Why the Anti-Circumvention Clause of the DMCA Should be Repealed and Why DRM May be Malicious and Anti-Competitive

 

Karl Reichenberger

 

Idependent Study with Professor Nicholas Johnson

 

April 21, 2006

 

I.          Ongoing Tension: The Incentive Ends v. the Costly Means. 2

A.         The Balancing Act of Copyright Law.. 2

B.         The Scales are Tipped; Digitization and Internet Communications. 4

C.        Overcorrection: A Look at Sony Rootkit Copyright Protection Technology. 6

II.        The Digital Millennium Copyright Act Was Passed to Protect Copyrighted Works in the Age of Digital Transmission. 9

A.         Lobbyists Buy the DMCA.. 9

B.         The Anti-Circumvention Provisions. 10

C.        Digital Rights Management Technology and Copyright Protection Technology Adds Strength to the DMCA’s Bite. 12

D.        Mass Piracy Is Not Deterred by DRM or the DMCA; the Loser is the Non-Technically Savvy Law Abiding Customer. 13

III.       The Anti-Circumvention Clause of the DMCA Improperly Expands the Effective Scope of Copyright Law   15

A.         Maximum Protection for Some Copyright Owners Does Not Necessarily Promote the Progress of Science and Useful Arts; The Landes & Posner Model for Understanding Copyright 16

B.         The DMCA Increases the Costs of Creating New Intellectual Property; Landes & Posner Applied  18

IV.       The Anti-Circumvention Clause of the DMCA Improperly Eviscerates Fair Use. 21

V.        The DMCA Destroys the First Sale Doctrine by Making Illegal the Activities Necessary to Resell or Transfer the Copyrighted Work; the Destruction of the First Sale Doctrine Runs Afoul of both the Copyright Clause and the Specific Policies Behind the First Sale Doctrine. 29

VI.       When the Public Cannot Practice Fair Use Without Violating a Law, Free Speech is Restricted  32

VII.     The DMCA Enables Malicious and Anticompetitive DRM... 37

A.         Law Should Restrict Malicious DRM Technology Such as the Sony BMG Rootkit Software  37

B.         The Sony BMG Software is Anticompetitive; Using Oligopoly Power and Malicious DRM to Force Users to Products in Other Markets is Anticompetitive and Anti-consumer. 39

C.        Recent DMCA Case Law Both Highlights the Potential Abuses of the DMCA and Provides Some Hope. 42

1.         Chamberlain Group v. Skylink Technologies. 42

2.         Lexmark International, Inc. v. Static Control Components, Inc. 44

3.         Chamberlain and Lexmark Highlight the Potential for
Abuse of the DMCA.. 45

VIII.    The Anti-Circumvention Clause of the DMCA Should be Repealed Unless the Offender is Distributing Tools Designed Primarily for Mass Infringement 46

 

The Anti-Circumvention Clause of the Digital Millennium Copyright Act should be repealed. When combined with the latest Digital Rights Management technology, the DMCA creates an intellectual property scheme that gives content creators greater protection than necessary to promote the progress of the useful arts and that restricts the public interests of fair use and free speech.

 

I.   Ongoing Tension: The Incentive Ends v. the Costly Means

 

A.   The Balancing Act of Copyright Law

 

     Historical statements from Framers of the Constitution, such as George Washington, evidence an intent for copyright law to create a marketplace of writings.[1] This goal of a marketplace of writings was driven by visions of liberty rather than visions of money.[2] The Framers were acutely aware of the dangers of overly intrusive government.[3] Indeed, the Copyright Clause may explicitly mention that rights should vest in authors because removal of publishing power from the state was thought necessary to prevent tyranny and to nurture liberty.[4]

     Thus, the end aimed for by the Copyright Clause of the Constitution was more liberty through a marketplace of writings. The means chosen were exclusive rights to authors and inventors. The Framers were surely aware that exclusive rights for some would mean restricted rights for others. However, given the high level of importance the Framers placed on free speech and liberty, it is unlikely they envisioned or could have predicted the extent of the tension between private protection and public access their system would create.

     Little in law or life is ever truly new. The tension between copyright protection and uses of the public has existed since the beginning of the Copyright Act. Throughout this time, this tension has been highlighted by the conflict between authors’ media and copy technology. Advances in print technology threatened to harm printed books and newspapers, Xerox machines further threatened printed media, audio cassette tapes and radio, video recorders and television; and the trend continues today. Recently, however, this tension has accelerated due to unprecedented advances in personal technology over the past few decades.

     Two advances that have most accelerated the tension between copyright protection and public access are digitization and mass high-speed Internet access. In all direct ways, these two technologies are no different than their predecessors; they increase the speed and precision of copying, while decreasing the cost. However, the state these technologies triggered is new. For arguably the first time, the average American truly has access to “instantaneous, ubiquitous, no-cost communication.”[5] Copies may be transferred over this communications infrastructure, and they are low cost and perfect.

    

B.   The Scales are Tipped; Digitization and Internet Communications

 

Copyright holders have never had more to worry about. Prior to digitization and high-speed internet, a single casual infringer could do little damage; much effort was required to create and distribute copyrighted materials en masse. Technical barriers caused this relatively high level of necessary effort. First, analog copies are less than perfect, and expensive equipment is required to obtain a high quality digital-to-analog or analog-to-analog copy.[6] Second, copies took the form of a physical object; the copy was no more convenient to handle or transfer than the original. Third, relative to broadband, the transfer of copied files was difficult and very slow.

Even in the mid 1990s, when CD-Recordable devices were popular but broadband Internet was not, a CDROM copy of a compact disk, a digital bit-for-bit perfect copy, took significant time and effort to create and distribute. For example, prior to college dormitories wired with Ethernet, a student wishing to distribute the latest top CD to a floor of 50 students needed to (1) buy a spindle of 50 CDROM disks; (2) go through the copying (burning) process 50 times; and (3) walk 50 disks down the hall.

Contrast this relatively slow and expensive copying process to the current situation. Weeks before the latest top CD is officially released to the public, students at universities across the country can download a close-to-perfect copy of the disk from the Peer-to-Peer (P2P) utility du jour.[7]

Copyright owners, understandably, do not like the current situation. While copyright owners turned a blind-eye to the Internet for a few early years, they are now acutely aware of the copy enabling nature of the Internet. Consider the introductory text to a 2002 U.S. Senate “Content Protection Status Report”: “While positive progress is being made on many fronts, ever-increasing levels of online piracy may destroy the market for digital entertainment before it has a chance to be fully birthed.”[8] The wording of this quote seems to draw on George Washington’s goal of creating a marketplace of expression. On one hand, copyright owners argue that something must happen to protect their marketplace from technically savvy teenagers. On the other hand, access advocates argue that increased protection of copyright will only restrict the availability of expressive works, shrinking the marketplace the Founders sought to nurture with copyright.

In an effort to correct the scales, copyright owners have put their money where their mouths are, successfully lobbying for the Digital Millennium Copyright Act (DMCA) and developing restrictive copy protection technology called “Digital Rights Management” (DRM).

C.   Overcorrection: A Look at Sony Rootkit Copyright Protection Technology

On October 31, 2005, an expert computer engineer named Mark Russinovich[9] discovered that software behaving like a virus had been installed on his personal computer.[10] Mr. Russinovich was initially confused and could not guess the source of the troublesome software. While the computer software and movie industries had used copy protection technology for years, compact disk stereo audio had remained unencumbered by such technology. However, on further review, Mr. Russinovich found that software known as a Rootkit had been installed by Sony BMG with a recent compact disk (CD) he had played on his computer.[11] In Russinovich’s words, “Rootkits are cloaking technologies that hide files, Registry keys, and other system objects from diagnostic and security software, and they are usually employed by malware attempting to keep their implementation hidden . . . .”[12] After he initially discovered the Rootkit he began extensive testing of his system in an effort to determine the source and extent of the damage.[13] Although the source was well cloaked, he eventually discovered that the Rootkit was developed by First 4 Internet, Ltd.[14] Mr. Russinovich further traced the Rootkit back to a Sony BMG compact disk (CD) from country music group Van Zant.[15]

Mr. Russinovich described the experience with these words:

Not only had Sony put software on my system that uses techniques commonly used by malware to mask its presence, the software is poorly written and provides no means for uninstall. Worse, most users that stumble across the cloaked files with a [simple] scan will cripple their computer if they attempt the obvious step of deleting the cloaked files.[16]

Equally alarming, Mr. Russinovich discovered that the software (1) restricted use to Sony Media Player software when played on a Windows PC; (2) distorted the sound if the user attempted play in different software; (3) restricted his ability to rip or copy the CD; (4) only allowed transfer to Sony hardware devices (i.e., transfer to Apple iPod devices was not allowed); (5) remained in memory at all times, wasting system resources; and (6) communicated with Sony when the CD was accessed.[17]    

What began as one expert telling the world of Sony’s DRM technology grew into a story for the mass media as the technical population of the Internet spread the story. Soon media outlets such as the Washington Post,[18] BBC,[19] Boston Globe,[20] and Fox News[21] were covering the story. As more people caught wind of the story, they started expressing their displeasure with Sony’s actions by posting to Internet forums and commercial sites, such as News.com that allow users to comment on news stories. Posters to these boards were calling for the boycott of Sony products for the 2005 holiday season.[22] Perhaps most importantly, on Amazon.com’s CD store, users began warning potential Sony CD buyers of the malicious nature of Sony’s Rootkit DRM. Amazon.com’s CD store contains a unique feature called “Sales Rank” that ranks products available for sale based on daily sales. Needless to say, the Amazon.com Sales Rank of the copy protected CDs dropped rapidly. One story reported that:

