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Congress responded with the Copyright Act of 1909, which created a new form of intellectual property, mechanical reproduction rights.
For mechanical reproduction rights, GEMA entered into reciprocal agreements with 51 different collecting societies.
On many old contracts, a vague clause - usually referring to "mechanical reproduction rights" - allowed publishers to retain the rights for any unforeseen future media.
"People say it's unfair to pay a levy at all," said David Basskin, president of the Canadian Mechanical Reproductions Rights Agency, one of the groups seeking the fee.
The Canadian Broadcasting Company purchased the mechanical reproduction rights for the percussion quartet composition, "Implosion" (1981), for broadcasting throughout Canada and 1,000 affiliated stations worldwide (1989; composers: Varese, Beluse, Morel, Lanza, Kondo, Hood)