The Second Wave of MIM Begin-ups, since 2021 – Music Enterprise Analysis

The Second Wave of MIM Begin-ups, since 2021 – Music Enterprise Analysis

by | Aug 24, 2025 | Entertainment Law, Music Business, Podcast News


The second wave of music funding marketplaces began in Europe, notably in Sweden, from 2021 onwards (for the primary start-up wave see half 2 of the collection). With Tangy Market, Grasp Trade and Anotherblock three new gamers entered the Swedish market between 2021 and 2023. The wave of latest firms continued with Bolero (2021) in France, Sonomo (2023) within the Netherlands, OG Music (2023) in Italy and Parca (2023) in Istanbul, Turkey. Within the US, three new music funding marketplaces have been launched in the identical interval: Band Royalty in 2021 and sliceNote in addition to JKBX in 2023. The developments within the music funding market since 2021 at the moment are the main target of the third a part of the weblog collection.

Music Funding Marketplaces – Half 3: The Second Wave of MIM Begin-ups, since 2021*

MIMs from Sweden: Tangy Market, MasterExchange, Anotherblock

Tangy Market was initially based in 2018 by former managing director of the Swedish music advocacy physique Musiksverige, Linda Portnoff, in Stockholm, however was launched for the general public in 2021. Within the meantime, Tangy Market in partnership with the Swedish accumulating society STIM to course of royalty funds, developed the cell app for the buying-and-selling-platform and purchased preliminary music property.[1] Tangy Market is a typical fractional royalty platform. Artists and different rightsholders can lease their royalty streams from their copyright for a restricted interval. Nonetheless, the rightsholders hold 100 per cent of the copyrights, as a result of they solely promote participation rights of their royalty revenues.[2] Tangy Market targets small traders and music followers, who can obtain the cell app, create a private account and deposit cash for funding. Buyers can then purchase and promote royalty shares of their favorite artists and take part within the royalty payouts. Apart from native Swedish music catalogues, Tangy Market additionally gives songs lined by celebrity artists resembling “Totally different Form of Love Tune” by Cher, “She Don’t Just like the Lights” by Justin Bieber and “Work B**ch!” by Britney Spears.[3]

MasterExchange was based by AI and blockchain knowledgeable Alexander Fred-Ojala with Star Steady founder Johan Edfeldt and music producer Jakke Erixson in Stockholm in 2022. MasterExchange is a music funding platform to purchase and promote shares in music royalty income streams. In an Preliminary Music Providing (IMO) the unique royalty proprietor sells a predetermined portion of the grasp royalties to traders. A royalty share is the distinctive tradable asset on the MasterExchange platform, representing a stake in a tune’s future grasp royalties. Like different fractional royalty platform, the traders don’t management the underlying copyright however personal a participation proper within the royalty income stream. In contrast to ANote Music or Tangy Market, the MasterExchange’s royalty share is related to an NFT on the Polygon blockchain. Nonetheless, MasterExchange conducts transactions in Euros reasonably than in cryptocurrency.[4] In August 2023, MasterExchange raised US $2.7 million in funding from a number of traders together with Vectr Fintech and launched the primary preliminary music providing of the tune “Sofia” by Alvaro Soler, launched in July 2016, which has generated over 2 billion music streams throughout numerous platforms, particularly in Italy and in Spain.[5]

The Stockholm-based Web3 platform Anotherblock launched an NFT market for music royalties in 2022 and secured a threat funding of US $8 million by way of three seed funding rounds.[6] Music rightsholders can supply shares of their royalty income streams on Anotherblock’s platform.[7] One instance was the Swedish songwriter and producer Alex Karlsson, who wrote songs for Ok-Pop acts resembling BTS, NCT, TXT and Twice, and provided the BTS hit “We Are Bulletproof: The Everlasting” on Anotherblock’s web site. Buyers should buy a 0.004 per cent share of a royalty NFT for 0.023 Ether, which truly equates to US $63.[8] The royalty NFTs are tradeable and will be bought on the secondary market on the Anotherblock platform.

Paris, Amsterdam, Milan and Istanbul: Bolero, Sonomo, OG Music, Parça

Bolero was based by William Bailey and Arthur Amon in Paris in 2021 and is a fractional royalty platform. The enterprise mannequin is similar to that of ANote Music. Buyers should buy and promote so-called “Tune Shares” in single songs or tune catalogues. A Tune Share is a digital asset that entitles to get a share of the correct to obtain proportional royalties from publishing and grasp rights of a particular tune or tune catalogue. Rights holders can switch their revenue streams from the accumulating societies to Bolero for a predefined interval however retain the underlying rights. Subsequently, the traders don’t management the underlying copyright however purchase a participation proper within the income stream generated by licensing of the tune/tune catalogue to music customers resembling music streaming companies, radio and TV stations. Bolero additionally gives a secondary market platform, the place the traders can commerce their acquired Tune Shares.[9]

Sonomo is one other fractional music funding platform working in an identical approach to the aforementioned firms. Based by Faris Saher within the Netherlands in 2022, it gives investments in the correct to say future revenues derived from grasp royalties, however not the underlying royalties or grasp rights.[10] Sonomo is targeted on grasp rights and doesn’t supply participation rights in income streams from exploiting publishing rights. The primary goal, subsequently, are indie file labels and artists, who personal their grasp rights. The rightsholders outline the preliminary share value, beginning at EUR 10, and Sonomo solely facilitates the change of shares and handles all following payout disbursement. At present traders from the EU should buy shares from 6 songs and three baskets of songs containing 42, 47 and 685 songs respectively.[11]

OG Music was based by Edoardo Tamburi and Federico Fundarò in Milan/Italy in 2023. OG Music copies the idea of quite a few pre-existing platforms resembling Anotherblock and MasterExchange, by which revenue participation rights are bought to future revenues from the exploitation of music rights. OG Music guarantees traders: “if you buy 1% of the streaming rights of a tune for five years, you’ll have the chance to periodically obtain the royalties that the tune collects by way of streaming.” The traders need to deposit an amount of cash in Euros on the platform by bank card or financial institution switch. This may be allotted to completely different tasks; nonetheless, a minimal funding of EUR 10 is critical. In return they obtain periodic funds from the completely different makes use of of the songs.[12]

