Decades later, after Wolfe’s death, that deposit copy was retrieved from the vaults of the Library of Congress when Michael Skidmore, co-trustee of the Randy Craig Wolfe Trust, alleged that the iconic introduction to Led Zeppelin’s legendary rock hit, “Stairway to Heaven,” was substantially similar to the first eight measures of “Taurus.”12×12. H.R. In December of 1967, guitarist Randy Wolfe (known as “Randy California”) filed a single page of music (the “deposit copy”) with the United States Copyright Office.9×9. The Consent Decrees mitigate anticompetitive action by ASCAP and BMI. As Skidmore reduced the viability of selection and arrangement infringement claims, it signaled that formal attribution of songwriting influences may no longer be necessary to avoid expensive settlements. Read online books for free new release and bestseller See Edwin F. McPherson, Crushing Creativity: The Blurred Lines Case and Its Aftermath, 92 S. Cal. For tutoring please call 856.777.0840 I am a recently retired registered nurse who helps nursing students pass their NCLEX. Absent original selection and arrangement, there can be “no liability for taking ‘ideas and concepts,’” such as musical building blocks, “even in combination.”41×41. Evolutions des sociétés ces dernières années Ci-dessous, l'évolution par an (depuis 2012) des créations et suppressions d'entreprises en France, par mois avec des courbes en moyenne mobile de 12 mois afin de voir l'évolution et les tendances, idem par semaine avec des moyennes mobiles sur 4 semaines. See, e.g., Smith v. Weeknd, No. See Vaidhyanathan, supra note 56, at 118. would have classified most blues songs as infringements and hindered the evolution of jazz and rock music.61×61. The “availability of passive income streams from the sale or licensing of copyrights is a prime economic incentive for the creation of artistic works,”52×52. at 1076 n.13 (majority opinion). Shyamkrishna Balganesh See Lynskey, supra note 5. Concurring in part and dissenting in part, Judge Ikuta, joined by Judge Bea, contended that both the trial record and common sense showed Skidmore had presented an argument that the five musical elements he identified “cohere[d] to form a holistic musical design.”44×44. The panel then vacated and remanded the amended judgment in part on the grounds that the district court failed to instruct the jury that an original “selection and arrangement” of otherwise nonprotectable elements would qualify for copyright protection26×26. 952 F.3d 1051. the en banc Ninth Circuit established that the scope of copyright in unpublished musical works registered under the 1909 Act is limited to their deposit copies and clarified that protection for original selection and arrangement requires more than a mere “combination” of musical building blocks.7×7. at 1059–60. 15-cv-05642, 2020 WL 1275221, at *8–11 (C.D. In an opinion authored by Judge McKeown,30×30. It was written by David Guetta, Savan Kotecha, Giorgio Tuinfort, Rami Yacoub, and Carl Falk.The song was produced by the latter two, with Tuinfort serving as a co-producer and Ilya serving both as a co-producer and vocal producer. Id. at 1075–76. Id. at 124. See U.S. Dep’t of Just., Statement of the Department of Justice on the Closing of the Antitrust Division’s Review of the ASCAP and BMI Consent Decrees 2 (2016), https://www.justice.gov/atr/file/882101/download [https://perma.cc/5QHE-N8KW]. at 1130–31, and any failure to play the sound recording to prove access was harmless as well, given already substantial evidence of access in the record, see id. decided as a matter of first impression that the deposit copy defined the scope of the “Taurus” copyright under the 1909 Act.25×25. Concerning the ASCAP and BMI Consent Decrees, Copyrights and Copywrongs: The Rise of Intellectual Property and How It Threatens Creativity, Statement of the Department of Justice on the Closing of the Antitrust Division’s Review of the ASCAP and BMI Consent Decrees, Legal Internalism In Modern Histories of