Sony Corp. of America v. Universal City Studios Inc.
Sony Corp. of America v. Universal City Studios Inc. was an important 1984 Supreme Court case which allowed for the sale of the VCR to continue unimpeded. The case had its origins in the development of the Betamax cassette, which was introduced to the market in the 1970s by Sony. The technology allowed consumers to record television broadcasts and replay them at their convenience but also opened the possibility that these taped broadcasts could be shown to others or reproduced and sold for commercial gain by someone other than the company or person holding copyright on the broadcasts in question.
Sony Corp. of America v. Universal City Studios Inc. began as a case in District Court in central California, which began in 1976. Universal claimed that Sony was liable for any potential copyright infringement which might occur. During the course of the District Court trial, Universal presented evidence of 32 separate acts of copyright infringement. In its defense, Sony Corp. introduced testimony from broadcasters of sports and other programs who said they had no objection to the practice of "time-shifting." "Time-shifting" is defined as the act of recording a program for private viewing at a more convenient date, then erasing the program. Prior to Sony Corp. of America v. Universal City Studios Inc., both companies conducted polls showing that this was the primary use of such technologies.
The district court ruled against Universal, stating in its opinion that time-shifting was a legitimate practice. The court further ruled that even if violations of copyright law were to occur, Sony could not be held responsible for them. Sony then appealed the ruling to the Supreme Court, which heard the case in 1983 and issued its verdict in 1984.
In deciding the case of Sony Corp. of America v. Universal City Studios Inc., the Supreme Court based its decision on the question of whether Sony should be held liable for copyright violations and whether timeshifting was a legally defensible practice. In a five to four majority ruling in favor of Sony, the Supreme Court decided that Sony could not be held responsible for illegal practices.
The crux of the Supreme Court's opinion in Sony Corp. of America v. Universal City Studios Inc. was the question of whether "non-minimal harm" was caused by the manufacture and sale of Betamax technology. The Supreme Court concluded that Universal could not demonstrate that this was the case. In issuing its ruling in Sony Corp. of America v. Universal City Studios Inc., the Supreme Court also took into consideration the testimony of a number of broadcasters and television program creators who stated that they had no objection to standard time-shifting practices.
As a result of Sony Corp. of America v. Universal City Studios Inc., manufacture and sale of Betamax, VHS and other technologies allowing for reproduction and replay of televisual broadcasts was allowed to continue, leading to the expansion of the home video market.