Thomas Hesse, President of Sony BMG's global digital business division, showed up on NPR to try and sweep the entire thing under the rug: ‘Most people, I think, don't even know what a Rootkit is, so why should they care about it,’ he asked? ‘The software is designed to protect our CDs from unauthorized copying, ripping.’[23]

In addition to the dropping Sony Sales Rank on Amazon and the already negative press regarding the Rootkit technology, hackers began realizing the potential of Sony’s technology. Hackers soon developed and began circulating a virus was that used vulnerabilities in Sony’s code to harm the user’s system and further spread itself undetected.[24] Antivirus companies began listing the Sony’s code as a virus.[25] This is the reason Sony BMG cited for recalling all CDs embedded with the Rootkit DRM.[26]

While Sony BMG was burnt by its overly aggressive DRM technology on this occasion, they remain committed to DRM.[27] Seemingly, at the top of Sony’s priority list is to develop a DRM technology that will not expose consumer’s computers to attacks, but will retain the same relative level of use and copy restriction.[28] Less than three months after the Sony Rootkit debacle, Sony tried at least two more copy protection measures.[29] One such copy protection measure is still in use.[30] Sony had not recalled CDs containing this technology, presumably because a hacker has not yet circulated a virus exploiting the technology. Sony has at least taken a less covert approach with this technology, including a warning insert with the CD.[31] The language of this insert tells customers exactly where they stand, explaining that the CD installs resident software onto a PC, will not work with many [PCs], and will not work with many CD players.[32] The insert then explains that the CD may not be returned except for manufacturing defects.[33] These warnings and terms are not included on the exterior of the disk.[34]

 

II.  The Digital Millennium Copyright Act Was Passed to Protect Copyrighted Works in the Age of Digital Transmission

 

A.   Lobbyists Buy the DMCA

 

With some apparent degree of foresight, the Recording Industry Association of America (RIAA), the Motion Picture Association of America (MPAA), the Business Software Alliance (BSA), and the Association of American Publishers (AAP) “lobbied for the DMCA while it was in Congress.”[35] The chief sponsor of the DMCA, Congessman Howard Coble (R-North Carolina), and his co-sponsor Senator Dianne Feinstein (D-California), both received a lot of money from the TV, movie, and music industries in 1998.[36] Opensecrets.org compiles and publishes money spent by industry and lobbying groups and given to political officials and candidates. The Opensecrets.org industry category encompassing TV, movie, and music companies was the top industry category supporting Rep. Coble in 1998.[37] Rep. Coble was also the second highest recipient of PAC money from TV, movie, and music in 1998.[38] Senator Feinstein is also strongly supported by TV, movies, and music, having received $300,872 from these industries during the 1993 to 1998 time period.[39] Lobbyists from the TV, movie, and music industries spent $30,942,761 reported dollars in 1998.[40]

The industry did not spend at this level again until a few years later, in 2001.[41] The DMCA received little opposition.[42]

 

B.   The Anti-Circumvention Provisions

 

Chapter 12 of the Digital Millennium Copyright Act, titled “Copyright Protection and Management Systems,” contains an aggressive expansion of copyright embodied in sections 1201 through 1205. Section 1201(a)(1)(A) prohibits the circumvention of “a technological measure that effectively controls access to a work protected under this title.”[43] Section 1201(a)(2) contains prohibitions against devices designed to accomplish the circumvention described in (a)(1).[44] Section 1201(a)(3) defines “circumvent a technological measure” as “to descramble a scrambled work, to decrypt an encrypted work, or otherwise to avoid, bypass, remove, deactivate, or impair a technological measure, without the authority of the copyright owner.”[45] Moreover, “a technological measure ‘effectively controls access to a work’ if the measure, in the ordinary course of its operation, requires the application of information, or a process or treatment, with the authority of the copyright owner, to gain access to the work.”[46] Section 1203 provides for civil remedies that include actual or statutory damages, with statutory damages equaling up to $2,500 per act of circumvention.[47] Section 1204 provides for criminal offenses and penalties if the circumvention was willful “and for purposes of commercial advantage or private financial gain.”[48]

     One important point to note before continuing is that section 1201 of the DMCA does not expressly expand any rights of the copyright owner.[49] Rather, section 1201 only expressly expands the methods of enforcement of copyright owners’ basic rights. Title 17, Section 106 of the United States Code defines a copyright owner’s exclusive rights in copyrighted works.[50] Nothing in section 1201 of the DMCA explicitly expands these rights. However, this Paper will frequently refer to the DMCA as an expansion of copyright law or copyright protection.[51] Additional methods of enforcement, including high statutory damages and criminal penalties, may only increase the effectiveness of the copyright laws.[52] At least one commentator has characterized the DMCA as effectually creating “an anti-circumvention right that is materially different from and much more sweeping than the underlying copyright.”[53] Regardless of how one characterizes the DMCA, either as an expansion of copyright or as a simple increase in enforcement means, the result is the same: the consumer has fewer rights and the copyright owner is more protected from infringement.

 

C.   Digital Rights Management Technology and Copyright Protection Technology Adds Strength to the DMCA’s Bite

 

Because of the difficulty of curbing widespread copyright infringement,[54] business has increasingly looked to private copy protection measures. The industries supporting these measures and the DMCA lovingly call the technology “Digital Rights Management” (DRM). While these industries and legislators primarily sell DRM to the public as a means to keep Hollywood safe from content pirates,[55] big business has not ignored its potential as a means to greater profit levels and control of customer behavior.[56]

DRM technology, even in the absence of enforcing laws, provides a certain level of protection for copyright owners. Many of the consuming public will neither be able nor motivated enough to break DRM protection. The time and effort necessary to research and break DRM will generally deter casual copyright infringers. While there will always be a certain population of the public that will infringe copyright regardless of technical and legal protections,[57] DRM technology provides copyright owners with more practical profit protection than mere copyright law. In other words, at least some people will not infringe copyright due to DRM technology.

However, when one combines the practical and deterrent effects of DRM technology with the civil and criminal penalties of DMCA circumvention, the result provides a powerful sword for copyright owners wishing to strike down would be infringers of copyright. The recent Sony BMG Rootkit scandal highlights the severity of the problem. DRM technology plus the DMCA present a serious threat to the public domain and consumer rights.

 

D.   Mass Piracy Is Not Deterred by DRM or the DMCA; the Loser is the Non-Technically Savvy Law Abiding Customer

 

All copy protection can and will be broken. The public masses will always win the copy protection arms race. Consider the “unbreakable” copy protection of the Microsoft Xbox 360, a closed and proprietary platform developed by the richest software company in the world.[58] Within weeks of the release of the Xbox 360, a team of hackers cracked into the software that runs the system and developed an extractor tool that allows savvy users to copy games.[59] In the same vein, distributors of pirated music will continue to pirate and distribute copyrighted goods. The international nature of the Internet makes controlling hacking groups generally beyond the reach and capability of the DMCA. Bypassing the Content-Scrambling System (CSS) measures of DVDs has been illegal and determined to be illegal under the DMCA and copyright infringement causes of action.[60] Yet it is still possible to download and install software to copy commercial DVDs in a short time period.[61]

     The pirate is not harmed by the DMCA; the consuming public is harmed by the DMCA. Pirates of copyrighted goods are already facing serious legal and financial problems if they are caught. Section 106 has always condemned pirates’ actions. In other words, the DMCA harms dedicated pirates in no way other than increasing the potential penalties of their actions. The DMCA harms the consuming public by limiting fair uses, limiting property rights such as first sale, reducing the utility of copyrighted goods bought, and harming free speech. Given these realities, how can the DMCA promote the progress of science and the useful arts?

 

 

 

 

III. The Anti-Circumvention Clause of the DMCA Improperly Expands the Effective Scope of Copyright Law

 

The United States Constitution, Article I, Section 8, Clause 8, grants Congress the “power to promote the Progress of Science and useful Arts, by securing for limited Times to Authors and Inventors the exclusive Right to their respective Writings and Discoveries.”[62] We know little about the intent of the framers, as the Convention record contains no record of an introduction or debate.[63] However, scholars have developed several possible historical, philosophical, economic, and public policy justifications for copyright law.[64] These may be used to help evaluate expansions of copyright law such as the DMCA.

