Summers v Tice (and Copyright?)

From: Eric Eldred <eldred[_at_]eldritchpress.org>
Date: Mon, 31 Jul 2000 10:02:41 -0400

Here is an interesting case for lawyers and law students. I'm trying to help out with the OpenLaw OpenDVD discussion in the DeCSS case in New York.

The discussion is online at:

   http://eon.law.harvard.edu/openlaw/DVD

Judge Kaplan has raised the odd problem of how to assign responsibility for something like contributory copyright infringement--very hypothetically, since there has been no proof of any such thing and it remains to be seen if anyone has to prove that, since the case is raised by movie studios under the DMCA. But in any case, he wants to be briefed on this point.

As a nonlawyer, I am puzzled about the question as to whether negligence (as in Summers) might be concluded without a finding of harm. And in copyright infringement, has there been a case where the direct infringer and any contributory infringer have been told to divide the proof, responsibility and damages, instead of putting the burden on plaintiff?

Here is the transcript from Friday, July 21, and following is the reference to the case online [the transcription says "Tyce" but it should be "Tice"]:

http://www.eff.org/IP/Video/MPAA_DVD_cases/20000721_ny_trial_transcript.html

                                                                818
...

	THE COURT:...
  14            Just by way of a parenthetical digression, I am well
  15 aware that the issue of the extent to which there is   16 sufficient proof that there are in fact decrypted movies   17 available over the Internet has not been decided and we are   18 going to have further discussion about that. My question   19 presupposes, just on a hypothetical basis, if there is   20 adequate proof to find that there are such movies out there.   21 The thought that occurred to me last night and on   22 which I may want briefs is whether the burden of proving that   23 whatever decryptions are out there came from the defendant or   24 more broadly DeCSS is on the plaintiff as distinguished from   25 the burden being on the defendant to prove that they did not.
                                                                819

   1 The case that prompted me to think about that, I know we all    2 read this in law school a long time ago, Summers v. Tyce,    3 decided by the California Supreme Court in 1948 which seems at    4 least superficially to be analogous to this problem.    5 The case involved a group of hunters out hunting with    6 shotguns, two hunters fired simultaneously. One shotgun    7 pellet hit the plaintiff. Because they were shotgun pellets    8 as opposed to bullets out of a rifled weapon, it was    9 impossible to tell which shotgun the pellet came from. The   10 California Supreme Court said that the burden of proof was on   11 the defendants to show that their shotgun did not discharge   12 the bullet that hit the plaintiff and in the absence of such   13 proof, everybody who fired a shotgun at that time was jointly   14 and severally liable.
  15 I am not inviting argument on that this morning, but   16 I wanted you to know that I am thinking about that and to give   17 you an opportunity to address it at the appropriate time.   18 OK. That said -- and I should add there is a lot of   19 development in the law of products liability, I am sure you   20 all the know the case Summers v. Tyce as its starting point   21 and some of you may know that. Let's continue where we are.
...

The case is online at:
http://eon.law.harvard.edu/archive/dvd-discuss/msg05493.html

Summers v Tice 33 Cal.2d 80
199P.2d1, SA.L.R.2d91
(cite as: 33 Cal.2d 80)

Charles A. Summers
v
Harold W. Tice

L. A. Nos. 20650, 20651
Supreme Court of California, In Bank.

Nov. 17, 1948.

-- 
"Eric"  Eric Eldred  Eldritch Press
mailto:Eldred[_at_]EldritchPress.org
http://www.eldritchpress.org/EricEldred.vcf
Received on Mon Jul 31 2000 - 13:59:11 GMT

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