Hot Labor Summer Meets Hollywood
The summer of 2023 was appropriately labeled by labor experts and advocates as the “Summer of Strikes,”1[1]Tim Ryan, Labor Sees Potential for Gains in ‘Summer of Strikes’, LAW 360 EMPLOYMENT AUTHORITY (Sept. 1, 2023, 6:45 PM), https://www.law360.com/employment-authority/articles/1717462. as well as “Hot Labor Summer.”2[2]Tyler Foggatt & E. Tammy Kim, The Historic Battles of ‘Hot Labor Summer’, THE NEW YORKER (July 27, 2023), https://www.newyorker.com/podcast/political-scene/the-historic-battles-of-hot-labor-summer. Unions across America, including the International Brotherhood of Teamsters, which represents United Parcel Service (UPS) workers3[3] Tim Ryan, Teamsters Members Ratify UPS Contract, Averting Strike, LAW360 (Aug. 22, 2023, 4:30 PM), https://www.law360.com/articles/1713880/teamsters-members-ratify-ups-contract-averting-strike. , United Auto Workers (UAW)4[4]Linda Chiem, Auto Cos. Warn of Supply Chain Woes as UAW Strike Grows, LAW360 (Sept. 29, 2023, 7:06 AM), https://www.law360.com/articles/1727068/auto-cos-warn-of-supply-chain-woes-as-uaw-strike-grows. , the Writers Guild of America (WGA), and the Screen Actors Guild–American Federation of Television and Radio Artists (SAG-AFTRA), rejected the contract proposals of their respective employers, and either threatened to or entered strikes.5[5]Helen Li, Hot Labor Summer, by the Numbers, L. A. TIMES (Sept. 1, 2023, 6:30 AM), https://www.latimes.com/california/newsletter/2023-09-01/hot-labor-summer-by-the-numbers-essential-california.
Most notably, the WGA and SAG-AFTRA strikes constituted the “two unions’ first joint walkout against the studios since 1960.”6[6]Megan McCluskey, What Happened When SAG and the WGA Went on Strike in 1960, TIME (July 14, 2023, 4:10 PM), https://time.com/6294777/sag-wga-strike-1960/. The tentative new WGA deal has been described as a “triumph.”7[7]Dani Anguiano & Lois Beckett, How Hollywood writers triumphed over AI – and why it matters, THE GUARDIAN (Oct. 1, 2023, 7:00 AM), https://www.theguardian.com/culture/2023/oct/01/hollywood-writers-strike-artificial-intelligence. The writers’ major wins included guaranteed protections and transparency regarding artificial intelligence (AI)8[8]Id. and increased residuals from streaming studios such as Netflix, Hulu, and Apple TV.9[9]Rick Porter, How the Writers Guild’s New Streaming Residual Will Work, THE HOLLYWOOD REPORTER (Sept. 27, 2023, 3:25 PM), https://www.hollywoodreporter.com/business/business-news/how-wga-streaming-residual-will-work-1235602660/. Many writers went on to claim that the deal has likely saved the profession’s future viability.10[10]Christy Hoffman, How the Hollywood Writer’s Strike Will Impact the Wider World of Work, FAST COMPANY (Oct. 3, 2023), https://www.fastcompany.com/90961199/how-the-hollywood-writers-strike-will-impact-the-wider-world-of-work. The tentative new SAG-AFTRA deal includes “a contract valued at over one billion dollars in new wages and benefit plan funding,”11[11]Id. “‘above-pattern’ minimum wage compensation increases, unprecedented provisions for consent and compensation that will protect members from the threat of AI”12[12]Id. , and a first-time establishment of “a streaming participation bonus.”13[13]Id.
The “Hot Labor Summer” has increased the public’s awareness of and appreciation for collective action. Considering the recent volatility in some industries, as well as some recent successes, this article examines whether recording artists who, like the members of the WGA and SAG-AFTRA, are concerned about pay equity from streaming services, should collectively bargain to achieve industry-wide benefits.
