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Judge Gutierrez found ‘that copyright ownership of an sound recording under 980(a)(2) includes the exclusive straight away to publicly perform that recording.’ His conclusion was largely using the indisputable fact that neither the statute itself, nor the legislative history for Section 980(a)(2), specifically excluded public performance rights for sound recordings. Originally my estimation was that Gutierrez’s decision have also been an outlier that would likely to wind up overturned on appeal.