Chamberlain Group, Inc. v. Skylink Technologies, Inc.

Skylink Remote This is a mind-bogglingly absurd case involving circumvention, in which Chamberlain Group - which holds a rather broad patent for "A Coding System for Multiple Transmitters and a Single Receiver for a Garage Door Opener" - contended that the small Canadian company Skylink was violating the DMCA by selling remote control devices that work with Chamberlain garage door openers. Chamberlain argued that Skylink's remote control device circumvents access controls to a computer program in its garage door opener. Skylink argued that garage owners have a right to open their own garages even if they've lost the remote control and choose to buy one from another company.

The Federal Circuit court rightly rejected Chamberlain's argument, saying that DMCA prohibitions must be tied to copyright rights to fit the balance copyright embodies.

Chamberlain's proposed construction would allow copyright owners to prohibit exclusively fair uses even in the absence of any feared foul use. It would therefore allow any copyright owner, through a combination of contractual terms and technological measures, to repeal the fair use doctrine with respect to an individual copyrighted work-or even selected copies of that copyrighted work. Again, this implication contradicts 1201(c)(1) directly. Copyright law itself authorizes the public to make certain uses of copyrighted materials. Consumers who purchase a product containing a copy of embedded software have the inherent legal right to use that copy of the software. What the law authorizes, Chamberlain cannot revoke.

With its reading of fair use, "authorization," and the dangers of copyright misuse by those who would block interoperability, the Fed. Circuit adds some important nuance to the DMCA. "[T]he DMCA emphatically did not 'fundamentally alter' the legal landscape governing the reasonable expectations of consumers or competitors."

Federal Circuit Court documents:

District Court documents:

International Trade Commission documents: