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UMG argues that SRLA Article 21(a) imports rates from another applicable agreement and that no AI-use agreement exists. It seeks dismissal and recounts AFM’s competing view that the SRLA itself can supply rates.
View full image ↗Opening page of the source document associated with “Universal Music Group Reply Memorandum Supporting Motion to Dismiss — Document 51”. Original page layout retained; follow the source for the full text.
Image source: U.S. District Court for the Southern District of New York; copy hosted by Music Business Worldwide; rights remain with the original rights holders.
Source · Universal Music Group Reply Memorandum Supporting Motion to Dismiss — Document 51 ↗Case 1:26-cv-04760-ER, Document 51. Cover, contents and opening argument checked. Defendant arguments are not a judgment; union pleadings require further reading.
Case chronology
UMG files reply seeking dismissal of AFM new-use payment action
UMG argues that SRLA Article 21(a) imports rates from another applicable agreement and that no AI-use agreement exists. It seeks dismissal and recounts AFM’s competing view that the SRLA itself can supply rates.
Warner and Atlantic file reply in AFM dismissal proceedings
Warner and Atlantic argue that existing recording terms do not supply additional AI-use rates and urge reliance on collective bargaining; AFM maintains that the contract permits competing reasonable interpretations.
Research question
Editorial interpretation: examines relationships between creative labour, permission and institutional responses in this record.
Related documents
DOC-0426Universal Music Group Reply Memorandum Supporting Motion to Dismiss — Document 51DOC-0427Warner Reply in Support of Motion to Dismiss — Document 52Sources
U.S. District Court for the Southern District of New York; copy hosted by Music Business Worldwide · EN · 2026-09-11
U.S. District Court for the Southern District of New York; copy hosted by Music Business Worldwide · EN · 2026-09-11
Cite this record
ANTI-AI ARCHIVE. “AFM: session-musician new-use payments after AI licensing.” case-0216. Include this page’s URL and your access date when citing.