Using Content: Coursepacks
Princeton University Press v. Michigan Document Services, Inc.
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What You Need To Know

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.