Copyright, https://www.gq-magazine.co.uk/culture/article/long-songwriting-credits, https://www.bloomberg.com/features/2019-classic-rock-riffs-loophole, https://news.bloomberglaw.com/us-law-week/musicians-more-careful-after-blurred-lines-case, https://www.songwritersguild.com/docs/SGA-comments-8-9-19-to-DOJ-re-Consent-Decrees.pdf, https://www.justice.gov/atr/file/882101/download. Skidmore appealed from the amended judgment.23×23. Id. See id. 2018). CV 19-2507, 2020 WL 4932074, at *6–7 (C.D. Accessibility Statement, Privacy at 1076. These artists’ original contributions to the genre did not translate well into sheet music, because originality in blues music, as in its West African antecedents,56×56. Postscript 67, 68 (2018). The court also affirmed the district court’s decision to deny Skidmore’s request for sanctions and to preclude Led Zeppelin’s musicologist from testifying, finding no conflict of interest, see id. Cal. "One Last Time" is a song recorded by American singer Ariana Grande for her second studio album My Everything. Id. A Collective Case Study of Effective Collaborative Practices in Elementary and Middle School Inclusion Classrooms in … Congress recognized that “one company might secure . . . a large number of copyrights of the most popular music, and by controlling these copyrights monopolize the business of manufacturing the selling [of] music-producing machines.” Id. 2018) (Nguyen, J., dissenting)). at 7, and has recently rejected proposals to allow publishers to “partially withdraw” their songwriters’ music from digital music streaming services to negotiate licenses directly, id. See Lynskey, supra note 5. Fearful that they too might be found to have illegally appropriated from their inspirations, popular musicians instituted the practice of granting songwriting credits and their associated royalties to anyone and everyone who may have influenced new music.5×5. Apr. 274, 281 (2017). But songwriters would likely beg to differ — absent a credible threat of litigation, they may have lost their best bargaining chip to negotiate more favorable contracts and enforce ethical borrowing norms. would contradict copyright’s purpose by stifling creativity.69×69. This accreditation regime that arose out of litigation anxiety reflected the collaborative nature of the creative process and facilitated greater distribution of royalties.77×77. Writing for the Ninth Circuit panel, Judge Paez24×24. In the aftermath, a slew of opportunistic claims are being made on other hits.” (statement of Dean Marsh)). 2018). Dr. Alexander Stewart, Skidmore’s witness, identified five categories of similarities between the two works,18×18. Recent Case Dorian Lynskey, How Many People Does It Take to Write a Hit Song in 2019?, GQ (Nov. 2, 2019), https://www.gq-magazine.co.uk/culture/article/long-songwriting-credits [https://perma.cc/9FLV-GLTD] (“[Williams] created a precedent that inspiration alone could lead to infringement. The specter of copyright litigation was a powerful tool to secure royalties on pop hits and enforce borrowing norms that are “aesthetic and ethical issues more than legal ones.”76×76. PDF. Id. at 1061–62. Multicultural Competence in Vocational Rehabilitation: The Role of Multicultural Awareness among Black VRCS, Regina Walden Alston, Secondary Content Teachers' Perceptions of Instructing English for Speakers of Other Languages (ESOL) Students: A Phenomenological Study, Wendy Lane Bailey, Millennials in the Workforce: An Examination of Motivation and Behavior, Josephine L. Bennett, Purging the New Age: A Theological Analysis of the Use of New Age Practices by the Church, Christopher Michael Berg, A Transcendental Phenomenological Study of the Motivations of Minority Police Recruits Participating in an Entrance-Level Police Academy, Jennifer A. Beskid, An Exploration into the Impacts of Life Satisfaction and Social Support on Military Wives' Successful Performance while Enrolled in Graduate School, Marlene Blyden, A Look at Short-Term Mission Trips in the Context of Cypress Baptist Church as a Sending Unit, John Daniel Bodine, Christian Women's Pornography Usage: The