Update… More On The Insanity of The MLC

On February 29th, 2023 I wrote an article about the insane Kafka-esque experience we have been having with The Mechanical Licensing Collective (The MLC).?

It has now been over 800 days of us trying to have musical works for a catalog we represent get registered to our account and we still can’t get The MLC to register them.?

This article was on top of the prior article I wrote in 2022 when we learned that someone within The MLC/HFA hacked into our MLC account, deleted our bank account information and re-channled our songwriter’s money to an HFA/SESACs owned sister company. And then the next follow up article in 2022 when The MLC further breached the regulatory requirements of the MMA when we exposed the fraud and theft.

And that bring us to now. I am just simply going to post the emails between us and The MLC. They speak for themsleves. And as they are emails, it will start with the most recent and go backwards in time. Note that in some cases they are very “inside baseball” as the jargon and language used are very specific to the technology systems/protocols and the music publishing administration sector. But the end result is what it is, The MLC appears to have been designed not to operate efficiently or to get songwriters and music publishers paid the money they earned.?

I suspect my extreme frustration is coming through in the tone of my emails. If not, I can assure I am.?

Finally note that in the emails you will see the names Jake Smith, Melanie Santa Rosa, David Willen and Eric Goldberg. They all work at Word Collections.?

Here is how the sausage is (not) made…

From: Jeff Price

Subject: See this sequence of events line/sixty nine days with CWR and now re-read Sean’s emailRe: MLC stated policy Re: More detailed response Re: Bridgeport Works Review

Date: March 13, 2024 at 5:17:51 PM EDT

To: Sean McNamara?

Cc: Jake Smith, Maurice Russell?, Melanie Santa Rosa?, Kris Ahrend?

Hi Sean,

On November 11, 2023 Word Collections submitted a CWR file named CW230056FRI_000.V21 to The MLC with 103 works in it.

On November 14th, 2023 we received back from The MLC and ACK for this CWR. The ACK file is named CW230118034_FRI.V21.

The Acknowledgement Type was 1. The Registration Status was “Transaction Accepted”.

This means that The MLC determined the formatting of the CWR was correct and it would move to step two. Step two is for The MLC to determine if it would register the 103 works we submitted via CWR on November 11th, 2023 to Word Collections.

Sixty nine days later, on January 19th, 2024, The MLC sent us a second ACK file named CW240383034_FRI.V21 for the November 11th CWR. The Acknowledgement Type was 2. The Registration Status was Registration Accepted with Changes.

This means that The MLC registered the 103 works submitted in the November 11th, 2023 CWR file to Word Collections and there were no issues.

Note that it took sixty nine days for The MLC to register the works to us.?

Now read you own email where you state The MLC will not provide feedback or responses to the administrator submitting works to The MLC.

This is false as The MLC does provide return files but ONLY for CWR submissions. Therefore it does treat its members differently. It does NOT provide any return file to anyone that uses the bulk upload or your website but DOES provide return files to an entity that has the resources to build to CWR and deliver with that protocol. Over 95% of The MLC members do not have the resources or knowledge to deliver via CWR.?

Second, you state The MLC will not tell us anything after submission and it is up to us to dig around The MLC on-line databases looking to learn if The MLC did/did not disregard our submission via its own unilateral undisclosed policies.

For arguments sake, assuming this was an appropriate way to do things, using what you write, we would have had to log into The MLC system every day for sixty nine days checking for to learn if ANY of the 103 works in our CWR file were registered by The MLC to our account. That’s looking up 103 individual works, one at a time via your website and trolling around through the data display interfaces one at a time trying to find something. And then after putting in the hours of work to do so, and finding NOTHING registered to Word Collections, we would then wait until the next day to do it again.

Assuming it took two hours a day to search for all 103 works, that’s 138 hours of our time spent looking for our works. With a 40 hour work week, that’s 3.45 days of a five day work week to search The MLC website with no results all due to The MLC not committing to any time frame to ingest upon submission and not providing feedback (which makes one question what the point of bulk submission to The MLC is).

And now let’s move on to the fact that we submitted 1,079 additional works to The MLC after November 11th. And while taking that fact into consideration, also know that we have all the past submissions prior to November 11th, 2023 that are still not registered to our account (thousands more).

So again, using the workflow you insist we use, we now need to manually search The MLC public database for over 1,079 works + 103 works + 1,000 older submitted works. Thats 2,182 works. It takes us two hours to handle 103 works. This means we need to spend over twenty hours a day each and every day to manually check. There are literally not enough work hours in a day for one human being to do that.

Note that per your email, that post submission, The MLC will tell us nothing, commit to no time frame to ingest/process and register. Instead we are supposed to log in each and every day to troll through the public database and/or download what The MLC designates as our catalog of works and then search through it to learn if a work is/is not registered.

