Sony Corp. of America v. Universal City Studios, Inc., 464 U.S. 417 (1984), also known as the "Betamax case", is a decision by the Supreme Court of the United States which ruled that the making of individual copies of complete television shows for purposes of time shifting does not constitute copyright infringement, but can instead be defended as fair use.

[1][2] The court also ruled that the manufacturers of home video recording devices, such as Betamax or other VCRs (referred to as VTRs in the case), cannot be liable for contributory infringement.

[3] The broader legal consequence of the Supreme Court's decision was its establishment of a general test for determining whether a device with copying or recording capabilities ran afoul of copyright law.

This test has created some interpretative challenges for courts when applying the precedent to more recent file sharing technologies available for use on home computers and over the Internet.

Universal Studios and Walt Disney Productions were among the entertainment companies who were wary of this development, but were also aware that the U.S. Congress was in the final stages of a major revision of copyright law and would likely be hesitant to undertake any new protections for the film industry.

The high court stated that Rogers' views were a notable piece of evidence "that many [television] producers are willing to allow private time-shifting to continue" and even quoted his testimony in a footnote.

However, in the eight years that had passed since the suit was initially filed, the use of home recording devices had become so widespread that Congress was not prepared to take any action detrimental to the significant population of VCR owners.

The Ninth Circuit further distinguished the cases because the Napster defendants operated a system that allowed them to monitor and control the potentially infringing activities of its users.