Role of Perceived Addiction, Social Anxiety, Shame, and Grace, Kathryn Ellen Bohannon, The Role of Leadership on Corporate Governance, John Brackett, Proximity Search Techniques to Reduce Cognitive Load: A Case Study, Donald G. Campbell, Surviving or Thriving? Serv. Id. See id. 3787, 1994 WL 901652 (S.D.N.Y. Judge McKeown was joined in full by Chief Judge Thomas and Judges Fletcher, Rawlinson, Murguia, and Nguyen, and in part by Judges Watford, Hurwitz, and Bade. at 1088. United States v. ASCAP, No. Mar. at 1070. at 1074–75. See Blake Brittain, Musicians More Careful After “Blurred Lines” Case, Bloomberg L. (Sept. 18, 2015, 4:00 AM), https://news.bloomberglaw.com/us-law-week/musicians-more-careful-after-blurred-lines-case [https://perma.cc/XAK6-CD3H]. See id. 5 ... to form a holistic musical design. Cal. Reddit, I've taken some time to crawl the internet and combine my findings into a single collection to share with you all. at 120; Arewa, supra note 47, at 584, 596–99. I have been a nurse since 1997. at 1127. it blurred the line between musical inspiration and appropriation.3×3. 895 F.3d 1106 (9th Cir. Expatica is the international community’s online home away from home. Omission of an inverse ratio instruction was harmless because the jury never reached the question of copying, see id. The panel ultimately found this omission to be prejudicial. The fact that composers had no control over mechanical reproductions (originally in the form of piano rolls, now sound recordings) generated from copies of their works reinforced the conclusion that compositional copyright did not extend to separate performance elements embodied in those reproductions.33×33. would serve to register the copyright in “Taurus,” a two-and-a-half minute instrumental guitar track released on the band Spirit’s first album, under the 1909 Act.11×11. After Williams, there was a noted uptick in music infringement claims as songwriters used copyright litigation offensively to secure songwriting credits on such megahits.74×74. at 1065. In his concurrence, Judge Watford explained that he saw no reason for the court to address the question of preservation of the selection and arrangement instruction when no reasonable jury could have found substantial similarity based on the deposit copy anyway.43×43. Rep. No. Then, in the recent case Skidmore v. Led Zeppelin,6×6. Yet the deposit copy ruling disadvantages songwriters, particularly black blues songwriters composing under the 1909 Act, who historically struggled to secure adequate compensation in the music industry.47×47. In the future, Ray dreams of owning a contemporary art space and a cafe. But Skidmore has the practical effect of reducing pressure to grant attribution and royalties to songwriting influences — an effect made particularly unfortunate in light of the music industry’s historical failure to fairly compensate black musicians writing music under the 1909 Act and the current shortcomings of the “winner-takes-all” streaming market. 2018)). When the Ninth Circuit affirmed the jury’s finding in Williams v. Gaye1×1. See id. Perhaps “[t]his result is neither unfair nor unfortunate. at 1074–76. See Vernon Silver, The Legal Loophole that May Leave Some of Rock’s Greatest Riffs Up for Grabs, Bloomberg (June 20, 2019), https://www.bloomberg.com/features/2019-classic-rock-riffs-loophole [https://perma.cc/9YL4-LUDL]. Jon Caramanica, It’s Got a Great Beat, and You Can File a Lawsuit to It, N.Y. Times (Jan. 6, 2020), https://nyti.ms/39J2lsi [https://perma.cc/AZV2-UN9E]. Id. Caramanica, supra note 15. Judge Watford contended that copying of “thin” copyright requires “virtual identity.” Id. Lynskey, supra note 5. at 1127. At the time of the 1909 Act, Congress extended copyright protection in compositions to copies made in any other system of notation or record, but did not provide that the copyrighted works themselves could be anything other than sheet music.32×32. at 1122. And by reducing the viability of selection and arrangement claims, Skidmore has the unfortunate effect of reducing pressure to