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Computer networks have caused a radical change in the means of disseminating information, a change that will likely be as profound as the changes caused by the telephone and television,' and that may even rival the changes caused by the invention of the printing press. Copyright law, which the printing press first made necessary, has "always been closely connected with . . . technological improvements in means of dissemination."2 And, as technology has evolved, "[s]uccessive ages have drawn different balances among the interest of the writer in the control and exploitation of his intellectual property, the related interest of the publisher, and the competing interest of society in the untrammeled dissemination of ideas."3 Thus, as the Supreme Court observed, copyright law needs to "strike a balance between a copyright holder's legitimate demand for effective-not merely symbolic-protection of the statutory monopoly, and the rights of others freely to engage in substantially unrelated areas of commerce."4 With the advent of computers, courts need to strike a new balance between the interests of copyright owners and the right of society to use computer networks. To date, in four reported cases, courts have addressed the use of computer networks to reproduce and disseminate copyrighted materials illegally.5 A primary question in these cases is which theory of copy-

When Should Computer Owners Be Liable for Copyright Infringement by Users?