Quimbee logo
DMCA.com Protection Status
  • U
  • Universal City Studios, Inc. v. CorleyUniversal City Studios, Inc. v. Corley
From our private database of 16,800+ case briefs...

Universal City Studios, Inc. v. Corley

United States Court of Appeals for the Second Circuit
273 F.3d 429 (2001)


In 1999, Congress passed the Digital Millennium Copyright Act (DMCA). Under the DMCA, copyright holders are entitled to protect their digital works behind encryption codes. Provisions of the DMCA prohibit facilitating access to technology that would circumvent property-protecting encryptions. In 1996, Universal City Studios, Inc. (Universal) (plaintiff) and other movie studios collaborated to created the Content Scramble System (CSS). CSS protected video content on DVDs from being accessed or displayed without the proper algorithm and player keys. In 1999, several individuals successfully replicated the necessary algorithm and player keys. These individuals then wrote an encryption program entitled DeCSS that circumvented the CSS protection and allowed access to the DVD content. Eric Corley (defendant) posted copies of the computer code underlying DeCSS to his website with information about CSS and how DeCSS could be used to duplicate DVD content. Universal sued Corley for facilitating encryption-circumventing technology. Corley defended the posting of DeCSS on First Amendment grounds, arguing that computer code was protected speech. The district court held that posting DeCSS’s computer code and links to DeCSS violated the anti-circumvention provisions of the DMCA. The district court issued a permanent injunction prohibiting Corley from continuing to post or link to DeCSS on Corley’s website. Corley appealed the decision.

Rule of Law


Holding and Reasoning (Newman, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 448,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 448,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,800 briefs, keyed to 224 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial