Play Meter

Issue: 1981 May 01 - Vol 7 Num 8

FROM THE RECORD:
The CRT rate hike
Editor's Note: The Copyright Royalty Tribunal's
decision to raise the compulsory jukebox royalty rate
appeared in the Federal Register January5,1981 (pages
884-891). /n that published decision, the CRT set forth its
reasons for raising the $8 per jukebox copyright royalty
rate to $25 in 1982, to $50 in 1984, and then euen higher
for "an inflationary adjustment" in 1987. The following
are excerpts and condensations from the text of that
decision as published.
Summary of positions
ASCAP (SESAC's case was presented also by
AS CAP) stated "they felt compelled to determine a com-
pulsory license fee similar to the fee which would be
reached on the open marketplace if performing rights
societies and jukebox operators were free to negotiate
for license absent a compulsory license.
"With that benchmark, they concluded that the most
useful approach in reading the marketplace value was to
use close [sic] marketplace analogies. These analogies
were used: (a) general establishments, such as bars,
grills, restaurants, and taverns using mechanical music
(i.e., music provided by non-live means); (b) background
music services; and (c) foreign jukebox operators."
On general establishments, such as bars, etc.-"The
lowest such fee for ASCAP alone is $70 . When the fees
for BMI and SESAC are added, the total minimum fee
paid by such establishments is $190 . Dr. Fagan
(ASCAP's chief economist and director of special pro-
grams) stressed there would be an administrative sav-
ings if all three repertories were licensed at once, estimat-
ing the resulting total minimum license fee at $140."
On background music seruices- "The annual rate
charged by AS CAP alone for locations similar to those in
which jukeboxes may be found is $27. This rate,
however, was described as an interim fee subject to
retroactive adjustment to 1971. Assuming that the rates
were adjusted only for inflation, Fagan said that it would
be $52 .08 in 1980."
On the foreign jukebox operator analogy- "The aver-
age fee paid by jukeboxes in the nineteen countries
ASCAP surveyed is $96.33 and the mean is $70.92. Dr.
Fagan further testified that the proposed $70 fee is one
that coin machine operators can afford, amounting to
only 19 cents per day."
BMI proposed a royalty rate that "follows directly from
the legislative history and the statutory mandate
requiring balancing of economic considerations There-
fore, BMI applies historical changes in the consumer
Price Index to the $19.70 base specifically recognized by
Congress as a reasonable fee. Application of the CPI
from 1975 to the $19.770 base results in a royalty rate of
approximately $30, adjusted annually."
The AMOA presented its case "through the testimony
of eleven witnesses and the submission of thirty exhibits,
the principal one being Exhibit #10, the Peat, Marwick,
PLAY METER, May 1, 1981
Mitchell and Company (PMM & Co.) survey of the
economic condition of the jukebox operators' business.
"AMOA contends that there has been a marked
increase in recent years in the numbers of amusement
games that are in operation, especially in contrast to the
decline in number of jukeboxes that are in operation and
that many operators do not segregate their operating
expenses for jukeboxes and games."
"The PMM & Co. survey indicates that for the
industry at large, 18% of the boxes in operation earned
for operators less than $300 per year, and that 47%
earned less than $700 per year. For smaller operators of
fewer than 40 machines, 23% of the boxes earned less
than $300 per year, and 57% earned less than $600 per
year."
"Jukebox operator witnesses offered testimony re-
flecting a continuing decline in the numbers of jukeboxes
that are in operation, citing two basic causes for the
decline: (1) the operators' inability to increase prices per
play so as to keep up with the rate of inflation, and (2) the
loss of jukebox locations due to socio-economic changes
such as urban redevelopment and replacement of
jukeboxes by other means of entertainment such as
background music, radio, television, discos, and live
entertainment.
"The AMOA, citing evidence of the decline in the
jukebox operating business, decreasing revenues and
margins of profit, and industrywide reduction in numbers
of locations and of jukeboxes in operation, argued
strongly that the $8 royalty fee should be left
unchanged."
Performing rights societies' financial data
"AMOA sought to bring into issue in this proceeding
the manner of how the performing rights organizations
distributed jukebox royalties to their affiliates and
members. AMOA argued that the Copyright Act called
for an investigation of the performing rights organiza-
tions' distribution methods."
"Finally AMOA argued that there is no logical way the
Tribunal can determine if a change should be made in the
compensation that is to be provided without calculation
of the specific compensation to individuals. Under
AMOA's approach, this was the only way that the "fair
return" standard of the Act could be met.
"In summary, AMOA's position in essence was asking
the Tribunal to establish the value of individual musical
works based on the time and expense incurred by the
songwriters for each one, together with a value inexpli-
cably derived from the placement of a work on a
popularity chart. It then asks the Tribunal to investigate
the internal distribution procedures of the performing
rights organizations to establish the exact payout for
each member or affiliate. A comparison of the two calcu-
lations-the costs and the payout-would, according to
AMOA, produce the "fair return" calculations supposed-
3
ly required by the Copyright Act.
"BMI argued that the language cited by the AMOA
'to afford the copyright owner a fair return for his
creative work,' reflects the broad goal of the legislation to
insure that creators are fairly compensated through
adoption of license fees establishing a reasonable value
for the use of the copyright works.
"We [the CRT] agree. The language in the statute is
not a directive authorizing the Tribunal to investigate
individual members or affiliates collections from the per-
forming rights organizations.
"We find that there is no indication either in the
statute or the legislative history, that Congress intended