Additionally in 2023, the fractional music funding platform Parça was based by Parça Teknoloji in Istanbul/Turkey. The enterprise idea is just like that of many music funding marketplaces already described. Buyers can purchase shares in royalty streams within the type of participation rights and resell them on a secondary market platform, though the latter is, nonetheless, solely in growth at Parça. For every profitable transaction, Parça costs a 5 per cent fee payment, no matter whether or not it’s an preliminary sale or a sale on the secondary buying and selling platform. Parça is the place traders can put their cash, primarily for Turkish repertoire. There are at present 69 songs on the market on the homepage, with lots of them by the identical artists.[13]

Again within the USA: Band Royalty and sliceNote

Within the USA, three additional music funding marketplaces have been launched within the second wave of start-ups. In 2021, the music trade veterans Barnaby Andersun and Noble Drakoln established Band Royalty, which has acquired music rights of 57 songs carried out by platinum-selling artists resembling Justin Timberlake, Jay-Z, Rihanna, Beyonce, Cher and so forth.[14] In contrast to different MIMs, the corporate doesn’t instantly supply stakes in songs and songs catalogues, however in royalty music swimming pools. If an investor buys a so-called BAND Music NFT, she is going to change into a member of the Music Mogul Membership, which gives entry to the three royalty music swimming pools. However to entry royalty income the investor should purchase no less than one of many acquired BAND NFT from these music royalty swimming pools and activate the staking of the BAND NFTs. This gives entry to the revenues from the royalty streams throughout the three staking swimming pools. The extra BAND Royalty NFTs an investor owns and stakes, the bigger is her royalty share. The NFTs are based mostly on the Ethereum blockchain and solely a complete of 12,000 NFTs can be found.[15]

In contrast to Band Royalty, sliceNote is a music funding market, that doesn’t use blockchain know-how and NFTs to commerce music royalty shares. SliceNote was based by the Utah-based BeatBread, which began as a platform to supply advances to artists for his or her current tune catalogues, but additionally for his or her unreleased music. In return, BeatBread receives a share within the artists’ royalty funds, over a interval decided by the artist. BeatBread was based in 2020 by Peter Sinclair and was in a position to elevate US $34 million in a primary funding spherical in February 2022 and closed one other US $100 million fund with Variant Investments in November 2022. In April 2023, BeatBread launched the music funding platform sliceNote, which gives certified traders (excessive web value people, file labels, music publishers and so forth.) the likelihood to put money into fractional shares as small as 1 per cent per deal.[16] Thus, sliceNote just isn’t a typical fractional royalty platform resembling SongVest and Musicow, however a music rights gross sales platform extra corresponding to Royalty Trade.

Determine 1: Listing of music funding marketplaces

Music Funding Market (MIM) Yr of basis Location MIM-Sort Variety of songs/rights
SongVest 2008
relaunch: 2020		 USA Fractional royalty gross sales platform 192
World Rockstar 2014 Austria Crowdfunded royalty gross sales platform greater than 400
Royalty Trade 2015 USA Music rights public sale platform 2,132
Vezt 2016 USA Fractional royalty gross sales platform defunct
Musicow 2016 South Korea Fractional royalty public sale platform greater than 1,400
Fanvestory 2017 Estonia Crowdfunded royalty gross sales platform defunct
ANote 2018 Luxembourg Fractional royalty public sale and buying and selling platform 26
Tangy Market 2021 Sweden Fractional royalty gross sales and buying and selling platform greater than 300
Band Royalty 2021 USA Fractional NFT royalty gross sales platform 57
Bolero 2021 France Fractional royalty gross sales and buying and selling platform 144
Grasp Trade 2022 Sweden Fractional NFT royalty gross sales and buying and selling platform 13
Anotherblock 2022 Sweden Fractional NFT royalty gross sales and buying and selling platform 11
Sonomo 2023 Netherlands Fractional royalty gross sales platform 9
OG Music 2023 Italy Fractional royalty gross sales platform 16
Parça 2023 Turkey Fractional royalty gross sales and buying and selling platform 39
sliceNote 2023 USA Music rights gross sales platform n.a.
JKBX 2023 USA Fractional royalty gross sales platform 97

The fourth a part of the weblog collection will take a more in-depth take a look at the US micro-royalty gross sales platform JKBX, which may act as a recreation changer by linking the billion-dollar music rights market with music funding marketplaces.

Endnotes

[1] Tangy Market, “About Us”, n.d., accessed: 2025-03-19.

[2] Tangy Market, “For Creators”, n.d., accessed: 2025-03-19.

[3] Tangy Market, “Funding Calculator”, n.d., accessed: 2025-03-19.

[4] MasterExchange, “How It Works”, n.d., accessed: 2025-03-19.

[5] Music Enterprise Worldwide, “After elevating $2.7m, music royalties market MasterExchange sells out its first ‘preliminary music providing’”, August 17, 2023, accessed: 2025-03-19.

[6] Music Enterprise Worldwide, “Web3 music startup anotherblock raises $4.3m in newest funding spherical”, Could 17, 2023, accessed: 2025-03-19.

[7] Anotherblock, “The trusted bridge to music rights investments”, n.d., accessed: 2025-03-19.

[8] Anotherblock, “‘We Are Bulletproof: The Everlasting’ by Alex Karlsson”, n.d., accessed: 2025-03-19.

[9] Bolero, “Incessantly Requested Questions”, n.d., accessed: 2025-03-19.

[10] Fintech Finance Information, “Sonomo Hits the Proper Notice With Weavr’s Help”, November 22, 2022, accessed: 2025-03-24.

[11] Sonomo, “How It Works”, n.d., accessed: 2025-03-24.

[12] OG Music, “FAQ”, n.d., accessed: 2025-03-24.

[13] Parça, “How It Works”, n.d., accessed: 2025-03-24.

[14] GlobeNewswire, “Band Royalty Makes Historical past With the Launch of the World’s First Multi-Monitor Music NFT”, Could 11, 2022, accessed: 2025-03-24.

[15] Band Royalty, “FAQs”, n.d., accessed: 2025-03-24.

[16] Music Enterprise Worldwide, “BeatBread brings fractional investing to the unbiased artist funding scene”, April 12, 2023, accessed: 2025-03-24.

* This weblog publish is predicated on the report IP Finance within the Music Trade, which was commissioned by the World Mental Property Rights Group (WIPO).

Much Time No Discover Audio

Much Time No Discover Audio

by | Aug 17, 2025 | Entertainment Law, Music Business, Podcast News

Apple Podcasƫs, Spotify, Amazon Musįc, and other programs αre available to talk on.

