Note: Harmonic Progressions to a Full Public Performance Right in Sound Recordings: Examining Recent Legislative Attempts that Could Rectify United States Non-Compliance with TRIPS and a Possible Modulation of the Issue to Reach a Finale

18 Wake Forest J. Bus. & Intell. Prop. L. 109

One of the most popular songs ever written is Irving Berlin’s
“White Christmas.” Since its inception in 1942, there have been
hundreds of renditions by various artists, including Bing Crosby,
Frank Sinatra, and Elvis Presley to name a few. The song can be
broken into two components. The first is the sounds heard, which are
composed of the voices and instruments, and are a part of the sound
recording. The second component is the musical composition
underlying that sound recording, which includes the actual lyrics and
composed music, and remains a legally separate work.