"...infringement of the distribution right requires an actual dissemination of either copies or phonorecords."The RIAA had been claiming that if someone could have downloaded copyrighted material from you, even if no one actually did, it should considered copyright violation. The court clearly rejected that claim and denied Atlantic's motion for a summary judgment in the case against Mr. and Mrs. Howell, the two defendants representing themselves without lawyers.
The court also opened the door to the idea that P2P file sharing may not infringe on the distribution right at all, if downloads are considered to be simply a series of reproductions.
For more info:
Electronic Frontier Foundation (EFF)
The Court Order on ilrweb