DIRECTV, Inc. v. Pepe
United States Court of Appeals for the Third Circuit
431 F.3d 162 (2005)
- Written by Miller Jozwiak, JD
Facts
DIRECTV, Inc. (plaintiff) was a corporation that provided satellite broadcast television. Robert Pepe and other individuals (the interceptors) (defendants) allegedly began using electronic devices, known as pirate access devices, to intercept DIRECTV’s encrypted satellite broadcasts. DIRECTV sued the interceptors for (among other things) violating the Electronic Communications Privacy Act of 1986 (ECPA). The ECPA prohibited the intentional and unauthorized interception of electronic communications. Under another provision in the ECPA, any person whose electronic communications were intercepted in violation of the law was authorized to seek damages and injunctive relief. The term “person” could include a corporation. The district court held that DIRECTV could not bring this claim on the grounds that another statute provided the sole remedy for the alleged conduct of the interceptors. DIRECTV appealed.
Rule of Law
Issue
Holding and Reasoning (Van Antwerpen, J.)
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