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Chamberlain Group, Inc. v. Skylink Technologies, Inc. | 381 F.3d 1178 (2004)

In Chamberlain Group versus Skylink Technology, the Federal Circuit opened the door on the statutory construction of Section Twelve Oh One of the Digital Millennium Copyright Act.

Garage door openers generally consist of two parts: a receiving device mounted to a motor in the homeowner’s garage and a portable transmitter. The transmitter sends a radio frequency signal to the receiver, directing the motor to open or close the door. Consumers can purchase additional or replacement transmitters aftermarket.

Chamberlain Group created a line of garage door openers known as Security Plus. Security Plus used a copyright-protected rolling-code technology that actively changed the signal between the transmitter and receiver. The concept was designed to protect against burglary.

Skylink Technology sold a universal transmitter called the model thirty-nine that allowed users to sync with Security Plus receivers and operate them by bypassing the rolling-code technology.

Chamberlain sued Skylink under Section Twelve Oh One of the Digital Millennium Copyright Act. Chamberlain alleged that Skylink built model thirty-nine to circumvent Security Plus’s rolling code, a technological measure that effectively controls access to Chamberlain’s copyrighted work. Skylink responded that consumers used model thirty-nine to activate Chamberlain’s garage door openers with Chamberlain’s implied consent.

Both Chamberlain and Skylink moved for summary judgment. The district court granted Skylink’s motion, finding that Chamberlain didn’t prove that access was unauthorized. Chamberlain appealed to the Federal Circuit.

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