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Limitations in the Distribution of

Public Performance Royalties in Ireland

Ron Healy and Joe Timoney
Department of Computer Science, National University of Ireland, Maynooth, Co. Kildare, Ireland,

Keywords: around the premise that the legal owner of

Public performance copyright, broadcast a piece of music (who might not
monitoring, digital signal processing necessarily be the writer or composer of it)
is entitled to fair recompense if that music
is used. This includes use for any
ABSTRACT: performance in public.1
This paper provides an overview of
the administration of Public
The purpose of copyright legislation at the
Performance copyright in Ireland,
time it was initially legislated for and the
while considering the motivation
role of copyright in the commercial and
behind the introduction of Copyright
artistic development of the modern
legislation almost 300 years ago. We
musician/singer are very different.
explore the idea that the
Whereas early legislation was intended to
administration of modern copyright
prevent the exploitation of authors’ works
helps to create the same environment
by what was then the perfectly legal
that existed prior to legislation for
reprinting and reselling of paper
copyright. We suggest a technological
publications without recompense to the
means by which the problems
creator of the original, modern copyright
experienced by developing artists, in
administration can make no claim that it is
terms of the administration of public
preventing the exploitation of grass roots
performance licensing, might be
Musicians and Performing Artists.
Indeed, it can be shown by the monitoring
of the output of broadcast media that the
INTRODUCTION: administration (if not the actual
In Ireland, the public performance legislation) of rights by copyright collection
(including broadcasting) of copyrighted societies actually causes, in the case of
material is governed by the “Copyright developing Artists, the same situation that
and Related Rights Act 2000”. This piece led to the development of copyright
of legislation, similar versions of which legislation. Copyright legislation was
exist in most modern jurisdictions, affords introduced to protect the exploited,
owners of copyrighted material some form uninformed or under-represented creators
of protection and/or redress if their works of works. Today, the need is just as valid
are used without permission or for
commercial gain. One of the most This paper addresses the issues
common implementations of the Copyright specifically relating to singers, songwriters
Act (as it is known in short) is music
licensing. This may be for pre-recorded 1
What constitutes ‘public performance’ may not
radio/television broadcast or for live always be obvious. There are legal definitions of what
performance, either as self-contained is considered ‘public’ in this regard. For example, a
radio played in a home at the rear of a shop is
musical pieces, background pieces or considered a public performance if customers can
advertisements etc. hear it. Similarly, even played in a locked empty
room, music has been legally held to be a ‘public
There are many derivations of the concept performance’ because the sound travelled through a
heating duct to a public area.
of licensing but they all essentially revolve
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 2

and performing musicians and the issues

discussed relate specifically to the
Authors’ understanding of the Irish music
industry. However, these issues are likely
to be replicated to a greater or lesser
extent in the administration of public
performance copyright in most developed
jurisdictions, perhaps even more
extremely in jurisdictions with recently
developed intellectual property


The first Copyright legislation dates back
almost 300 years to the ‘Statute of Anne’
in 1710. In 1774, England’s ‘House of
Lords’ heard that booksellers who were Fig 1: A reproduction of the first page of
reprinting the works of others for their own the ‘Statute of Anne’, considered the
gain had not ‘ever concerned themselves earliest Copyright legislation in the world
about authors, but had generally confined [1]
the substance of their prayers to the The original transcription of the “Statute of
legislature, to the security of their own Anne” details the motivation of the
property” [2]. Essentially, it was observed legislation and states that it is because
that those who didn’t want legislation authors and creators rights were exploited
introduced to protect creators of works “to their very great Detriment, and too
were not concerned with the actual often to the Ruin of them and their
creators of works but with their own Families”. Legislation was therefore
commercial interests. It might be required to prevent exploitation that was
suggested that this is still the motivation previously causing financial and
of those Companies in the Music Industry, developmental difficulties for authors and
as it should be. Copyright legislation was creators while simultaneously providing a
intended to address that issue, creating an handsome income for those who were
environment where ‘literary works, like all reproducing such works and selling them.
others, will be undertaken and pursued
with greater spirit, when, to the motives of Of course, modern copyright legislation
public utility and fame, is added the concerns itself in detail with the rights of
inducement of private emolument’ [2]. the author and creator. It allows for groups
This, then, is the basis for the of authors and creators to form a
development of modern copyright: that an collective organisation to protect and
author of a work has rights that s/he can administer their rights. All of this evolved
choose to use, waive or limit and that the out of early legislation and in this regard
potential to profit from their work by the current legislation is not necessarily
availing of their rights is at least a partial flawed. However, it is the administration of
incentive and affords the opportunity to such schemes that is creating a situation
further develop their creative works. for large numbers of developing writers
and performers that is no different to the
time, 300 years ago, when their works are
used, incidentally or accidentally in most
cases, “to their very great detriment” and
in a manner that essentially removes
some of the motivation, as mentioned in
[2], for artistic endeavour to be ‘pursued
with greater spirit, when, to the motives of
public utility and fame, is added the
inducement of private emolument’.
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 3

