Chamberlain claimed that Skylink's Model 39 Universal GDO Transmitter infringed the Digital Millennium Copyright Act (DMCA) by breaking the code used in radio controlled garage door openers that Chamberlain made. Judge Rebecca R. Pallmeyer of the United States District Court for the Northern District of Illinois rejected that claim. The United States Court of Appeals for the Federal Circuit upheld her decision on August 31, 2004 stating, among other things:

"The plain language of the statute ... requires a plaintiff alleging circumvention (or trafficking) to prove that the defendant's access was unauthorized-a significant burden where, as here, the copyright laws authorize consumers to use the copy of Chamberlain's software embedded in the GDOs that they purchased. "

"The DMCA emphatically did not "fundamentally alter" the legal landscape governing the reasonable expectations of consumers or competitors;..."

"The DMCA, as part of the Copyright Act, does not limit the scope of the antitrust laws, either explicitly or implicitly. "

"The DMCA does not create a new property right for copyright owners. Nor, for that matter, does it divest the public of the property rights that the Copyright Act has long granted to the public. The anticircumvention and anti-trafficking provisions of the DMCA create new grounds of liability. A copyright owner seeking to impose liability on an accused circumventor must demonstrate a reasonable relationship between the circumvention at issue and a use relating to a property right for which the Copyright Act permits the copyright owner to withhold authorization-as well as notice that authorization was withheld. A copyright owner seeking to impose liability on an accused trafficker must demonstrate that the trafficker's device enables either copyright infringement or a prohibited circumvention."

See also

Universal v. Reimerdes

Reference

• Chamberlain v. Skylink Federal Circuit decision