Radio Music License Committee v. American Society of Composers
Radio Music License Committee, Inc. v. American Society of Composers, Authors and Publishers
- John Cronan
- 1:22-cv-05023
- U.S. District Court · Southern District of New York
- 3
In Radio Music License Committee v. American Society of Composers, Judge Cronan adopted GMR’s limited intervention in the discovery dispute.
Global Music Rights, LLC may participate in the action for the limited purpose of protecting the confidentiality of the requested discovery. Radio Music License Committee, Inc. and Broadcast Music, Inc. are affected because the discovery dispute involves documents RMLC provided or may provide in response to BMI’s requests.
What happened
In Radio Music License Committee, Inc. v. American Society of Composers, Authors and Publishers, Global Music Rights moved to intervene, meaning to join the case for a limited purpose, to protect confidential information in documents that Broadcast Music sought from the Radio Music License Committee. A magistrate judge allowed GMR to intervene for that purpose.
The magistrate judge also denied GMR’s request to completely block disclosure of the documents but ordered additional protections. Broadcast Music sought reconsideration, which the magistrate judge denied. No party filed objections by the deadline.
Judge John P. Cronan reviewed the intervention ruling and adopted it in full. This order does not separately adopt or alter the magistrate judge’s ruling on the protective-order request.
The detailed version
- Radio Music License Committee v. American Society of Composers · No. 1:22-cv-05023
- John Cronan
- Oct. 18, 2024
Background
Global Music Rights, LLC (GMR) moved under Federal Rule of Civil Procedure 24(a)(2) to intervene in the action for the limited purpose of protecting its alleged confidentiality interests in documents that Broadcast Music, Inc. (BMI) sought from Radio Music License Committee, Inc. (RMLC) in discovery. GMR also requested a protective order that would bar RMLC from producing those documents.
Magistrate Judge’s Order
The court had referred the case to Magistrate Judge Stewart D. Aaron for general pretrial supervision and dispositive motions. On September 1, 2024, Judge Aaron granted in part and denied in part GMR’s motion. He allowed GMR to intervene for the limited purpose of protecting its interest in the confidentiality of the requested discovery. He denied GMR’s request to completely bar disclosure but found that GMR was entitled to additional protections described in that order.
BMI moved for reconsideration, and Judge Aaron denied that motion on October 2, 2024. The deadline for objections to the September 1 order passed without any party filing objections. The district court explained that, because an as-of-right intervention motion may be treated as dispositive, it would treat the portion of Judge Aaron’s order allowing intervention as a report and recommendation. When no objections are filed, a district judge generally reviews such a recommendation for clear error, but Judge Cronan stated that he conducted a more searching review of the intervention ruling.
Ruling
Judge John P. Cronan found the intervention ruling well-reasoned and its conclusions well-founded. He adopted the portion of the September 1 order allowing GMR to intervene in its entirety. The order did not separately rule on the protective-order portion of Judge Aaron’s decision; the opinion describes that motion as non-dispositive and notes that no party objected to it.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.