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In Re: Aimster Copyright Litigation

Citations: 334 F.3d 643; 67 U.S.P.Q. 2d (BNA) 1233; 2003 U.S. App. LEXIS 13229; 2003 WL 21488143Docket: 02-4125

Court: Court of Appeals for the Seventh Circuit; June 30, 2003; Federal Appellate Court

Narrative Opinion Summary

The case involves a legal dispute between major music copyright holders and the operators of the Aimster Internet service, later rebranded as Madster. The plaintiffs sought a preliminary injunction against the service, alleging contributory and vicarious copyright infringement. Aimster, akin to services like Napster, enabled users to share copyrighted music files, with encryption features that arguably prevented detection of infringing activities. The district court ruled in favor of the plaintiffs, finding a strong likelihood of success on both infringement claims. The court referenced the Sony Betamax case, emphasizing the necessity of demonstrating substantial non-infringing uses to avoid liability, which Aimster failed to do. Additionally, Aimster's reliance on the DMCA's safe harbor provisions was rejected due to its lack of efforts to curb infringement. The court issued a preliminary injunction against Aimster, determining that the potential harm to the music industry outweighed any business disruption Aimster might face. Aimster's objections, including claims of free speech infringement, were dismissed, affirming the injunction's scope and necessity in combating copyright violations.

Legal Issues Addressed

Contributory Copyright Infringement

Application: Aimster was found liable for contributory infringement by facilitating the swapping of copyrighted music files among users, as its service primarily enabled infringing activities.

Reasoning: The district judge determined that the recording industry has a strong likelihood of succeeding in its case regarding both vicarious and contributory infringement related to the Aimster file-sharing system.

Digital Millennium Copyright Act Safe Harbor Provisions

Application: Aimster was not entitled to DMCA safe harbor protections due to its failure to take reasonable steps to deter repeat infringers, instead facilitating infringement through user instructions.

Reasoning: While the DMCA offers safe harbors for ISPs, Aimster did not qualify because it failed to take reasonable steps to deter repeat infringers.

Fair Use Doctrine

Application: The court dismissed Aimster's argument of non-infringing use similar to the Sony Betamax case, citing a lack of evidence for substantial non-infringing uses.

Reasoning: Aimster's potential for non-infringing uses was deemed speculative; the service lacked evidence showing it was used for such purposes.

Preliminary Injunction Standards

Application: The court upheld the preliminary injunction against Aimster, finding that the potential harm to the recording industry outweighed any harm to Aimster.

Reasoning: The court found that any harm to Aimster was less severe than the irreparable harm the recording industry would suffer if the injunction were lifted.

Vicarious Copyright Infringement

Application: The court found Aimster potentially liable for vicarious infringement, as it indirectly benefitted from infringing activities without taking sufficient measures to prevent them.

Reasoning: Vicarious liability involves a principal's responsibility for the actions of an agent, but users of Aimster’s system are not its agents.