A federal district court in Pennsylvania had no trouble dismissing a copyright infringement suit brought by a DVD producer against its non-paying customer. The court ruled that the parties had intended for the customer to have an implied license to distribute copies of the producer’s work product; the producer could sue the customer for breach of contract because of nonpayment, but not for copyright infringement. See this Loeb & Loeb memo for more details about Beholder Productions, Inc. v. Catona, No. 08-261 (E.D. Pa. June 11, 2009) (granting defendant customer’s motion for summary judgment).