And if the work is NOT registered, as we get no feedback from The MLC and no time frame commitment, we have to guess what the reason is. One could be that The MLC has not gotten around to ingesting/processing our submitted file. And as the work is not showing up we keep checking until one day we think enough time may have gone by. So on the sixty eighth day we ask The MLC for some status update to the file we submitted. To do this we have to send an email. After sending the email we have to sit and wait for another undetermined period of time until we get a reply (could be a week, a day, a month). The reply then tells us the status and then wait again until we finally trip over something somewhere that tells us The MLC refuses to register our submitted work to us.

At that point, we then have to invent a rabbit hole to go down (as The MLC provides no real process) to get the work registered to Word Collections which may involve a conflict resolution. But, The MLC will not provide us contact info/email/phone or person to reach out to at the entity that is wrongfully claiming our work.

What is described in your email is not tenable for anyone. It does not work and cannot work. And in the meantime, The MLC either sits on our songwriter’s money earning bank interest which it gets to keep and use for its overhead, continues to knowingly pay the wrong entity or eventually distributes the royalties via a market share allocation disproportionately going to the majors who sit on the board of The MLC.

So I ask again, is what you wrote really The MLC policy. Billboard and Digital Music News are on copy. Perhaps they would consider publishing The MLC policies that are not available to view on The MLC website and are not disclosed to its members.

Jeff Price

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On Mar 11, 2024, at 5:49 PM, jeff price wrote:

Hi Sean,

To confirm, per your below email, you have stated that when a publisher/administrator remits data to The MLC via bulk submission or via its website, The MLC will provide no response. The MLC then has a secret undisclosed policy set by The MLC that the responsibility of that publisher/administrator is to log into The MLC website every day to download what The MLC states is that publisher/administrator’s catalog and for that publisher/administrator to then audit and compare against what it remitted to determine if The MLC has registered the work to them.?

If the publisher/administrator does not use its own technology and system to audit The MLC downloadable file, then the publisher/administrator will not know that The MLC did not register the work submitted to The MLC. Further, The MLC will ignore that publisher/administrator’s data and continue to knowingly and willingly remit payments to the prior publisher/administrator despite receipt of a valid Letter of Direction and metadata.

In addition, The MLC has no specific time frame upon which it will take a musical work submitted to it and then register it (or ignore it). The result being that the publisher/administrator has no idea if the reason for the work not appearing in The MLC catalog created output of that publisher/administrator works is due to The MLC not registering the submitted work (and not telling the administrator) or due to the random latencies that exist at The MLC (or for another reason).?

All of the above also holds true for The MLC Public Search database which randomly updates from time to time (but is asynchronous from the historical database).

However, the above does NOT hold true if the submission is done via CWR in which case The MLC will supply a ACK (acknowledgment) file back to the publisher/administrator (at random time intervals from one day to months) that indicates if a submitted song was or was not registered and provide at least a top of the trees reason with no specifics.

In addition, The MLC does have the information as to whom it has associated a musical work but refuses to disclose that information back to the publisher/administrator unless the publisher/administrator goes to The MLC website and searches (hoping The MLC website is functioning) and trolls through many pages of search results looking for the work.

If the publisher/administrator does find the missing work in The MLC database, then the burden is on the publisher/administrator to re-approach The MLC via email (and hope the person they email is working) with documentation to support why that work should be associated with that publisher/administrator. If the publisher/administrator does not do this, The MLC will willfully and directly ignore the publisher/administrator’s submission, Letter of Direction (LOD) and all other data.

In addition what you wrote is patently false and is not a uniform policy for all members.?

Specifically, (as with another songwriter we represent), an email was sent ahead of time to The MLC by a non Word Collections person. That person stated to The MLC that another entity was making a wrong claim on a work at which point The MLC ignored all of the points in your email and did what it thought was best at its discretion with no documentation provided by the entity that first wrongly claimed the work or the person that contacted The MLC.

As another example, The MLC switched who represented the Word Collections works for the December 2021 usage paid in March 2022 and The MLC re-assigned four of our catalogs with no documentation to an HFA/SESAC owned subsidiary and paid it close to $100,000 that was owed to Word Collections and its songwriters (which we ultimately were able to recover)

In addition, we remitted the Bridgeport works to The MLC over 800 days ago and at no point did The MLC state to us that:

? The MLC will not provide any information back?

? The rules The MLC created (arbitrarily) are to ignore submissions to the detriment of the submitting publisher and rule in favor of whomever got their data in first and/or whatever bad/wrong data was provided by HFA (who could not pay the money prior to the MMA due to having bad/wrong data).

? It has a prejudicial system against any entity that used the bulk or manual entry submission as there will be no return file provided (that is only provided to entities using CWR via an ACK return file).

? A member of The MLC is required to build its own audit systems and then download files from The MLC every day (due to no time commitment from The MLC) to learn if The MLC ingested a submitted work in order to identify that The MLC has not registered the work to us.

? If The MLC did not register a submitted work (as determined by our audit at our own cost), then we are required to manually scour The MLC website and/or download an outdated catalog file to find out where it is.

I am going to stop here, but I could keep going.