While these topics span multiple books and articles, a few observations are useful. First, the Copyright Clause is specific compared to other Constitutional grants of power to Congress.[65] Second, the text, context, and record of the Copyright Clause and its debates evidence thought by the Framers that the progress of knowledge could be furthered by the creation of new expressive works.[66] Third, suppression of copying is acceptable when it enhances the market for new creative works.[67] Fourth, copyright law enhances the market for new creative works by providing a mechanism through which creative works may be commodified.[68]

 

A.   Maximum Protection for Some Copyright Owners Does Not Necessarily Promote the Progress of Science and Useful Arts; The Landes & Posner Model for Understanding Copyright

 

As this Paper recognizes, the most universally recognized justification for copyright protection is an incentive it provides for authors to invest in the production of creative works.[69] In a recent book, William M. Landes and Richard A. Posner use this basic justification to present a formal economic model for analyzing copyright protection.[70] They particularly identify the “tradeoff between the incentive and cost-of-expression effects of varying levels of copyright protection.”[71] They state that a certain level of “copyright protection (z) simultaneously determines the price of a copy (p), the number of copies produced by the creator of the expressive work (x), the number of unauthorized copies (y), the economic returns to creating a work (R), and the total number of works created (N).”[72] This Paper will not belabor the intricacies of the model Landes and Posner derive, but will highlight a few relevant points. First, copiers’ costs will rise with increased protection z.[73] These costs will rise regardless of whether the copying is lawful, fair use or otherwise, or unlawful.[74] Second, an author’s gross profits, will increase with increased protection z.[75] Third, and possibly presenting the first counter-intuitive point, the greater copyright protection z is, the higher the author’s cost of expression is.[76] This is best explained by the Landes & Posner, “[i]f copyright protection increases, the [revenue] curve will shift upward . . . but so will the supply curve N of new works because expanding copyright protection by diminishing the public domain increases the costs of creating new intellectual property.”[77] These costs of expression that increase as copyright protection increases include transaction costs, acquisition costs, and substitution costs.[78]

Blending these components together, the most important teaching from the Landes & Posner book is that optimal copyright protection does not necessarily equal maximum copyright protection.[79] “[S]trengthening copyright protection beyond [optimal z] would [continue to] increase the incentive to create more works . . . but would not be worth the costs in reduced welfare per work, the higher costs of expression, and the greater administrative and enforcement costs.”[80] By increasing the level of effective copyright protection for the firms that use copy protection measures, Congress bolsters these firms’ ability to retain high prices.[81] These high prices, however, are not without cost; and when cost becomes too high, increased protection is no longer socially valuable.[82]

 

B.   The DMCA Increases the Costs of Creating New Intellectual Property; Landes & Posner Applied

 

The result seems clear when one applies the broad-reaching scope of the DMCA and DRM technology to Landes & Posner’s framework. While conclusions regarding the behavior of the model Landes & Posner propose cannot be reached absent extensive empirical work, it seems that the DMCA’s costs to society are high.

While a precise definition of transaction costs is difficult to articulate,[83] categories of transaction costs include, among others: “identification of contracting parties, information acquisition and production, policing of agreements, detection of breach, enforcement of agreements, valuation difficulties, and negotiation costs.”[84] Costs such as acquisition, substitution, and technical costs, also increase with the DMCA.[85] These all drive up the cost of creating new intellectual property.[86]

New intellectual property necessarily draws upon old intellectual property.[87] No person brings pen to paper without considering other works. It follows that creators of new intellectual property depend on a free-flowing marketplace of existing intellectual property and ideas.[88] Patent law supports this marketplace of intellectual property and ideas by publishing patents and patent applications, requiring adequate disclosure and notice to the public before property rights are ever granted.[89] Copyright previously supported the free-flowing marketplace of existing intellectual property and ideas via the concept of fair use.[90] The DMCA harms fair use, and harms the free-flowing marketplace of existing intellectual property and ideas.

The DMCA creates an additional legal and informational barrier between existing works and the creation of new intellectual property. The DMCA adds criminal and civil bite to all uses except the uses the digital rights management technology allows. Thus, a responsible and law abiding downstream creator of intellectual property must delay at least some time period to evaluate her rights and her options. This delay, however small, adds resistance to a free-flowing marketplace of intellectual property and ideas. Moreover, the more responsible the downstream creator is, the higher her costs will be. Any significant delay will affect her marginal profits negatively.[91] The delay may also be accompanied by actual costs in the form of legal or research fees.[92]

Even after the buying decision, the DMCA operates to slow and restrict the market for copyrighted goods. The DMCA validates and encourages DRM technology.[93] This DRM technology adds technical delay and expenses. Some DRM technology, such as Sony’s Rootkit DRM,[94] may restrict use to only applications sponsored by the copyright owner. If the creator of new intellectual property would like to use some different application or technology with the copyrighted work, she will incur further delay and cost searching for a substitute supply or a substitute good. If the creator of new intellectual property decides to go ahead without finding a substitute good, she adds more “legal risk” to her venture.[95] Increased risk is costly and can only deter entrepreneurs.[96]

This Part has highlighted potential costs of the DMCA that may render the DMCA a piece of law that does more harm to the progress of science and the useful arts than good. While a precise accounting of the social profits versus social costs of the DMCA is impossible, the costs should at least be considered. This Author was able to find no serious evidence that Congress seriously considered anything but profits when they drafted the DMCA. While deference to Congress would certainly be granted in a court of law, the “court of public opinion” should frown on Congress’s inadequate debate. This Author is of the opinion that the list of potential costs is long enough and real enough that the DMCA does more harm to the progress of science and the useful arts than good. Congress should repeal the DMCA, erring on the side of the public, the free-flowing marketplace of ideas, and new creators of intellectual property.

 

IV.  The Anti-Circumvention Clause of the DMCA Improperly Eviscerates Fair Use

 

The fair use doctrine, in terms of the Copyright Clause, “permits courts to avoid rigid application of the copyright statute when, on occasion, it would stifle the very creativity which that law is designed to foster.”[97] Fair use is codified in section 107 of the 1976 Copyright Act.[98] Section 107 reads, in part:

Limitations on exclusive rights: Fair use

Notwithstanding the provisions of sections 106 and 106A, the fair use of a copyrighted work, including such use by reproduction in copies or phonorecords or by any other means specified by that section, for purposes such as criticism, comment, news reporting, teaching (including multiple copies for classroom use), scholarship, or research, is not an infringement of copyright. In determining whether the use made of a work in any particular case is a fair use the factors to be considered shall include—

(1) the purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes;

(2) the nature of the copyrighted work;

(3) the amount and substantiality of the portion used in relation to the copyrighted work as a whole; and

(4) the effect of the use upon the potential market for or value of the copyrighted work.[99]

 

While the fair use doctrine is codified in section 107 of the 1976 Copyright Act, the doctrine remains open to judicial flexibility.[100] Indeed, scholars have noted that the legislative history of section 107 displays an intent to “allow the doctrine’s continuing development through the case law and its adaptation to changing times and technology.”[101] The DMCA seems to ignore this intent.

If circumventing overly restrictive DRM technology is necessary to the practice of fair use rights, and circumventing DRM is illegal per the DMCA, then the practice of fair use is illegal.

 

This simple statement of the effect the DMCA has on fair use highlights the primary way in which the DMCA increases the cost of creating new intellectual property. Consider the musician of Campbell v. Acuff-Rose Music, Inc.[102] In Campbell, a rap group named 2 Live Crew used parts of the 1960s hit “Oh Pretty Woman” in a parody of that song named “Pretty Woman.”[103] In Campbell, the Supreme Court held that 2 Live Crew’s commercial parody of “Oh Pretty Woman” could be fair use even though it was commercial in nature.[104] 2 Live Crew’s version of “Pretty Woman,” while a parody, included riffs similar to the original, lyrics similar to the original, and, obviously, the same name as the original.[105]

Now, consider even more desirable facts: the musician now seeks to use a single drum sound from that song, not even enough sound to conjure up the original sound or song in the mind of the listener. This drum sound is exactly what he desires a drum in his new song to sound like, and he only seeks to use it a few times. Even considered by a more conservative Court, this use would likely be considered fair use. More importantly, this example highlights how a low cost fair use of present intellectual property may be leveraged to create new intellectual property.

This fair use would not be possible if Campbell purchased a Sony Rootkit CD, and he wished to remain a legal user of intellectual property. Campbell would violate section 1201(a)(1)(A) by taking the steps necessary to use a digital sample from the CD. The Sony Rootkit copy protection measures would certainly be considered “technological measure[s] that effectively control[] access to a work protected under this title.”[106] The Sony Rootkit copy protection ties a user to Sony’s player software and Sony’s player software does not allow the extraction of digital samples from the CD.[107] It would be necessary to bypass the copy protection measures to extract such a digital sample. This bypassing fits into the definition of “circumvention” per the DMCA.

Must Campbell wait until the song he would like to sample from plays across the radio to extract samples? Assuming no DRM copy protection of radio songs exists, this extraction would not violate the DMCA and would allow Campbell to exercise his fair use rights. This result is counterintuitive. In the first instance Campbell purchased the CD. In the second instance Campbell did not purchase the CD, he only snagged the sample from the airwaves. The second instance appears to be more harmful to the market for copyrighted goods.  

The RIAA is not shy about using the tenuous “starving artist” argument (i.e., that the DMCA is necessary because piracy causes artists to go poor).[108] However, new creators of intellectual property likely have less money than the artists selling copy protected works. Copy protection costs money; the artist is likely already successful if her CD is sold with copy protection. With the DMCA, Congress has chosen the financial interests of already successful artists over the financial interests of new creators of intellectual property.