Although they had only recently met at a comedy show one day, Long Time No View: The Podcast don’t be based on their small experience. Fortunately, the two quiçkly rekindle theįr friendship after α magnificent bombing.

In a harsh tale, Drummond reveals how she forgot all of her quips during her first Don’t Show Comedy performance in San Francisco before going offstage after a brief moment of silence and shutting herself in a closet only to realize the full market could hear her through the glass ceiling. Urbano bars with his record-setting weapon aƫ the Mαll of America, ωhich iȿ “heaɾd” and” cursed” by Drummond. ” The bar said it was the most uprisings he’s ever seen.

The duo’s conversation is utterly bizarre, ranging from ridiculous talents ( Urbano can create balloon animals from his birthday clown days, while Drummond demonstrates a bird noise she learned from her friend’s drunk uncle at a quinceaera ) to where they would haunt as ghosts. Ɽummond chooses her mother’s hoưse as retaliation for ƫimes of breaking the law by getting heɾ apartment dooɾ removed. When asked about ȿtar crushes, thȩy veer off with crude laughter, lįke Urbano’s jokȩ about” ls there a Mr. Ghislaine Maxwell”? and Drummond’s quip about Trump before rehashing it.

Thȩ podcast’s most recent seαson can be lįstened to or watched on yσur preferred radio program. Don’t forget to follow the present and leave reviews, particularly on Apple Audiobooks.

Wes Brumbaugh and Jack Fink’s Much Time No Notice Comedy display series is the source of Long Time No View: The Podcast. Consequence Podcast Network and Los Angeles ‘ Gold-Diggers, which just launched the production company Gold-Diggers Media, are the partners in creating and presenting the radio.


IPRMENTLAW WEEKLY HIGHLIGHTS (July 28- August 3, 2025)

IPRMENTLAW WEEKLY HIGHLIGHTS (July 28- August 3, 2025)

by | Aug 10, 2025 | Entertainment Law, Music Business, Podcast News


Centre Withdraws Order For Cuts In Udaipur Information Movie After Delhi Excessive Courtroom Queries, Will Resolve On Certification Afresh

The Delhi Excessive Courtroom questioned the Centre’s authority to order six cuts to the movie ‘Udaipur Information: Kanhaiya Lal Tailor Homicide’ underneath the Cinematograph Act. On August 1, the Centre withdrew its reduce order and agreed to re-decide on the movie’s certification by August 6. The Courtroom directed producers to satisfy with the federal government on August 4. It emphasised that its concern was the authorized train of revisional powers, not the movie’s deserves, noting the Centre’s actions appeared like impermissible instructions. The movie’s launch, initially June 11, is now August 8 as a result of this certification dispute.

Case in opposition to producer for forging Malayalam actor Nivin Pauly’s signature to get rights of movie’s title

A case has been registered in opposition to Malayalam movie producer P. A. Shamnas for allegedly forging actor Nivin Pauly’s signature to amass the title rights for “Motion Hero Biju-2” from the Kerala Movie Chamber. Pauly alleges Shamnas used a cast doc, bypassing a 2023 settlement that granted all movie rights to Pauly’s manufacturing firm, Pauly Junior. An FIR was filed in opposition to Shamnas for forgery. This follows an earlier criticism by Shamnas in opposition to Pauly regarding movie rights. The dispute entails the sequel to the profitable 2016 movie “Motion Hero Biju.”

CBFC calls for main edits in Son of Sardaar 2

The CBFC demanded vital edits for Ajay Devgn’s movie “Son of Sardaar 2.” References to Chinese language President Xi Jinping had been muted, “merchandise” modified to “madam,” and “kuttey ki tarah” to “bahut buri tarah,” amongst different dialogue revisions. Regardless of these, the movie secured a U/A 13+ score with a 2h 27m 32s runtime.

Vijay Sethupathi Denies Sexual Misconduct Allegations, Information Cybercrime Complain

Tamil actor Vijay Sethupathi has vehemently denied latest sexual misconduct allegations circulating on social media and has filed a proper criticism with the Cybercrime Wing of the Chennai Police. The allegations, which surfaced just lately, claimed inappropriate conduct. Sethupathi’s authorized workforce said that these claims are baseless, defamatory, and a part of a malicious marketing campaign aimed toward tarnishing his popularity. The actor has sought authorized motion in opposition to these liable for spreading the false accusations on-line, emphasizing his dedication to transparency and justice. The police have initiated an investigation into the matter based mostly on his criticism. This transfer underscores the rising use of authorized recourse by public figures in opposition to on-line defamation and unverified claims.

Ruchi Gujjar slaps producer Karan Singh at movie premiere, recordsdata police criticism alleging Rs 23 lakh fraud

Mannequin-turned-actress Ruchi Gujjar allegedly slapped producer Karan Singh Chauhan with a sandal on the premiere of his movie “So Lengthy Valley”. An FIR was filed by Gujjar, accusing Chauhan and his workforce of defrauding her of ₹23 lakh. She claims the cash was for a promised tv function, revenue sharing, and on-screen credit score that by no means materialized. Gujjar now faces assault fees, whereas her lawyer plans a counter-complaint. The movie’s director, Man Singh, dismissed the altercation as a “publicity stunt.”

Girls Movie Circuit recordsdata criticism with SWA in regards to the lack of honest pay

The Girls Movie Circuit (WFC) has filed a criticism with the Screenwriters Affiliation (SWA) concerning the extreme underpayment of writers, significantly for “micro dramas” and short-form digital content material. WFC founder Sulagna Chatterjee highlighted that writers are paid as little as Rs 1,000-Rs 2,000 per episode, considerably under SWA’s 2019 Minimal Fundamental Contract charge of Rs 11-12 lakh for movie initiatives. The criticism factors out that present SWA mandates primarily apply to movies, leaving digital codecs unregulated and prone to exploitation. WFC urges SWA to ascertain clear charge playing cards for all digital content material to make sure honest compensation and deal with this loophole.

HC pulls up CBFC for delay in certifying movie on Yogi Adityanath

The Bombay Excessive Courtroom has questioned the CBFC over its delay in certifying “Ajey: The Untold Story of a Yogi,” a movie purportedly based mostly on Yogi Adityanath. Producers Samrat Cinematics challenged the refusal, noting that the Cinematograph Act mandates processing inside every week and screening inside 15 days. They alleged arbitrary delay, claiming the CBFC demanded an “misguided and extraneous” no-objection certificates from the Chief Minister’s Workplace. The movie, initially set for an August 1 launch, was stalled for over a month. The Courtroom noticed the censor board can’t indefinitely delay a choice, particularly after charging precedence charges.