PUBLIC PERFORMANCE IN IRELAND stores, workplaces and shopping centers

In terms of real-world Irish where music is used in the background; in
implementations of copyright licensing of fact, almost any type of outlet where
music, the most well-known licensing music can be heard by anyone other than
agent is IMRO – the Irish Music Rights in the ‘domestic circle’. These outlets must
Organisation. There are others, such as all have permission from the collective
RAAP (Recorded Artists and Performers) rights societies to use their members’
and PPI (Phonographic Performers of works.
Ireland). Contrary to popular
misconception, even among its members, What this means is that when an outlet
IMRO is not a statutory body, nor does it negotiates a license to use music owned
have any Regulatory position. It is simply a by members, the licensing agent (IMRO,
private company, authorised by the PPI or RAAP) is obliged to add this money
Controller of the Copyright Act, which to the payments to be made to all of the
exists to administer the licensing and owners of all of the music that is
publishing rights of its members – who are subsequently made available. The license
all either writers or publishers of music fee received for a particular outlet over a
and related works. Similarly RAAP exists to given period should then be distributed
administer rights for Performers (not pro-rata amongst all the members who
writers, although they may be the same) have had their works made available by
while the PPI is a collective organisation that particular outlet and in the same ratio
representing the recording industry itself. as these works were used.

In some jurisdictions, including currently While this appropriation of license fees to

the United States of America, the rights of owners may be a relatively simple task
performers to royalties when their when a one-off license is sought, perhaps
recorded performances are used in radio for a fireworks display that is set to music,
and TV broadcasts are not protected in the or for a live performance where the music
same way as are the rights of songwriters. is known and constant, it is not feasible for
Notwithstanding this, there is legislation IMRO or any other Organisation to keep a
under debate in the US that seeks to complete and perfect record of all the
address this limitation as it is an obvious pieces used in all of the outlets for whom it
exploitation of the rights of at least some has issued licenses. They cannot therefore
of the creators of a work (i.e. the singers distribute the license fees received as
and performers on a recording, who are Royalties to all of the correct owners in the
often not the writers of the work being correct ratios for each use of their work.
performed). IMRO readily admits this limitation.

In Ireland, any outlet that wishes to ‘make There are, however, systems and
available’ works that are protected under processes in place to generate playlist
the Copyright Act and are owned by data from outlets such as radio and
IMRO’s members must apply for a license television and then extrapolate the
to make those works available publicly. ‘overall’ statistics. This might seem like a
Similarly, outlets are required to obtain good compromise and, in fact, it is a good
permission from the PPI (and thereby from system for established, well-informed and
RAAP) for public performances of the developed artists, writers and performers
actual performance as IMRO members are as their works are well known and
not necessarily RAAP/PPI members and adequately reported. Indeed, as will be
vice versa. A similar arrangement exists, illustrated, it is a system unfairly weighted
or will exist, in most jurisdictions where in favour of the established sector but to
legislation is enacted. the detriment of the developing group of
artists, writers and performers.
In this regard, outlets likely to require a
license when ‘making available’ Unfortunately, the limitations accidentally
copyrighted works include radio and created by the systems and processes
television broadcasters; public houses, used by Organisations like IMRO are by
hotels, and other venues where music is definition likely to overlook a certain
performed either live or pre-recorded; section of their members from the
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 4

