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EASTMAN INITIATIVES

In 1995, the Eastman School of Music of the University of Rochester, a premier school of music, opted to adopt a sensible approach to the education of its future performing artists. Working under the rubric The Eastman Initiatives, the original goal of the Eastman faculty was to "revitalize and reexamine the presentation, teaching and content of western art music through the development of a new generation of musicians." In part this goal reflected a growing concern with the tenuous financial condition of the modern classical and jazz worlds, and in part it was "driven by a common concern for the decline of music's infrastructure in America, including both the orchestra and the public school music program." And, at Eastman, there was also the lamentable overriding realization by the faculty that the public has a "growing inability to discern anything but the most simplistic artistic messages.(2)

ARTS LEADERSHIP PROGRAM

The Arts Leadership Program was the pilot program flowing from the Eastman Initiatives. It was put in place to provide "a cogent series of mini-courses focused on future-oriented issues for a selected group of 20-25 seniors." It offered seven week, half-semester courses "on a variety of career-related topics relevant to professional musicians and music educators," and by the spring of 1998 was not limited to seniors. The program itself was divided into several subsections, including Arts Administration/Music & Society; Career Development; and Emerging Technologies. This article will focus attention on the Eastman course offering in the ALP, entitled Music and the Law.

MUSIC AND THE LAW(3)

There is, of course, no way to do justice at the undergraduate level to any legal area. So then, specifically what should be the goals of the law instructor in an educational environment like a music school, where only a one or two semester hour course may be offered?

The main goals are these: to acquaint and excite the music student with law in general; to demonstrate that law permeates the music industry, and to confront the student with the fact that during his or her performing career, personal legal problems may arise. Therefore, no music major can afford to ignore the law completely.

Furthermore, the law plays a part in either limiting or expanding individual, corporate, or group rights, thereby in a sense controlling society and, in particular for purposes here, the music industry as well. Yet, as is true of students in other disciplines, most music majors are clueless regarding their most basic civil liberties. For instance, not many college students are sure of how to respond to police questioning after a simple traffic stop. Nor do they understand whether or not college officials may randomly search a dormitory room, much less whether an employer (for an example the administrators of a symphony orchestra) may randomly search a performing artist's employer-provided workspace. While a law course in a school of music may not be geared to answer these specific questions (though it perhaps it should the latter), it can prepare a music student to be at least aware that such problems exist. More importantly, such a course may also encourage such a student to seek the advice of a responsible attorney at the earliest opportunity after a legal issue manifests itself. By the time a student leaves a music and law course, he or she should be able to identify a possible legal problem and, perhaps, remember some specific legal notions. For sure, he or she should know that it has been held by at least one court that a musician can be held liable for copyright infringement through subconscious plagiarism, and that an oral contract may be enforceable. How can this be accomplished in the short period of time allowed by a one or two semester hour course?

Unfortunately, many undergraduate law texts, most often written for college business law courses, are rather dry reading (and very expensive). No matter how such books are used in the classroom to spark student interest, the material itself is often dull.(4) This is unfortunate, for it sometimes seems as if textbook publishers conspired to make business law dull. Occasionally, though, an exciting case excerpt is presented in the text, and students react more positively. Sometimes, the positive motivating factor simply is student knowledge of a famous litigant, or the relevance of a particular case to the student age group.(5)

Also, many teachers have little in common socially or historically, with their students. It is hard for many instructors of the 60's generation, to connect with the contemporary students.(6) Yet, there is at least one common ground between the instructor and music student.(7) The 60's generation lived during the so-called golden age of rock ‘n roll.(8) And, while focusing on classical music and/or jazz, music students today listen to rock ‘n roll. In fact, a case can be made that they like 50's and 60's rock music as much or more than that of the present era. It is at least a fact that such middle-aged rockers as the surviving Beatles, Rolling Stones, The Who, and The Moody Blues, not to mention Eric Clapton, whomever he plays with, today draw heavy financial subsistence from the youonger generation.

As a result, ideally through the use of materials that present the subject through the eyes of the music industry, law can be made more interesting to music students. Of course, it is the rock music industry that the more litigious, and rock music industry cases and materials are easily obtainable, whether concerning rock generally, or specific rock artists or recording companies. They are also interesting and fun to read.(9) Too often, students believe that the law as presented in dry texts and cases is itself rather dry and uninteresting. This is a fallacy that creative law teachers can and should extinguish in any educational setting.