Delhi Excessive Courtroom Grants Interim Aid To Ching’s, Restrains Native Producer From Utilizing ‘Schezwan Chutney’ Mark

The Delhi Excessive Courtroom has granted interim reduction to Capital Meals (Ching’s Secret) in opposition to Pitambari Merchandise, restraining them from utilizing the trademark “Schezwan Chutney.” The Courtroom discovered that Ching’s is the registered proprietor of this phrase mark and likewise holds copyright in its product’s inventive packaging. Justice Manmeet Pritam Singh Arora noticed a prima facie case for infringement, emphasizing that the injunction particularly covers using the “Schezwan Chutney” mark, not the commerce costume of Pitambari’s merchandise. The defendant was selling its “Schezwan Chutney” on social media. This determination reinforces trademark safety for established manufacturers even when phrases might sound descriptive. The case might be additional heard in December.

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GLC was ours earlier than you: Justice Gautam Patel slams Principal for discover in opposition to podcast run by alumni

Former Bombay Excessive Courtroom Justice Gautam Patel has strongly condemned Authorities Legislation Faculty (GLC), Mumbai’s principal for a public discover warning authorized motion in opposition to “GLC Legislation and Lore,” a podcast run by alumni. The discover, issued July 31, 2025, disassociated the school from the podcast for unauthorized use of “GLC” in its identify. Justice Patel, an alumnus himself, despatched a scathing letter on August 1, emphasizing GLC’s legacy belongs to its alumni and calling the discover “mean-spirited” and “disgraceful” for threatening college students. He additionally supplied authorized help to the scholars if the school pursues motion. The principal clarified the discover was a precautionary measure for model safety.

CCI rejects ADIF’s criticism in opposition to Google Advertisements insurance policies

The Competitors Fee of India (CCI) has rejected a criticism by the Alliance of Digital India Basis (ADIF) in opposition to Google’s promoting insurance policies. ADIF alleged Google abused its dominant place by imposing unfair circumstances, together with banning third-party tech help advertisements, limiting mobile-only ‘Name Advertisements’, non-transparent advert rating, and permitting trademark bidding. Google defended its insurance policies as pro-consumer and pro-competition. The CCI dismissed the criticism underneath Part 26(2A) of the Competitors Act, citing that the problems had already been adjudicated in earlier instances (Matrimony.com and Vishal Gupta), and no new materials circumstances had been introduced. This determination emphasizes the precept of res judicata in competitors legislation, avoiding reinvestigation of beforehand settled issues.

Delhi HC Recognises ‘Nutella’ as Properly-Identified Trademark in Trademark Infringement Go well with Filed by Ferrero

The Delhi Excessive Courtroom has declared “Nutella” a well known trademark underneath Part 2(zg) of the Commerce Marks Act, 1999, in a go well with filed by Ferrero. Justice Saurabh Banerjee famous Nutella’s world recognition, together with by WIPO and INTA. The ruling got here after Ferrero found M.B. Enterprises manufacturing counterfeit Nutella merchandise, which the courtroom deemed a mala fide try to take advantage of Nutella’s goodwill. Highlighting public well being dangers from misleading edible objects, the courtroom decreed the go well with in Ferrero’s favor, granting a everlasting injunction and damages. This determination reinforces sturdy safety for well known manufacturers.

Columbia Sportswear sues Columbia College for trademark infringement

Columbia Sportswear has sued Columbia College for trademark infringement and breach of contract. The lawsuit, filed July 23, 2025, in Oregon federal courtroom, alleges the college’s merchandise, significantly clothes that includes solely the phrase “Columbia” in a shiny blue, violates a 2023 settlement. This pact mandated the college use a recognizable insignia, its mascot, “college,” an instructional division identify, or its founding 12 months alongside “Columbia” on attire. Columbia Sportswear claims this breach causes client confusion and seeks to halt gross sales, recall merchandise, donate merchandise, and obtain triple damages.

CoStar sues Zillow for alleged copyright infringement of 1000’s of images

CoStar Group has sued Zillow in New York federal courtroom for alleged widespread copyright infringement of over 46,000 of CoStar’s actual property images. CoStar claims Zillow revealed its watermarked photos greater than 250,000 instances, extending to companion websites like Redfin. CEO Andy Florance expressed outrage over Zillow’s alleged theft, citing CoStar’s funding in its picture database. The lawsuit additionally references Zillow’s previous legal responsibility in an identical case with VHT, Inc. CoStar estimates potential damages exceeding one billion {dollars}, probably making it one in all historical past’s largest picture infringement instances.

Sony Sues Tencent for Copyright Infringement, Says Its Recreation Is ‘Slavish Clone’ of Horizon Franchise

Sony has sued Tencent for copyright infringement, alleging Tencent’s upcoming recreation, “Mild of Motiram,” is a “slavish clone” of Sony’s Horizon franchise. Sony claims “Mild of Motiram” copies Horizon’s gameplay, story, and inventive components, doubtlessly complicated prospects. The lawsuit follows Sony’s refusal of Tencent’s 2024 collaboration provide for a brand new Horizon recreation. “Mild of Motiram,” introduced in November 2024, options “Mechanimals” and a post-apocalyptic setting, drawing quick comparability. Sony seeks financial damages and an injunction, confirming Horizon gross sales exceed 38 million copies globally.

‘Cheat software program’ will not be copyright infringing, however advert blockers could also be, German courtroom guidelines

The German Federal Courtroom of Justice (BGH) has dominated that cheat software program is usually not copyright infringing if it solely modifies short-term knowledge in a recreation’s RAM with out altering the unique program code. This follows a CJEU ruling (Sony v. Datel). Relating to ad-blockers, the BGH’s stance is much less definitive, however earlier German courtroom choices, together with an April 2018 BGH ruling, have usually discovered ad-blocking software program like Adblock Plus to be permissible and never in violation of competitors legislation or copyright, as they don’t unlawfully copy or modify copyrighted software program however quite impression how content material is displayed. The copyright implications of advert blockers are nonetheless underneath ongoing authorized scrutiny, with some instances stayed pending CJEU choices.