distribution of Royalties and, even will all be able to circumvent these

disregarding the moral considerations, this limitations and requirements and will take
leads to an ever-increasing disadvantage steps to ensure that their works are
to this section of their membership. It is, properly recorded and reported to the
moreover, this section of their distributing Agent, whether IMRO or any
membership that the entire concept of other similar organisation. Moreover, these
Copyright was evolved to protect. commercially-aware sections of the
membership are likely to be involved on a
By way of illustration of this point, regular basis on the Music Industry as this
consider the following scenario, which will is the only real way that such concepts
no doubt be repeated in most jurisdictions come to light as far as Artists etc are
to a greater or lesser degree: concerned. Newcomers to the industry,
particularly new Artists and Writers, are
If ‘Song A’ is played ten times on one often woefully unaware of even what
broadcaster and does not appear in the Copyright is, let alone how it is
data supplied by the station or collected administered and so on. Even when they
by/for the Agent, while ‘Song B’ is played are (eventually) informed enough to have
ten times and does appear in the data, their works copyrighted and register as
then – all other things being equal – ‘Song members of organisations like IMRO, they
B’ will generate more royalties than it is make the assumption, incorrectly, that
entitled to as it’s share of the overall these Agents will administer their rights
royalty pool will include some of the perfectly. They do not. They cannot.
portion that otherwise should have been
distributed for ‘Song A’. Moreover, if Song It is up to the Artist to ensure that they are
‘B’ is only played once, and this play is paid the correct amount of Royalty from
included in the sample data taken from the ‘pool’ of any given license fee
broadcasters where the data is not received. Of course, like IMRO and its peer
complete and is instead extrapolated, then organisations, Artists are even less able to
song ‘B’ may well end up with rather large monitor all radio and television output, as
payouts (comparatively speaking) and well as all publicly-aired music in all shops
some of these payouts would actually and factories. They are therefore at the
belong to the owner of song ‘A’. mercy of the collection societies who act
as their agents. Given that more
In terms of the more accessible commercially-aware members will be
“community radio” sector, IMRO and actively submitting data to the Agent, and
others find it is not economically viable to that the Agent’s collection and distribution
collect play data so they simply add the system is inherently weighted against the
fees generated from community developing Artist, the disadvantage
broadcasters to the large pool of license suffered through lack of awareness is
fees generated by the National magnified, often to the long-term
broadcaster and its subsidiaries. This, of detriment of Artists who see no return,
course, means that the radio plays that even when relatively successful in terms of
developing Artists and Writers do receive, the Irish marketplace and allow their
which very often happen on easily- artistic development to be stifled, often
accessible community and local radio when it warrants being pursued.
stations, will be overlooked and, instead,
the royalties due to these developing
Artists will be paid to the very well-known In order to overcome the problems caused
and usually very commercially aware by the systems currently used to collate
Artists who are more often broadcast on information and then calculate
the National broadcaster’s channels, distributions, and to make the entire
thereby exacerbating the already-limiting process of collection and distribution of
problems faced by developing Artists. royalties fairer (albeit never perfect), in
particular for works played less often and
It does not take much of a leap of the for specialist or developing musical works/
imagination to realise that the more shows/ stations, a complete and accurate
organised, informed and commercially list of all works broadcast at all times on
aware Artists, Writers and Publishers etc all stations needs to be made available.
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 5

This is unlikely to ever be possible, but A knock-on effect of the development of a

modern technology should be able to system that more accurately represents
produce a system fairer than it currently what is currently being broadcast by radio
is, whereby the entire license fee paid by a and television broadcasters would be the
radio station may be distributed in its provision of a useful barometer for
entirety to the owners of as little as 10% of developing culture. More accurate
the works broadcast in the full period 2. representation of the relative popularity of
Artists, developing and otherwise, in the
Moreover, a single payment-calculation data produced and therefore in the
metric should be used for the calculation Royalty distribution pools, would lead to
of distributions. It is likely that the current an increase in the amount of revenue
multiple-metric calculation system (i.e. currently generated by Royalties that
pay-per-play, pay-per-duration, pay-per- eventually stays in Ireland and trickles
sample pay-per-audience size) has down to developing Artists and
evolved because of the way in which data Performers. This can only be good for the
is reported to the Agent, rather than for Irish Music Industry in general and is likely
any reason relating to the legal or moral to cause a spiral effect where more
fairness of the systems employed. It is also revenue in the lower levels of the Industry
likely that the reason that some stations leads to more successful Artists in the
are sampled, some are full census and medium term, in turn leading to more
some are mixed is simply a result of the revenue staying in Ireland.
availability of data from those
broadcasters and the reticence on the part Given that IMRO alone generated circa
of royalty collection agents to ensure and €36.8 million in license fees in 2007 [3]
demand compliance with the duties of the and that the European collective rights
music-users under current legislation. sector is worth more than €5 billion per
annum, the revenue is not insubstantial
Of course, other outlets licensed to [4].
publicly use copyrighted material, such as
shops and factories, simply cannot be An interesting further development of such
monitored at all so estimates and a modernized, automated, digital system
extrapolations are used to distribute the designed to monitor the output of
license fees collected from these groups of traditional radio and television
outlets. This is sometimes done using the broadcasters is that it would be a very
same metric derived from the extrapolated easy task to extend its operation to the
data generated by incomplete radio and area of digital radio, which is already a
television playlist data, using the logic that digital medium. One of the issues that
a large number of outlets are going to be must be dealt with when trying to create a
using radio and television for public digital watermarking scheme is that the
performance anyway, without regard for traditional broadcast environment is an
those that might use CD, or those that analogue medium. Digital information
never play music other than live music. cannot be easily transmitted as a side-
There are always going to be limitations channel to the music etc that is being
like this, but it is obvious that the more broadcast. In digital radio transmissions,
complete the available data is, the more also, some of the processing requirements
accurate the distribution to members who would be unnecessary (for example,
own the works will be, which is a collection converting analogue signals to digital) and
society’s prime raison d’etre. much of the interference suffered by
analogue transmissions would be lessened
if not eradicated. This makes
THE CULTURAL AND FINANCIAL watermarking more likely to increase in
IMPACT accuracy.