From an economic point of view, rock n' roll is very big business, and the major driving force in the music industry. By reading rock music cases, the student of more serious music may become more interested in the law as it is applied to a dynamic entertainment and social force. And, he or she can see the law twist and turn around a relevant industry that generates billions of dollars each year.(10)

The cases and materials that can be developed in this regard can satisfactorily supplement a standard textbook. However, a textbook is neither necessary nor advisable in a one or two semester hour law course in a music school.(11) And the materials should be chosen to highlight music industry related problems, not to survey the entire legal field.

One warning, though, some of the available cases and materials would appear to be a bit outdated, and an instructor should strive for the more contemporary. Yet, this is not a major problem. The purpose of such a course in the music school is to make students aware of how lawyers and judges think, not to bring them up to speed with the newest legal developments. Stating the obvious, one does not become a lawyer after taking such a course.(12) It is important to note also, that while law changes, the manner in which law is applied to factual situations remains fairly static.(13) Furthermore, an instructor can find many connecting social and business links between the specific rock music industry and the music industry in general.(14) This is necessary because of rock music’s social and financial predominance in the field of music and the fact that the rock music industry generates most of the music related cases coming before the courts. Yet, there are music industry cases involving classical, jazz and other forms of contemporary music. These cases may be obtained and utilized by the instructor, as well.

Pulling together a whole body of law as it applies to a specific industry is not done in standard business law texts. Generally, each chapter of a standard business law textbook deals with a specific legal area. In very few of these books do the authors seriously attempt to tie it all together, and certainly not in the manner discussed here.

Of course, rock music cases and materials totally cannot do this either. But such materials could partially succeed in a unique and satisfying way at the undergraduate music and law level. And, the cases in this area are broad. Further, each case holds interest and sparks discussion on its own merits. It is fascinating to discuss the fight over the injunction to prohibit the singer James Brown from recording with another record label (15), or to review the New York City Landmark Commissioner's denial of a permit to alter rock’s historic Beacon Theater.(16) Some cases, for sure, are more exciting to debate, such as the attempt to pin a fan’s suicide on Ozzy Osbourne's song lyrics.(17) Taken together these and other such cases teach important legal principles, and demonstrate how the rock music industry is seriously affected by the legal decisions.

Other legal documents and materials may be used as well. The class- action complaint between Frank Music Corporation and Compuserve Incorporated, that involves among other legal issues the storing and dissemination through computer downloading of copies of copyrighted musical material is one example.(18) The civil jury instructions in the case of Yvette Marine against Virgin Records of America (19); and John Lennon's or Jerry Garcia's will (20), are pertinent and highly interesting for the undergraduate. By focusing on such cases and materials, students begin to notice that the whole body of legal principles studied may have application to a whole myriad of legal problems encountered by the music industry. It is only a short step further to realize that the law permeates the entire American work place. From contract and sales questions, to a discussion of the legal framework and liability of business entities, environmental concerns, and labor/management disputes, just to name a few pertinent issues, the law is a powerful force in the business world, including the entire music industry.

Actual music also may be played in the classroom. This is entirely appropriate to sometimes acquaint students with the subject, or personages of a particular case. Music students especially will relate to this. When reading about an action challenging the use of a Shriner photo on an album called Frankenchrist, by The Dead Kennedys, there are students who have never heard of, much less listened to, this punk rock group.(21) Some cases revolve around a specific song or lyrics. For instance, in 1990, 2 Live Crew sued Nicholas Navarro, the sheriff of Broward County, Florida.(22) The complaint alleged that the sheriff's department had violated the groups civil rights by threatening store owners with prosecution for carrying and selling the album As Nasty As They Wanna Be. The case is a first amendment obscenity dispute, and only by playing representative samples of the album's music and lyrics, can a student fully understand the problem. In the Ozzy Osbourne case already mentioned, playing the song "Suicide Solution", allows even a music student to determine, as did a judge, whether or not the song is in essence a suicide recommendation, or merely an ode to the evils of alcohol abuse.

SAMPLE CLASS PROBLEM

At the apex of his initial solo career, the former Beatle, George Harrison, now deceased, was embarrassed by a suit alleging that he plagiarized a song. This copyright infringement case is interesting on several levels. Actually, there are three reported decisions: Bright Tunes Music Corp. v. Harrisongs Music, LTD(23); ABKCO Music, Inc. v. Harrisongs Music, LTD(24); and the appeal, ABKCO Music, Inc. v Harrisongs Music, LTD(25).

