Copyright Owners Versus Car Makers on 1992 Digital Statute’s Meaning

The Alliance of Artists and Recording Companies (AARC) sued General Motors and other car manufacturers and parts suppliers for violating the Audio Home Recording Act of 1992 (AHRA).  The AHRA, which is included in the Copyright Act, sets copying technology control and royalty payment requirements for manufacturers, importers, and distributers of digital audio recording devices (DARDs).  AARC is a non-profit organization responsible for enforcing the AHRA and collecting and distributing the royalties to sound recording artists and copyright owners.  The AARC alleged that the car manufacturers installed DARDs in certain car models without complying with the AHRA or paying royalties.

The defendants moved to dismiss the lawsuit or for judgment on the pleadings.  They argued that none of the devices at issue met the AHRA’s DARD definition and that the AHRA’s technology limits and royalty payment requirements do not apply.  The district court agreed with the defendant’s interpretation of the AHRA for the most part, but thought that the AARC’s allegations were sufficient to survive the defendants’ motions and denied the motions.

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