credit songwriting influences. ... but are unknown to most guitar players... Once you learn to use these exotic scales, your guitar playing, soloing and songwriting will become very unique. PDF. The Department of Justice requires ASCAP and BMI to license their entire repertoires to users, id. Concerning the ASCAP and BMI Consent Decrees 2 (Aug. 9, 2019), https://www.songwritersguild.com/docs/SGA-comments-8-9-19-to-DOJ-re-Consent-Decrees.pdf [https://perma.cc/9FRJ-NALW] (“[T]he inability to earn fair value for public performances (our most important source of royalty income) is continuing to cripple the ability of songwriters and composers to earn a living through our chosen profession.”). Taylor Swift credited Fred and Richard Fairbrass of the 1990s group Right Said Fred on her song “Look What You Made Me Do” even though the artists did not contact her. See Songwriters Guild of Am., Inc., Comments of the Songwriters Guild of America, Inc. at 1127, 1130. The uptick in claims was accompanied by a steady increase in songwriting credits.75×75. Sitemap . June 11, 2001); United States v. BMI, No. However, in correctly deciding the selection and arrangement issue with respect to Congress’s policy purposes, Skidmore has the unfortunate effect of reducing pressure to extend songwriting credits to anyone who may have influenced new music, a practice that arose in the context of cases like Williams and the “winner-takes-all” streaming market.70×70. See Arewa, supra note 47, at 576, 597–98. Thus, the district court had not abused its discretion in restricting Skidmore from playing sound recordings of “Taurus” for the jury, and the question of whether sound recordings could be played to prove access was moot.34×34. Tuneen E. Chisolm, Whose Song Is That? In circumscribing the scope of the compositional copyright embodied in the deposit copy, the Ninth Circuit preserved Congress’s distinction between the composition and the reproductions, a distinction intended to avoid “powerful and dangerous monopolies” that might restrict public enjoyment of music.49×49. H.R. Id. and royalty income is often songwriters’ central livelihood.53×53. See Feist Publ’ns, Inc. v. Rural Tel. See id. The jury returned a verdict for Led Zeppelin, finding no extrinsic similarity21×21. See id. Id. It explicitly recognized that assigning exclusive rights to “commonplace elements . . . firmly rooted in [a] genre’s tradition”68×68. Id. 2004)). Id. Take A Sneak Peak At The Movies Coming Out This Week (8/12) #BanPaparazzi – Hollywood.com will not post paparazzi photos; What’s poppin’? & Tech. at 1064. See Skidmore, 952 F.3d at 1056–57. at 1069 (quoting Williams v. Gaye, 895 F.3d 1106, 1141 (9th Cir. The 1976 Copyright Act provided for submission of sound recordings as deposit copies for musical compositions, effective after 1978. See id. See Olufunmilayo B. Arewa, Blues Lives: Promise and Perils of Musical Copyright, 27 Cardozo Arts & Ent. Cal. As there are “relatively few ways to express a combination of five basic elements in just four measures, especially given the constraints of particular musical conventions and styles,” Judge Watford contended that the portion of “Taurus” at issue enjoyed only “thin” copyright. See Skidmore v. Led Zeppelin, No. This situation benefitted music listeners — a selection and arrangement monopoly over the simple twelve-bar I-IV-V chord progression60×60. Mar. Led Zeppelin itself borrowed heavily from blues artists, particularly the legendary blues musician Willie Dixon — whom it was often unwilling to credit.64×64. between the deposit copy and “Stairway to Heaven.”22×22. 41-1395, 2001 WL 1589999 (S.D.N.Y. It began by overruling Ninth Circuit precedent, joining the majority of circuits in abrogating the inverse ratio rule, which “is not part of the copyright statute, defies logic, and creates uncertainty for the courts and the parties.”35×35. See id. The 124 notes of piano music distilled on that one page10×10. See id. at 1084. and amounted to a miscarriage of justice.46×46. Id. at 1079 (Watford, J., concurring). Known for the study of jazz and modern American music, it also offers college-level courses in a wide range of contemporary and historic styles, including rock, hip hop, reggae, salsa, heavy metal and bluegrass. at 1063, 1075. 