321 Studios has chosen to play David to Motion Picture Association of America’s Goliath in the legal arena. This small company has released a software application for $99.99 that allows purchasers to easily make copies of DVD movies to blank DVDs. The MPA contends that the Digital Millennium Copyright Act of 1998 prevents 321 Studios from a blatant circumvention of DVD encryption control technology, referred to as CSS (Content Scrambling System). 321 Studios argues fair use allows consumers to legitimately make a backup copy of any DVDs they have purchased for personal use.