Clearly The MLC system is not architected and built for efficiency. You worked at the Orchard and HFA prior to The MLC. Can you provide the systems you encountered where you remitted data and the recipient of that data provide you no response and told you 100% of the burden was on you to figure out what was/was not registered via random downloads of out of synch files with no clear path to resolution?

Is this how you get paid each by The MLC or does The MLC have to pay you what you earned without you having to build audit systems to check your payroll? If they don’t, do you have recourse of does The MLC say “tough” and pay a portion (or all) of your salary to another MLC employee?

Did HFA respond to its clients or say nothing?

When you registered works for public performance you really got no response from any entity?

Thank You

Jeff Price

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On Mar 11, 2024, at 4:36 PM, Sean McNamara MLC wrote:

Jake,

Like all Members, you have a complete and up to date record of the full catalog of work shares that have been registered to WC at all times in both your Portal account and The MLC Public Search of the musical works database. If a work share is not registered to WC because it was already registered to someone else, that is also fully apparent to you in the Portal and The MLC Public Search at all times. The only reason WC would not know at any point in time exactly what work shares are registered to WC, and what work shares are not, is if WC has not looked at its Portal account and The MLC Public Search to see.?

If, after your review of the existing registration records and your own rights you conclude that WC is the proper legal payee for a work share that is registered to someone else, then you can request to initiate a conflict under The MLC’s ownership dispute policy found here and follow those procedures, which apply to all Members. This is the same process that any other Member would have to follow if they tried to register a work share that WC had already registered.

With respect to the 126 works you reference below, we have already notified you that the dispute procedure has begun, and that pursuant to that policy, WC must submit substantiating documentation for its claims. Examples of adequate documentation are outlined in Section 5 of the dispute policy.

Each of the 126 works you list below, where WC wants to claim a work share that is already registered, involve Existing Claims under the dispute policy. As a result, if and when we receive substantiating documentation from WC for a work share, that work will go into interim suspense, and beginning with the distribution based on the next snapshot, royalties will be accrued and held pending resolution. WC has access at all times via the public database to the names and shares of the entities who may be receiving royalties in connection with a work share subject to a conflict, unless and until that work or work share goes into suspense, and The MLC will not make adjustments for royalties that may have been paid for periods prior to the placement of royalties in suspense pursuant to the Ownership Dispute Policy. These are all the same rules that apply if any other Member tries to register shares of a work that is registered to WC.

Finally, please note that I am in the midst of looking over the bulk upload files you’d provided for my review on Friday afternoon, and further clarification regarding that inquiry is forthcoming.?

Regards,

SEAN MCNAMARA (he/him/his) Manager, Publisher Services themlc.com 333 11th Avenue South | Suite 200 Nashville, TN 37203 ?

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From: Jake Smith? Sent: Monday, March 4, 2024 10:38 AM To: Sean McNamara? Cc: Maurice Russell?; Melanie Santa Rosa?; Jeff Price? Subject: Re: More detailed response Re: Bridgeport Works Review

?EXTERNAL EMAIL: This email originated from outside of MLC’s email system. DO NOT click links or open attachments unless you recognize the sender and know the content is safe.

Hi Sean,

Thank you for your reply, however this still does not answer several of the questions I have asked multiple times in my previous emails. Posting again:

1. For the unregistered works, why were multiple submissions of these works not accepted? What assurances do we have that these works will be accepted now after multiple submissions were disregarded? Have any other parties been receiving payments on these works?

2. Why did The MLC not notify Word Collections of the 126 conflicting ownership claims prior to February 9, 2024?

3. Have the other publishers listed on these works been receiving payment since the initial Word Collections notification on December 22, 2021?

4. For any instances in which royalties have been paid to the incorrect publisher/administrator, what will the MLC do to ensure Word Collections and its songwriters are paid for this past earned revenue?

I appreciate your replies to these specific questions as soon as possible, and I will speak with Bridgeport about the requested materials re: the conflict process.

Best,

Jake Smith Director, Strategic Projects WordCollections.com

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On Mar 1, 2024, at 7:09 PM, Sean McNamara The MLC wrote:

Jake,

I am writing on behalf of myself and Maurice, in response to your inquiries regarding the conflicts and unregistered works discovered during my manual analysis of more than 200 Bridgeport works requested by Word Collections (WC).

Conflicts For the 126 WC work share claims it cannot register with The MLC due to existing registrations by other members, a conflict for each work has been noticed as of my email dated February 9, 2024. As explained in the same 2/9 email and again in Maurice’s 2/15 and 2/27 emails, WC must now follow the conflict procedure outlined in The MLC Ownership Dispute Policy found here and identify for each work the writer(s) you represent and the shares you are disputing, and then send us documentation establishing Bridgeport’s ongoing agreements with these writers to administer these shares. Once we receive this information and have addressed any questions we may have, we will notify the other Member(s) currently claiming the shares in question and ask them to provide similar substantiating documentation.