8, 2016) (quoting Swirsky v. Carey, 376 F.3d 841, 849 (9th Cir. Id. Also left uncertain was the scope of copyright protection in works like Gaye’s that were registered in the form of sheet music “deposit copies” under the Copyright Act of 1909.4×4. PDF; When the Ninth ... popular musicians instituted the practice of granting songwriting credits and their associated royalties to anyone and everyone who may have influenced new music. lay “not in the raw materials employed for the composition, but in the style and presentation.”57×57. : 952 F.3d 1051 (9th Cir. | But Congress made clear that composers would have no control over the recordings made by these machines, and any benefit they accrued through this scheme was merely a “bonus” — such rights were given “primarily for the benefit of the public.”51×51. See id. See 17 U.S.C. L. Rev. Lynskey, supra note 5. Skidmore, 952 F.3d at 1060. You need a holistic approach to learn scales together with a set of chords and specific ways to put everything together. at 1057 (majority opinion). § 101; Skidmore v. Led Zeppelin, 952 F.3d 1051, 1062 (9th Cir. at 603. 60-2222, at 7 (1909). at 1130. Id. © 2021 Government of Singapore. at 1059. The Ninth Circuit granted rehearing en banc.29×29. at 1078, and its denial of the separate motion for attorneys’ fees and costs by Led Zeppelin’s publisher, see id. at 1079–80. Led Zeppelin performed at the same location as Spirit four times between 1968 and 1970 and covered Spirit’s song “Fresh Garbage.” See id. And the court’s clarification that selection and arrangement requires more than a mere combination of elements reduces pressure to credit artists who influenced new music — a practice that arose in the context of cases like Williams and today’s difficult winner-take-all digital streaming market.48×48. arguing that these same elements made both “Taurus” and “Stairway to Heaven” unique and memorable.19×19. 320, § 1(e), 35 Stat. that a collection of “signature phrases, hooks, bass melodies, [and] word painting” in Robin Thicke’s “Blurred Lines” was substantially similar to Marvin Gaye’s “Got to Give It Up,”2×2. Nov. 18, 1994). 2020). at 1071. L. No. Berklee College of Music is a private music college in Boston, Massachusetts.It is the largest independent college of contemporary music in the world. Id. In the Ninth Circuit, extrinsic similarity is similarity that is “‘substantial’ and to ‘protected elements’ of the copyrighted work.” Skidmore v. Led Zeppelin, No. Id. À tout moment, où que vous soyez, sur tous vos appareils. See Vaidhyanathan, supra note 56, at 118–19. Copyright Act of 1909, ch. at 1075 (majority opinion)). 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Shields Jr, A Study on the Development and Effectiveness of Christian Leaders through Cambodia Christian International School, Changsoon Son, Promotion of Leaders Based on Skills Not Related to Leadership, Emily Kathryn Stites, Employee Perceptions of Honesty and Integrity within National Park Service Leadership, Christy Lea Strand, Integrative Review on the Initiation of a Systematic Oral Care Education Program, Toni Rochelle Thomas, Mentor Programs as a Strategic Approach to Nurse Retention: Integrative Review, Nancy Jo Thompson, Employee Wellness Program Participation: Exploring Participation of Registered Nurses in East Tennessee, Jacquelyn Turner, A Case for Basic Belief in the Christian Scriptures: An Augmented Aquinas/Calvin Model in Favor of Including Scripture Beliefs among the Great Things of the Gospel, Peter William Van Kleeck Jr, Understanding the Impacts of Altering Safe Harbor Plans within Small Business Organizations, Svetlana Kirilova Velikova, African American Women in Leadership in Faith-Based Higher Education: A Qualitative Study, Michael Charles Walker, The Power of a Personal Testimony Booklet: Increasing Gospel Witness in