Jeffrey P. Cunard, of Debevoise & Plimpton, Washington, D.C.,
>
termed secondary liability a “leaping mess,” which he
>
attributed to an effort on the part of the courts to erode the
>
Sony-Betamax
>
prescription for secondary liability, and not have
>
it apply in a digital era.
> In Sony Corp. v. Universal Studios
Inc., 464 U.S. 417 (1984), the U.S. Supreme Court held that if a
technology is “capable of substantial noninfringing uses,”
the manufacturer of that technology cannot be liable for the
infringing acts of users.