What did the court rule regarding fair use in rock documentaries?

The court ruled that a filmmaker's critical commentary in rock documentaries did not sufficiently transform the underlying songs, thus denying fair use claims and finding copyright infringement.

Which music companies sued the filmmaker for copyright infringement?

ABKCO and Universal Music Group (UMG) sued the filmmaker, alleging infringement of 80 songs featured in his classic rock documentaries.

How does this ruling affect AI and copyright?

The ruling clarifies the limits of 'fair use,' which is a significant issue in ongoing lawsuits where AI developers argue that training models on existing works without licenses is fair use.

Home / Arts and Entertainment / Rock Docs Ruling Clarifies Fair Use Limits

Rock Docs Ruling Clarifies Fair Use Limits

10 Feb

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Summary

Filmmaker liable for infringing 80 songs in rock documentaries.
Judge ruled critical commentary doesn't transform songs.
Decision impacts AI copyright discussions on fair use.

Rock Docs Ruling Clarifies Fair Use Limits

A New York federal judge ruled on February 4, 2026, that filmmaker Robert Carruthers and Coda Publishing infringed upon 80 songs owned by ABKCO and Universal Music Group (UMG). The songs were featured in documentaries about The Rolling Stones, ABBA, U2, Elton John, Lynyrd Skynyrd, and Nirvana. Carruthers contended that his documentaries qualified for "fair use" due to included critical commentary.

However, Judge Katherine Polk Failla determined that simply juxtaposing "hot takes" from critics alongside reproduced videos did not "transform" the songs. This ruling provides critical clarity on "fair use," a concept central to ongoing copyright litigation involving artificial intelligence. Technology developers are currently arguing that AI's transformative nature makes training models on existing works without licenses a fair use.

ABKCO and UMG are actively contesting this AI fair use theory in separate lawsuits. In 2024, UMG and other major labels also sued AI music services for unlicensed training data. The rock documentary case, which began in 2020, saw allegations that music from iconic tracks was infringed. Judge Failla found the infringement to be willful, potentially leading to enhanced damages for the music companies.