Chamberlain v. Skylink
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Chamberlain v. Skylink, 381 F.3d 1178 (Fed. Cir. 2004), is an American legal case known for being one of the first uses of the Digital Millennium Copyright Act (DMCA) as a prosecution aid in a copyright case, setting the boundaries and limitations of the controversial act.
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[edit] The case
Chamberlain, a company known for automated door and gate openers, claimed that Skylink's Model 39 Universal GDO Transmitter infringed the Digital Millennium Copyright Act. The transmitter acted as a universal garage door opener, in which the consumer enters in a manufacturer's code through jumpers, bypassing the need for the original radio controlled garage door openers that shipped with original doors.
Chamberlain had added in a rolling code system to their garage doors. This system prevented possible intruders from recording and playing back door codes, as they were generated each time the remote was used. Skylink reverse engineered this system, and included a workaround in their own universal remotes. Chamberlain claimed that the reverse engineering of a rolling-code system constituted a violation of the DMCA, complaining that the Skylink universal remotes circumvent "technical measures" initiated in the original remotes.
[edit] Ruling
Judge Rebecca R. Pallmeyer of the United States District Court for the Northern District of Illinois rejected that claim. The United States Court of Appeals for the Federal Circuit upheld her decision on August 31, 2004 stating, among other things:
- "The plain language of the statute ... requires a plaintiff alleging circumvention (or trafficking) to prove that the defendant's access was unauthorized-a significant burden where, as here, the copyright laws authorize consumers to use the copy of Chamberlain's software embedded in the GDOs that they purchased. "
- "The DMCA emphatically did not "fundamentally alter" the legal landscape governing the reasonable expectations of consumers or competitors;..."
- "The DMCA, as part of the Copyright Act, does not limit the scope of the antitrust laws, either explicitly or implicitly. "
- "The DMCA does not create a new property right for copyright owners. Nor, for that matter, does it divest the public of the property rights that the Copyright Act has long granted to the public. The anticircumvention and anti-trafficking provisions of the DMCA create new grounds of liability. A copyright owner seeking to impose liability on an accused circumventor must demonstrate a reasonable relationship between the circumvention at issue and a use relating to a property right for which the Copyright Act permits the copyright owner to withhold authorization-as well as notice that authorization was withheld. A copyright owner seeking to impose liability on an accused trafficker must demonstrate that the trafficker's device enables either copyright infringement or a prohibited circumvention."
