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