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Songwriters warn that a 100% licensing mandate would reduce creative freedom, constrain collaboration choices, lower royalty fees, delay payments, complicate distributions through multiple PROs, and disrupt long-standing industry practice and songwriter viability.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":35,"@type":76,"position":81},"https://docshare.wps.com/document/healthcare/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/re-justice-department-review-of-the-bmi-and-ascap-consent-decrees-songwriters-urge-against-100-licensing/514799/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/re-justice-department-review-of-the-bmi-and-ascap-consent-decrees-songwriters-urge-against-100-licensing/514799.png","ImageObject",300,407,{"name":92,"@type":93},"Miles","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-09","2026-10-06",true,{"@type":102,"interactionType":103,"userInteractionCount":24},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What question does the Department of Justice ask in this letter?","Question",{"text":112,"@type":113},"It seeks public comments on whether BMI and ASCAP consent decrees should require PROs to license on a 100% basis instead of fractionally licensing jointly owned songs.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"How would a shift to 100% licensing affect songwriters’ ability to collaborate?",{"text":117,"@type":113},"Songwriters say they would have to collaborate only with writers affiliated with their chosen PRO to keep work entirely within that organization, limiting collaborator choice by government rules rather than artistic fit.",{"name":119,"@type":110,"acceptedAnswer":120},"What financial and administrative problems do the writers foresee under 100% licensing?",{"text":121,"@type":113},"They warn royalty payments could be delayed and lowered, with money flowing through two PROs, requiring writers to monitor payments, performance reporting, distribution of bonuses, and related processes across unfamiliar representation.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},514799,1791877724,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":34,"category_name":35,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":24,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":139,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":145,"preview_page_count":4},13056703019404,"https://ap-avatar.wpscdn.com/davatar_29158cc5080c5b710cf443261637dec0","November 20, 2015 Chief, Litigation III Section Antitrust Division  \nU.S. Department of Justice 450 5th Street NW, Suite 4000 Washington, DC 20001  \nRe: Justice Department Review of the BMI and ASCAP Consent Decrees  \nTo the Chief of the Litigation III Section:  \nEach of us is a songwriter and an affiliate of BMI. We truly value our association with BMI.  \nWe write today in response to the Justice Department’s request for public comments on the issue of whether BMI and ASCAP’s consent decrees should require the PROs to license on a 100% basis, as opposed to fractionally licensing jointly-owned songs, which has been the historical industry practice. It’s important that our voices are heard, because a shift to 100% licensing would severely impact our creative freedom, our ability to choose which PRO licenses our music and, ultimately, our livelihood as songwriters.  \nSongwriters are the ultimate small business owners. Many of us have families that depend on the income we receive from BMI. Each of us has carefully chosen BMI as our PRO for multiple reasons: the trusted relationships we’ve developed there; the opportunities BMI provides for our music to be heard; the various creative networking opportunities BMI provides; and, at the end of the day, we like the way BMI values our music and fights for writers to get fees that reflect the fair value of our creative work.  \nLike most modern songwriters, we often choose to collaborate with other writers. Just recently, every song in the Top 10 on Billboard’s Pop, Country, Christian, and R&B/HipHip charts was the result of collaboration. If the practice of 100% licensing is mandated by the Justice Department, our co-written works could be licensed – and we could be paid – by a PRO that represents our co-writers’ interest in our songs. The licensing fee the other PRO charges might be lower than the one BMI has negotiated or fought for in rate court, and despite our chosen affiliation, we would have to accept the lower fee. Because BMI values music differently than other PROs, we also wouldn’t be able to keep the benefits of BMI’s specific valuation system.  \nAs a result, having our work licensed by a different organization than the one each of ushas chosen could dramatically affect our income. It could delay and potentially lower our royalty payments, which would now have to flow through two PROs. Somehow we would each have to monitor what we are being paid by a PRO we have no relationship with, figure out whether they have missed any of our performances, understand how and when they will pay us, determine whether we are getting our fair shares of bonuses under the other PRO’s distribution system, and so on. For these reasons, it might no longer be financially viable for any ofus to collaborate with a writer outside of BMI.  \nIt also might not be creatively viable either. The creativity and success of any songwriter stems from being able to work with songwriters of our choosing, regardless of their PRO affiliation. If the 100% licensing model were imposed on the PROs, in order to keep our work entirely within BMI, our PRO of choice, we would have to collaborate only with fellow BMI writers. All of a sudden, our individual and careful choice of collaborator would not be driven by artistic chemistry or compatibility, but by rules imposed by the government. The 100% licensing model sounds like the government stepping into the creative process and effectively dictating our collaborators and our licensing representatives.  \nAs we understand it, music users from radio to digital music services to local television have all traditionally paid the PROs according to their respective shares ofthe music. Similarly, BMI has only ever paid us for our shares of co-written songs. What the Justice Department is contemplating is in stark contrast with how the PROs have been conducting business for decades and would wreak havoc in the songwriting world as we know it.  \nEach of us urges you to carefully co","cbCaiuFBUwRJh22P","https://ap.wps.com/l/cbCaiuFBUwRJh22P","pdf",1366514,289,"English","# Justice Department Review Request\n## Impact on Creative Freedom and Collaboration\n## Effects on Royalty Payments and PRO Representation\n## Concern About Disrupting Long-Standing Industry Practice","[{\"question\":\"What question does the Department of Justice ask in this letter?\",\"answer\":\"It seeks public comments on whether BMI and ASCAP consent decrees should require PROs to license on a 100% basis instead of fractionally licensing jointly owned songs.\"},{\"question\":\"How would a shift to 100% licensing affect songwriters’ ability to collaborate?\",\"answer\":\"Songwriters say they would have to collaborate only with writers affiliated with their chosen PRO to keep work entirely within that organization, limiting collaborator choice by government rules rather than artistic fit.\"},{\"question\":\"What financial and administrative problems do the writers foresee under 100% licensing?\",\"answer\":\"They warn royalty payments could be delayed and lowered, with money flowing through two PROs, requiring writers to monitor payments, performance reporting, distribution of bonuses, and related processes across unfamiliar representation.\"}]","Re: Justice Department Review of the BMI and ASCAP Consent Decrees - Songwriters Urge Against 100% Licensing | PDF",1791302107,728]