This failed to slow the decline in revenue and was a public relations disaster. Some academic studies have even suggested that downloads were not the true cause of the decline. The turmoil in the industry changed the balance of power among all the various players. The major music-only stores such as Tower Records (which once wielded considerable influence in the industry) went bankrupt, replaced by box stores (such as Wal-Mart and Best Buy). Recording artists began to rely primarily on live performances and merchandise for their income, which in turn made them more dependent on music promoters such as Live Nation (which dominates tour promotion and owns a large number of music venues.) In order to benefit from all of an artist's income streams, record companies began to rely on the "360 deal", a new business relationship pioneered by Robbie Williams and EMI in 2007. At the other extreme, record companies also used simple manufacturing and distribution deals, which gives a higher percentage to the artist, but does not cover the expense of marketing and promotion. Many newer artists no longer see any kind of "record deal" as an integral part of their business plan at all. Inexpensive recording hardware and software made it possible to create high quality music in a bedroom and distribute it over the internet to a worldwide audience. This, in turn, caused problems for recording studios, record producers and audio engineers: the "Los Angeles Times" reported that, by 2009, as many as half of the recording facilities in that city had failed. Consumers benefited enormously from the ease with which music can be shared from computer to computer, whether over the internet or by the exchange of physical CDs. This has given consumers unparalleled choice in music consumption and has opened up performers to niche markets to which they previously had little access. According to a Nielsen and Billboard report, in 2012 digital music sales topped the physical sale of music. Napster was an online music file sharing service created by Shawn Fanning while he was attending Northeastern University in Boston and operating between June 1999 and July 2001. Its technology allowed people to easily copy and distribute MP3 files among each other, bypassing the established market for such songs and thus leading to the music industry's accusations of massive copyright violations. The first peer-to-peer case was "A&M Records, Inc. v. Napster, Inc.", 239 F.3d 1004 (9th Cir. 2001). The court found that Napster was contributory liable for the copyright infringement of its end-users because it "knowingly encourages and assists the infringement of plaintiffs' copyrights."