The financial interests and incentives of creators of new intellectual property are not the only important interests protected by the fair use doctrine. For example, parody, criticism, and rebuttal frequently make fair uses of copyright. Economic interests aside, these fair uses are important to the fiber of our democracy. Campbell above was an example of fair use parody.[109] Fair use may also importantly help protect citizens from personal attacks. Consider Hustler Magazine v. Moral Majority, Inc.,[110] a case in which a defendant charged with copyright infringement successfully invoked a fair use defense when he copied the original work to defend himself from a horrible parody.[111] If a similarly slanderous statement was embedded on a Sony Rootkit CD, and the person defamed sought to use a digital sample of the track to rebut or defend, the DRM and DMCA would give the defamed a serious technical and legal hurdle to accomplishing this fair use. These fair uses, criticism, parody, and rebuttal, especially if practiced in small amounts, rarely economically harm the copyright holder. The DMCA does not care. While purporting to retain fair use in spite of the anti-circumvention provisions, the DMCA effectively removes fair use by making its practice difficult for the average person.

Congress must have been keenly aware that the DMCA would negatively affect fair use rights. However, rather than more carefully drafting the main anti-circumvention provisions, Congress chose to create a clumsy list of exceptions. These exceptions include: a section 1201(a)(1)(A) exception for non-profit libraries, archives, and educational institutions,[112] an exception of all of section 1201 for law enforcement, intelligence, and other government activities,[113] an unclear reserve engineering exception to section 1201(a)(1)(A),[114] a narrow encryption research exception,[115] and exceptions for protecting personally identifying information[116] and conducting security testing.[117] While this list of exceptions seems long and insightful at first glance, it ignores the fair use rights of the general public and new creators of intellectual property. This result makes sense when one does the simple math of adding (a) the lobbying and interests of the entertainment industry for the DMCA; and subtracting (b) the most capably vocal opponents to the DMCA (i.e., libraries, local governments, education, etc.). This “equation,” in more general terms, is: (Broad DMCA Anti-circumvention) - (Exceptions for Vocal Interests[118]) = (a Broad DMCA Anti-circumvention Remainder for Non-Vocal Interests).

The DMCA’s Clause that Claims Fair Use is Unaffected by the DMCA is Mere Lip Service, at Best.

 

Section 1201(c) of the DMCA, titled “Other Rights, Etc., Not Affected,” reads in part: “(1) Nothing in this section shall affect rights, remedies, limitations, or defenses to copyright infringement, including fair use, under this title.”[119] There are a few notable features of this clause. First, this clause is not an exception to section 1201 anti-circumvention. Second, this clause is not a defense to section 1201 anti-circumvention. Third, no part of section 1201(a) or (b) anti-circumvention depends on a finding of copyright infringement. When one considers these features, the bottom line is clear: this clause regarding fair use says nothing. While the DMCA may not directly legally affect fair use, the real and practical effect is harmful. If a DRM technology allows no fair use access, and the DMCA makes the circumvention of the DRM technology illegal, practicing fair use on that work will be illegal.

The Purported Difference Between Access and Protection is Untested and Inadequately Ameliorates the DMCA’s Damage to Fair Use.

    

     The purported difference between section 1201(a) and section 1201(b) is in the word “access” in section 1201(a) versus the word “protection” in section 1201(b). Recall that section 1201(a)(2) includes the language “[n]o person shall manufacture . . . that - (A) is primarily designed [] for the purpose of circumventing a technical measure that effectively controls access to a work protected under this title.”[120] Section 1201(b), on the other hand, includes the language “no person shall manufacture . . . that – (A) is primarily designed [] for the purpose of circumventing protection afforded by a technological measure that effectively protects a right of a copyright owner under this title in a work or a portion thereof.”[121] The Report from the Judiciary Committee gives great importance to this difference in language.[122] The Report explains: “[Section 1201(a)(1)(A)] does not apply to the subsequent actions of a person once he or she has obtained authorized access to a copy of a work protected under title 17, even if such actions involve circumvention of other types of technological protection measures.”[123] Remember, a measure controls access “if the measure, in the ordinary course of its operation, requires the application of information, or a process or treatment, with the authority of the copyright owner, to gain access to the work.”[124] This language, again, seems like cleverly written flair[125] meant to distract opponents of the DMCA. The definition of “controls access” reads like a direction to copyright owners of how to write DRM software for maximum protection. The direction, while less than clear, seems to teach the following: (a) if a technical measure only controls subsequent copying, section 1201(a) will not be implicated; while (b) if a technical measure controls access (with or without protections that control subsequent copying), section 1201(a) will be implicated. So, copyright owners of the world, tie together access and protection for maximum technical and legal protection. In other words, always depend basic access on the intended use of the user. Sony’s Rootkit protection did this. In pseudo-code:

If [intended use valid] then grant [access to intended use only].

     If [intended use NOT valid] then deny all access.

     Repeat when any access requested.

Such a measure, like Sony’s, would require the “application of information, or a process or treatment, with the authority of the copyright owner, to gain access to the work.”[126] A court would be free to use Congress’s purported intent (per the Report) to help judge any specific case, but it appears that Sony’s scheme and its circumvention, even if practiced on a perfectly legal CD, would fall under section 1201(a) and be actionable. Regardless of the final outcome of such a hypothetical lawsuit the deterrent effect on fair use promises to be high.

V.   The DMCA Destroys the First Sale Doctrine by Making Illegal the Activities Necessary to Resell or Transfer the Copyrighted Work; the Destruction of the First Sale Doctrine Runs Afoul of both the Copyright Clause and the Specific Policies Behind the First Sale Doctrine

 

Copyright owners have the exclusive right to distribute “work[s] to the public by sale or other transfer of ownership, or by rental, lease, or lending.”[127] While the distribution right generally operates, the first sale doctrine provides an important limitation on the distribution right. Title 17, Section 109(a) of the United States Code provides: “[n]otwithstanding the provisions of section 106(3) . . . the owner of a particular copy or phonorecord lawfully made under this title . . . or any person authorized by such owner, is entitled, without the authority of the copyright owner, to sell or otherwise dispose of the possession of that copy or phonorecord.”[128]

Scholars have noted that in close cases the courts “often side with the defendant when the rights of the copyright owner encroach on the right of [a downstream] owner to dispose of physical copies of the work.”[129] Section 109 results in an important limit to authors’ distribution rights and helps to create secondary markets for copyrighted goods.

Even the Copyright Office has noted the potential damage to the first sale doctrine that the DMCA plus DRM technology poses. They “recognized” in a 2001 report on the DMCA that the “tethering” of a copyrighted good to one machine or device “could have serious consequences for the operation of the first sale doctrine.”[130] Nevertheless, the Copyright Office suggests no legislative change because the use of such tethering technology, “does not appear to be widespread at the present time, at least outside the context of electronic books.”[131] Apparently a harmful provision must create widespread problems in more than one important market for the Copyright Office to suggest any corrective action. Indeed, little should be expected from the Copyright Office; its conclusion that the first sale doctrine does not apply to digitally transmitted goods shows a blanket disregard for enabling robust markets of digital goods.[132]

     Going back to the Landes & Posner model,[133] this impediment to the secondary market for copyrighted goods allows the copyright owner to increase prices, but simultaneously decreases the end user’s utility of the copyrighted good, increases transaction costs, and may increase the cost of creating new intellectual property.[134] The Copyright Office defends its positions by asserting that the specific and narrow mechanics of the first sale doctrine render the Office’s conclusions immune from arguments that draw on the Copyright Clause.[135] This might be correct in the judicial-constitutional-law sense, but certainly should not exempt an administrative body from weighing potentially harmful means against the constitutionally mandated ends. In other words, regardless of the precise purposes behind sections of the Copyright Act, the “progress of science and the useful arts” should remain a benchmark against which all sections of the Copyright Act should be evaluated.[136] If a section or interpretation of a section could result in more overall harm than good to the progress of science and the useful arts, then legislators and officials at the Copyright Office should at least consider this harm prior to the harm becoming widespread.[137]

     According to the Copyright Office, the “precise purposes”[138] of the first sale doctrine were (a) to avoid restraints on the alienation of physical property and (b) to prevent copyright owners from controlling both the market for initial sales and aftermarket resales.[139] The Copyright Office hangs its entire argument that the first sale doctrine does not apply to digitally transmitted goods on the word “physical.”[140] Since the year electronic storage was invented, this distinction has grown more meaningless, and this trend will continue. Is personal property stored on a personal computer not personal property? When software or music may be burned or ripped to and from CDROMs in minutes, the piece of plastic that separates a digital copy from a physical copy seems empty and meaningless. A tune purchased online is personal property that may be alienated just as a CD purchased at Wal-Mart. As more commerce occurs online where a digital first sale doctrine does not exist, the more copyright owners will be able to restrict the availability and affordability of copyrighted goods.[141]

Legislators and administrative bodies such as the Copyright Office should rethink their position on the DMCA; both for DRM protected works that are first sold as physical goods and for works first solid in the digital world. The “precise” purposes of the first sale doctrine as well as the broad purpose of the Copyright Act are offended by the DMCA. A repeal of the anti-circumvention clause of the DMCA and the inclusion of digital works into the first sale doctrine would lift the most significant barriers that stand in the way of robust and productive secondary markets for copyrighted digital goods.

 

VI.  When the Public Cannot Practice Fair Use Without Violating a Law, Free Speech is Restricted

 

Fair use is necessary for free speech to thrive in a digital society. The DMCA threatens free speech by narrowing the scope of fair use to include only those fair uses the copyright owner contemplates when she creates the DRM software surrounding her copyrighted work. This is an argument that the public must believe in, present to legislators, and even continue to fight in the courts. Free speech case law, especially involving the DMCA, provides only little hope for a court win on such an argument.