Unregistered Works We also discovered that 19 of the claims WC inquired about involve works that have not yet been registered to The MLC musical works database. WC is therefore free to register these 19 works and its claims to these works with The MLC. For the avoidance of doubt and confusion we would suggest re-submitting these works at your earliest convenience, so that their submission progress can be monitored leading up to these works’ registration.? We look forward to receiving the information we outlined above.? Regards,

<Outlook-pe4ladd0.png> SEAN MCNAMARA (he/him/his) Manager, Publisher Services <Outlook-t4tvvpp4.png> <Outlook-aahegkgd.png> <Outlook-0dwnjjbu.png> <Outlook-vx0mmtvd.png> 333 11th Avenue South | Suite 200 Nashville, TN 37203

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?From: Jake Smith? Sent: Friday, March 1, 2024 9:18 AM To: Maurice Russell Cc: Kris Ahrend Sean McNamara?; Melanie Santa Rosa?; Jeff Price

Subject: Re: More detailed response Re: Bridgeport Works Review ?

EXTERNAL EMAIL: This email originated from outside of MLC’s email system. DO NOT click links or open attachments unless you recognize the sender and know the content is safe.

Hello Maurice,

Thank you for your email to Jeff on 2/27/24. I have reviewed your email and have a few questions, specifically relating to status of the 215 works:

1. Shares of 66 of the 215 works were already registered to WC

Can you please provide the dates that these works were registered, and when the MLC updated its records to show Word Collections as the administrator? As these works were submitted as part of the original LOD A submitted on 12/22/21 we’re just trying to get a clear history of when The MLC updated its records.

2. 19 of the works had not yet been registered with The MLC, which means that WC needed to register those works and then claim shares on behalf of Bridgeport

Per my email to Sean on 2/14/24, 17 of these 19 works had been submitted to The MLC on three separate occasions:

- Original LOD A 12 22 21?—?this was the schedule of works sent by Dan Hegarty to [email protected] on December 22, 2021 (over three years ago). On December 23, 2021, Jessica Dorow confirmed receipt, saying “I have sent this to our Rights Management team for processing. I will let you know when this is complete.” - Still Missing June 15 23 Resubmission?—?this is a list of works that met the following criteria A. We had previously submitted these works to the MLC on or before May 2023 B. We could not locate these works in our MLC catalog exports C. We resubmitted these works via the bulk submission tool on June 15, 2023 D. We confirmed on August 22, 2023 that these works still did not appear in our catalog exports. E. I emailed Sean on September 6, 2023 with the list of missing works (subject: Analysis of works resubmitted to MLC on June 15 23) - Works not in MLC as of 10 5 23 (email subject: Analysis of works submitted to The MLC Between June 15 23 and July 31 23). This is a list of works that met the following criteria: A. We submitted (or resubmitted) these works to the MLC via the bulk tool between June 15, 2023 and July 31, 2023 B. We could not locate these works in our MLC catalog exports as of October 5, 2023. C. The sheet was organized by publisher.

As we have already attempted to register these works on three separate occasions dating back to 12/22/2021, it is unclear how registering the works a fourth time will resolve the issue. Can you please review the three previous attempted submissions and let us know why those submissions were not accepted, and what we need to change in order for these submissions to be accepted by The MLC?

3. The relevant shares of 126 of the works were currently being claimed by other parties, in whole or in part, which means WC needed to confirm that it had the right to claim the shares in question; if it did, WC needed to notify The MLC of its intent to initiate a conflict for each work and then provide substantiating documentation of its claims for each work in accordance with The MLC’s Ownership Dispute Policy.

These conflicting works were submitted to The MLC on at least three separate occasions, on the same dates as listed under item 2. After multiple submissions dating back to 12/22/2021 and multiple emails, I was first notified that there were conflicting claims on these works in Sean’s email on 2/9/2024, over three years after our initial submission of these works.

At no point during any of Word Collections bi-weekly calls with Sean where I asked about these specific Bridgeport issues were we notified that Word Collections is required to submit 126 separate conflict requests to The MLC.

I just spoke with Sean (1:15 PM ET on 2/29/24) who confirmed that the conflict process has still not been initiated on these works (despite email requests I sent on 2/12/24, 2/14/24, and 2/23/24). I was notified on this call that we need to provide the following to start the conflict process, despite having documented previous instances where MLC conflict process was initiated without supporting documentation:

- Specifying which writers on which works are claimed by Bridgeport - Provide agreements between Bridgeport and the writers in question - Provide the settlement agreement (in the case that the rights were obtained via settlement).

The following questions originally submitted on 2/14/24 have still not been responded to:

1. For the unregistered works, why were multiple submissions of these works not accepted? Are they in the process of being ingested now or do we need to submit again? What assurances do we have that these works will be accepted now after multiple submissions were disregarded? Have any other parties been receiving payments on these works?

2. Why was Word Collections not previously notified of the 126 conflicting ownership claims?

3. Are these 126 overclaimed works currently in the MLC conflict process? If so, when was the conflict process initiated? If they were previously in the conflict process, what were the dates of these conflicts?