In the first case, the issue is liability. Did George Harrison , when composing "My Sweet Lord", infringe on the copyright of an earlier song called "He’s So Fine", recorded by the Chiffons, and owned by a company called Bright Tunes Music. Millions of dollars in royalties were at stake. By listening to both songs in class, the music student learns that though the songs are later found to be the same, this is not so easy to discern by ear, at least for the non-musically initiated. "He’s So Fine" for instance, is jumpy and rather trite.(26) "My Sweet Lord", on the other hand, is slower and extremely contemplative. Therefore, merely playing the songs in front of a judge or jury, generally people without formal musical training, is important, but not enough. What else is then required?

By analyzing the case, the music student learns that in order for the plaintiff, Bright Tunes, to prevail, it was required to introduce expert testimony. It did, and its music expert demonstrated that the pleasing combination of sounds that make up "My Sweet Lord", are the exact same combination that produced "He's So Fine". Of course, this may be something that the trained musician, or music student, may have been able to detect without such testimony.(27) However, while learning fundamental copyright law, the music student realizes that such cases must be decided by expert opinion, and that in the music business the use of experts in such cases is crucial.

Further, progressing through this case, it becomes clear that a copyright violation may be unintentional. Harrison (with a little help from his friends) basically began composing "My Sweet Lord", by vamping some guitar chords backstage before a concert in Denmark. The rest of his backup band joined in by singing Hallelujahs, Hare Krishnas, My Sweet Lords, and Dear, Dear Lords. Later, in a recording studio, the melody and lyrics were formalized. No one involved consciously thought of the tune "He's So Fine", during the making of "My Sweet Lord", but Harrison admitted that not only was he aware of the Chiffons 1963 chart topping hit, but "that the two songs were substantially similar." This led Judge Owen to conclude that While Harrison did not deliberately plagiarize "He's So Fine", he did so subconsciously, which in fact rises to the level of copyright infringement. This decision may come as a total surprise to music majors, especially when considering that all music is somewhat derivative. The music student now knows that there is danger in composing, as one can be sued and found liable for copyright infringment if even subconsciously utilizing another melody!

The second Harrisongs case determined the issue of damages. Initially, the student learns that an action may be bifurcated between liability and damages, and that it can take years before damages are assessed after the initial determination of liability. In this case, five years.

The music student also learns about the mechanics of damage assessment, here the types of royalties earned by "My Sweet Lord".(28) By apportioning the amount of earnings of "My Sweet Lord", from two albums and a single, the judge determined the gross amount to be $2,152,028. He then subtracted from this gross, production expenses, totaling "$18,712, thereby reducing the song's earnings to $2,133,316. After factoring in other contributions to the song’s earnings, including George Harrison's name and artistic stature, and the special religious lyrics of "My Sweet Lord", the final determination was that the net amount of $1,599,987 could be attributed to the "He's So Fine" tune. No doubt many music students about to enter the classical or jazz arenas will be astounded by the amount of money one rock song can generate.

Yet, this was not the end of the assessment of damages. A very troublesome question remained. During the litigation, Allen B. Klein (29), George's former manager, injected himself into the case. After Harrison made an offer of settlement, Klein, through his company ABKCO, offered to purchase the claim of Bright Tunes for a higher amount. This then caused Bright Tunes to stop negotiating with Harrison, who had made the lower offer. The liability trial then ensued. Afterwards, after protracted settlement negotiations, and before the inquest on damages, Klein paid the sum of $587,000 to Bright Tunes for the copyright to "He's So Fine", and its infringement claim against his former client, George Harrison.(30) Concluding after the damages trial that Klein's "intrusion irreparably destroyed the ability of Harrison to further negotiate a settlement," the judge held that ABKCO was not entitled to profit from this detrimental impropriety. And, as a result of Klein's purchase price, Judge Owen was able to compromise the actual value of "He's So Fine", to a sum less than the original estimated $1,599,987. Sympathetic to George, he fashioned an equitable remedy that ordered Harrison to pay the sum of $587,000 back to ABKCO, which in turn was ordered to transfer the copyright of He's So Fine under constructive trust principles over to the rock star. In fact, Allen Klein, made nothing, and ABKO was forced to appeal.(31)

Reading this damages case, the music student learns not only that assessment of damages is complex, but that in America even a lawsuit may be purchased! The student also learns that a personal manager, who is in a fiduciary (32) relationship with his client, should not profit from self-interested dealings. And, in such a situation, a judge may fashion an appropriate equitable remedy that compensates fairly the parties in interest. Here George ends up with the copyright of "He’s So Fine", and since this case has most likely recouped his half million dollars and more.