In the 2002 case United States v. Elcom Ltd., the defendant argued that the DMCA violated free speech rights; the court quickly dismissed Elcom’s argument.[142] This case provides a look at the hurdles to making a free speech argument against the DMCA. Elcom sold a software program that allowed users to remove DRM restrictions from Adobe PDF and eBook files.[143] The United States indicted Elcom for violating DMCA section 1201(b).[144] Elcom asserted First Amendment challenges.[145] The court in Elcom agreed that the First Amendment was implicated, as the DMCA may ban the sale of a good that contains some protected expression.[146] In this case, the software of Elcom’s program contained some expression.[147]

While the First Amendment was triggered in the Elcom case, and software was affirmed to be capable of consituting expressive speech, these were the only free speech victories for Elcom. Because the DMCA and Congress’s intent in passing the DMCA are content neutral,[148] the court decided that only intermediate, rather than strict, scrutiny should apply.[149] The court continued to apply intermediate scrutiny, which holds a statute constitutional if it “promotes a substantial governmental interest that would be achieved less effectively absent the regulation and the means chosen do not burden substantially more speech than is necessary to further the government's legitimate interests.”[150] The court had little trouble determining that thwarting piracy was a substantial government interest,[151] but spent slightly more time evaluating the means.[152]

It is the means analysis that the court incorrectly decided. The DMCA burdens substantially more speech than is necessary to further the government’s interests in preventing piracy. The court stated, “[t]he absence of effective technological restrictions to prevent copyright infringement would inevitably result in even more rampant piracy, with a corresponding likely decrease in the willingness of authors and owners of copyrighted works to produce them in digital form or make the works available on-line.”[153] First, in the absence of the DMCA, nothing would prevent copyright owners from “imposing effective technical restrictions to prevent copyright infringement.”[154] Second, old-fashioned contributory copyright infringement, NOT the DMCA has brought down two sources of mass piracy, Grokster[155] and Napster[156] P2P services. Third, prior to the DMCA, digital works were thriving. The court’s statement that the absence of the DMCA would likely decrease the willingness of authors to post digital works online seems baseless. With the increasing popularity of the Internet, where new markets are opening up and buckets of money are waiting to be made with successful business models, that authors of digital works would stay away is tenuous, at best. Moreover, recent events seem to show that the DMCA and DRM may be having the opposite effect. These schemes represent confusing hurdles for consumers. Digital works protected by the DMCA and DRM have been available via the Internet. The authors of digital works have put works on the Internet. The consumers have not bought the works.[157] It would seem that the actors stalling the placement of more digital works online are not the authors, but rather the consumers. The consumers may be rejecting digital works because of overly restrictive and unimaginative DRM backed by the DMCA. The claim that the DMCA is necessary for effective DRM and that effective DRM is necessary to provide incentive for authors to publish digital works requires multiple leaps of logic. This tenuous claim of effectiveness, balanced against the DMCA’s burden to free speech, burdens substantially more speech than is necessary.

Elcom further argued that the DMCA does not pass free speech review because the DMCA effectively eliminates fair use.[158] Since many fair uses constitute protected expression, the anti-trafficking provisions of the DMCA, argued Elcom, “do not respond precisely to the substantive problem which legitimately concerned Congress and that it therefore does not comport with the First Amendment.”[159] Elcom had it right. The court, without actually evaluating the exemptions contained in 1201, simply noted that there are many exemptions, so the DMCA must be sufficiently tailored.[160] The following paragraph is too amusing in its unedited form not to quote:

[T]he DMCA does not “eliminate” fair use. Although certain fair uses may become more difficult, no fair use has been prohibited. Lawful possessors of copyrighted works may continue to engage in each and every fair use authorized by law. It may, however, have become more difficult for such uses to occur with regard to technologically protected digital works, but the fair uses themselves have not been eliminated or prohibited. For example, nothing in the DMCA prevents anyone from quoting from a work or comparing texts for the purpose of study or criticism. It may be that from a technological perspective, the fair user my find it more difficult to do so-quoting may have to occur the old fashioned way, by hand or by re-typing, rather than by “cutting and pasting” from existing digital media. Nevertheless, the fair use is still available.[161]

    

     In other words, the court in Elcom recognized that hundreds of millions of free speech enhancing fair uses are effectively made more difficult and more expensive by the DMCA; the court not only admits this, it provides an illustration. However, these difficulties and expenses are apparently not enough evidence that the means chosen by Congress burden substantially more speech than is necessary to further the government’s legitimate interests in padding the pocket books of the record industry. Forgive this author’s sarcasm, but Landes & Posner’s model[162] combined with the Elcom court’s line of thought reveal the DMCA for what it is; a subsidy to current intellectual property owners at the expense of the public and would-be creators of new intellectual property.

 

VII. The DMCA Enables Malicious and Anticompetitive DRM

 

A.   Law Should Restrict Malicious DRM Technology Such as the Sony BMG Rootkit Software

 

While some computer laws may be available to attach malicious DRM distributions,[163] the cloaked and rights-encroaching nature of the Sony BMG DRM method begs for clear rules marking the boundaries of acceptable DRM intrusion. While the outside of the CD case was marked as copy protected software, buyers of the Sony BMG software had no notice that they would be unable to uninstall the software that would always be taking resources and posing a security risk to their systems. Moreover, Sony provided no notice that the customer would be required to use the Sony Media Player when played on a PC. When users attempted to uninstall the Sony BMG software, their computers were harmed; CDROM drives were rendered inoperable.

One would think that a license to harm consumers’ personal property prior to a trial because of mere copyright infringement[164] or acts that may look like copyright infringement is an idea that would never seem reasonable. However, Senator Orrin Hatch believes that copyright owners should be able to legally destroy a customer’s computer if the owner believes the customer is improperly copying the file.[165] Some copyright owners would likely applaud such a response. This strengthening of copyright owners’ hammer would surely reduce the amount of copyright infringement and allow copyright owners to charge higher prices. Such a radical strengthening of copyright enforcement, however, would also radically increase the cost of creating new intellectual property and encroach upon the rights of the consuming public.

 

 

 

B.   The Sony BMG Software is Anticompetitive; Using Oligopoly Power and Malicious DRM to Force Users to Products in Other Markets is Anticompetitive and Anti-consumer.

 

Beyond the malicious and intrusive nature of the Sony BMG DRM technique, Sony required customers of the CD to use Sony’s player software to play the CD and required customers to use their Walkman hardware to play the music on a portable digital device. This restriction shocked many users of the popular Apple iPod devices and fans loyal to other media players.

Under formal antitrust law the Sony Rootkit behavior is most similar to an antitrust tying arrangement. A tying arrangement “is a sale or lease of one product (the ‘tying product’) on the condition that the buyer or lessee take a second product (the ‘tied’ product) as well.”[166] The most common test for an impermissible tying arrangement under either section 1 of the Sherman Act or section 3 of the Clayton Act is generally: (a) “the scheme in question involves two distinct items and provides that one (the tying product may not be obtained unless the other (the tied product) is also purchased”; (b) “the tying product possesses sufficient economic power appreciably to restrain competition in the tied product market”; and (c) “a ‘not insubstantial’ amount of commerce is affected by the arrangement.”[167]

     The first element should be met by Sony BMG. The CD is the tying product and is a distinct product from the tied media player embedded on the CD. While the “items” are not physically separate, they could be; and there is a separate market for media players. This analysis is analogous to the tying arrangement the European Union found Microsoft guilty of in recent years.[168] The E.U. found that Microsoft had leveraged its monopoly power in the operating system market by tying the Windows Media Player to its operating system software.[169] This tying occurred in spite of the fact that Windows Media Player is included on the CDROM that contains the Windows Operating System. In fact, Sony BMG’s actions are more egregious than those of Microsoft. Not only is the Sony Media Player included with the CDROM, but PC users are forced to use the Sony Media Player if they would like to play the music contained on the CD on their PC.[170]

The market power test would be the most difficult to meet for a party suing Sony BMG. Sony BMG is the second largest distributor of recorded music.[171] In 2005, Sony BMG controlled 20.5% of the global recorded music market.[172] This market share jumps 5 to 10 percent in the United States.[173] While these numbers seem high, the market and economic power element usually requires more. In one Supreme Court case, a market share of 30% was not enough to meet the market power test in a tying case.[174]

A party seeking to sue Sony BMG would not be without argument on the market power element, however. Some courts have found per se illegal tie-ins, varying definitions of market power, and others presume market power when the tying product is copyrighted.[175] For example, in Digidyne Corp. v. Data General Corp., the court quoted the Supreme Court, holding “requisite economic power is presumed when the tying product is patented or copyrighted.”[176] Also, the finding of market power does not entail only a formalistic look at the market share percentage. The same Supreme Court case that found a market share of 30% insufficient to find market power, also applied less than a formalistic approach. They cited the Areeda and Turner Antitrust treatise to define market power leverage as “a supplier's ability to induce his customer for one product to buy a second product from him that would not otherwise be purchased solely on the merit of that second product.”[177] Under this definition, and remembering that the tying CDs are unique copyrighted works, market power may exist. Individual artists are often only available from one distributor. For example, while customers might normally be willing to substitute away from one music distributor to the other, or from one PC manufacturer to another, they may not be so willing to substitute one copyrighted work for another.