This is the case in stations where a two-day per It would then be a simple task to scale the
month sample of data is used to calculate the entire system to monitor the output of
distribution, with the assumption made that the rest International broadcasters. Why is this
of the month is likely to have included the same
important? There are some interesting
pieces. This is patently absurd, particularly in an
ever-changing radio environment statistics which serve to illustrate the
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 6

reasons and the potential scale of the shown in their 2007 results. Similarly,
long-term benefit to the members of one might expect the figures for other
IMRO/RAPP and the Irish economy in jurisdictions to be higher than €450,000
general: (USA), €900,000 (EU countries
combined), €400,000 (Rest of the
1. The Royalty collection Industry in world)
Europe alone is worth an estimated €5
Billion in 2004 and is increasing in size. 4. According to the Music Industry
This excludes the rest of the World. governing body, “Revenues from public
China is currently undergoing a shift to performance and broadcasting income
an economy that protects intellectual grow incrementally every year”i so
property, while the USA is considering there is ever more reason for both more
extending its public performance accurate and more widespread public-
legislation to include performers, not performance playlist data 3.
just writers.
5. “The fact that Irish people use
2. IMRO collects only approximately English is often cited as increasing our
€3.3 million in royalties from affiliated vulnerability to Anglo-American mass
Organisations in the rest of Europe culture. This is so, but it also increases
(including the UK) in 2007 [3], our opportunities in the vast English-
suggesting that Irish-originated content speaking market, the most affluent in
accounted for only a fraction of one the World" (former Irish Cultural
percent of radio/television output and Minister Michael D. Higgins, 1999)
live performances in these jurisdictions.
Given the success of Irish-originated 6. The fact that there is a huge
Artists, this is obviously open to debate, Diaspora of Irish people and their
particularly in the US and UK which both descendents, particularly in the UK and
have much larger royalty revenues US, would lead to the inevitable
generated from broadcast sources. conclusion that a disproportionate
IMRO itself admits that it faces major percentage of the output from their
obstacles trying to recover royalties for broadcasters would have some Irish
its members from public performances content, in comparison to the output of
abroad because it cannot quantify other demographic sectors and the
them. owners of this content are legally
entitled to fair recompense for such
3. In the UK market, ‘Irish-originated’ use.
Artists were recently ranked a
cumulative third place in the overall The problem with all of the above is that
sales statistics [5] in all of the years there is no complete record of works
from 1986 – 1994, except 1989 when broadcast. There is nothing in legislation
Irish Artists were ranked 4th overall in that suggests that owners of the copyright
terms of sales. It is also claimed in [5] of any work can be treated any differently
that Irish artists are considered by than the owners of another work, in the
Industry observers to be the 5th highest same jurisdiction. In fact, that would be
ranked demographic in terms of patently unfair. Therefore, the owners of
combined International repertoire. If content broadcast on UK and US channels
radio output reflects, to an extent, are entitled to the same royalty rate no
repertoire and sales statistics then it matter what their Nationality.
would be logical to assume that Irish-
originated Artists made up a Conversely, the owners of content
comparatively large proportion of broadcast by Irish broadcasters are
public-performances in, at least, the UK entitled to the appropriate royalty
and the US. From IMRO’s annual results,
it is apparent that – especially 10 years 3
From "The threat becomes the opportunity", speech
on from these statistics – income from by John Kennedy, CEO and Chairman IFPI, MIDEMNET
UK public-performance royalties should Keynote speech, 22 January 2005
be a lot higher than the €1.5 million
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 7

