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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.
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Source · Universal Music Group Reply Memorandum Supporting Motion to Dismiss — Document 51 ↗What changed
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.
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.
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Evidence & sources
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.
SRC-0435PDF pp.1–5.
U.S. District Court for the Southern District of New York; copy hosted by Music Business Worldwide · EN · 2026-09-11
Case
Related documents
DOC-0426Universal Music Group Reply Memorandum Supporting Motion to Dismiss — Document 51Cite this record
ANTI-AI ARCHIVE. “UMG files reply seeking dismissal of AFM new-use payment action.” evt-0365. Include this page’s URL and your access date when citing.

