COPYRIGHT, COMPETITION & TECHNOLOGY
Berkeley Law | Class 278.001 | Spring Semester 2022
This seminar will present a selective overview of current topics at the intersection of copyright and antitrust law. From music, to the “metaverse,” to social media networks, to mobile device operating systems, digital initiatives across industries increasingly implicate both of these complex legal regimes, rather than just one. Policy solutions to challenges presented by new technologies frequently reflect limitations imposed by antitrust and copyright working in tandem–or, occasionally, at cross-purposes; to consider legislative, regulatory, or judicial responses by reference to one body of law without the other is to ignore an entire category of essential constraints and opportunities.
In lieu of a final exam, students will draft an 8-10 page paper on a topic related to the subject of the course. In non-pandemic years, I’ve used a grading policy for this course in which the quality of the assigned paper accounts for 85% of a class member’s grade for the semester, with the remaining 15% attributable to the thoughtfulness and constructiveness of his or her participation during seminar meetings. The ongoing pandemic, however, changes things. It is reasonably likely, at the time of this writing, that we will hold in-person class meetings at least at some point this semester–and it is absolutely imperative that students not feel any pressure at all to attend those meetings if they are even a little bit sick. For that reason, this semester, in-class participation will presumptively not affect anyone’s grade, with exceptions made (in either direction) only the case of exceptional circumstances.
Office hours will be held virtually, at times to be announced throughout the semester.
Here are the topics to be discussed in this course, week-by-week, along with required and optional readings for each class session:
WEEK 1 (January 11): Introduction & Overview
Topics to discuss:
- Why think about the same technological, business, legal, and policy problems simultaneously from the perspective of copyright law and antitrust law?
- When and where, if at all, do we see tension between the values and answers that copyright and antitrust, respectively, would bring to bear on a given problem?
- High-level overview of the two legal regimes
Optional preparation:
- Christopher Sprigman, “What Does Antitrust’s Revival Mean for Copyright?” NYU School of Law Working Paper No. 21-09
- Cory Doctorow, “Newspapers vs Big Tech: Antitrust Tackles the Problems That Copyright Just Can’t Fix,” EFF (Dec. 9, 2021)
- Kyle Jahner, “Copyright-Related Repair Roadblocks Tied to Biden Antitrust Push,” Bloomberg Law (July 14, 2021)
PLEASE NOTE THAT THERE WILL BE NO CLASS MEETING ON JANUARY 18
WEEK 2 (January 25): Music licensing: antitrust
Topics to discuss:
- Understanding the precedent addressing Sherman Act claims against “performing rights organizations”
- Market definition in music rights cases
- Antitrust attacks on licensee-side collective negotiating organizations
Required reading:
- Broadcast Music, Inc. v. CBS, Inc., 441 U.S. 1 (1979)
- Radio Music License Committee, Inc. v. SESAC, Inc., 29 F. Supp. 3d 487 (E.D. Pa. 2014)
- Second Amended Complaint, Radio Music License Committee, Inc. v. Global Music Rights, LLC, Case No. 2:19-cv-03957 (C.D. Cal., June 20, 2019)
Optional reading:
- John Bowe, “The Music-Copyright Enforcers,” New York Times (Aug. 6, 2010)
- Letter from Global Music Rights, LLC to Department of Justice Antitrust Division (July 22, 2020)
Week 3 (February 1): Music licensing: rate-setting
Topics to discuss:
- What problem is compulsory licensing, and the attendant need for rate-setting, a solution for? Is it a good solution?
- Should government-established rates reflect the projected outcome of real-world hypothetical negotiations, the projected outcome of hypothetical negotiations in an effectively competitive market, or something else altogether?
- Allegations of buyer- and seller-side market power in music licensing transactions
Required reading:
- Johnson v. Copyright Royalty Board, 969 F.3d 363 (D.C. Cir. 2020): please read three passages of the slip opinion (linked in the case caption above)–specifically (a) pages 3-18; (b) pages 32-39; and (c) pages 43-50
- Determination of Rates and Terms for Digital Performance of Sound Recordings and Making of Ephemeral Copies to Facilitate Those Performances (Web V), Copyright Royalty Board, 86 Fed. Reg. 59,452 (Oct. 27, 2021): please read just the first six Federal Register pages–those numbered 59,452-‘457
- Public Comments of Digital Media Association, Public Workshop on Competition in Licensing Music Public Performance Rights, United States Department of Justice Antitrust Division (July 22, 2020)
Optional reading:
- Statement of Bureau of Competition Director Richard A. Feinstein In the Matter of Vivendi, S.A. and EMI Recorded Music (Sept. 21, 2012)
- Arista Records LLC v. Launch Media, Inc., 578 F.3d 148 (2d Cir. 2009) (describing and defining the contours of the section 114 license)
- BMI’s Response to the Department of Justice’s June 5, 2019 Request for Public Comments Concerning the BMI and ASCAP Consent Decrees (Aug. 9, 2019)
Week 4 (February 8): Copyright misuse
Topics to discuss:
- The relationship between copyright misuse and the question of what parts of a work are copyrightable in the first place
- Do the same principles of competition economics apply in the context of copyright misuse and antitrust? Should they?