according to the percentage of works that billion in 2004 collection totals. The UK
they own. Therein lies one of the potential collected close to €850 million in
obstacles to such a system. Authors/Publishers royalties alone. If Irish
content was to account for only 1% of the
Irish radio output does not generally real ownership of the content that was
consist of Irish material. This is not a used to generate UK royalties, then in
secret. In fact, the legislation that governs 2004 the income due to Irish societies
the issuing of broadcast licenses would have been €7.5 million. Instead,
specifically includes provisions for license €1.3 million was collected.
applicants to allocate a percentage of their
output for ‘Irish’ content. This ‘Irish’ Given that Irish-originated content is
content does not only include music but considered to be the 5th highest-ranked
also current affairs, talk shows etc. The contributor to International repertoire and
percentage of ‘Irish’ content required in that UK sales output, which might be
many cases is 20%. Again, this is not expected to somewhat reflect, or in some
music. A broadcaster may decide to cases be reflected by, broadcast output
honour the requirement for 20% Irish from commercial broadcasters, for the
content with 20% of their output being period to 1994 (and presumably since then
News, Chat shows, Current affairs. Of their to a similar extent) ranked Irish content as
music, it might be 100% non-Irish. Also, cumulatively 3rd in sales, it would seem
some broadcasters do not have this likely that Irish content on UK broadcasters
requirement attached to their license so would exceed 1%. Each additional 1%
their Irish output could theoretically be nil. represents an increase on 2004 figures of
A casual observation of the playlist of any €8.5 million in combined royalties. This, of
commercial radio station, including the course, pales almost into insignificance
National Broadcaster (RTE) will illustrate when the US and the Rest of the World are
that a very large proportion of their output considered.
is International, mostly originating in the
UK and US as would be expected. The likelihood is that, if a situation arose
where perfect, accurate and complete
This would suggest that the collective broadcast data was available, the overall
rights societies that operate in the Irish royalties due to Irish content owners – in
industry would be expected to distribute the Music Publishing Industry alone –
their collected license fees to a proportion would far exceed the outflow from the Irish
of non-Irish content owners. One might market.
estimate that as much as 80% of royalties
generated by Irish collective rights agents
actually does not belong to any Irish HOW DOES WATERMARKING WORK?
content owner and should therefore be At its very simplest, the concept of digital
transferred to affiliates abroad. For IMRO, audio watermarking can be likened to the
that would amount to approximately €26 process whereby a watermark is added to
million of the €33 million it generated in a banknote to help prove its validity. In the
Ireland in 2007. digital era, many Internet users will be
familiar with images reproduced on web
This is, naturally, an unpalatable pages with the photographer or copyright
possibility for the Irish industry. However, details superimposed on the actual image.
it is likely that if the broadcast data In both cases, the idea of the watermark is
provided were more complete and similar: validation of
accurate Internationally, especially given identification/authenticity. There are
the size of the EU and US markets, we digital audio watermark techniques with
might expect to see a rather large net the same motivation, namely validation of
inflow to Ireland. the identification of a piece of audio.
However, watermarks in audio can be
The combined total generated by used for a wide range of purposes such as
collection societies for Authors, Producers, copy prevention, tracing of the source of
Publishers and Performers in Europe alone illegal copies or simply adding information
was c€5 billion in 2004, and growing. of value to audio.
France alone accounts for almost €1.25
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 8