Apple Sues Apple Cinemas for Trademark Infringement

Apple Inc. has sued Apple Cinemas, a Massachusetts movie show chain, for trademark infringement. Apple argues the cinema’s identify confuses customers, particularly given Apple’s enlargement into leisure providers like Apple TV+ and movie manufacturing. The lawsuit, filed in opposition to a series working since 2016, seeks an injunction to drive rebranding and unspecified damages. This motion displays Apple’s aggressive model safety technique and will set a precedent for trademark scope throughout industries, doubtlessly influencing naming conventions within the leisure sector.

SC Rejects Ilaiyaraaja’s Plea to Shift Copyright Case to Madras HC

The Supreme Courtroom has dismissed a plea by Ilaiyaraaja Music N Administration Pvt Ltd (IMMPL) looking for switch of a copyright infringement go well with filed by Sony Music from the Bombay Excessive Courtroom to the Madras Excessive Courtroom. IMMPL had argued {that a} parallel case regarding 310 of the 536 musical works in query was already pending within the Madras Excessive Courtroom since 2014, and that it operated solely out of Chennai. Nevertheless, the Supreme Courtroom held that Sony’s go well with had been filed in Bombay previous to IMMPL’s Madras petition and refused to permit the switch, thereby allowing the Bombay Excessive Courtroom proceedings to proceed.

Trade Teams Increase Alarm Over Proposed Telecom Cybersecurity Guidelines

Main business associations together with IAMAI, NASSCOM, BIF, and CUTS Worldwide have raised critical considerations over the Division of Telecommunications’ draft telecom cybersecurity guidelines. The proposed amendments, they argue, considerably increase the regulatory scope to cowl non-telecom entities comparable to OTT platforms, retailers, and even academic establishments underneath the brand new “Telecommunication Identifier Consumer Entities” class. Key objections embrace the chance of regulatory overreach, potential battle with present IT legal guidelines, lack of satisfactory privateness safeguards, and substantial compliance prices—significantly because of the proposed Cell Quantity Verification system that might cost entities as much as ₹3 per transaction. Trade our bodies warn that these measures could hinder innovation, disproportionately impression MSMEs, and complicate India’s digital ecosystem.

The Securization of Music Rights – Music Enterprise Analysis

The Securization of Music Rights – Music Enterprise Analysis

by | Aug 3, 2025 | Entertainment Law, Music Business, Podcast News


Non-public fairness initiatives, wherein music catalogues are purchased up for hundreds of thousands, might simply be a transitional section in the direction of a brand new growth wherein music turns into a speculative commodity. The buzzword is securitisation. Which means that monetary giants are creating new monetary merchandise primarily based on music rights and the revenue streams they generate. In enterprise jargon, these are known as asset-backed securities (ABS), which gained their doubtful fame throughout the monetary and financial disaster that started in 2008. Nevertheless, on this case, it’s music rights somewhat than actual property loans which can be being securitised. This fifth and last a part of the weblog collection takes a more in-depth have a look at how this works and the benefits and downsides of this growth.

Comply with the Cash! Huge Capital within the Music Rights Market – Half 5: The Securization of Music Rights*

The Revival of the “Bowie Bonds”

In December 2021, Northleaf Capital Companions issued US $303.8 million in asset-backed securities (ABS) for buyers to subscribe to. These securities had been backed by a combination of music publishing and grasp rights to 52,729 music titles from the Spirit Music Group catalogue, together with the publishing rights to songs by Pete Townshend of The Who and the masters catalogue of nation star Tim McGraw, [1] each of which had been acquired by Spirit Music Group earlier than Northleaf’s funding in 2020. [2] This elevated the funding in music rights to a brand new degree, because it turned music right into a commodity that may be traded alongside different securities. This idea is paying homage to the ‘Bowie Bonds’, which British celebrity David Bowie launched on the U.S. market in 1997. These bonds bundled the rights to Bowie’s songs and assured buyers a set annual rate of interest of seven.9 per cent for ten years. Though buyers had been repaid their capital plus curiosity on the finish of the bond’s time period, the report business’s recession, starting round 2000, led ranking businesses to downgrade the Bowie Bonds from an preliminary triple-A ranking to Baa3, simply above junk degree.[3] The worldwide monetary disaster that adopted ultimately put an finish to this and related ventures.

A New Increase of Music Rights Securization

A long time later, Bowie’s avant-garde monetary experiment will be seen in a brand new mild because the time appears ripe for brand new monetary merchandise that package deal music rights for buyers. After Northleaf, KKR in February 2022 introduced the securitization of an unlimited music rights portfolio, acquired by its Chord Music three way partnership with Dundee Companions. KKR Credit score Advisors meant to promote greater than US $732 million of ABS supported by publishing and sound recording royalties from a list of 65,000 songs, together with hits from The Weeknd, Infantile Gambino, and Stevie Nicks.[4]

Nevertheless, a forerunner of this securitization increase was the US music accumulating society SESAC, which was purchased by Blackstone in 2017. In August 2019, SESAC bought US $560 million in bonds backed by licensing agreements and music royalty streams. In comparison with the later ABS offers, SESAC bought basic company bonds providing a yield of 5.25 per cent for a weighted common lifetime of 6.7 years. Kroll Bond Ranking assigned these bonds a ranking of BBB minus.[5] Three years later, in July 2022, SESAC once more issued company bonds price US $335 million to finance the acquisition of Audio Community, acquired by SESAC in 2021.[6] These bonds act like loans, however from a bunch of buyers as a substitute of elevating cash from a financial institution. The buyers anticipate the payback of their investments plus curiosity after an outlined interval, when the underlying asset has earned the required revenue.

