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National Football League v. TVRadioNow Corp.

53 U.S.P.Q.2d 1831 (2000)

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National Football League v. TVRadioNow Corp.

United States District Court for the Western District of Pennsylvania
53 U.S.P.Q.2d 1831 (2000)

Facts

The National Football League, the National Basketball Association, and NBA Properties, Inc. (collectively, the sports leagues) (plaintiffs) filed an action against TVRadioNow Corp. (defendant), alleging that TVRadioNow’s operation of the streaming website iCraveTV.com violated the Copyright Act. The sports leagues claimed that TVRadioNow captured United States programming, including their copyrighted professional football and basketball games, and converted those television signals into computerized data, then streamed them over the internet on iCraveTV.com. Any internet user could access iCraveTV.com by simply entering three digits of any Canadian area code. Moreover, the website’s cookie system allowed users from the United States and elsewhere to revisit the site and automatically bypass the initial screening process. The sports leagues presented evidence showing that substantial numbers of US residents accessed iCraveTV.com. Website-traffic data for January 25, 2000, showed 1.6 million page views from US users, second only to the 2.0 million page views from Canadian users. TVRadioNow admitted to copying and publicly performing the sports leagues’ copyrighted works over the internet but argued that its website was intended only for Canadian viewers. The sports leagues filed a motion for a preliminary injunction.

Rule of Law

Issue

Holding and Reasoning (Ziegler, J.)

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