In the U.S. Supreme Court’s opinion in American Broadcasting Cos. Inc. v. Aereo Inc., 573 U.S., 134 S.Ct. 2498 (2014), the court held Aereo’s “watch live” Internet streaming service constitutes a “public performance” within the meaning of the transmit clause of the U.S. Copyright Act, 17 U.S.C. 106(4). The court’s ruling resulted in the immediate and voluntary shutdown of Aereo’s subscription service, which had allowed subscribers to watch network television programs …