In digital audio watermarking terms, the audio in the process of watermarking. In

system requires that musical pieces can an Artistic endeavour such as song-writing
be ‘marked’ (preferably, if possible) before and production, this is a very important
public release in such a way that the mark consideration.
is difficult or impossible to hear and
difficult or impossible to alter and that the Once the components are modified, it
piece can then be identified ‘on the fly’, in would then be relatively easy to identify in
the real world. Recent developments in the the monitoring of the output of any
areas of Digital Audio Fingerprinting and broadcast medium by using the CSPE
Digital Audio Watermarking have shown technique again. Identification of the
promise. Indeed, the current state of these content has been more than 99% accurate
research areas, allied with the ever- in earlier work and is expected to increase
increasing processing power and in accuracy and efficiency as the
throughput of modern communications technique is developed.
systems, is such that there is no reason
why a highly efficient automated
watermarking system cannot be CONCLUSION:
implemented today. This could be done The current system for administering
either by a State body responsible for the public performance copyright in Ireland
monitoring and administration of and, to a greater or lesser extent, in other
Copyright royalties for audio (and, by jurisdictions is inadequate in the digital
extension, video) or, more likely, by IMRO era. These systems can operate to the
and similar collective rights Organisations. detriment of under-informed and under-
represented writers, performers and artists
The administration of such a system might who are often in the early stages of their
appear to be the proverbial nightmare, but career development. Current systems may
compared to the current system of serve to exploit these people to the
inaccurate incomplete and unfair benefit of more established and well-
distribution, these Organisations legally represented peers. Modern Copyright
owe it to their members to do the best administration is not protecting their rights
they can to produce data as accurately any more than was the case before
and completely as possible. Moreover, the Copyright was legislated for.
cost of producing such data would rapidly
decrease, while its inherent value (Airplay In our work, the purpose of an added
charts etc) would increase with watermark is the monitoring of broadcast
completeness, both to its members as well output by radio and TV to identify the
as to the Entertainment Industry at large. broadcast item accurately before using the
combined collected data for accurate
We have developed a technique which distribution of royalties. Other uses such
uses digital signal processing methods to as publishing airplay statistics are, of
manipulate the magnitude of no more course, possible once the data has been
than frequency components which are collected. The watermark ‘channel’ can be
already present in a signal (the signal, in used to inaudibly encode the audio with
this case, being audio). Rather than adding added-value information such as lyrics and
audio components to the audio to be purchase details.
watermarked, which we achieved
previously [6], we have recently developed If the collection societies which make up
a new technique that uses a new super- the Irish royalty-collection industry were to
resolution frequency-identification method take a lead in the development of an open-
called Complex Spectral Phase Evolution source, transparent and accountable
(CSPE) [7] to identify frequency measuring and reporting system based on
components that are present in a piece of digital audio watermarking, then Irish
audio. We then modify the inherent Artists (meaning, by default, the more
components to represent the values we established and well-known members)
want to watermark into the audio [8] in a could easily benefit exponentially from
manner that would not be detectable to being at the forefront of this development
human listeners. This technique is superior by generating an increased inflow of
to [6] as it does not add anything to the revenues from European/Worldwide
Limitations in the Distribution of Public Performance Royalties in Ireland - Ron Healy ( Page 9

royalty revenues. Simultaneously, those

developing and under-informed artists and
writers for whom copyright is such an
important career-enhancing tool, would be
able to benefit from a more accurate
distribution of royalties generated for the
use of their material in Ireland. We have
proposed a Digital audio watermarking
technique that would permit this with low
financial and computational cost and
inconsequential impact on the audio being
[1] Karl-Erik Tallmo.
“The Misunderstood Idea of Copyright’”,

[2] Donaldson v. Beckett.

“Proceedings in the Lords on the Question of Literary Property, February 4 through February 22, 1774”.

[3] “IMRO Annual Reports and Accounts”, 2007.

[4] “The Economy of Culture in Europe, Study prepared for the European Commission (Directorate-General for Education and
Culture)” October 2006. Page 246.

[5] Paula Clancy and Mary Twomey. “Clusters in Ireland: The Irish Popular Music Industry”, published by the National Economic and
Social Council, November 1997, page 7, para 3.

[6] Ron Healy and Joe Timoney. “300 years of copyright: have we gone full circle”, Social-Legal Studies Association Annual
Conference, De Montfort University, Leicester, 7–9 April 2009.

[7] K. M. Short and R. A. Garcia. “Signal Analysis using the Complex Spectral Phase Evolution (CSPE) Method”, Audio Engineering
Society 120th Convention, May 2006, Paris, France.

[8] Jian Wang, Ron Healy and Joe Timoney. “Digital Audio Watermarking by Magnitude Modification of Frequency
Components Using the CSPE Algorithm”, China-Ireland International Conference on Information and Communications Technologies,
Maynooth, Ireland, August 2009 (Accepted for Publication).