It's like the difference between trespassing vs. breaking and entering. If you have to turn a doorknob, it's trespassing. But picking a lock is breaking and entering. If you can read the plain text in Notepad, I don't think it counts. From http://www.law.duke.edu/journals/dltr/articles/2009dltr003.h...
The anti-circumvention provisions of ยง1201 were intended to "encourage[] technological solutions" to piracy by providing legal sanctions against the circumvention of such technology. Realizing that "what may be encrypted or scrambled often may be decrypted or unscrambled," Congress thought it necessary to provide an alternate form of protection to those willing to invest in (and implement) "effective" technological measures. Section 1201 "does not mandate the adoption of any . . . technological protection;" it merely "takes those technological measures that win adoption because of their efficacy and confers [statutory] protection on them." If, as Congress suggested, the circumvention of a technological measure designed to protect a copyrighted work truly is "the electronic equivalent of breaking into a locked room in order to obtain a copy of a book," providing a legal remedy if the lock fails seems entirely reasonable and appropriate.
The anti-circumvention provisions of ยง1201 were intended to "encourage[] technological solutions" to piracy by providing legal sanctions against the circumvention of such technology. Realizing that "what may be encrypted or scrambled often may be decrypted or unscrambled," Congress thought it necessary to provide an alternate form of protection to those willing to invest in (and implement) "effective" technological measures. Section 1201 "does not mandate the adoption of any . . . technological protection;" it merely "takes those technological measures that win adoption because of their efficacy and confers [statutory] protection on them." If, as Congress suggested, the circumvention of a technological measure designed to protect a copyrighted work truly is "the electronic equivalent of breaking into a locked room in order to obtain a copy of a book," providing a legal remedy if the lock fails seems entirely reasonable and appropriate.