2004)[1] is a legal case heard by the United States Court of Appeals for the Federal Circuit concerning the anti-trafficking provision of the Digital Millennium Copyright Act (DMCA), 17 U.S.C.

It discusses the statutory structure and legislative history of the DMCA to help clarify the intent of the anti-circumvention provisions and decide who holds the burden of proof.

Chamberlain markets a "Security+" line of GDOs which includes rolling code software that actively alters the transmitted signal by cycling through a series of strings (of which only some are able to open the door).

Chamberlain claims that the rolling code system makes it unlikely for a burglar to send a valid signal by replaying the recorded one.

§ 1201(b) states: No person shall manufacture, import, offer to the public, provide, or otherwise traffic in any technology, product, service, device, component, or part thereof, that— (A) is primarily designed or produced for the purpose of circumventing a technological measure that effectively controls access to a work protected under this title;[2]Chamberlain sued Skylink in the United States District Court for the Northern District of Illinois in two cases.

The court also noted that Chamberlain's construction and interpretation of the DMCA would make its own consumers violate §1201(a)(1), which prohibits circumvention of a technological measure that controls access.

[1] In response to Chamberlain's assertions that the DMCA "renders the pre-DMCA history in the GDO industry irrelevant," "fundamentally altered the legal landscape," and "overrode all pre-existing consumer expectations about the legitimate uses of products containing copyrighted embedded software,"[1] the court disagreed.

In Chamberlain's view, all use of products that contain copyrighted software and use protective technological measures would violate the DMCA and this would give companies a loophole around antitrust laws as well as take away the fair use defense.

[1][3] By examining the structure and history of the statute and the intent of Congress, the court attempted to interpret the statutory language.

As Chamberlain failed to show the fourth and fifth requirements to prove their claim, the Federal Circuit affirmed the District Court's grant of summary judgment to Skylink, writing, Chamberlain, however, has failed to show not only the requisite lack of authorization, but also the necessary fifth element of its claim, the critical nexus between access and protection.