The final case of this rock music triumvirate is ABKCO's appeal and Harrison's cross-appeal, which occurred two years later. ABKCO presented two main arguments to the Second Circuit Court of Appeals. First, it claimed that it did not breach its fiduciary duty to Harrison, since no confidential information was improperly passed from ABKCO to Bright Tunes during the settlement negotiations, and its actions did not cause the pre-damage trial settlement breach between Harrison and Bright Tunes. Secondly, it argued that the award of damages by Judge Owen was improper. George Harrison simply cross-appealed on the issue of whether or not a copyright infringement could be subconscious.

The Second Circuit easily disposed of Harrison’s claim by holding that "innocent intent should no more constitute a defense in an infringement action than in the case of conversion of tangible personality."(33) As to ABKCO's two-pronged appeal, the court split. Regarding ABKCO's claim that it did not engage in fiduciary misconduct, it concluded that there was an egregious breach of a fiduciary duty, a factual issue properly addressed by the district court, and not "clearly erroneous or not in accord with applicable law."(34) However, on the issue of damages, the court remanded the case back to Judge Owen for a proper determination of the amount of damages in light of previous settlements between Harrison and ABKCO regarding foreign infringement claims.

By reviewing these three cases involving the same players, the music student not only has the opportunity to follow an action as it passes through various litigation stages, including an appeal, but how an appellate court reviews a lower court decision. The student also learns that an appellate court may partially affirm a holding below, and remand an issue back for a further determination in conformity with the appellate court's legal ruling. Here, also, the issue of fiduciary duty is discussed in great detail, and as a practical, not theoretical matter. Many musicians will find themselves in such a relationship during their professional careers. This may lead into a good class discussion of such ethical considerations, and the duties of an agent to his or her principal and vice versa.

CONCLUSION

This article has been devoted to the idea that the study of law, while complex, may also be made fun, or at least interesting, especially when applied in a music school setting. It discusses an attempt to relate legal issues to a specific type of student, a music student, vis-a-vis the rock music industry. And, it is suggested that rock music may be a tie binding both the instructor and such a student. As such, utilizing rock music cases both acquaints and excites the music student with the law. By focusing on a particular industry, in this case the rock music industry, the music student learns that law permeates the whole fabric of the music industry, and that he or she may be faced with similar legal problems in the future, even if focusing on classical music and jazz.

However, teaching music students with such cases and materials forever could lead to boredom, for both the music student and the instructor. One way to prevent this is to constantly change the materials. The Internet (35) is now an ideal way to pull music cases and materials together. Another tactic might be to change the focus throughout the course from the rock music industry to the music industry in general. In that way, an instructor could utilize legal cases and materials from the classical or jazz genres, as well. Focusing part of the course on music in general would be more eclectic for the music student, as cases and materials regarding legal issues facing for example symphonies, musicians unions, and jazz artists and venues could be included.(36)

On a final note, it is difficult to teach law from cases and materials entirely focused on one specific business industry. Further, there may be other cases that are important for the music student, especially landmark cases in a particular business law area. It is also a truism that the law is an effective social and business force, and not just another entertainment form.(37) The suggestion here is not to dispose necessarily of the instructor's favorite materials, but to spice it up with interesting cases and materials, especially for the music student. For sure, not all cases and materials relating to the music industry, need to be discussed in class. Yet, music students, no different from students in other disciplines, are more easily excited by the study of law when faced with legal issues that have a direct influence on their chosen field, or are more relevant to them. When this happens, they will also be better informed in a practical way to enter the music industry, whether as performers or in some other capacity, including that of agents or entertainment lawyers.(38) NOTES

1. Associate Professor, Business Law, SUNY, Geneseo; part-time Associate Professor in Leadership and the Arts, Eastman School of Music, University of Rochester. Author of the casebook The Law and Rock 'n' Roll (McGraw-Hill, 1996) and Law and Popular Culture (Pierson Education). This article is dedicated to my step- son, Reece. Author’s personal webpage may be found at www.geneseo.edu/~sciarrin

2. Information concerning the Eastman Initiatives and the Arts Leadership Program (ALP) was furnished to the author by Prof. Douglas Demster, first Director of the ALP. Prof. Demster also forwarded a copy of the Report of the Eastman Initiatives Steering Committee, dated September 5, 1996, prepared by Prof. James Undercofler, now the current Dean of the Eastman School of Music, University of Rochester. This document is the main source of the information about the original Eastman program that follows.

