White-Smith Music Publishing Company v. Apollo Company, 209 U.S. 1 (1908), was a decision by the Supreme Court of the United States which ruled that manufacturers of music rolls for player pianos did not have to pay royalties to the composers. The ruling was based on a holding that the piano rolls were not copies of the plaintiffs' copyrighted sheet music, but were instead parts of the machine that reproduced the music.
This case was subsequently eclipsed by Congress's intervention in the form of an amendment to the Copyright Act of 1909, introducing a compulsory license for the manufacture and distribution of such "mechanical" embodiments of musical works.
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