In Sony Corp. v. Universal City Studios, the Supreme Court held that a movie maker could recover damages from Sony, which manufactured VCRs that consumers used at home to make personal copies of movies without paying Universal Studios royalties.

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The Supreme Court actually held the opposite in Sony Corp. v. Universal City Studios. They ruled that Sony could not be held liable for copyright infringement by consumers who made personal copies of movies using VCRs. This decision established the "Betamax doctrine," which states that companies cannot be held liable for contributory infringement if their products have substantial non-infringing uses.