Columbia Pictures Industries, Inc. v. Redd Horne, Inc.
United States Court of Appeals for the Third Circuit
749 F.2d 154 (1984)
Maxwell's Video Showcase (defendant) let customers select and rent VHS films in a showroom, then watch them individually in one of many small, private exhibition rooms; the facility itself was open and marketed to the general public even though each viewing room was restricted to that particular renter. Columbia Pictures (plaintiff) sued, claiming these private, repeated showings to different paying customers infringed its exclusive public-performance right; the district court granted Columbia summary judgment and an injunction, and Maxwell's appealed.
Whether the display of an audiovisual work in a publicly accessible, private setting constitutes a public performance for purposes of copyright infringement.