1908: The Supreme Court ruled piano rolls were not copies. 1909: The Copyright Act was amended to include piano rolls and recordings.
In 1908, the Supreme Court looked at the copyrightability of piano rolls in the case of White-Smith Music v. Apollo. {FN1: 209 U.S. 1 (1908)} In a unanimous decision finding that piano rolls were not copies of the musical work under the copyright law as it existed at that time, and therefore not an infringement
Congress amended the copyright act in 1909 by giving the copyright owner for a musical work the exclusive right “to make any arrangement or record in which the thought of an author may be recorded and from which it may be read or reproduced.”
This was the first step in a chain of legislation that led to copyright for computer software.
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