These music rights ABS transactions, nonetheless, created new monetary merchandise, tradeable in a specialised market. This was the intention of Blackstone’s Hipgnosis Songs Capital fund, when it introduced the launch of a US $221.65 million securitization of 950 songs of its music catalogue, together with hit songs by Leonard Cohen, Justin Timberlake, and Nelly Furtado.[7]

Determine 1: The method of securitization of music rights catalogues, 2019-2025

Date of transaction Firm Sort of securitization Catalogue Transaction worth (in US$ m)
Aug 2019 Blackstone Group Company bonds SESAC licensing catalogue 560
Dec 2021 Northleaf Capital Companions ABS 52,729 music titles from the Spirit Music Group catalogue 303.8
Feb 2022 KKR ABS 65,000 songs acquired by Chord Music 732
Jul 2022 Blackstone Group Company bonds SESAC licensing catalogue 335
Aug 2022 Blackstone Group ABS 950 songs from the Hipgnosis Songs Capital fund 221.7
Dec 2022 Apollo Asset Administration ABS Greater than 1 million songs from the Harmony catalogue 1,800
Feb 2024 ATLAS SP Companions and Truist Securities ABS 5,000 songs from the Kobalt Music Publishing catalogue 266.5
Mar 2024 KKR ABS HarbourView music rights catalogue 500
Nov 2024 Blackstone Group ABS 45,000 songs catalogue from the Hipgnosis Songs Fund 1,470
Complete       6,189

In December 2022, Apollo Asset Administration’s Capital Resolution issued asset-backed securities price US $1.8 billion in cooperation with JP Morgan. Apollo’s ABS are backed by greater than 1 million copyrights from Harmony’s music catalogues, together with songs from Phil Collins, Creedence Clearwater Revival, Daft Punk, Miles Davis, Genesis, Think about Dragons, James Taylor, 9 Inch Nails, Pink Floyd, Cyndi Lauper, Little Richard, Otis Redding, R.E.M. and lots of different superstars.[8] In February 2024, it was introduced that ATLAS SP Companions, along with Truist Securities, had provided to promote US $266.5 million price of music ABS primarily based on roughly 5,000 songs from 66 songwriters from the Kobalt Music Publishing  catalogue.[9] A month later HarbourView efficiently satisfied the personal fairness agency KKR to challenge US $500 million in ABS backed by the royalty revenue from the exploitation of the acquired rights catalogue.[10] In November 2024, Blackstone accomplished a US $1.47 billion music rights ABS transaction, backed by the Hipgnosis Songs Fund 45,000-song portfolio, which Blackstone had acquired in July 2024 for US $1.58 billion. The proceeds from the so-called Lyra 24-2 ABS deal had been used primarily to repay debt and to finance future music catalogue acquisitions.[11]

A complete of US $6.2 billion of music-related bonds and asset-backed securities (ABS) has been issued since 2019 primarily by the big PE corporations, Apollo, Blackstone, KKR, and Northleaf. The securitization of music catalogues is each a monetization of music rights but additionally an exit technique for PE initiatives.

How the Securization Enterprise Works: Benefits & Disadvantages

In 2022, the pre-sale report for Hipgnosis Music Belongings (MUSIC 2022-1) by Kroll Bond Ranking Company (KBRA) highlighted how the ABS enterprise works. The MUSIC 2022-1 ABS had been issued by Hipgnosis Music Belongings 2022-1 L.P. with a price of US $221.65 million, collateralized by the royalty streams from the music publishing and grasp rights catalogue comprising 950 songs from charting songwriters and artists, together with Justin Timberlake, Nelly Furdato, and Leonard Cohen. This music catalogue was administered by the three music majors Common, Sony and Warner in addition to seven different music rights directors. The 950 songs catalogue was valued at US $341 million with a reduction fee of seven per cent. The bonds bear curiosity semi-annually and no repayments are scheduled earlier than the anticipated compensation date in Could 2027. The ranking company instructed a ranking of A- for the MUSIC 2022-1 bonds, suggesting a low danger profile.[12]

The pre-sales report additionally included an evaluation of the royalty construction of the music catalogue. Virtually two thirds of the entire annual income of US $13.4 million (earlier 12 months to Q1 2022) had been derived from licensing of publishing rights with one third from sound recording rights. Nevertheless, the income figures present that only some songs are worthwhile. For instance, ‘Hallelujah’, written by Leonard Cohen and carried out by himself and 9 different acts, generated by far the very best annual revenues accounting for 12.8 per cent or US $1.71 million.[13] General, the highest 10 songs accounted for nearly 40 per cent of all royalties. This extraordinarily uneven distribution of royalties can be seen among the many artists. The highest 10 artists within the catalogue account for 78 per cent of the entire revenue. An evaluation by age of songs revealed that outdated repertoire, outlined as songs launched 30 years in the past or extra, generated income of US $4.6 million per yr, or 35 per cent of complete income. An additional 34 per cent of gross sales had been generated by songs 10 to twenty years outdated, and an additional 8 per cent got here from songs that had been between 20 and 30 years outdated. General, songs that had been greater than 10 years outdated generated gross sales of US $10.2 million, which corresponds to a 77 per cent share of gross sales. Conversely, this meant that solely 23 per cent of annual catalogue income got here from repertoire lower than 10 years outdated.[14]

Nevertheless, in comparison with different ABS transactions, the focus of income from the highest 10 songs within the Hipgnosis MUSIC 2022-1 ABS is the very best at virtually 40 per cent. By comparability, the highest 10 songs from the 65,000-song Chord Music catalogue, on which the KKR ABS is predicated, generated 10.7 per cent of annual revenues, whereas the highest 10 songs from the 52,729-song Spirit Music catalogue, on which the Northleaf ABS is predicated, generated 15.9 per cent of complete annual revenues. This robust focus of revenue within the Hipgnosis ABS most likely led to the A- ranking by the KBRA, whereas the KKR and Northleaf ABS had been every rated A.[15]

The KBRA report highlights each, the benefits of the securitization of music rights catalogues in addition to the disadvantages. ABS transactions allow the monetisation of music catalogues, which thereby enhance in worth. Securitisation additionally creates new monetary merchandise that may be traded on a market which supplies music rights an financial worth that’s decided by provide and demand.

The KBRA report additionally reveals one other downside that the worth of the brand new monetary merchandise depends upon a couple of fashionable songs. Ought to these songs, for no matter motive, lose their reputation, the worth of the related music bonds will undergo. If, as well as, different leisure rights or different claims to future revenue (e.g. authorized proceedings received) are bundled with the music rights within the ABS, non-transparent monetary merchandise might come up that solely serve hypothesis. On this case, losses in different areas might even have a unfavorable impression on the worth of the music rights.

All elements of the collection “Comply with the Cash! Huge Capital within the Music Rights Market”

Half 1: A Quick Historical past

Half 2: The Funding Giants

Half 3: Shamrock Capital Advisors

Half 4: The Enterprise Mannequin of Non-public Fairness Corporations

Half 5: The Securization of Music Rights

Endnotes

[1] Music Enterprise Worldwide, “‘Bowie bonds’ are again: Northleaf makes use of Spirit Music Group belongings to lift $303.8m providing”, December 20, 2021, accessed: 2025-02-14.

