For Puff Daddy to sample from the phonorecord of The Police’s music, he must get both a mechanical license from the copyright holder of the underlying musical work, and a license from the copyright holder of the phonorecord from which he copies the sample. He is free to hire musicians to reproduce the Police's sound, but he cannot copy from any phonorecord with only a mechanical license. A mechanical license can only be used after the original copyright holder has exercised their exclusive right of first publishing, or permission is negotiated. In American law, US Code Title 17, Chapter 1, Section 115(a)(2) states: "A compulsory license includes the privilege of making a musical arrangement of the work to the extent necessary to conform it to the style or manner of interpretation of the performance involved, but the arrangement shall not change the basic melody or fundamental character of the work ..." thus preventing mechanical licenses being used to make substantially derivative works of a piece of music. Musicians often use this license for self-promotion. For instance, a cellist who performed a musical work on a recording may obtain a mechanical license so he can distribute copies of the recording to others as an example of his cello playing. Recording artists also use this when they record cover versions of songs. This is common among artists who don't usually write their own songs. In the United States, this is required by copyright law regardless whether or not the copies are for commercial sale. The musician must serve the copyright owner a Notice of Intent (NOI) to obtain a compulsory license to distribute non-digital mediums of the recording. A mechanical license is not required for artists who record and distribute completely original work. History The idea of mechanical licenses came about the turn of the 19th century, with the popularity of player pianos, with the ability to play songs encoded on a roll of paper. The sheet music industry then believed that the recreation of their songs was violation of copyright, and initiated legal action that resulted in the Supreme Court of the United States case, White-Smith Music Publishing Co. v. Apollo Co. (209 U.S. 1) in 1908. The Supreme Court ruled that the piano rolls were not copies of the plaintiff's music, but instead part of the machine that created music, and thus player piano and piano roll makers did not