United States v. LaMacchia
871 F. Supp. 535 (D. Mass. 1994) - full text opinion
Unfortunately for the government, the Supreme Court's ruling in the case of Dowling v. United States prevented a conviction for wire fraud for infringing copyrights. At the same time, because LaMacchia did not act for financial reasons, he could not be convicted of criminal copyright infringement. Therefore, the defendant escaped conviction.
Congress acted quickly to close the loophole and passed the No Electronic Theft (NET) Act in 1997. This bill changed the criminal infringement statute by dropping the requirement for financial motivation.