door opener) did not violate the anti-circumvention provisions because its use did not lead to any copyright violation. However, in a number of cases involving DVD decryption courts have held that there is no fair use defense in circumvention cases. In Universal City Studios v. Reimerdes, 111 F. Supp. 2d 294, 322 (S.D.N.Y. 2000), the court stated that "[i]f Congress had meant the fair use defense to apply to such actions, it would have said so." Reverse Engineering and Circumvention Sec. 103(f) of the DMCA (17 U.S.C. § 1201 (f)) says that you are allowed to reverse-engineer a protected program in order to figure out how to get it to interoperate (i.e., exchange and make use of information) with other programs.. The section states: (f) Reverse Engineering.— (1) Notwithstanding the provisions of subsection (a)(1)(A), a person who has lawfully obtained the right to use a copy of a computer program may circumvent a technological measure that effectively controls access to a particular portion of that program for the sole purpose of identifying and analyzing those elements of the program that are necessary to achieve interoperability of an independently created computer program with other programs, and that have not previously been readily available to the person engaging in the circumvention, to the extent any such acts of identification and analysis do not constitute infringement under this title. (2) Notwithstanding the provisions of subsections (a)(2) and (b), a person may develop and employ technological means to circumvent a technological measure, or to circumvent protection afforded by a technological measure, in order to enable the identification and analysis under paragraph (1), or for the purpose of enabling interoperability of an independently created computer program with other programs, if such means are necessary to achieve such interoperability, to the extent that doing so does not constitute infringement under this title. (3) The information acquired through the acts permitted under paragraph (1), and the means permitted under paragraph (2), may be made available to others if the person referred to in paragraph (1) or (2), as the case may be, provides such information or means solely for the purpose of enabling interoperability of an independently created computer program with other programs, and to the extent that doing so does not constitute infringement under this title or violate applicable law other than this section. (4) For purposes of this subsection, the term "interoperability" means the ability