- Is it copyright misuse for a software copyright holder to restrict redistribution or resale of server hardware? A connected refrigerator? A Tesla?
Required reading:
- Omega S.A. v. Costco Wholesale Corporation, 776 F.3d 692 (9th Cir. 2015): please read only the concurring opinion by Judge Wardlaw
- SAS Institute Inc. v. World Programming Ltd., 496 F. Supp. 3d 1019 (E.D. Tex. 2020)
- Brief of 44 Intellectual Property Law Scholars as Amici Curiae in Support of Defendant-Appellee, SAS Institute Inc. v. World Programming Ltd., Case No. 2021-1542 (4th Cir.) (Aug. 30, 2021)
Optional reading:
- Eriq Gardner, “Disney Misused ‘Star Wars,’ ‘Frozen’ Copyrights, Says Judge,” The Hollywood Reporter (Feb. 21, 2018)
- Mike Masnick, “Disney Fixes Its Sketchy DVD Rental License, Wins Injunction Against Redbox Over Digital Downloads,” TechDirt (Aug. 31, 2018)
- Congressional Research Service, “Repair, Modification, or Resale of Software-Enabled Consumer Electronic Devices: Copyright Law Issues” (Aug. 11, 2016)
Week 5 (February 15): Content moderation requirements and platform competition
Topics to discuss:
- What problems are content moderation requirements for large-scale internet platforms ostensibly intended to solve?
- Do content moderation requirements themselves create barriers to entry or otherwise impede competition?
- Should we think about content moderation requirements for copyright enforcement differently than content moderation requirements for false/defamatory/otherwise objectionable content?
Required reading:
- Mark Lemley, The Contradictions of Platform Regulation, 1 Journal of Free Speech Law 303 (2021)
- Daphne Keller, “For Platform Regulation Congress should use a European cheat sheet,” The Hill (Jan. 15 2021)
- Rebecca Tapscott, “Senator Tillis Releases Draft Bill to Modernize the Digital Millennium Copyright Act,” IPWatchdog (Dec. 22, 2020)
Optional reading:
- Daphne Keller, “Problems with Filters in the European Commission’s Platforms Proposal,” Stanford Law School Center for Internet and Society Blog (Oct. 5, 2017)
- United States Copyright Office, Section 512 of Title 17: A Report of the Register of Copyrights (May 2020)
- Pamela Samuelson, “The US Copyright Office Section 512 Study: Why the Entertainment Industry Is Claiming Victory,” Kluwer Copyright Blog (May 25, 2020)
PLEASE NOTE THAT THERE WILL BE NO CLASS MEETING ON FEBRUARY 22
Week 6 (March 1): DMCA anticircumvention
Topics to discuss:
- How can you tell if a “tying” arrangement is pro-competitive or anticompetitive?
- For tying arrangements that are likely to be pro-competitive, is there something wrong with using section 1201 to enforce them? Is the concern instead that section 1201 is used to enforce “tying” arrangements that are unlikely to be pro-competitive?
- Section 1201 and the “right to repair”
Required reading:
- Lexmark International, Inc. v. Static Control Components, 387 F.3d 522 (6th Cir. 2004)–please read only the majority opinion
- Randal C. Picker, Copyright and the DMCA: Market Locks and Technological Contracts, John M. Olin Law & Economics Working Paper No. 238 (2d Series) (2005)
- Kyle Wiens, “Some Electronic Repairs are Illegal: Federal Law Could Change That,” Scientific American (Nov. 12, 2021)
Optional reading:
- Andy Gass, Considering Copyright Rulemaking: The Constitutional Question, 27 Berk. Tech. L.J. 1047 (2012), pp. 1067-1081 (on the legislative history of section 1201)
- Statement of Jessica Litman, The Digital Millennium Copyright Act at 22: What Is It, Why It Was Enacted, And Where Are We Now?, Hearing Before the United States Senate Committee on the Judiciary Subcommittee on Intellectual Property, 116th Congress (Feb. 11, 2020)
Week 7 (March 8): NFTs
Topics to discuss:
- What you own when you own an NFT
- What can the blockchain do with respect to ownership of an interest in royalties or downstream profit-sharing that normal contracts can’t?
- NFTs and music royalties
Required reading:
- Kal Raustiala and Christopher Jon Sprigman, “The One Redeeming Quality of NFTs Might Not Even Exist,” Slate (Apr. 14, 2021)
- Albert Wenger, “Web3/Crypto: Why Bother?” Continuations (Dec. 28, 2021)
- Moxie Marlinspike, “My first impressions of web3,” Moxie.org (Jan. 7, 2022)
- Samantha Hissong, “NFTs May Seem Like Frivolous Fads. They Should Be the Future of Music,” Rolling Stone (July 26, 2021)
Optional reading:
- Dan Brooks, “The Future Is Not Only Useless, It’s Expensive,” Gawker (Dec. 20, 2021)
- This tweet.
- Brian L. Frye, After Copyright: Pwning NFTs in a Clout Economy, forthcoming, Columb. J. Law & Arts