ANTI-AI ARCHIVE
EVENTS / EVT-0365

UMG files reply seeking dismissal of AFM new-use payment action

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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.

SOURCE DOCUMENT PAGE
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.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 ↗
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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.

RESEARCH NOTE

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.

Editorial research question

Editorial interpretation: examines relationships between creative labour, permission and institutional responses in this record.

This is an editorial interpretation or question, separate from factual statements.

Evidence & sources

01

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-0435

PDF pp.1–5.

SRC-0435
Universal Music Group Reply Memorandum Supporting Motion to Dismiss — Document 51

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 51

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