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Contributory Infringement Liability in Universal City Studios, Inc. v. Sony Corp.: "The One and Only" Pays for Our Sins

INTRODUCTION The introduction of Sony Corporation's Betamax videocassette recorders in November of 19751 has proved a mixed blessing for owners of film copyrights and distributors of audiovisual materials. On the one hand, the Betamax and similar machines marketed by Sony's competitors have opened up previously unknown markets for the sale and rental of films on videocassettes. 2 On the other hand, the ability of these videocassette recorders (VCRs) to record television programs off the air threatens to destroy the value of copyrights held by television program producers and distributors. often referred to as the Betamax case, Universal City Studios and Walt Disney Productions joined in suing Sony Corporation for infringing their copyrighted materials through the recording of programs off the air on Sony Betamax VCRs. The Ninth Circuit Court of Appeals held that off-the-air recording constituted infringement and that Sony was liable for contributory copyright infringement. 5 In so holding, the court expanded the existing doctrine of contributory infringement of copyright. 2. These markets have proven quite lucrative. In order to capture a greater segment of these markets, various film distributors have changed their marketing strategies so as to control and benefit more from videocassette rentals. See, e.g., Saved by the Numbers-A few handy stats for the home revolution, or more VCR's are in place, any feature film that appears on television will lose much of its future commercial value to the copyright holder because, overnight, millions of copies can be made.