replacement garage door openers (GDOs) did not violate the anti-trafficking provisions of the Digital Millennium Copyright Act (DMCA), because owners of GDOs were authorized to access Plaintiff's GDO software and Plaintiff failed to allege or show a nexus between access and copyright infringement. Plaintiff had the burden to prove that Skylink's Model 39 garage door openers violated the DMCA and failed to do so. Summary judgment upheld in favor of Skylink. | |
Keywords | |
Digital Millennium Copyright Act, Anti-circumvention |