Internet-only service providers like UUNET, The Pipeline, Panix, Netcom, the World, EarthLink, and MindSpring provided no content of their own, concentrating their efforts on making it easy for nontechnical users to install the various software required to "get online" before consumer operating systems came internet-enabled out of the box.
Erlich's act of sending a message to a.r.s. caused reproductions of portions of plaintiffs' work on both Klemesrud's and Netcom's storage devices, and these reproductions were sufficiently "fixed" to constitute recognizable copies under the Copyright Act.