2) Real Networks, Inc. v. Streambox, Inc.

       - "Secret handshake" is a technological measure that effectively controls access to the

              copyrighted work

           - "Copy Switch" is a technological measure that effectively controls copying

           - VCR circumvents the protection by mimicking the secret handshake and runs afoul of the


           - Argument:  Protection not "effective" because a user could video tape the computer

                 monitor with a camcorder.  Court found argument not valid because the result would not

                 be a perfect digital copy.  The Court held that even if it were so, it would make no

                 difference because by merely circumventing the secret handshake was enough to

                 violate the DMCA provisions.

          - Note:  Proprietary format protected?

3)  Microsystems Software, Inc. v. Scandanavia Online AB,

          - Cyber Patrol software was decrypted to get lists of blocked sites.

          - Held that Appellant's had no standing.

4)  Sony Computer Entertainment Corporation of America v. Gamemasters

<<     >>