[2] Music Enterprise Worldwide, “Spirit Music Group acquires grasp recordings of Tim McGraw initially launched by Huge Machine”, September 9, 2020, accessed: 2025-02-14.

[3] Music Enterprise Worldwide, “The title’s bonds. Music bonds.”, October 19, 2021, accessed: 2025-02-14.

[4] Music Enterprise Worldwide, “KKR purchased a music catalog from Kobalt for $1.1bn. Now it’s turning it into bonds”, February 7, 2022, accessed: 2025-02-24.

[5] Reuters, “SESAC sells $560 million in bonds backed by music royalties”, August 2, 2019, accessed: 2025-02-24.

[6] Bloomberg, “Adele License Charges to Assist Fund $335 Million of Bonds”, July 1, 2022, accessed: 2025-02-24.

[7] Music Enterprise Worldwide, “Music’s bond journey continues, as SESAC and Hipgnosis each launch nine-figure choices”, August 10, 2022, accessed: 2025-02-24.

[8] Music Enterprise Worldwide, “Harmony costs $1.8bn bond providing backed by over 1m music copyrights”, December 8, 2022, accessed: 2025-02-24.

[9] Billboard, “Kobalt Elevating $267M From Safety Backed by Tune Catalog Together with YoungBoy & Extra”, March 19, 2024, accessed: 2025-02-24.

[10] Music Enterprise Worldwide, “HarbourView raises $500m in debt financing led by KKR”, March 13, 2024, accessed: 2025-02-24.

[11] Music Enterprise Worldwide, “Blackstone’s Hipgnosis closes $1.47bn asset-backed securities transaction”, November 11, 2024, accessed: 2025-02-24.

[12] Kroll Bond Ranking Company, 2022, Hipgnosis Music Belongings 2022-1 L.P., ABS Pre-Gross sales Report, August 2, 2022.

[13] Ibid., p. 8.

[14] Ibid., p. 7.

[15] Ibid., p. 9.

* This weblog publish is predicated on the report IP Finance within the Music Business, which was commissioned by the World Mental Property Rights Group (WIPO).

Much Time No Notice Comedy Podcast

Much Time No Notice Comedy Podcast

by | Jul 27, 2025 | Entertainment Law, Music Business, Podcast News

Aρple Podcasts, Spotiƒy, Amazon Music, and other programs are available to talƙ on.

You get what you geƫ on Łong Timȩ No View: The Audio wheȵ thȩ mask comes off, even though Matty Chyɱbor aȵd Dean Delray may have been ready tσ satisfy ȩach another! Watch the instance above, listen via the participant above, or wherever you can find podcasts to find out what happens when two completely stranger comedians must actually respond to absurd, revealing questions.

Rocket stories and business frustrations are the subject of a wonderfully dark conversation. According to Delray ( Let There Be Talk radio ), “bombing in secret is the best,” he says, describing the pleasure of trying where” no one saw that” as opposed to attack “in front of people who paid to see me. ” Chymbor describes his terrible JFL interview experience, revealing that despite a five-minute slump, he was strangely satisfied. Even though it wasn’t well received by the business crowd, he says,” It felt fine, like I was, like you actually get off phase and you’re like, man, that felt great. “

Wheȵ questiσned about opening lineȿ and star crushȩs, thȩ combo reveals their beautifully awkward ways of acting. Chymbor αdmits to being drawn to Қat Dennings froɱ Two Broke Ladies, confessing that ⱨe woulḑ “lose best away” if he said his opening seɾies would becσme “hey, I dσ fμnny. ” Scarlett Johansson iȿ α choice tⱨat Delray makes, and he’d be upfront aboưt his beloved film anḑ saყ he’s Iikely never seen any of them.

When both entertainers discuss existence changes they wish they had made early, the episode turns remarkably resilient. Chymbor discusses quitting having since the New Year’s, explaiȵing how liquor was making him feel moɾe anxious:” Ⱳhy ḑo yσu pick alcohol over like your emotionαl welfare ƒor fouɾ days a weeƙ? ” Delray, who was diagnosed with diabetes and was experiencing$ 800-a-month in-patient treatment costs, shares his extraordinary sugar cleansing. His transformation was so profound that he lost 40 pounds and discovered that fruit tastes “orgasmic” in comparison to processed sweets ‘ “wax. “

The podcast’s most recenƫ episode is available σn youɾ pɾeferred podcast platform, Long Time Ɲo See: The Podcast. Dσn’t forget to follow the sⱨow and leave reviews, especially on Apple Podcaȿts.

Wes Brumbaugh and Jack Fink’s Long Time No See Comedy showcase series is the source of Long Time No See: The Podcast. Consequence Podcast Network and Los Angeles ‘ Gold-Diggers, which recently launched the production company Gold-Diggers Media, are the partners in creating and presenting the podcast.


IPRMENTLAW WEEKLY HIGHLIGHTS (JULY 7-13, 2025)

IPRMENTLAW WEEKLY HIGHLIGHTS (JULY 7-13, 2025)

by | Jul 20, 2025 | Entertainment Law, Music Business, Podcast News


Division Bench of the Delhi Excessive Courtroom stays launch of the movie ‘Udaipur Recordsdata’

In Maulana Arshad Madani v. Union of India & Ors., the Delhi Excessive Courtroom handled a problem to the certification of the movie Udaipur Recordsdata on the grounds that it vilified a selected neighborhood and posed a risk to public order. The petitioner argued that the movie violated Part 5B of the Cinematograph Act, 1952 and the 1991 certification tips. Whereas the Courtroom acknowledged that the petitioner had not exhausted the statutory treatment beneath Part 6 of the Act (which permits revision by the Central Authorities), it held that such treatment was out there even to 3rd events aggrieved by the certification. The Courtroom permitted the petitioner to file a revision earlier than the Central Authorities by July 14, 2025, and directed that the discharge of the movie be stayed till the appliance for interim reduction is set by the Authorities. The Courtroom additionally famous that the movie’s producer had admitted to circulating uncertified teaser content material, prompting the Board to contemplate additional motion.

Learn order right here.

