District Judge Rules that Replacement Transmitter for Garage Door Openers Does Not Violate DMCA

The Chamberlain Group filed suit against Skylink Technologies in the United States District Court for the Northern District of Illinois alleging a violation of the Digital Millennium Copyright Act (DMCA), 17 U.S.C. § 1201. The district court granted summary judgment in favor of Skylink, and dismissed the complaint. Chamberlain manufactures and markets garage door openers (GDOs), including a “Security+” line that uses a “rolling code” technology to prevent “code-grabbing” (i.e., the capturing and recording of transmitter signals to obtain unauthorized access to a consumer’s garage). Skylink markets a universal remote transmitter that is capable of operating Chamberlain’s Security+ GDOs. Chamberlain claimed that Skylink’s transmitter unlawfully circumvented Chamberlain’s rolling code technology in violation of the DMCA. In response, Skylink asserted that Chamberlain had authorized its customers to circumvent the rolling code technology, and therefore that Skylink could not be held liable for the use of its remote transmitter to operate Chamberlain GDOs.

Chamberlain denied authorizing its customers to circumvent the security technology in its GDOs. Chamberlain admitted that it never explicitly warned customers against using competitors’ transmitters, but asserted that the compatibility charts found on Chamberlain’s webpage and in its owner’s manuals implied such a restriction by not listing any non-Chamberlain transmitters. Chamberlain also noted that its GDO warranty contained an exclusion for the use of unauthorized accessories.

The court found that Chamberlain had not established an intent to discourage its customers’ use of competing remotes. The court also found that GDO customers had a reasonable expectation that they would be able to replace lost or broken transmitters with a competing product without violating federal law. Based on these findings, the court concluded that consumers were authorized to use competing transmitters with Chamberlain’s GDOs.

Chamberlain argued that even if its customers were authorized to circumvent its protective technology, Skylink was not. The court held that Skylink was authorized because (1) it is common practice in the GDO industry to market universal transmitters; (2) Chamberlain did not restrict the use of competing transmitters with its Security+ GDOs; and (3) consumers must voluntarily program the Security+ GDO to operate with Skylink’s transmitter. Skylink, therefore, was also authorized to circumvent Chamberlain’s rolling code technology, and in doing so it did not violate the DMCA. The court granted partial summary judgment in Skylink’s favor.