Master Copies, Unique Copies and Volitional Conduct: Cartoon Network’s Implications for the Liability of Cyber Lockers

As technology advances, new types of devices and increasing compatibility of data formats make it possible to use files previously accessible on only one or two devices. For example, a person might wish to access a business file (formerly stored on a work computer or perhaps even in a file cabinet at the office) from her smart phone. Similarly, another might wish to access his MP3 collection (stored on an iPod or personal computer) from his work computer. Such technological progress has paved the way for innovative digital, cable and Internet services that enable users to enjoy copyrighted content in new ways: from time-shifting via VCRs to place-shifting via new TV devices; from instantly purchasing a movie through video on demand to watching a live stream of sports coverage on the Internet. One type of service that has recently proliferated is the digital storage locker—also known as the cyber locker. Digital storage lockers enable users to