Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913 (2005)
Metro-Goldwyn-Mayer v. Grokster is a landmark Supreme Court decision at the intersection of copyright law and emerging technologies.
Does the Sony-Betamax doctrine immunize a distributor of a dual-use technology from secondary liability when there is evidence the distributor intended to induce and actively encouraged users to infringe copyrights?
One who distributes a device with the object of promoting its use to infringe copyright, as shown by clear expression or by affirmative steps taken to foster infringement, is liable for the resulting acts of infringement by third parties. The availability of substantial noninfringing uses (Sony) does not preclude liability where there is evidence of purposeful, culpable inducement.
No. The Sony-Betamax doctrine does not shield a distributor that intends to induce infringement. The Supreme Court reversed the grant of summary judgment for Grokster and StreamCast and remanded, holding that evidence of intent to promote infringing uses could support liability for inducement notwithstanding the software's lawful capabilities.
Grokster is foundational for understanding secondary liability in copyright. It reconciles Sony's protection for innovative technologies with accountability for actors who purposefully exploit infringement. For law students, the case clarifies how intent and marketing conduct can transform a neutral technology provider into an inducer, distinguishes inducement from contributory and vicarious liability, and provides a framework for analyzing platform liability in the digital age. Its reasoning informs how courts assess platform design choices, business models, and communications to infer inducement, and it continues to shape risk assessments for startups and online intermediaries.