Chamberlain Group, Inc. v. Skylink Technology, Inc.
United States Court of Appeals for the Federal Circuit
381 F.3d 1178 (2004)
Chamberlain Group, Inc. (plaintiff) sold garage-door openers under its Security+ line, which used a copyright-protected rolling code to sync a mounted device with a handheld transmitter. Skylink Technology, Inc. (defendant) sold a universal aftermarket transmitter, the Model 39, that could sync with Security+ systems without actually using or reproducing Chamberlain's copyrighted rolling code. Chamberlain sued under 17 U.S.C. § 1201, the Copyright Act's anti-circumvention provision, arguing the Model 39 circumvented Security+'s access controls. The district court granted summary judgment for Skylink, rejecting Chamberlain's theory that § 1201 barred consumers from accessing its products with a competitor's device, and Chamberlain appealed.
Whether, under the Copyright Act, the plaintiff bears the initial burden of proving that a defendant's technology allows unauthorized access to a protected work in a way that infringes a valid copyright.