 

C.   Recent DMCA Case Law Both Highlights the Potential Abuses of the DMCA and Provides Some Hope

           

In 2004, two cases were decided that provided a narrow interpretation of the Anti-Circumvention clauses of the DMCA. The facts of these cases highlight ways in which copyright owners may abuse the overly broad language of the DMCA to harass competitors. The holdings of these cases provide hope that at least the courts, if not Congress, recognize the dangerous over breadth of the language of the DMCA.

     1.   Chamberlain Group v. Skylink Technologies

 

In Chamberlain Group v. Skylink Technologies,[178] a garage door company named Chamberlain sued competitor Skylink, alleging, among other things, that Skylink violated DMCA section 1201(a)(2).[179] Chamberlain developed a complicated code scrambling and rolling program for its garage door opener system.[180] Skylink developed an aftermarket universal garage door opener that only simulates the rolling, but effectively bypasses Chamberlain’s security code and opens Chamberlain’s doors, once programmed to do so by the user.[181] Chamberlain did not allege a copyright violation.[182] Chamberlain only alleged that because the garage opener and transmitter include computer programs protected by copyright law, Skylink is liable for violating the DMCA because its universal opener bypassed Chamberlain’s technical measures that control access to those programs.[183]

     The Federal Circuit in Chamberlain frankly stated that, “Chamberlain's interpretation of the DMCA would [] grant manufacturers broad exemptions from both the antitrust laws and the doctrine of copyright misuse.”[184] The court concluded that section 1201 “prohibits only forms of access that bear a reasonable relationship to the protections that the Copyright Act otherwise affords copyright owners.”[185] Along these lines, the court asserted a series of proofs a plaintiff must show to properly allege a section 1201(a)(2) violation.[186] While the majority of the language tracks that of section 1201(a)(2), the court held that a plaintiff must also allege circumvention of a copy protected work, “that third parties can now access [] without authorization, in a manner that [] infringes a right protected by the Copyright Act.”[187] The Federal Circuit affirmed summary judgment in favor of Skylink, the defendant.[188] Chamberlain neither showed a lack of authorization “nor explained how the access provided by the Model 39 transmitter facilitates the infringement of any right that the Copyright Act protects.”[189]

 

            2.       Lexmark International, Inc. v. Static Control Components, Inc.

           

Lexmark, the manufacturer of laser printers, attempted to control the downstream market for its toner cartridges through the DMCA anti-circumvention clauses.[190] Lexmark began producing toner cartridges embedded with microchips designed to only allow Lexmark to sell and refill the toner cartridges.[191] When Static Control Components (SCC) mimicked Lexmark’s microchip design to create competing generic cartridges, Lexmark sued, alleging a violation of DMCA section 1201.[192] Lexmark based this claim on an authentication sequence that occurred between the toner microchip and the printer, and two copyrighted programs embedded on the microchip that SCC copied.[193] Lexmark viewed the authentication sequence as the technical measure SCC circumvented to obtain access to the copyrighted programs embedded on the chip.[194]

     The Sixth Circuit held that the authentication sequence neither provides access to nor protects the code on the printer cartridges.[195] Rather, the court reasoned, the purchase of the Lexmark printer allowed access to code on any compatible printer cartridges.[196] The court looked to Congressional History to conclude that Congress did not intend to “prevent consumers from using consumer goods while leaving the copyrightable content of a work unprotected.”[197]

            3.   Chamberlain and Lexmark Highlight the Potential for Abuse of the DMCA

           

Congress enacted the anti-circumvention clauses of the DMCA to battle massive piracy and to update the United State’s Copyright Laws to better conform to WIPO.[198] These two cases highlight the propensity of commercial interests to use broadly and carelessly drafted statutes to gain competitive advantages, rather than for their intended purposes. Sony BMG could have brought DMCA cases against users that bypassed their Sony Rootkit copy protection. One wonders what would result in such a case. If public outcry against the Sony Rootkit copy protection hadn’t been as loud, would Sony have successfully presented a fact pattern that (a) fit the language of the DMCA section 1201, (b) survived the reasoning of Chamberlain and Lexmark, and (c) anti-competitively boosted Sony’s aftermarket sales of software and hardware media players?

     It seems they may have. First, the Sony Rootkit copy protection measures effectively control access to a copyrighted work. Secondly, the Sony Rootkit protection protects copyrighted works clearly unlike those of Chamberlain and Lexmark. The music contained on the CD is expressive and original, and is the precise work the copy protection protects. Third, the Sony Rootkit scheme may actually prevent casual piracy of the copyrighted work. Sony could certainly argue with a straight face that their measures were an honest attempt to curb the massive piracy that Congress intended to battle with the DMCA. The Sony Rootkit scheme, while perhaps a sad indication of the direction we’re headed with respect to consumer rights, does provide a good illustration of the dangers of the DMCA. Sony BMG might have been able to leverage the DMCA to anti-competitively increase its position in the markets for software and hardware media players.

 

VIII.     The Anti-Circumvention Clause of the DMCA Should be Repealed Unless the Offender is Distributing Tools Designed Primarily for Mass Infringement

 

The Anti-Circumvention Clause of the Digital Millennium Copyright Act should be repealed because when combined with the latest Digital Rights Management technology, it creates an intellectual property scheme that gives content creators greater protection than necessary to promote the progress of the useful arts and that restricts the public interests of fair use and free speech.

The Harm to Science and the Useful Arts Outweighs the Benefits the Current Anti-Circumvention Clause Provides

 

Restricting fair use, encumbering free speech, further increasing the costs of creating new intellectual property, and enabling anti-competitive behavior are unacceptable prices to pay for slightly more legal protection of copyright. In the Internet era, an impressive amount of innovation and economic development happens when individuals on a forum, chat room, user’s group, or newsgroup come together to develop a new technology or form a new business in a garage. Traditional fair use principles would allow these entrepreneurs and intellectuals to study, adapt, and use copyrighted works to further the development of their own projects. By making illegal the mere unwrapping of the copyrighted work and simple tools to help this unwrapping, we require honest entrepreneurs to either (a) risk civil and criminal sanctions under the DMCA or (b) negotiate a less restrictive license with the copyright holder. Option (a) can only harm innovation, investment and economic development. Option (b) is not only unrealistic, but raises transaction costs to a level that is likely unbalanced by the added investment incentive the DMCA provides to a copyright owner.

 

Private Control Over Copyrighted Content Has Increased; The DMCA Anti-Circumvention Clause is No Longer Necessary to Promote the Progress of Science and the Useful Arts

 

Technology has advanced since the dawn of the Internet. DRM technology is here to stay, and copyright owners now have more copy control and copy deterrent mechanisms than ever. When a work is copy protected with restrictive DRM technology, the vast majority of the population has neither the means nor the motivation to break the DRM. Those that are motivated and have the means will do so regardless of a law like the DMCA. The DMCA does not attack the ends it is aimed at (i.e., the mass piracy), but rather means that may also be used for productive purposes. In the absence of the DMCA, the rights of copyright owners will remain protected by copyright law, DRM technologies, and contract law. The marginal increase in protection the DMCA effectively provides copyright owners does not justify its societal negatives. Thus, the anti-circumvention clause of the DMCA should be repealed.

 


 



[1] Marci A. Hamilton, The Historical and Philosophical Underpinnings of the Copyright Clause 10 (1999).

[2] Id. at 3.

[3] Id. at 1-9 (discussing the probable history of the Copyright clause).

[4] Id.

[5] Howard Johnson, The Greening of Nicholas Johnson, Rolling Stone, April 1, 1971 (quoting Nicholas Johnson), available at http://www.nicholasjohnson.org/.

[6] Prior to the Internet, copying and distribution could not be accomplished easily in the digital domain, but was rather relegated to the analog domain. In basic terms, a digital file is stored as a large string of binary information: 0s and 1s. Analog information, on the other hand, is represented by electromagnetic waves. A compact disc is an example of a digital medium, whereas VHS or cassette tapes are examples of analog medium. Analog copying necessarily results in less than perfect copies. Each subsequent analog copy results in an additional level of information loss. For example, the copying of a compact disk onto a tape will result in some small level of loss, but by the fifth copy, depending on the equipment and media used during each copy, the copied material may be significantly degraded.

[7] Ryan Roemer, Trusted Computing, Digital Rights Management, and the Fight for Copyright Controls on Your Computer, 2003 UCLA J. L. & Tech. 8 (2003).

[8] Content Protection Status Report, April 25, 2002, available at: http://judiciary.senate.gov/special/content_protection.pdf.

[9] Few experts are more qualified to comment on the windows operating system than Mr. Russinovich. Mr. Russinovich earned a B.S., M.S. and Ph.D. in computer engineering, and is Chief Software Architect and co-founder of Winternals Software, a company that specializes in advanced system software for Microsoft Windows. Mr. Russinovich has co-authored two versions of an extensive book named Windows Internals, regularly delivers seminars to public and private entities, including Microsoft itself, and serves as senior contributing editor to Windows IT Pro magazine.

[10] Lorraine Woellert, Sony’s Copyright Overreach, Bus. Wk., Nov. 17, 2005.

