A federal appeals court has reaffirmed what might seem to be obvious: replacement garage door openers are legal to sell.
In a case with important implications for the technology industry, the U.S. Court of Appeals for the Federal Circuit on Tuesday upheld a lower court decision saying that certain garage door openers cannot be banned under the Digital Millennium Copyright Act (DMCA).
The Chamberlain Group, a prominent manufacturer of residential and commercial garage door openers based in Elmhurst, Ill., had sued the Skylink Group, a competitor that sold a universal opener that worked with Chamberlain's products. Chamberlain argued that the Skylink product's ability to tap into its doors' digital security mechanisms violated the DMCA.
The appeals court took a dim view of that argument, ruling that "Chamberlain cannot prevail" on its DMCA claims. Because Skylink owners merely wanted to open their garage doors, not commit copyright infringement, the judges said the company's products would remain legal.
Tuesday's decision, only the second time a federal appeals court has evaluated the DMCA's "anticircumvention" prohibitions, represents the most exhaustive review so far of that section of the controversial law. In the previous case, the 2nd Circuit upheld a lower court decision that prohibited publishing or linking to DVD-descrambling code.
Deirdre Mulligan, director of a legal clinic at the University of California at Berkeley, said the garage door opener case clarifies that the DMCA can't be used as broadly as some companies have envisioned. In a similar case, Lexmark claimed the DMCA prohibited Static Control Components from selling chips that permit Lexmark toner cartridges to be refilled.
"What the court says is that consumers have expectations about the way they'll be able to interact with products that they purchased," said Mulligan, whose clinic filed briefs siding with Skylink. "The DMCA didn't create this new right that undermines those expectations...This particular decision is very good for consumers and good for technology companies. It's going to promote competition."
Section 1201 of the DMCA says nobody may "circumvent a technological measure that effectively controls access" to a copyrighted work or sell a device that is primarily designed to do so. Skylink's Model 39 universal transmitter works with Chamberlain garage doors that use a copyrighted "rolling code" computer program that constantly changes the transmitter signal required to open the door.
"A homeowner who purchases a Chamberlain (garage door opener) owns it and has a right to use it to access his or her own garage," the appeals court said. "At the time of sale, Chamberlain does not place any explicit terms or condition on use to limit the ways that a purchaser may use its products."