4. Have the other publishers listed on these works been receiving payment since the initial Word Collections notification on December 22, 2021?

5. For any instances in which royalties have been paid to the incorrect publisher/administrator, what will the MLC do to ensure Word Collections and its songwriters are paid for this past earned revenue?

Thank you for your attention to these matters.

Jake Smith Director, Strategic Projects WordCollections.com

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On Feb 29, 2024, at 6:12 PM, jeff price wrote:

From: Jeff Price Subject: More detailed response Re: Bridgeport Works Review Date: February 29, 2024 at 6:10:15 PM EST To: Maurice Russell Cc: Sean McNamara?, Jake Smith, Melanie Santa Rosa?, Kris Ahrend?

Hi Maurice

Jake Smith is sending you a specific detailed response to your below email that provides concrete dates and requests that The MLC has not done or responded to.

From the top of the trees, the facts are

We were first notified that there were conflicting claims on these works in Sean’s email on 2/9/2024, over three years after our initial submission of these works.?

We submitted the works to The MLC almost 800 days ago and they still are not associated with our account. In addition, there are the ISRCs that should be attached to the works which we have zero insight into as to which works they are associated with.

We submitted to The MLC the Bridgeport works with all associated metadata and ISRCs for those works again, and again and again and again over the years using every method of submission The MLC has (manual, bulk upload and CWR). No matter what we did/do, the MLC did not/will not register all the works nor provide the needed information to allow us to resolve conflicts or have ISRCs correctly attached to the works.?

In addition, until we sent the works and ISRCs for the fourth or fifth time via CWR, there was zero response from The MLC in regard to indicating which works it was not registering to us and why. There was no response/return file for the bulk uploads or manual entry. Nothing. The MLC operates like a black hole. You submit works and information and it literally says nothing back to you.?

Can you please provide me a reference point to another entity on the planet in the same space as The MLC that does this? There are over 90+ MRO/PRO/CMOs around the world not to mention more entities like MRI. Every single one of them say something back. Not the MLC with one exception.?

Note that The MLC does have ACK files it sends back to CWR submissions so clearly it believes it should have some sort of response file or it would not bother with ACK files. But note, the response files are ONLY to CWR submissions meaning you provide NO response file back if someone uses the bulk or manual entry to submit. CWR is extremely complex and complicated limiting its use only to those with large tech budgets and tech teams. As you are aware of 95% of The MLC’s individual members do not use CWR to submit works. This means you have created a prejudicial and tiered system working to the detriment of the majority of your members. Why??

And as far as the ACK response files we get from our CWR submissions, here is a copy and paste of a typical ACK message we get back:

ERROR: CONFLICT: THE SUBMITTED MECHANICAL CLAIMS ARE IN CONFLICT WITH SPLITS CURRENTLY AT SESAC/HFA. TOO MUCH OF THE WORK HAS PREVIOUSLY BEEN CLAIMED AND THERE IS NOT ENOUGH ROOM FOR YOUR SUBMISSION.

There is zero information in this message beyond The MLC stating it refuses to add us to the composition despite our valid LOD, effective date, clean metadata and associated ISRCs. You do not even bother to give us The MLC work ID in the return file. So now what? I have to go to your website and manually search through your database loaded with bad and incorrect data to try to find this one work (and recall we have tens of thousands of works) and when I do manually scroll through screen after screen to even see the associated ISRCs.?

And once I do this, there is nothing in the MLC site that allows me to communicate with the other entities on the work that The MLC and its back-office entity HFA wrongly associated or connected the work. So now I have to try to find a contact email or phone number to reach out to the other entities all because The MLC does nothing. No feedback, not putting the composition into conflict, no holding our royalties. The MLC ignores our data, uses the bad data from its back office vendor, pays the wrong entities, provides no resolution path. And this is the GOOD response. If you use the bulk upload and manual entry you don’t even get this pittance of a response. You get nothing.?

We cannot administer works if the entity we are collecting from (in this case The MLC) is literally non-responsive and hides data. We send you data, you send nothing back. Then we have to play Sherlock Holmes in order to try to solve the problem by auditing royalty statements and works associated with our account from a MLC download as The MLC pro-actively tells us nothing.?

And when we do find the issues (which we did again and again and again) and email them to you (as you have no other way to resolve or communicate the issues) we then have to hope someone at The MLC does the research and responds. If they do not, we have zero recourse. And here we are almost 800 days later with the works still not registered. Like me or hate me, you can’t dodge the valid point. We know what we are doing, we do it well, and The MLC is not paying us, our songwriters and/or publishers their earned royalties.?

We only have this issue with The MLC. Not with any other entity on the planet. This is unique to The MLC. We do not have the same no response/black hole issue the we have with the MLC with MRI, YouTube, Meta, Peloton, DSPs outside of the US such as Amazon, Spotify, Apple, Deezer TikTok etc etc etc. Let me repeat, this issue is unique and specific only to The MLC.?

