## Facts

- Chamberlain manufactured “Security+” garage door openers containing embedded, copyrighted software that used a rolling-code system intended to deter code-grabbing.
- Skylink sold a universal garage door transmitter (Model 39) designed to operate multiple brands of openers, including Security+ units.
- Model 39 did not replicate Chamberlain’s rolling-code algorithm; it transmitted signals that triggered the opener’s built-in resynchronization/reset functionality to achieve interoperability.
- Chamberlain sued Skylink in federal district court asserting patent infringement and a claim under the DMCA’s anti-circumvention/anti-trafficking provisions, focusing on 17 U.S.C. § 1201(a)(2).
- The patent claims were dismissed, and the district court granted summary judgment to Skylink on the DMCA claim.
- Chamberlain appealed the DMCA ruling to the Federal Circuit.

## Issues

1. Whether the Federal Circuit had appellate jurisdiction where patent claims were dismissed and only a DMCA claim remained.
2. Whether a universal transmitter that enables consumers to operate their own Chamberlain openers “circumvents” an “effective technological measure” and violates 17 U.S.C. § 1201(a)(2).
3. Whether the plaintiff must prove that the alleged circumvention enables unauthorized access that bears a connection to infringement of rights protected by the Copyright Act.

## Decision

- The Federal Circuit held it had appellate jurisdiction over the appeal.
- The court affirmed summary judgment for Skylink on the DMCA claim.
- The court held Chamberlain failed to prove that Skylink trafficked in a device that enabled “unauthorized” access within the meaning of § 1201(a)(2), as applied to consumers using the opener they purchased.
- The court held Chamberlain failed to show a sufficient link between the alleged circumvention and infringement of Chamberlain’s exclusive rights under Title 17.

## Legal Principles

- DMCA § 1201 anti-circumvention provisions create liability causes of action; they do not create a new, freestanding property right to control all access or interoperability.
- In a § 1201(a)(2) claim, the plaintiff bears the burden to prove that the accused device enables unauthorized access to a copyrighted work.
- “Unauthorized access” under § 1201(a) must be construed in light of the Copyright Act’s allocation of rights and limits; access that merely enables lawful use by an authorized user is presumptively lawful.
- Liability under § 1201(a)(2) requires a meaningful connection between the alleged circumvention and infringement (or interference with) a right protected by Title 17; circumvention that only enables noninfringing, authorized use is not enough.

## Conclusion

The Federal Circuit affirmed judgment for Skylink because Chamberlain did not prove that the universal transmitter enabled unauthorized access, nor did it show that the access facilitated by the device was tied to infringement of Chamberlain’s copyright rights, preventing § 1201(a)(2) from being used to block lawful aftermarket interoperability.


Chamberlain Grp., Inc. v. Skylink Techs., Inc., 381 F.3d 1178 (Fed. Cir. 2004)