have to pay royalties to the sheet music composers. Songwriters lobbied to the United States Congress following the ruling, and succeeded in establishing the nature of mechanical licenses in the Copyright Act of 1909. Since then, the nature of copyright law with respect to mechanical licenses have been continually updated to include new types of phonorecords mediums and recordings. For example, in October 2006 the Register of Copyright ruled that ring tones are subject to compulsory licensing. The Music Modernization Act passed in 2018 implemented processes for digital streaming services to pay for the compulsory mechanical license through a new non-profit organization created by the law, known as the Mechanical Licensing Collective (MLC). The Music Modernization Act changes the process of filing Notices of Intent (NOI) to obtain a compulsory license. Whereas a potential licensee intending to make digital reproductions of the work could previously submit a NOI to the copyright office when the name and/or address of the copyright owner could not be found, under the new law, the Copyright Office no longer accepts notices of intention to obtain a mechanical license for digital phonorecord deliveries of a work. The Office continues to accept notices of intention for non-digital phonorecord deliveries (e.g., for CDs, vinyl records, tapes, and other physical media). See also Copyright Compulsory license Section 115 Reform Act of 2006 Notes Copyright licenses Music licensing