[11] Mark Russinovich, Sony, Rootkits and Digital Rights Management Gone Too Far, Mark’s Sysinternals Blog, Oct. 31, 2005, http://www.sysinternals.com/blog/2005/10/sony-rootkits-and-digital-rights.html [hereinafter Initial Russinovich Report].

[12] Id.

[13] Id.

[14] Id.

[15] Id.

[16] Id.

[17] Id.

[18] Brian Krebs, Sony Raids Hacker Playbook, Washingtonpost.com (Nov. 2005) at http://blogs.washingtonpost.com/securityfix/2005/11/sony_raids_hack.html

[19] Viruses Use Sony Anti-Piracy CDs, BBC News, Nov. 11, 2005 at http://news.bbc.co.uk/1/hi/technology/4427606.stm.

[20] Hiawatha Bray, Security firm: Sony CDs secretly install spyware, The Boston Globe, Nov. 8, 2005 at http://www.boston.com/business/technology/articles/2005/11/08/security_firm_sony_cds_secretly_install_spyware/

[21] Paul F. Roberts, Sony BMG Hacking into Buyer’s Computers, Nov. 3, 2005, at http://www.foxnews.com/story/0,2933,174334,00.html.

[22] See Ingrid Marson & Graeme Wearden, Sony 'rootkit' Prompts Office Clampdown on CD Use, CNet News.com, at http://ecoustics-cnet.com.com/Sony+rootkit+prompts+office+clampdown+on+CD+use/2100-7355_3-5951177.html; John Borland, ‘Bots’ for Sony CD Software Spotted Online, CNet News.com, Nov. 10, 2005, at http://news.com.com/2100-1029-5944643.html?tag=tb; Joris Evars, Microsoft Will Wipe Sony’s Rootkit, CNet News.com, Nov. 13, 2005, at http://news.com.com/2100-1002-5949041.html?tag=tb. 

[23] Ken Fisher, Sony: What You Don’t Know Can’t Hurt You, Arstechnica.com, Nov. 9, 2005, at http://arstechnica.com/news.ars/post/20051109-5542.html.

[24] See John Leyden, First Trojan using Sony DRM Spotted, The Register, Nov. 10, 2005, at http://www.theregister.co.uk/2005/11/10/sony_drm_trojan/.

[25] See Bruce Schneider, Sony’s DRM Rootkit: The Real Story, Nov. 17, 2005, at http://www.schneier.com/blog/archives/2005/11/sonys_drm_rootk.html (reporting on the Sony Rootkit timeline). Indeed, the Wikipedia definition of “spyware” reads: “spyware refers to a broad category of malicious software designed to intercept or take partial control of a computer's operation without the informed consent of that machine's owner or legitimate user.” wikipedia.com.

[26] See Mark Russinovich, Sony: No More Rootkit – For Now, Mark’s Sysinternals Blog, Nov. 14, 2005, http://www.sysinternals.com/blog/2005/11/sony-no-more-rootkit-for-now.html (containing a copy of Sony BMG’s Official Statement, which has since been removed from the Sony website).

[27] Id. (“We stand by content protection technology as an important tool to protect our intellectual property rights and those of our artists.”).

[28] Indeed, not even two months after the Rootkit scandal Sony was again backpedaling because of another insecure copy protection measure called Mediamax. See Mediamax, Dec. 6, 2005, Sony.com at http://www.sonybmg.com/mediamax/statement.html

[29] Id. See also Ken Fisher, A CD Insert to Make Sony Blush, Arstechnica.com, Jan. 1, 2006 at http://arstechnica.com/news.ars/post/20060102-5877.html

[30] Id.

[31] Id.

[32] Id. (“Thank you very much for purchasing this CD and helping the cause of ‘Anti-Piracy.’ The recordings in this CD have an anti-copying function. They cannot be copied into a PC. In order for you to enjoy high quality music, we have added this special technology. [This CD] might not play in the following players: Some CD players that have the capability of burning into an MP3 (such as portable players or car stereos). Some CD players that possess CD-R/RW functions (such as portable players or car stereos). Some car stereos with satellite "Guidance" systems. Some CD players or car stereos with hard disk recording capacity. Some CD-R/RW Recorders used for music. Some portable CD players. Some DVD players. Some CD/LD Convertible Players. Some Game Players. Although you can use your PC's Windows program to listen to certain tracks, this does not mean that the CD can be played in all PCs. The first time that this program is used (in Windows automatic starter software) it gets registered in Windows File. Thus, programs already registered do not affect Windows operations. This CD does not support Macintosh PC software. Except for manufacturing problems, we do not accept product exchange, return, or refund.”).

[33] Id.

[34] Id.

[35] Declan McCullagh, Rep: Give Fair Use a Fair Shake, Wired Magazine, July 25, 2001, at http://www.wired.com/news/politics/0,45548-0.html?tw=wn_story_page_prev2

[36] Opensecrets.org – Money in Politics Data, at http://www.opensecrets.org/.

[37] Howard Coble: Campaign Finance / Money – Contributions – Congressman 1998, Opensecrets.org, at http://www.opensecrets.org/politicians/indus.asp?CID=N00002247&cycle=1998.

[38] Top Recipients from PACs Only: TV/Movies/Music, 1998 Cycle, Opensecrets.org, at http://www.opensecrets.org/industries/pacrecips.asp?Ind=B02&cycle=1998.

[39] Dianne Feinstein, Campaign Finance / Money – Contributions – Senate 1998, Opensecrets.org, at http://www.opensecrets.org/politicians/indus.asp?CID=N00007364&cycle=1998.

[40] Opensecrets.org

[41] Opensecrets.org

[42] The Digital Millennium Copyright Act, Text, History, and Caselaw 247 (2003)

[43] 17 U.S.C. § 1201(a) (2005).

[44] 17 U.S.C. § 1201(a)(2) (2005)(“ No person shall manufacture, import, offer to the public, provide, or otherwise traffic in any technology, product, service, device, component, or part thereof, that— (A) is primarily designed or produced for the purpose of circumventing a technological measure that effectively controls access to a work protected under this title; (B) has only limited commercially significant purpose or use other than to circumvent a technological measure that effectively controls access to a work protected under this title; or (C) is marketed by that person or another acting in concert with that person with that person’s knowledge for use in circumventing a technological measure that effectively controls access to a work protected under this title.”).

[45] 17 U.S.C. § 1201(a)(3).

[46] Id.

[47] 17 U.S.C. § 1203(c)(3) (2005).

[48] 17 U.S.C. § 1204 (2005).

[49] Thank you, Professor Johnson, for pointing out this sophisticated distinction.

[50] 17 U.S.C. § 106 (2006).

[51] Timothy B. Lee, Circumventing Competition: The Perverse Consequences of the Digital Millennium Copyright Act, The Cato Institute, available at http://www.cato.org/pub_display.php?pub_id=6025 (characterizing the DMCA as “a dramatic expansion of the rights of copyright holders”).

[52] LP, 71 (describing some contributing factors in effective amount of copyright protection as including the “efficacy and cost of enforcement”).

[53] Timothy B. Lee, Circumventing Competition: The Perverse Consequences of the Digital Millennium Copyright Act, The Cato Institute, available at http://www.cato.org/pub_display.php?pub_id=6025.

[54] And, because of the RIAA’s thickheaded loyalty to old and outdated business models…

[55] See Quote from Jack V. on bottom of Roemer ~fn 34

[56] See Quote on the bottom of Roemer from Pres. Of Universal Music Group. ~fn 37

[57] See infra note 56 and accompanying text.

[58] Joris Evers, Hackers Find First Xbox 360 Cracks, CNet News.com (December 16, 2005).

[59] Id.

[60] See Universal City Studios, Inc. v. Corley, 273 F.3d 429 (2d Cir. 2001); Universal City Studios, Inc. v. Reimerdes, 111 F.Supp.2d 294 (S.D.N.Y. 2000).

[61] See DeCSS – Wikipedia for some links, at http://en.wikipedia.org/wiki/DeCSS.

[62] U.S. Const. Art. I, § 8, cl. 8.

[63] Marci A. Hamilton, The Historical and Philosophical Underpinnings of the Copyright Clause 9 (1999).

[64] Id.

[65] Id. at 8.

[66] Id. at 12.

[67] Id. at 12.

[68] Id. at 17-25.

[69] See Report on Legal Protection for Databases, U.S. Copyright Office, August, 1997 (“Copyright law embodies an appropriate balance between incentives for creation and the free flow of information, by granting rights but leaving ideas and facts in the public domain and providing leeway for public interest activities through the doctrine of fair use and other exceptions. This balance furthers Constitutional policies and should not lightly be disturbed.”), at http://www.copyright.gov/reports/dbase.html.

[70] Willliam M. Landes & Richard A. Posner, The Economic Structure of Intellectual Property Law 71 (2003) [hereinafter Landes & Posner].

[71] Id. at 72.

[72] Id. at 74.

[73] Id. at 72.

[74] Id. at 72

[75] Id. at 73

[76] Id. at 72-73

[77] Id. at 76

[78] Id. at 78

[79] Id. at 83

[80] Id. at 83

[81] Let’s call the DMCA what it is: a government subsidy to the RIAA and the MPAA. This point can be derived from a model that Landes and Posner provide. Id.

