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The phrase “RIAA sues Napster for copyright infringement” is shorthand for a case brought by record companies, not a lawsuit filed by the RIAA itself. On December 6, 1999, A&M Records and 17 other record companies sued Napster in federal court in California, alleging copyright infringement and related claims. Music publishers filed a related case soon afterward. The reported appellate case is A&M Records, Inc. v. Napster, Inc.
What Napster did—and what the record companies alleged
Napster’s service maintained an index that let users find MP3 files stored on participating users’ computers. Users then copied files directly from one computer to another; Napster was not simply a central server distributing every music file. The U.S. Copyright Office describes this indexed, peer-to-peer arrangement in its brief in A&M Records v. Napster.
The record companies alleged that users directly infringed copyright and that Napster was liable for contributory and vicarious infringement. Their complaint also included California statutory claims and unfair competition. Judge Marilyn H. Patel opened the district-court opinion by describing the dispute as concerning “the boundary between sharing and theft, personal use and the unauthorized world-wide distribution of copyrighted music and sound recordings.”
The distinction between the claims matters: the case addressed alleged infringement by users as well as whether Napster could be held responsible for facilitating or benefiting from that activity. It did not treat every kind of online music sharing as the same legal question.
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When the lawsuits and key rulings happened
| Date | Event |
|---|---|
| December 6, 1999 | A&M Records and 17 other record companies filed suit in the U.S. District Court for the Northern District of California. |
| January 7, 2000 | Jerry Leiber, Mike Stoller, and Frank Music Corporation filed a related complaint on behalf of a proposed class of music publishers. |
| July 26, 2000 | The district court granted a preliminary injunction. At this preliminary stage, it found extensive user infringement and concluded Napster was contributorily and vicariously liable. |
| February 12, 2001 | The Ninth Circuit issued its decision on Napster’s interlocutory appeal, rejecting its fair-use position on the record then before the court and requiring changes to the injunction. |
| 2001 remand proceedings | The injunction was modified to specify how rights holders had to identify protected works and files before Napster had a duty to remove indexed material. |
| 2002 | The Ninth Circuit affirmed the modified injunction and shutdown order after the district court found Napster’s compliance unsatisfactory. |
The filing date, claims, related publisher action, and Judge Patel’s statement appear in the district-court opinion. The appellate sequence is summarized in the Copyright Office’s Fair Use Index entry and addressed in the 2002 Ninth Circuit opinion.
Why the Ninth Circuit rejected Napster’s fair-use defense
Napster argued that users had legitimate reasons to exchange music, including sampling songs before buying them, accessing recordings they already owned (often described as space-shifting), and receiving authorized distributions. The Ninth Circuit considered those arguments against the familiar fair-use factors: the purpose and character of the use, the nature of the copyrighted works, how much was copied, and the effect on potential markets.
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The court rejected fair use for the unauthorized transfers on the record before it. It considered the commercial character of the copying, the creative nature of recorded music, the copying of entire works, and evidence of market harm. The Copyright Office’s summary says the court found sufficient evidence that Napster reduced audio CD sales and hindered the plaintiffs’ entry into digital sales. That is the court’s assessment of the evidence in that case, not a standalone sales statistic or a general measurement of the effect of file sharing.
Why the injunction had to be narrowed
The Ninth Circuit did not leave the original injunction unchanged. It required a more specific notice process: rights holders had to identify a protected work and at least one file containing it. Napster then had to remove indexed files it reasonably knew contained works identified in those notices.
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This requirement tied Napster’s removal duty to identifiable works and files rather than an unspecified demand to police all potentially infringing material. The modified injunction thus addressed both the rights holders’ claims and the practical question of how Napster was expected to act on notice.
Why Napster was ordered to shut down its file-transfer service
After the case returned to the district court, the modified injunction remained in force. The district court found Napster was not satisfactorily complying with it, and in 2002 the Ninth Circuit affirmed the resulting shutdown order. The order followed the court’s finding about compliance with the injunction; it was not simply an immediate consequence of the first complaint in 1999.
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Napster’s separate Audio Home Recording Act argument
Napster also invoked Section 1008 of the Audio Home Recording Act (AHRA), which provides protections for certain consumer noncommercial copying involving specified recording devices. The U.S. Copyright Office filed an amicus brief limited to this issue and argued that the statute’s immunity was designed for those devices and uses, not Napster’s public file-sharing system. That description is the government’s position in its brief, and should not be confused with the Ninth Circuit’s fair-use ruling.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What the case does—and does not—establish
A&M Records v. Napster is a landmark dispute over a particular indexed peer-to-peer service, the alleged infringement at issue, and the injunction imposed in that litigation. Its rulings do not resolve every later question involving peer-to-peer technology, online platforms, or digital music distribution. The Ninth Circuit’s fair-use conclusion applied to the record before it, while the injunction’s notice requirement addressed the specific facts and parties in the case.
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