Constitutional Code reports that Macrovision is invoking the Digital Millennium Copyright Act against an analog "signal noise" reducer. This touches on the little-known 17 USC 1201(k), the "Macrovision provision" of the DMCA (Macrovision DMCA Lawsuit Targets DVD Copying Products). This isn't about digital anti-circumvention (the most commonly invoked), but analog anti-circumvention. The following is probably not directly invoked in the case, but will shed some background:

[1201](k) Certain Analog Devices and Certain Technological Measures. -

(1) Certain analog devices. -

(A) Effective 18 months after the date of the enactment of this chapter, no person shall manufacture, import, offer to the public, provide or otherwise traffic in any -

(i) VHS format analog video cassette recorder unless such recorder conforms to the automatic gain control copy control technology;
(ii) 8mm format analog video cassette camcorder unless such camcorder conforms to the automatic gain control technology;
(iii) Beta format analog video cassette recorder, unless such recorder conforms to the automatic gain control copy control technology, except that this requirement shall not apply until there are 1,000 Beta format analog video cassette recorders sold in the United States in any one calendar year after the date of the enactment of this chapter;
(iv) 8mm format analog video cassette recorder that is not an analog video cassette camcorder, unless such recorder conforms to the automatic gain control copy control technology, except that this requirement shall not apply until there are 20,000 such recorders sold in the United States in any one calendar year after the date of the enactment of this chapter; or
(v) analog video cassette recorder that records using an NTSC format video input and that is not otherwise covered under clauses (i) through (iv), unless such device conforms to the automatic gain control copy control technology.

(B) Effective on the date of the enactment of this chapter, no person shall manufacture, import, offer to the public, provide or otherwise traffic in -

(i) any VHS format analog video cassette recorder or any 8mm format analog video cassette recorder if the design of the model of such recorder has been modified after such date of enactment so that a model of recorder that previously conformed to the automatic gain control copy control technology no longer conforms to such technology; or
(ii) any VHS format analog video cassette recorder, or any 8mm format analog video cassette recorder that is not an 8mm analog video cassette camcorder, if the design of the model of such recorder has been modified after such date of enactment so that a model of recorder that previously conformed to the four-line colorstripe copy control technology no longer conforms to such technology. Manufacturers that have not previously manufactured or sold a VHS format analog video cassette recorder, or an 8mm format analog cassette recorder, shall be required to conform to the four-line colorstripe copy control technology in the initial model of any such recorder manufactured after the date of the enactment of this chapter, and thereafter to continue conforming to the four-line colorstripe copy control technology. For purposes of this subparagraph, an analog video cassette recorder ''conforms to'' the four-line colorstripe copy control technology if it records a signal that, when played back by the playback function of that recorder in the normal viewing mode, exhibits, on a reference display device, a display containing distracting visible lines through portions of the viewable picture.

(2) Certain encoding restrictions. - No person shall apply the automatic gain control copy control technology or colorstripe copy control technology to prevent or limit consumer copying except such copying -

(A) of a single transmission, or specified group of transmissions, of live events or of audiovisual works for which a member of the public has exercised choice in selecting the transmissions, including the content of the transmissions or the time of receipt of such transmissions, or both, and as to which such member is charged a separate fee for each such transmission or specified group of transmissions;
(B) from a copy of a transmission of a live event or an audiovisual work if such transmission is provided by a channel or service where payment is made by a member of the public for such channel or service in the form of a subscription fee that entitles the member of the public to receive all of the programming contained in such channel or service;
(C) from a physical medium containing one or more prerecorded audiovisual works; or (D) from a copy of a transmission described in subparagraph (A) or from a copy made from a physical medium described in subparagraph (C). In the event that a transmission meets both the conditions set forth in subparagraph (A) and those set forth in subparagraph (B), the transmission shall be treated as a transmission described in subparagraph (A).

(3) Inapplicability. - This subsection shall not -

(A) require any analog video cassette camcorder to conform to the automatic gain control copy control technology with respect to any video signal received through a camera lens;
(B) apply to the manufacture, importation, offer for sale, provision of, or other trafficking in, any professional analog video cassette recorder; or
(C) apply to the offer for sale or provision of, or other trafficking in, any previously owned analog video cassette recorder, if such recorder was legally manufactured and sold when new and not subsequently modified in violation of paragraph (1)(B).

(4) Definitions. - For purposes of this subsection:

(A) An ''analog video cassette recorder'' means a device that records, or a device that includes a function that records, on electromagnetic tape in an analog format the electronic impulses produced by the video and audio portions of a television program, motion picture, or other form of audiovisual work.
(B) An ''analog video cassette camcorder'' means an analog video cassette recorder that contains a recording function that operates through a camera lens and through a video input that may be connected with a television or other video playback device.
(C) An analog video cassette recorder ''conforms'' to the automatic gain control copy control technology if it -

(i) detects one or more of the elements of such technology and does not record the motion picture or transmission protected by such technology; or
(ii) records a signal that, when played back, exhibits a meaningfully distorted or degraded display.

(D) The term ''professional analog video cassette recorder'' means an analog video cassette recorder that is designed, manufactured, marketed, and intended for use by a person who regularly employs such a device for a lawful business or industrial use, including making, performing, displaying, distributing, or transmitting copies of motion pictures on a commercial scale.
(E) The terms ''VHS format'', ''8mm format'', ''Beta format'', ''automatic gain control copy control technology'', ''colorstripe copy control technology'', ''four-line version of the colorstripe copy control technology'', and ''NTSC'' have the meanings that are commonly understood in the consumer electronics and motion picture industries as of the date of the enactment of this chapter.

(5) Violations. - Any violation of paragraph (1) of this subsection shall be treated as a violation of subsection (b)(1) of this section. Any violation of paragraph (2) of this subsection shall be deemed an ''act of circumvention'' for the purposes of section 1203(c)(3)(A) of this chapter.

This is called the "Macrovision provision" of the DMCA because it essentially mandates use of Macrovision's Analog Copy Protection in VCRs. Wouldn't you love to have your technology mandated by law? Must be nice.

One example of the products under fire is the GoDVD! Model CT-2. Because it is not actually a VCR it doesn't fall under 1201(k), but it would likely run afoul of 1201(b), which makes it illegal to distribute anti-copy protection devices. However, 1201(k) makes it quite clear that Congress considers this technology copy protection technology, and because it is mandated for VCRs, makes arguing around it quite difficult.

Read the Macrovision press release: Macrovision Files Lawsuit Against Sima and Interburn’s DVD Copying Products.