Arista Records LLC v. Lime Group LLC
United States District Court for the Southern District of New York
784 F. Supp. 2d 398 (2011)
Lime Group LLC created and distributed the peer-to-peer file-sharing program LimeWire. LimeWire users employed the program to share and download digital copies of copyrighted music. Arista Records LLC and other record companies (collectively, Arista) (plaintiffs) sued Lime Group and related individuals and entities (collectively, LW) (defendants) for secondary copyright infringement. Arista sought summary judgment on its inducement-of-infringement claim; the parties cross-moved for summary judgment on Arista’s contributory-infringement claim; and LW sought summary judgment on Arista’s vicarious-infringement claim. Arista presented evidence showing that most files requested for download through LimeWire were copyrighted and not authorized for free distribution, internal LW documents acknowledged that LimeWire users downloaded copyrighted music without authorization, LW maintained an articles file labeled “Knowledge of Infringement,” articles about LimeWire users’ infringing activities appeared in newspapers, LW marketed LimeWire to users seeking to replace the shuttered file-sharing program Napster, LW conducted tests to improve LimeWire’s ability to search for and download unauthorized copies of recordings, LW assisted LimeWire users in sharing and downloading copyrighted music files, LW’s revenues grew as a result of LimeWire’s infringing capabilities, and LW failed to implement meaningful filters to limit infringement. LW presented evidence of LimeWire’s noninfringing uses, including sharing public-domain ebooks, and argued that additional noninfringing uses would likely be developed.
Rule of Law
Holding and Reasoning (Wood, J.)
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