The phrase “RIAA sues Napster for copyright infringement” refers to a lawsuit filed on December 6, 1999, by A&M Records and 17 other record companies—not a suit filed by the RIAA itself. The case, A&M Records, Inc. v. Napster, Inc., challenged Napster’s role in helping users find and exchange copyrighted music. A related group of music publishers also sued. The Ninth Circuit rejected Napster’s fair-use defense for the unauthorized transfers on the record before it, and a shutdown order followed in 2002 after the court found Napster was not complying satisfactorily with an injunction.
Who sued Napster, and when?
On 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. The complaint alleged contributory and vicarious copyright infringement, violations of California law, and unfair competition. The reported case name is A&M Records, Inc. v. Napster, Inc., rather than a lawsuit brought by the RIAA as the named plaintiff. The filing date and plaintiffs appear in the district-court opinion.
On January 7, 2000, Jerry Leiber, Mike Stoller, and Frank Music Corporation filed a related complaint on behalf of a proposed class of music publishers. Their action addressed music-publishing rights, alongside the record companies’ case.
Judge Marilyn H. Patel opened the 2000 district-court opinion with this framing: “The matter before the court concerns the boundary between sharing and theft, personal use and the unauthorized world-wide distribution of copyrighted music and sound recordings.”
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How did Napster’s file-sharing service work?
Napster maintained a centralized index that helped users locate MP3 files on other participating users’ computers. Once users found a file, the music was copied directly between their computers, peer to peer; Napster’s index helped connect them but was not itself the source of the music file. The U.S. Copyright Office describes this arrangement in its brief in the case.
The legal distinction mattered: users’ copying raised direct-infringement questions, while the record companies argued that Napster was secondarily liable for contributing to and benefiting from infringement by users.
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What did the courts decide about fair use?
The district court granted a preliminary injunction on July 26, 2000. At that preliminary stage, it found extensive infringement by users and concluded Napster was contributorily and vicariously liable. This was not the final resolution of every copyright issue surrounding online file sharing.
Napster argued that users had legitimate purposes, including sampling songs before buying them, accessing recordings they already owned (“space-shifting”), and receiving authorized distributions. On February 12, 2001, the Ninth Circuit considered the fair-use factors: whether the use was transformative, its commercial character, the creative nature of the music, how much of each work was copied, and the effect on potential markets. The court rejected the fair-use defense for the unauthorized transfers on the record before it. The Copyright Office’s Fair Use Index summary reports that the court found sufficient evidence that Napster reduced audio CD sales and hindered the plaintiffs’ entry into digital sales. That was the court’s assessment of the evidence in the case, not a standalone sales statistic.
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Why did the Ninth Circuit narrow the injunction?
The Ninth Circuit required the injunction to be more specific about how Napster had to identify and block infringing material. Rights holders first had to give notice identifying 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. The court’s approach placed a defined notice obligation on rights holders rather than requiring Napster to identify every infringing file without that information.
In 2002, after the district court found Napster’s compliance with the modified injunction unsatisfactory, the Ninth Circuit affirmed the shutdown order as well as the modified injunction. The later appellate decision is reported at 284 F.3d 1091.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What was Napster’s Audio Home Recording Act argument?
Napster also invoked Section 1008 of the Audio Home Recording Act (AHRA). The U.S. Copyright Office filed an amicus brief limited to that issue and argued that the statute’s immunity applied to specified recording devices and noncommercial consumer recording—not Napster’s public file-sharing system. That description is the government’s argument in its brief, not a substitute for the court’s holdings on the copyright claims.
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What the Napster case did—and did not—establish
- It involved named record-company plaintiffs, with A&M Records and 17 other labels filing on December 6, 1999; related music publishers brought a separate action.
- It addressed Napster’s particular indexed, peer-to-peer system and the evidence presented in that litigation.
- The Ninth Circuit rejected the fair-use defense for unauthorized transfers on the record before it, while requiring specific notices to trigger Napster’s blocking duty.
- It did not settle every later dispute over peer-to-peer technology, online platforms, or copyright liability.
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