the Tribunal to calculate rates or returns for each piece
of music and then base royalty adjustments on these
rates of return.
"We find nothing in the Copyright Act or its legisla-
tive history which indicates that the Tribunal was
intended to regulate the internal operations of the
performing rights societies. In our opinion the Tribunal's
authority is strictly limited to setting applicable royalty
fees and establishing the distribution to claimants."
Determination of the rate
"The Tribunal finds that the case presented by the
AMOA, including the industry survey, has failed to pro-
vide reliable data concerning the operating expenses,
revenues, or even return on investment of jukebox
operators.
"The Tribunal convened a conference of the parties
on February 13, 1980 in order to permit the Tribunal and
all of the parties to make suggestions concerning the
contents of a questionnaire which would be used by the
AMOA to survey the financial condition of jukebox
operators. At that conference the representatives of the
AMOA stated that it was too late to revise the
questionnaire.
"We note the limited response rate to the question-
naire, estimated by Peat Marwick to be approximately
14%. Dr. John Scarbrough, the Peat Marwick manager
in charge of the survey, testified: 'I wouldn't argue very
hard if you wanted to say that it was not a good
response.'
"The record of this proceeding contains detailed
testimony reciting the procedures utilized in the prepara-
tion and distribution of the questionnaire, which
presents significant questions as to the survey's
methodology and objectivity, as well as the nature and
scope of the data provided."
The CRT also noted that the survey findings were not
consistent with other evidence in the record, including
other industry surveys, such as the one conducted
annually by PLAY METER magazine.
"We have reviewed the testimony of the AMOA
witnesses- five jukebox operators, representatives or
distributors of the three American jukebox manufac-
turers, a 'one-stop' distributor of records, and a trade
association official. We find that this testimony does not
provide a basis for forming any representative picture of
the jukebox industry nor does it create a foundation for
the industry's claim of economic hardship. The
testimony does establish an industry practice to turn
over 50% of the gross revenues from jukeboxes to the
location owner.
BMI's proposal to apply the CPI to a proposed$19.70
rate that was mentioned in a congressional committee
report was ruled by the CRT to be " not in accord with
our statutory responsibilities in this proceeding."
"In reaching our determination in this proceeding, we
4
found the ASCAP/ SESAC concept of basing the rate on
marketplace analogies to be the most attractive. We
have examined the three marketplace analogies urged
upon us by ASCAP/ SESAC- the license fees paid by
general establishments using mechanical music,
background music services, and foreign jukebox fees .
These analogies, individually and collectively, are subject
to limitations and distinguishing features . We believe that
certain distinctions set forth in the AMOA pleading have
validity. While acknowledging that our rate cannot be
directly linked to marketplace analogies, we find that
they serve as an appropriate benchmark to be weighed
together with the entire record and the statutory criteria.
"We find that a per box payment of $50 is a
reasonable fee for the jukebox industry as a whole. We
have phased in the rate to accord the jukebox industry
opportunity to adjust , since tn our v1ew the jukebox
industry has ne ver peviouslt pa id reas o na ble
compensation for the use of copyrigh ted music. We note
that ASCAP/ SESAC , in their proposed findings , con-
cluded that an interim fee would be appropriate 'to afford
the coin machine industry an opportunity to adopt to
compulsory licensing at marketplace rates.'
Consequently, the adjustment of the jukebox rate on
January 1, 1982 will be limited to $25 .
"We are aware that some jukebox operators fun ction
on a narrow profit margin, and that certain jukeboxes
produce modest revenues. The Tribunal is satisfied that
adequate attention has been given to the small operator,
including the adoption of an amendment to the proposed
fee schedule that was proposed for the benefit of such
operators."
Maximize the availability of music
"We do not maintain that the jukebox rate is crucial
to assuring the public of the availability of creative works.
As has been observed in the pleadings, musical works
were created and exploited for many years, during
which, in our view, songwriters and publishers were un-
justly denied reasonable compensation for a commercial
use of their works. We concur in the ASCAP/ SESAC
finding that 'reasonable payment for jukebox perform-
ances will add incrementally to the encouragement of
creation by songwriters and exploitation by music
publishers, and so maximize the availability of musical
works to the public. We find nothing in this record which
would justify any reasonable concern that the schedule
we have adopted will deprive the public access to music."
"We reject the contention that copyright owners are
paid for jukebox royalties derived from record sales. We
recognize that performing rights are distinct from
recording rights. The Congress has determined that
copyright owners are entitled to be paid reasonable fees
for both. The Tribunal also rejects the contention that no
adjustment of the royalty fee should be made unless the
copyright owners established their 'need to receive' an
increase.
"We have given our analysis of the testimony
presented by the jukebox industry. We find nothing in
that testimony which would warrant a conclusion that
our schedule will deprive the jukebox operator a fair
income under existing economic conditions."
"On the basis of the record in this proceeding, we
have no basis for concluding that jukebox operators and
owners of establishments with jukeboxes make any
unique or distinctive contribution concerning creativity,
technology, capital investment, cost, risk, and the
opening of new markets for creative expression and
media for their communication. We find in this record no
PLAY METER , May 1, 1981

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