University Press v. Michigan Document Services, Inc.
Princeton University Press, Macmillan, Inc., and St. Martin's
Press, Inc. brought a copyright infringement action against Michigan
Document Services, Inc. (MDS). The plaintiffs claimed that MDS
infringed on their copyrights when it made multiple copies of
excerpts from various materials provided by university professors,
compiled them into coursepacks and sold the coursepacks to students
for a profit. The district court found that MDS's infringement
was willful and issued an injunction against it. MDS appealed
the district court's decision, defending its copying practices
primarily on the ground that the coursepacks were a fair use of
the copyrighted works. The Sixth Circuit Court of Appeals, sitting
en banc, upheld the district court, ruling that coursepack use
was not a fair use of the publishers' works.