mechanical license to allow anyone to make a mechanical reproduction (known today as a phonorecord) of a musical composition without the consent of the copyright owner provided that the person adhered to the provisions of the license. (Congress intended it to govern piano rolls.) In later practice, compulsory license made it possible to record and distribute a cover version of a hit song – once a recording had been released, and the copyright owner was served with a notice of intention to use – that directly competed with the original. Case law White-Smith Music Publishing Company v. Apollo Company In February 1908, the Supreme Court ruled that manufacturers of pianola music rolls were not required to pay royalties to composers, based on the holding that these music rolls were not copies of musical compositions within the meaning of copyright law because it was not "a written or printed record in intelligible notation." This decision on sheet music was superseded by the Act. F. W. Woolworth Co. v. Contemporary Arts, Inc. In 1952, the Supreme Court held that the Act gave trial judges significant freedom in imposing legal remedies to discourage copyright infringement. Under this ruling, judges could penalize copyright infringers with repaying profits or paying compensation for damages. If damages could not be determined, judges could levy statutory damages instead. Herbert v. Shanley Co. On January 22, 1917, Supreme Court Justice Oliver Holmes upheld the right for copyright owners to compensation for a public performance of a musical composition, even if there was no direct charge for admission. This ruling forced Shanley's Restaurant in New York to pay a fee to songwriter Victor Herbert for playing one of his songs on a player piano during dinner. This decision helped the ASCAP adopt the royalty-payment mechanism known as a "blanket license", which is still used today. Under a blanket license, signatory businesses such as restaurants have the right to play any composition of an ASCAP artist for an annual fee. Notable amendments The Townsend Amendment of 1912 This amendment resulted in motion pictures being specifically added to the category of protected works. Prior to this amendment, United States copyright law did not protect nor register motion picture films. Instead, most motion picture filmmakers would register their work as a collection of still photographs. The Act of March 28, 1914 This amendment amended section 12 of the Copyright Act of 1909, allowing