3. Portions of what follows regarding business law courses appeared in the Introduction to the author’s casebook, The Law and Rock ‘n’ Roll, McGraw-Hill, 1996. The full text of the Introduction may be viewed at http://www.frontiernet.net/~ajs

4. This is not to suggest that all of the texts are completely dull. More and more publishers are attempting to add at least a smattering of interesting, contemporary cases.

5. The basic subject of this article, which follows.

6. As the difference between Woodstock I and Woodstock II suggests. The original Woodstock was a poorly planned concert that spontaneous became a cultural event. Woodstock II was a well planned commercial success, meant to cash in on the emotions and finances of the now affluent 60's generation and their children.

7. Take my example. Like me, most of my students want to boogie. I was born on January 8, 1947, before the birth of modern rock, but on the same day as Elvis, and on the same day, year, and almost exact time as David Bowie.

8. It was a golden age because what future groups will ever sound as good as The Platters, Buddy Holly and the Crickets, The Temptations, The Drifters, The Shirelles, The Chiffons, The Supremes, or Jay and the Americans, to name but a few? Who again will ever wield the electronic axe quite like Chuck Berry, Bo Diddley, Jimi Hendrix, and Duane Allman?

9. I do not subscribe to any educational theory that suggests that because certain material is fun, that it cannot be presented seriously.

10. The actual amount of money all forms of music generates is staggering. In 1993, pre-recorded music in all formats (records, cd's, tapes, video-tapes) generated 10.4 billion dollars. American royalties and licensing fees generated another 390 million in 1992. Another 92 million in 1992 came from foreign royalties and licensing fees. Millions more are expected to be generated each year from licensing fees from the sale of home recording equipment. Industry Outlooks 1994, http://sci.dixie.edu/Bu...oks/31Entertainment.txt, Internet.

11. The earliest case I've used is Berry v. United States, 283 F.2d 465 (8th Cir.,1960), and its companion case, Berry v. United States, 295 F.2d 192 (8th Cir., 1961). Chuck Berry was jailed after being convicted of a violation of the Mann Act by transporting a minor across state lines for immoral purposes. The Berry case is suitable for a criminal law section. The most recent cases and materials have been downloaded from the Internet, and include not only cases but materials such as Elvis Presley's, John Lennon's, and Jerry Garcia's wills, obviously to be used in to highlight Estates and Trusts.

12. However, I’ve had several music students later indicate that they would be taking the LSAT and contemplating entering law school with a goal of practicing entertainment law.

13. Especially in certain areas such as Estates and Trusts, and Real Property. Changes in these legal areas occur in a fashion similar to the retreat of a glacier. In criminal law, however, changes occur daily in the courts.

14. There are many music industry cases involving copyright infringement. In fact, these cases may predominate. However, many others involve such substantive subjects as agency, partnerships, contracts and sales, and torts. Two cases involving suicide are interesting. One involves Ozzy Osbourne, and whether or not his lyrics promoted a suicide. McCollum v. CBS, Inc., 202 Cal.App.3d 989 (1988). The Osbourne case can be utilized in a discussion of constitutional matters that regulate business, criminal law and torts. Another involves Mark David Chapman, the killer of John Lennon. He sued prison authorities in New York over the issue of his right to starve himself to death in order to call attention to the plight of the starving children of the world. He lost. Mtr. Von Holden v. Chapman, 87 AD2d 66 (4th Dept., 1982). This case can be utilized to demonstrate how silly cases get to the courts, although it also discusses the constitutional issues of freedom of expression and the right to privacy. Environmental concerns during the age of Woodstock (the first), such as whether municipalities could zone out rock concerts, appears to have died down for now. See: County of Sullivan v. Filippo, 64 Misc.2d 533 (NYS Sup.Ct., 1970).

15. King Records v. Brown, 21 AD2d 593 (1st Dept., 1964). King Records was granted a restraining order prohibiting Brown from making vocal recordings for Mercury Records after a company called Fair Deal Record Corp., formed by himself and his manager sold Mercury the rights to Brown's music. Pending a hearing on the issue of King Record's exclusive rights to Brown's music and recordings, Mercury was also forbidden from making, manufacturing, distributing, or selling any vocal recordings of Brown. This case actually fits neatly into the Arbitration section, since the main issue involved Brown's King Record's contract and the arbitration clause..

