A Dish Network device that can digitally record network television shows and replay them without commercials may be far more advanced technologically than Sony's Betamax VCR from the 1980s.

But Sony Corp. of Am. v. Universal City Studios remains the gold standard for copyright litigation arising from TV recordings. And under that precedent, Dish Network didn't likely infringe Fox TV's copyright — though it might have breached its programming contract, a unanimous Ninth Circuit panel ruled Wednesday in a case closely watched by traditional TV networks.