Medical Imaging & Technology Alliance v. Library of Congress

Summary

The court affirmed summary judgment upholding the Librarian of Congress's medical-device repair exemption from the DMCA's anticircumvention prohibition. Applying APA review rather than independently deciding infringement, the court held that the Librarian reasonably considered all four fair-use factors and adequately explained why the exemption covered transformative, functional, non-substitutive repair uses. The appellants failed to identify record evidence showing that the exemption concerned a separate market for repair software or that the agency's conclusions were arbitrary or capricious.