Everyday Life, Patrick Bram Walker, Predictive Effects of Physician Assistant Students' Pre-Admission Direct Patient Contact Hours on Performance in Supervised Clinical Practice Experiences, Gerald Robert Weniger, Hispanic First-Generation College Student Perceptions of University Support Programs, Katelynn Elizabeth Wheeler, Does the Management of Compassion Fatigue in the Healthcare Setting Decrease Nurse Turnover: An Integrative Review, Barbara Fulcher Williams, Effective Pastoral Leadership to Catalyze a Disciple-Making Church, Juan Victor Acevedo, Overall Level of Marital Satisfaction in Christian Individuals Based on Marital Setting and Ethnicity, Rafael DeJesus Acosta, Improving Adoptive Mergers at River Community Church, Gavin Roger Adams, The Role of Leading Worship in the African Church, Emmanuel Olugbenga Adu, Improving Support for Non-Japanese Students Bullied in Japan's Elementary Schools, Corey Joseph Algood, Strength in Community: A Community-Based Health Program to Improve Weight Loss and Blood Pressure within an African American Faith-Based Organization, Leonna Sylvitrice Ameduite, The Right Mix: A Single Case Study into a Blended Learning Program at Tobrikay Corporation, Angela Marie Andrews, A Mixed Methods Study Concerning Biblical Worldview Formation in Children and Adolescents through Informal Learning by Parents and/or Guardians, Joan Ellen Appleton, The Effectiveness of Patient Education Utilizing the Teach-Back Method to Improve Patient Satisfaction, Gladys Cajucom Apuli, Loving The Unloveable: A Biblical Approach for the Local Church to Homosexuality in a Morally Declining Society, Robert Jonathan Archer, The Reentry Experience for Study Abroad Counselors-in-Training, Corinna Arndt, Attitudes of Health Profession Faculty Involved in a Simulation-Based Interprofessional Education Experience, Shannon Ashe, Healthcare Facilities Management Leadership Style Compared to Traditional Healthcare Business and Clinical Leaders, Joshua Paul Ashlock, A Nested-Case Study Investigating Distributed Leadership at the Middle School Level, Darrell M. 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Bell, Biblical Warrior Integration Connecting Veterans and Civilians in Oakland Baptist Church, Alva Ray Bennett, The Effects of Enrollment In Remedial Classes on Students’ High School Graduation Rates, Amy Paulson Bennett, The Dual Enrollment Challenges of First-Generation Appalachian College Students: A Holistic Single-Case Study, Cecil Todd Bennett, A Multisite Case Study of High-Performing Charter School Boards in Florida, Kristine Lynn Bennett, The Relationship Between the Average Number of Principal Walkthroughs and School Accountability Grade of Florida High Schools, Robert Leslie Bennett, Love Your Neighbor: An Educational Strategy to Cultivate Compassion in Adolescent Males, James Allan Benson Jr, Lonely Zs: Examining the Relationships among Time Spent on Social Networking Sites, the Fear of Missing Out (FOMO), and Loneliness among Undergraduate College Students, Chantelle Elam Bernard, The Impact of Racial Segregation on School Performance in Charter Schools, Billie Wright Berry, A Mother's Trauma in the Face of Child Removal, Candace Deborah Berry, The Relationship Between Music Performance Anxiety and Self-Efficacy in Sixth to Eighth Grade Instrumental Students, Brian Bersh, A Qualitative Study of Elementary Teachers' Perspectives of Professional Learning Communities, Chanel Lee Bess, Strategies and Biblical Principles to Keep Church Plants From Closing its Doors Within the First Three Years, Damian Billups, Mental Health Counseling for Individuals with Intellectual/Developmental Disabilities: Attitudes and Experiences of Licensed Counselors, Alysha Dawn Blagg, Improving Student Attendance in Two Rural Mississippi Elementary Schools, Angela A. Bonner, A Mixed-Method Study: Executive Pastors and the Performance Of Fast-Growing Churches, Donald Wouter Bosch, Class Standing and Student Perceptions of Safety in Christian Higher Education: A Causal-Comparative Study, Bradley Carlton Bowen, Home