I thought [IANAL] that resale of a product containing software was covered by the first-sale
doctrine and did not require a license from the copyright holder (first sale holds that the
first sale of an instance of a work covered by copyright exhausts the author's rights in that
copy). That would suggest that Actiontec would be responsible for supplying the source code
and not Verizon (unless plaintiffs know something additional - for instance, that Verizon is
modifying the software loaded in the device).
First sale is pretty important - without it you wouldn't be able to sell your used CDs or
books, let alone computers with software on them, without permission from the authors. I
thought this was reasonably well settled, in the US at least.
The complaint didn't seem to allege that Verizon had installed or modified the software...