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From LaMacchia to the No Electronic Theft Act: Criminal Copyright Infringement and the New Digital Media

David LaMacchia was a student at the Massachusetts Institute of Technology (MIT). In 1994 he created two computer bulletin boards on the MIT computer network, Cynosure and Cynosure 11. 1 Hiding behind the veil of various pseudonyms, LaMacchia encouraged users to post software (Excel 5.0 and WordPerfect 6.0) and computer games (Sim City 2000) to Cynosure. After files were posted LaMacchia transferred them to a password protected address, Cynosure II. From this bulletin board users who knew the password could download any of the posted files to their own computers. Through this simple arrangement of bulletin boards LaMacchia made it possible for a large number of users to efficiently share copyrighted computer software with one another. Despite LaMacchia's best efforts to hide these bulletin boards, the sheer volume of traffic attracted the attention of both university officials and federal authorities. While LaMacchia's bulletin boards were quickly shut down by MIT it was not readily apparent to prosecutors that his actions were criminal. After considering a variety of charges, on April 7, 1994, a federal grand jury indicted LaMacchia for conspiring with "persons unknown" to violate the federal wire fraud statute. On September 30, 1994, LaMacchia's attorney brought a motion to dismiss the indictment claiming that the Supreme Court's decision in Dowling v. United States preempted the use of the wire fraud statute as a means to punish criminal copyright infringement. In United States v. LaMacchia, the U.S. District Court for Massachusetts agreed, and as a result dismissed the charge against LaMacchia (Lewis I 0). While this may seem a relatively trivial case, LaMacchia has had a dramatic effect on intellectual property law in the United States. In direct response to pressure brought by the copyright industry after the court's decision in LaMacchia, Congress adopted the No Electronic Theft (NET) Act. This article, an analysis of this little known but increasingly significant act, is organized in three parts. The first part offers a brief history of criminal copyright infringement in the United States, the second part discusses legislative responses to LaMacchia culminating with the passage of NET, and the final part offers an analysis of this controversial legislation.