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S.D.N.Y.Procedural orderFiled Jan. 21, 2025

Radio Music License Committee v. American Society of Composers

Full caption

Radio Music License Committee, Inc. v. American Society of Composers, Authors and Publishers

Judge
John Cronan
Docket
1:22-cv-05023
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

In Radio Music License Committee v. American Society of Composers, Authors and Publishers, Judge Cronan granted GMR’s request to seal two transcript references revealing confidential licensing terms.

Who this affects

Global Music Rights, LLC, whose requested transcript redactions were approved; the Radio Music License Committee and Broadcast Music, Inc., whose positions were not prejudiced according to the request.

What happened

Radio Music License Committee, Inc. v. American Society of Composers, Authors and Publishers concerns a request by non-party Global Music Rights, LLC to seal limited portions of a January 2, 2025 hearing transcript. Judge Cronan is identified in the case information.

GMR asked the court to seal two references made by Broadcast Music, Inc.’s lawyer to terms in GMR’s licenses with specific radio station groups. GMR said those terms were not public, remained in some current licenses, and could cause competitive harm if disclosed. The parties identified in the request did not object.

Judge Cronan granted the application. The court found that the proposed redactions were narrowly tailored to protect confidential business information and ordered the redacted transcript filed publicly while keeping the unredacted version under seal.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Radio Music License Committee v. American Society of Composers · No. 1:22-cv-05023
Judge
John Cronan
Date
Jan. 21, 2025

Background

Non-party Global Music Rights, LLC (GMR) asked the court to seal limited portions of the transcript from a January 2, 2025 hearing. GMR sought to redact two references made by counsel for Broadcast Music, Inc. to terms contained in GMR’s individual licenses with specific radio station groups.

GMR represented that the terms were not publicly known and were competitively sensitive, particularly because some remained in effect in current licenses. It argued that disclosure could reveal commercially sensitive information to competitors and other industry participants involved in negotiations with GMR. The Radio Music License Committee and BMI did not object, and GMR stated that both already knew the information it sought to redact.

Court’s reasoning

The court recognized the general presumption that judicial documents are publicly accessible but explained that this presumption must be balanced against competing considerations, including privacy interests and the potential injury from disclosure. The court accepted GMR’s explanation that the proposed redactions were narrowly tailored to protect confidential business information.

Ruling

The court granted GMR’s application. It directed the Clerk of Court to file the redacted version of the January 2, 2025 hearing transcript as a separate docket entry and to maintain the unredacted version under seal. Judge John Cronan is identified in the supplied case information.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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