[82] Id. at 83.

[83] Pierre Schlag, The Problem of Transaction Costs, 62 S. Cal. L. Rev. 1661 (1989).

[84] Pierre Schlag, The Problem of Transaction Costs, 62 S. Cal. L. Rev. 1661, 1673 (1989).

[85] See Landes & Posner, supra note 68 at 78 (describing these costs as common costs that increase as effective copyright protection increases).

[86] Id. at 78.

[87] Campbell v. Acuff-Rose Music, Inc., 510 U.S. 569 (1994)

[88] See Landes & Posner, supra note 68.

[89] 35 U.S.C. §112 (2006)(“ The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.”).

[90] DSC Communications Corp. v. DGI Technologies, Inc. 898 F.Supp. 1183, 1191 (N.D.Tex.,1995)(recognizing that the “fundamental purpose of the Copyright Act-to encourage the creation of original works by protecting the creator's expression while leaving the ideas, facts and functional concepts in the free marketplace to be built upon by others”).

[91] She must still pay fixed costs while delay is occurring.

[92] Information regarding the specific nature of the DRM software is sparse at the buying stage. A prospective customer has little way of knowing what his or her rights will be with regards to the music contained on the disk. The customer does not know what agreement he or she will be required to accept when selecting disks on the shelf. After the Sony BMG Rootkit event, a customer does not even know whether his or her computer will work with the software he or she is about to purchase. Will the customer be able to return the disk?

[93] Indeed, encouraging DRM and other technical barriers was a goal of the drafters of the DMCA. See S. Rep. No. 105-109, p. 11 (1998) (“Title I encourages technological solutions, in general, by enforcing private parties’ use of technological protection measures with legal sanctions for circumvention…”).

[94] See Initial Russinovich Report.

[95] See Lee, supra note 51, at 9.

[96] Id.

[97] Iowa State University Research Foundation, Inc. v. American Broadcasting Companies, 621 F.2d 57, 60 (2d Cir. 1980).

[98] 17 U.S.C. § 107 (2006).

[99] 17 U.S.C. § 107 (2006).

[100] Marshall Leaffer, Understanding Copyright Law 319 (2d ed.)

[101] Marshall Leaffer, Understanding Copyright Law 319 (2d ed.)(citing H.R. Rep. No. 94-1476, 94th Cong., 2d Sess. 66 (1976).

[102] Campbell, 510 U.S. 569.

[103] Id. at 572.

[104] Id. at 574.

[105] Id.

[106] 17 U.S.C. § 1201(a)(1)(A) (2005).

[107] See Initial Russinovich Report, supra note 11.

[108] One doesn’t have to look far for examples of the RIAA spouting this tenuous argument. See RIAA – Anti-Piracy, http://www.riaa.com/issues/piracy/default.asp (“Though it would appear that record companies are still making their money and that artists are still getting rich, these impressions are mere fallacies.” and “Musicians, singers, songwriters and producers don’t get the royalties and fees they’ve earned. Virtually all artists (95%) depend on these fees to make a living.”).

[109] Campbell, 510 U.S. 569 (1994).

[110] 796 F.2d 1148 (9th Cir. 1986).

[111] Id.

[112] 17 U.S.C. §1201(d) (2005).

[113] 17 U.S.C. §1201(e) (2005).

[114] 17 U.S.C. §1201(f) (2005).

[115] 17 U.S.C. §1201(g) (2005).

[116] 17 U.S.C. §1201(i) (2005).

[117] 17 U.S.C. §1201(j) (2005).

[118] One may read this as “well organized and well-funded.”

[119] 17 U.S.C. § 1201(c) (2005).

[120] 17 U.S.C. § 1201(a) (2005).

[121] 17 U.S.C. § 1201(b) (2005).

[122] S. Rep. No. 105-109, at 28-30 (reprinted in The Digital Millennium Copyright Act: Legislative History at 98-100).

[123] Id. at 28.

[124] 17 U.S.C. § 1201(a)(3)(B) (2005).

[125] Or flare.

[126] 17 U.S.C. § 1201(a)(3)(B) (2005).

[127] 17 U.S.C. § 106(3) (2005).

[128] 17 U.S.C. § 109(a) (2005).

[129] See Leaffer, supra note 95 at 239.

[130] Copyright Office Section 104 Report, 76 (2001).

[131] Id. at 76.

[132] Id. at 80.

[133] See supra Part III.A (describing the Landes and Posner model and applying it to the DMCA and DRM).

[134] Id.

[135] Copyright Office Section 104 Report, 88-89 (2001).

[136] The progress of the science and the useful arts are the ends at which the means should be aimed.

[137] Doing more than considering the harm might be more than one could expect. New creators of intellectual property and the public that participate in secondary market resale of copyrighted goods pale in comparison to the mighty MPAA and RIAA.

[138] Copyright Office Section 104 Report, page 89 (2001).

[139] Id.

[140] Id at 86-96

[141] For more on this point, see R. Anthony Reese, The First Sale Doctrine in the Era of Digital Networks, 44 Boston College L. Rev. 577 (2003).

[142] United States v. Elcom Ltd., 203 F. Supp. 2d 1111 (N.D. Cal. 2002).

[143] Id at 1118.

[144] Id. at 1119.

[145] Id. at 1125.

[146] Id. at 1126.

[147] Id. at 1126.

[148] Id. at 1128.

[149] Id. at 1129

[150] Id.

[151] Id. at 1129-30.

[152] Id.

[153] Id. at 1130.

[154] Id at 1130.

[155] Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd. 125 S.Ct. 2764 (U.S.,2005)

[156] A&M Records, Inc. v. Napster, Inc. 239 F.3d 1004, 1017 (9th Cir. 2001).

[157] See Barnes & Noble Help Desk: eBooks, at http://www.barnesandnoble.com/help/ebooks.asp (“B&N.com no longer sells or provides support for eBooks. We apologize for any inconvenience this may cause.”).

[158] United States v. Elcom Ltd., 203 F. Supp. 2d at. 1130.

[159] Id. at 1130 (quoting defendant’s First Amendment Motion).

[160] Id. at 1130-31.

[161] Id. at 1131.

[162] See supra Part III.A. 

[163] Sony BMG is already being sued by multiple states. Class action suits were filed against Sony in New York and California. Sony Sued Over Copy Protected CDs, BBC News, Nov. 10, 2005, at http://news.bbc.co.uk/1/hi/technology/4424254.stm. The Texas Attorney General is also suing Sony BMG. See Attorney General Abbott Brings First Enforcement Action In Nation Against Sony Bmg For Spyware Violations, Attorney General of Texas, Monday, November 21, 2005, at http://www.oag.state.tx.us/oagnews/release.php?id=1266.

[164] Copyright infringement is “merely” copyright infringement when balanced against a copyright owner’s ability to strike out at possible copyright infringers because, at the end of the day, copyright infringement is about money, not personal health, safety, welfare, or some fundamental human right.

[165] Fred Locklear, Batten Down the Hatch: Storm Abrewin’, arstechinca.com, http://arstechnica.com/news/posts/1055897910.html (“’I'm interested, Hatch interrupted. He said damaging someone's computer ‘may be the only way you can teach somebody about copyrights’.").

[166] Herbert Hovenkamp, Antitrust (3d ed. 1999).

[167] Herbert Hovenkamp, Antitrust (3d ed. 1999) (quoting Siegel v. Chicken Delight, Inc., 448 F.2d 43 (9th Cir. 1971)).

[168] EU News Release, EU Commission Concludes Microsoft Investigation, Imposes Conduct Remedies and a Fine, Mar. 24, 2004, available at http://www.eurunion.org/News/press/2004/20040045.htm.

[169] Id.

[170] See Initial Russinovich Report

[171] Sony BMG Market Share Slipped to 20.5% in 2005, Reuters, Thurs. March 23, 2006.

[172] Id.

[173] Eric Pfanner, On Top of Talk of Rifts, the Problems Keep Piling Up for Sony-Bertelsmann Venture, International Herald Tribune, Nov. 28, 2005.

[174] Jefferson Parish Hosp. Dist. No. 2. v. Hyde, 466 U.S. 2 (1984).

[175] Herbert Hovenkamp, Antitrust 147-51 (3d ed. 1999)

[176] Digidyne Corp. v. Data General Corp., 734 F.2d 1336, 1341 (9th Cir. 1984) (quoting U.S. v. Loew’s, 371 U.S. 38 (1962)).

[177] Jefferson Parish Hosp. Dist. No. 2 v. Hyde, 466 U.S. 2, 12-14 (quoting V P. Areeda & D. Turner, Antitrust Law ¶ 1134a at 202 (1980)).

[178] 381 F.3d 1178 (Fed. Cir. 2004).

[179] Id. at 1183-86.

[180] Id.

[181] Id.

[182] Id. at 1185.

[183] Id.

[184] Id at 1193.

[185] Id. at 1203.

[186] Id. at 1203.

[187] Id. at 1203.

[188] Id. at 1204.

[189] Id. at 1204.

[190] Lexmark Intern., Inc. v. Static Control Components, Inc., 387 F.3d 522 (6th Cir. 2004).

[191] Id.

[192] Id. at 4.

[193] Id. at 4.

[194] Id.

[195] Id. at 19.

[196] Id.

[197] Id. at 22.

[198] Id. at 21.