Your system does not work as it. should. Your back-office vendor HFA has bad and wrong data. Your conflict “policy” appears to be to reject data that is correct and not bother to notify the entity submitting the data unless its submitted by CWR in which case at some point you will send back a ACK return file with zero specificity.?

And we have not even begun to touch on the issue of ISRCs. We submit data to The MLC and we have ZERO insight into which ISRCs are/are not associated with the work unless we manually troll through your website (hoping its working when we go to use it), type in a work, scroll through pages of works until we find the right one then manually scroll through pages of ISRCs line by line trying to identify if the twelve alphanumeric digits that identify the ISRC are present. And if they are not, then what? I have no way to find an ISRC that should be attached to our work in The MLC system. It does me no good to have a work registered to Word Collections if you don’t bother to connect the sound recording embodying the work to the ISRC as its the stream of the recording that generates the mechanical royalty.?

When we remit our metadata to The MLC via CWR, bulk upload or manual entry, the MLC provides NO feedback of any sort in regard to the ISRCs. We have some works like Rockin’ Around The Christmas Tree with thousands and thousands of recordings embodying that one work. When we deliver these ISRCs to The MLC connected to our work we get no feedback at all on the ISRCs. Are they connected to the work/not connected? If they are not connected, where are they and what are they connected to? How much money have they generated in mechanicals and who has been getting our money and for how long? How do we even resolve this issue beyond sending an email and hoping someone bothers to respond? And when they do, how long do we have to wait as our money is paid to others or not paid at all but sits in the accrued but unpaid bucket? And what if it’s distributed out in a market share allocation despite us delivering the data?

And now let’s move to response times to CWR files. When we send them we first get a “Transaction Accepted” response indicating that according to The MLC the submitted work passed an initial check that it was correctly formatted according to CWR spec.

Then we sit and wait for random time periods that can literally take over eight weeks for the submitted work to be added or updated by the MLC. As an example, we submit at the start of January, 2023 and over sixty days later we are still waiting for our work to get associated to us. In the interim two pay cycles have gone by and the prior administrator is getting our money.?

Then there are the “reprocessing” files. The October 2023 usage paid to us in January 2024 had reprocessing royalties for us from two years prior for works/ISRCs The MLC had been paying us on prior to the reprocessing date. The MLC sat on our money for over two years earning bank interest that it keeps. Why? Was it The MLC or the DSPs that were negligent??

You cannot fix a problem if you do not admit you have one. The sad part is, there are zero repercussions to the MLC’s actions in the MMA. It can act (and does) with impunity. The beneficiaries are your board members who get to take our (and other) songwriter’s money or The MLC who sits on our money and earns over 4% bank interest year to year.

In the meantime, the constituency you were theoretically built to serve does not get paid all their royalties.

I do hope there will be forthcoming incremental requirements added to the law. As right now, we are all suffering due to its actions.?

Thank You

Jeff Price

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On Feb 27, 2024, at 5:58 PM, Maurice Russell The MLC wrote:

Jeff, ?You recently sent several e-mails to Kris which were forwarded to me for reply: two of those pertained to the Bridgeport catalog, and one pertained to general questions you had about some patterns your team noticed in the royalties that were reported to you. I am writing today to respond to your notes about the Bridgeport catalog. ?In your notes, you strongly imply that The MLC has not done anything related to the Bridgeport catalog for over two years. This is simply not the case. Within two weeks of receiving the LOD your team sent us confirming your authorization to administer the Bridgeport catalog, we processed the transfer of nearly 4,000 works from the catalog of Bridgeport’s prior administrator to the Word Collection (“WC”) catalog. At that point, it was incumbent on your team to review the works in your catalog to determine if there were any additional works controlled by Bridgeport not included in this transfer that still needed to be registered. Our team gave your team the information they needed to perform this check. For whatever reason, it appears that your team did not do that work for well over a year, because it was not until September of last year that your team sent us a schedule of 215 works that it claimed were also a part of the Bridgeport catalog and were not reflected in WC’s catalog. Although your team had the ability to look for each of these works using The MLC’s member tools, they did not. So, our team expended significant internal resources to review this schedule of 215 works for your team, and here is what we found: ?? Shares of 66 of the 215 works were already registered to WC; ? 19 of the works had not yet been registered with The MLC, which means that WC needed to register those works and then claim shares on behalf of Bridgeport; ? 4 of the works do not contain any shares claimed in the name of Bridgeport, which means WC needed to claim those work shares; ? The relevant shares of 126 of the works were currently being claimed by other parties, in whole or in part, which means WC needed to confirm that it had the right to claim the shares in question; if it did, WC needed to notify The MLC of its intent to initiate a conflict for each work and then provide substantiating documentation of its claims for each work in accordance with The MLC’s Ownership Dispute Policy.? To date, WC has not registered the missing works or claimed its shares of the works already registered by other rightsholders, and all WC has done is express its desire to initiate conflicts for all of the 126 works currently being claimed by other parties; WC has not provided The MLC with any substantiating documentation to support its claims to any of these works. WC needs to take these actions in order to effectuate its claims to these works. The MLC cannot do this for WC.? That brings me to my final point. It seems that the overarching issue in this situation (and many others) is that WC seems intent on trying to shift the burden for fulfilling its core responsibilities as an administrator to The MLC and then blaming The MLC when its desired outcomes are not accomplished?—?rather than fulfilling these core responsibilities in the first instance. This strategy is both unproductive and ineffective. WC has certain core responsibilities as an administrator that it cannot shift to The MLC. ?In closing, The MLC has made itself available to WC on an almost weekly basis to provide reasonable assistance to WC where we can, but WC must fulfill its core responsibilities as a Member. Our hope is that WC will start doing so. ?Regards, Maurice

