Not long after the passage of the 1976 Copyright Act, the scope of contributory infringement liability was tested in a case in which the copyright owners claimed that the sale of a recording device – the VCR - illegally contributed to infringement. In "Sony Corp. of America v. Universal City Studios, Inc." was established a variant on contributory liability claims with respect to technologies. When Universal City Studios initially sued Sony for making and selling the Betamax, the theory was that Sony materially contributed to acts of infringement performed by users of the Betamax, and knew or had reason to know that the technology would be used for infringing purposes. The Supreme Court of the United States held that, even though material contributions and knowledge of the infringement are generally sufficient to establish secondary liability, in the case of infringing technology, contributory liability cannot be imposed unless the technology lacks substantial non-infringing uses. As the Court phrased the "Sony" exception with regard to new technologies: "The sale of copying equipment, like the sale of other articles of commerce, does not constitute contributory infringement if the product is widely used for legitimate, unobjectionable purposes. Indeed, it need merely be capable of substantial noninfringing uses."