Delhi Excessive Courtroom Grants Interim Injunction to Ideas Movies Restricted for its movies “Maalik” and “Sarbala Ji” In opposition to 56 Rogue Web sites 

The Delhi Excessive Courtroom has granted an interim injunction in favor of Ideas Movies Restricted, restraining 56 web sites from unauthorized streaming of the plaintiff’s upcoming movies “MAALIK” and “SARBALAJI”. The Courtroom famous that the defendants had been prone to stream pirated variations of those movies with out authorization, which might trigger irreparable hurt. Granting an interim injunction, the Courtroom restrained the web sites from internet hosting or streaming the content material, directed area identify registrars to lock and droop these domains, and requested web service suppliers, together with DoT and MeitY, to dam entry to them. The Courtroom additionally allowed Ideas Movies to inform authorities of any new infringing web sites through the pendency of the go well with for immediate blocking, making certain safety of the plaintiff’s rights and safeguarding its promotional launch technique.

Learn order right here

Delhi Excessive Courtroom restrains Kuku FM from streaming sure exhibits after Pocket FM alleges violation of IP rights

The Delhi Excessive Courtroom barred audio content material platform Kuku FM (defendant) from enjoying new episodes of 5 exhibits because of claims of copyright and trademark infringement by Pocket FM. Pocket FM claimed that Kuku’s exhibits such Shivay, Jobless Ghar Jamai, Immortal Yodha, The Legend of Amrapali, and Avataar breached their mental property rights. Justice Saurabh Banerjee additionally directed Kuku FM to reveal income particulars associated to the exhibits. Pocket FM, represented by Senior Advocate Amit Sibal, claimed that Kuku FM had intentionally copied whole collection, together with characters, themes, and promotional supplies, and cited prior cases of comparable conduct. Regardless of Kuku FM’s competition that the exhibits had been out there since June 2024 and the delay in Pocket FM’s criticism, the Courtroom discovered benefit within the plaintiff’s claims and granted interim reduction.

Delhi Excessive Courtroom grants interim reduction to the German footwear firm, Birkenstock

The Delhi Excessive Courtroom has awarded an interim injunction in favor of German footwear agency Birkenstock in a lawsuit alleging trademark, copyright, and design infringement. The Courtroom prohibited Agra-based manufacturing items and Indian retailers from producing, promoting, distributing, or exporting counterfeit Birkenstock objects.

Bombay Excessive Courtroom grants reduction to Swiss pharmaceutical main Galderma Holdings towards infringers utilizing ‘Cetaphil’ emblems

The Bombay Excessive Courtroom has granted reduction to Swiss pharmaceutical firm Galderma Holdings in an mental property (IP) enforcement motion towards counterfeit objects utilizing its ‘CETAPHIL’ trademark. Galderma, appearing by way of its Indian subsidiary Galderma India, has filed a go well with requesting the Courtroom fast motion to fight widespread counterfeiting of its items on on-line platforms and in native markets.

Karnataka authorities to desk a invoice within the upcoming session of the State Legislature to ban on-line playing and the identical has been hailed by All-India Gaming Federation

In a renewed effort to fight the rise in on-line playing, the Karnataka authorities plans to current complete new laws on the upcoming session of the State Legislature. The proposed invoice seeks to criminalize every kind of web playing whereas establishing a managed licensing framework for skill-based video games.

The All-India Gaming Federation (AIGF) has known as for a nationwide framework to fight the “menace of offshore playing platforms” that function outdoors India’s jurisdiction, whereas applauding Karnataka’s intentions to determine a web based gaming and betting regulating group.

Nayanthara’s documentary in authorized hassle once more over copyright declare, Madras HC points discover

Nayanthara’s documentary Nayanthara: Past The Fairytale is as soon as once more embroiled in a authorized battle. This time, it’s about utilizing one other movie’s footage with out the precise permission. The Madras Excessive Courtroom has despatched a discover to an OTT platform. They’ve been invited to react inside two weeks about the usage of particular materials within the documentary. In line with reviews, the documentary contains footage from Rajinikanth’s 2005 movie Chandramukhi—however with out permission. The petition was introduced by AP Worldwide, which owns the rights to Chandramukhi, directed by P Vasu and starring Rajinikanth. They allege the tape was used with out their permission, regardless of authorized notices requesting its elimination and compensation of Rs 5 crore.

Janaki V v. State of Kerala – Filmmakers settle for the title change as steered by CBFC

Following issues from the Central Board of Movie Certification (CBFC) relating to potential offense to non secular feelings, the makers of ‘Janaki vs State of Kerala,’ starring Suresh Gopi, have consented to rename the movie ‘Janaki V vs State of Kerala.’ As well as, the protagonist’s full identify will likely be muted throughout a courtroom situation. Whereas certification is predicted quickly, the producers’ authorized efforts proceed, with a Excessive Courtroom listening to scheduled.

Enforcement Directorate lodges report towards 29 actors and social media personalities

In a large operation, ED has issued an Enforcement Case Info Report (ECIR) towards 29 actors and social media figures for allegedly advocating unlawful on-line betting networks. Excessive-profile names within the ECIR embrace actors Vijay Deverakonda, Rana Daggubati, Prakash Raj, Nidhi Agarwal, Pranitha Subhash, and Manchu Lakshmi in addition to two TV hosts. Harsha Sai, an influencer, and the workforce behind the ‘Native Boi Nani’ channel are beneath investigation by ED. Investigators imagine big portions of cash had been funneled by way of these efforts, maybe leading to cash laundering.

Enforcement Directorate searches Probo for ‘unlawful playing’

The Enforcement Directorate (ED) raided Probo Media Applied sciences, alleging illegal gaming actions through its ‘Probo’ app. Investigations found that the corporate duped customers with fraudulent methods, selling playing beneath the pretense of opinion buying and selling. ED searches revealed monetary irregularities, together with ₹134.84 crore from abroad corporations and a scarcity of consumer verification checks.

Ilaiyaraaja Strikes Madras HC Over Unauthorized Use of His Music in Tamil Movie Mrs & Mr

In a recent copyright dispute, legendary composer Ilaiyaraaja has approached the Madras Excessive Courtroom looking for the elimination of his 1990 track “Siva Rathiri” from the lately launched Tamil movie Mrs & Mr, directed by Vanitha Vijayakumar. He alleges the track was utilized in a distorted kind with out his permission, constituting copyright infringement. This transfer follows a collection of comparable actions by Ilaiyaraaja, who has persistently objected to the unauthorized use of his works in movies resembling Manjummel Boys, Good Unhealthy Ugly, and Coolie, demanding removals, compensation, and formal apologies to guard his rights as the unique composer.