—?—?—?—?—?—?—?—?—?—?—?—? ?From: Jeff Price Sent: Saturday, February 24, 2024 12:46 PM To: Kris Ahrend? Subject: Fwd: Bridgeport Works Review

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?Hi Kris ?Following up again as we still have not received replies to all of the below. The below email as sent on Friday. ?What is it on your side that you are disputing? ?On our side, coming up on 800 days of trying to register works/ISRCs and get paid.

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?From: “Jake Smith”? Subject: Re: Bridgeport Works Review Date: February 14, 2024 at 12:42:02 PM EST To: “Sean McNamara” Cc: “Maurice Russell”, “Jeff Price”?, “Melanie Santa Rosa”? Reply-To: “Jake Smith”? ?Hello Sean, ?Thank you again for providing the list of missing Bridgeport works with their most recent MLC statuses. ?I compared your sheet against four other sheets previously submitted to the MLC: ?Original LOD A 12 22 21?—?this was the schedule of works sent by Dan Hegarty to [email protected] on December 22, 2021 (over three years ago). On December 23, 2021, Jessica Dorow confirmed receipt, saying “I have sent this to our Rights Management team for processing. I will let you know when this is complete.” ?Bridgeport Conflicts 4 17 23?—?this was a list of conflicts in the MLC which I emailed to Sean on April 17, 2023, subject line “Word Collections Compositions in Conflict Requiring MLC Attention Bridgeport” ?Still Missing June 15 23 Resubmission?—?this is a list of works that met the following criteria A. We had previously submitted these works to the MLC on or before May 2023 B. We could not locate these works in our MLC catalog exports C. We resubmitted these works via the bulk submission tool on June 15, 2023 D. We confirmed on August 22, 2023 that these works still did not appear in our catalog exports. E. I emailed Sean on September 6, 2023 with the list of missing works (subject: Analysis of works resubmitted to MLC on June 15 23) ?Works not in MLC as of 10 5 23 (email subject: Analysis of works submitted to The MLC Between June 15 23 and July 31 23). This is a list of works that met the following criteria: A. We submitted (or resubmitted) these works to the MLC via the bulk tool between June 15, 2023 and July 31, 2023 B. We could not locate these works in our MLC catalog exports as of October 5, 2023. C. The sheet was organized by publisher. ?Please see the attached spreadsheet which compares your Bridgeport Music?—?Analysis and Codes in Overclaim sheet against the four sheets listed above. I’d like the highlight the following: ?—?17 works show as “unregistered” despite being included in the initial LOD A sent to the MLC on December 22, 2021, being resubmitted via the bulk tool on June 15, 2023, and via Word Collections emailing the MLC on multiple occasions asking for an update. ?—?2 works show as “unregistered” despite being submitted via the bulk tool between June 15, 2023 and July 31 2023, with an email from Word Collections to the MLC asking for a status update on October 5, 2023. ?—?126 works show as “OVERCLAIMS”. These overclaimed compositions were all: A. Submitted as part of the initial catalog registration email sent by Dan H on December 22, 2021. B. Resubmitted via the bulk tool on June 15, 2023 / included in a followup email on September 6, 2023. C. Included in another followup email on October 5, 2023. ?Despite submitting and resubmitting these works in multiple ways over three years, we were not notified of conflicting ownership claims until Sean’s email on February 9, 2024. ?—?2 of these “OVERCLAIMS” also appeared in the list of of MLC conflicts which I emailed to Sean on April 17, 2023, subject line “Word Collections Compositions in Conflict Requiring MLC Attention Bridgeport”. These works are “THAT NEW FUNKADELIC” and “SONG IS FAMILIAR”. ?With this analysis in mind, could you please let me know the following: ?1. For the unregistered works, why were multiple submissions of these works not accepted? Are they in the process of being ingested now or do we need to submit again? What assurances do we have that these works will be accepted now after multiple submissions were disregarded? Have any other parties been receiving payments on these works? ?2. Why was Word Collections not previously notified of the 126 conflicting ownership claims? ?3. Are these 126 overclaimed works currently in the MLC conflict process? If so, when was the conflict process initiated? If they were previously in the conflict process, what were the dates of these conflicts? ?4. Have the other publishers listed on these works been receiving payment since the initial Word Collections notification on December 22, 2021? ?5. For any instances in which royalties have been paid to the incorrect publisher/administrator, what will the MLC do to ensure Word Collections and its songwriters are paid for this past earned revenue? ?If you have any questions or need any other information, please let me know. I appreciate your looking into this as soon as possible. ?Best,