16. Committee v. City of New York, 146 AD2d (1st Dept., 1989). The court was asked to review the New York City's Landmark Preservation Commission's designation of portions of the famous Beacon Theater as a landmark, which made alterations difficult or impossible. The Beacon Theater is a popular venue for rock concerts. Not to many years ago, Van Morrison had a great one there with Georgie Fame and the Blue Flames. The case fits nicely into the Administrative law section, as it discusses the issue of whether an administrative agency made a final determination subject to court review.

17. McCollum, cited in footnote 12.

18. http://www.courttv.com. Class action complaint by licensing and collecting agents against Compuserve.

19. http://www.courttv.com. Pertaining to a trial where a singer, Yvette Marine contended that her lead vocals were mixed together with those of Paula Abdul.

20. For the Lennon and Garcia wills see: http://www.courttv.com.

21. Morris et al. v. Boucher, et al., 875 F.2d 866 (E.D. Mich, 1989) (unpublished: text in Westlaw). The Shriners are thirty-third degree Masons.

22. Skywalker Records, Inc., v. Navarro, 739 F.Supp. 578 (S.D.Florida, 1990), and the appeal which reversed the lower court decision: Luke Records, Inc, a Florida corporation formerly known as Skywalker Records, Inc. v. Navarro, 960 F.2d 134 (11th Cir., 1992). 2 Live Crew won the case. Their lyrics were found not constitutionally obscene, they became famous, and they made millions. A less obscene version of "As Nasty As They Wanna Be," entitled "As Clean As They Wanna Be," was later issued for public consumption.

23. 420 F.Supp 177 (S.D.N.Y., 1976) (referred to as Harrisongs).

24. 508 F.Supp 798 (S.D.N.Y., 1981) (referred to as ABKCO I).

25. 722 F.2d 988 (2nd Cir., 1983) (referred to as ABKCO II).

26. Though young love is never really trite!

27. In fact, both parties used expert witnesses who all agreed, to George's detriment, that the main motif used in both songs is "a highly unique pattern." Harrisongs, cited supra. As the court points out, while the expert witnesses for the defense (George Harrison) asserted crucial differences, "[t]hese claimed differences essentially stem, however, from the fact that different words and numbers of syllables were involved. This necessitated modest alterations in the repetitions or the places of beginning of a phrase, which, however, has nothing to do whatsoever with the essential musical kernel that is involved." Harrisongs, cited supra.

28. Besides sales from sheet music and folios, and the profits of Apple Records, Inc., "My Sweet Lord," also earned mechanical and performance royalties. A mechanical royalty is the amount paid by the manufacturer of a recording to the music publisher, who licenses the use of the song. A performance royalty is the money paid to the publisher and writer, generated by a public performance, usually radio. The students learn that the monitoring of performances, and the calculating of royalties, is itself a major industry. See ABKCO I, cited supra.

29. He also managed the Beatles. Paul McCartney, however, despised him. This was a contributing factor to the Beatles break-up. Paul chose instead to be managed by his wife's father and brother. Later the other three Beatles sued Klein for mismanagement and fraud. Brown & Graves, The Love You Make, McGraw Hill, 1983.

30. These were determined later to be the sole assets of Bright Tunes.

31. Under Agency law principles, an agent can be held to have purchased an item, in this case a corporation with the single asset He’s So Fine, in trust for his principal. As a result, when Alan Klein bought the company, he bought it for his client George.

32. Fidiuciary under the law implies a relationship of trust.

33. ABKCO II, cited supra, f. 24.

34. ABKCO II, cited supra., f.24.

35. This solves the past problem of a lack of law books in a music school library.

36. However, the use of such cases would undermine any attempt to relate the whole body of law to a specific industry, one of the primary teaching goals discussed.

37. Although the Internet provides many websites, which presents law basically as entertainment. See http://www.courttv.com. The motherlode of law on the Internet is found at http://www.findlaw.com.

38. The Eastman School of Music students claimed that they learned quite a bit about entertainment law. They also suggested that the course be turned from a one-semester hour course to at least a two-semester hour course offering. It is now a two hour course. Student evaluations may be reviewed upon request.