Jake Smith Director, Strategic Projects WordCollections.com

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?On Feb 12, 2024, at 10:41 AM, Jake Smith wrote: ?Hi Sean, ?I would like to immediately start the conflict process (not the informal outreach) for all “OVERCLAIMS” if it has not been started already. Please let me know when this is complete. ?I am going through the list now and will respond shortly with comments and questions. ?Best,

Jake Smith Director, Strategic Projects WordCollections.com

—?—?—?—?—?—?—?—?—?—?—?—? ?On Feb 9, 2024, at 5:16 PM, Sean McNamara wrote: ?Hi Jake - ?As discussed during our weekly call, please see the attached spreadsheet where I have detailed my review of the Bridgeport Music works that you’ve brought to my attention. I have separated the Bridgeport Music works into 3 categories: ?? Word Collections’ claims to works that I discovered have already been registered with The MLC in the name of Word Collections (highlighted in green), ? Word Collections’ claims to works that not yet been registered with The MLC by Word Collections (highlighted in orange), and ? Works that are registered with The MLC by other members that are unavailable for Word Collections to register a claim and will have to proceed through a conflict procedure pursuant to The MLC Ownership Dispute Policy found here (highlighted in red). ?Next steps: ?1. Please submit the Bridgeport Music works that have not yet been registered with The MLC via CWR at your earliest convenience.? 2. For those Bridgeport Music works that require a conflict procedure, please provide us with documentation in support of Word Collections’ claims pursuant to the conflict procedure outlined in The MLC Ownership Dispute Policy. As mentioned during our call yesterday afternoon, I would like to begin a bulk outreach to all claimants with existing claims to these works. ?Please let me know if you have any questions. ?Best, ?<Outlook-zy5zrmad.png> SEAN MCNAMARA (he/him/his) Manager, Publisher Services 333 11th Avenue South | Suite 200 Nashville, TN 37203

—?—?—?—?—?—?—?—?—?—?—?—? ?From: Jake Smith? Sent: Friday, February 9, 2024 1:54 PM To: Sean McNamara? Cc: Maurice Russell?; Jeff Price?; Melanie Santa Rosa Subject: Re: Bridgeport Works Review

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?Hey Sean, ?Just checking on the Bridgeport list since you indicated it would be completed by today. Thanks!

Jake Smith Director, Strategic Projects WordCollections.com

—?—?—?—?—?—?—?—?—?—?—?—? ?On Feb 6, 2024, at 3:13 PM, Jake Smith wrote: ?Hi Sean, ?Checking in on the status of the Bridgeport return from the MLC showing the status of the various works we submitted. Thanks!

Jake Smith Director, Strategic Projects WordCollections.com

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?On Jan 29, 2024, at 10:49 AM, Sean McNamara The MLC wrote: ?Hey Jake?—? ?I greatly appreciate your providing me with this amended list! It’s very helpful, and I’ll be back in touch with you shortly on this. ?Thanks again, and happy Monday.? ?<Outlook-5ngsza4y.png> SEAN MCNAMARA (he/him/his) Manager, Publisher Services 333 11th Avenue South | Suite 200 Nashville, TN 37203

—?—?—?—?—?—?—?—?—?—?—?—? ?From: Jake Smith? Sent: Thursday, January 25, 2024 3:27 PM To: Sean McNamara? Cc: Maurice Russell; Jeff Price; Melanie Santa Rosa? Subject: Re: Bridgeport Works Review

?EXTERNAL EMAIL: This email originated from outside of MLC’s email system. DO NOT click links or open attachments unless you recognize the sender and know the content is safe. ?Hi Sean, ?Per our call, please see the amended list of Bridgeport works that I could not locate in the Word Collections account. ?Hopeful that this will expedite the return of the Bridgeport missing works analysis so we can move forward with correcting any issues/conflicts.

Jake Smith Director, Strategic Projects WordCollections.com

—?—?—?—?—?—?—?—?—?—?—?—? ?On Jan 2, 2024, at 2:49 PM, Jake Smith wrote: ?Hi Sean, ?I hope you had a nice holiday! ?I’m checking on the status of the Bridgeport works review you had been working on to see if you knew when we should expect to receive that (this was your analysis showing the status of various Bridgeport works submitted by Word Collections that we could not find in the Word Collections account). ?If the file is not complete could you send over whatever has been completed so far so we can start working on rectifying those issues?

Jake Smith Director, Strategic Projects WordCollections.com

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?<Bridgeport Music?—?Analysis and Codes in Overclaim.xlsx>