Music Industry and Labor Organizing
Under the National Labor Relations Act (NLRA), employees have the right to join labor organizations or unions and, through a representative, collectively bargain and engage in other concerted activities or other mutual aid or protection.14[14]29 U.S.C.A. § 157. Collective bargaining occurs when there are “[n]egotiations between an employer and the representatives of organized employees [that] determine the conditions of employment, such as wages, hours, discipline, and fringe benefits.”15[15]Collective Bargaining, BLACK’S LAW DICTIONARY (11th ed. 2019).
Despite “the top 1%”16[16]See Elias Leight, There’s a Musician’s Union. Many Musicians Are Unaware – or Unable to Join, ROLLING STONE (May 6, 2019), https://www.rollingstone.com/music/music-features/theres-a-musicians-union-many-musicians-are-unaware-or-unable-to-join-831574/ (describing how major label vocalists are the recording artists who automatically qualify for SAG-AFTRA membership). of recording artists having SAG-AFTRA membership17[17]SAG-AFTRA, https://www.sagaftra.org/about (last visited Oct. 19, 2023)., many recording artists, who are either unsigned or belong to an independent label18[18]Leight, supra note 16., do not belong to a union. Reasons for recording artists’ lack of union membership include a general lack of awareness19[19]L. Camille Cordova, “Stronger” Together: Kanye Could Have Owned His Masters by Engaging in Collective Bargaining, 22 PEPP. DIS. RES. L.J. 39, 57 (2022); Leight, supra note 16. and many artists’ status as independent contractors.20[20]See, David Arditi, How record contracts musicians and how we can fix it | Opinion, THE TENNESSEAN (Nov. 24, 2020, 6:19PM), https://www.tennessean.com/story/opinion/2020/11/24/kanye-west-right-record-labels-exploit-musicians-how-fix/6062315002/ (discussing how artists are often treated as independent contractors and can be susceptible to being “stuck” when labels decide against distributing an album, leaving the artist unable to sell their album to the public or sell it with another label). Under the NLRA, the term “employee” explicitly does “not include … any individual having the status of an independent contractor,” excluding independent contractors from the right to join unions and collectively bargain.21[21]29 U.S.C.A. § 152 (3). Thus, many recording artists face the major record labels without equal bargaining power and the support of a collective power.22[22]SAG-AFTRA, supra note 17; See e.g., Cordova, supra note 19, at 57; August Brown & Kenan Draughorne, Musicians deal with stingy streamers and AI threats, too. So why aren’t they on strike?, L.A. TIMES (July 26, 2023, 9:10 AM), https://www.latimes.com/entertainment-arts/music/story/2023-07-26/musicians-sag-aftra-strike-wga-actors-writers.
Furthermore, while many recording artists automatically qualify for SAG-AFTRA membership through their label23[23]Cordova, supra note 19, at 57; SAG-AFTRA, https://www.sagaftra.org/production-center/contract/806/getting-started (last visited Oct. 3, 2023)., many artists are unaware of this option. Moreover, while many recording artists could technically join The American Federation of Musicians (AFM), the once powerful union has witnessed a steady membership decline “by over 75% since the 1980s.”24[24]Dick Weissman, The Viability of the American Federation of Musicians in the 21st Century, 28 (MUSIC & ENT. INDUS. EDUC. ASS’N. 2019), https://doi.org/10.25101/19.17. Due anti-trust laws of the 1940s limiting the union’s ability to bargain on behalf of its members25[25]See 29 USC § 158(b).; Robert A. Gorman, The Recording Musician and Union Power: A Case Study of the American Federation of Musicians, 37 SW. L. J. 697, 722 (1983) (discussing how the Taft-Hartley Act of 1947 made secondary boycotts and other AFM tactics illegal)., the industry shift from 15-20 person orchestras to 3-5 member groups increasing the difficulty of identifying and organizing new potential members26[26]Weissman, supra, note 24, at 29., and the increased individualization of the music business27[27]Id., overtime, the AFM has lost relevancy with younger recording artists, and currently represents predominantly professional instrumental musicians in the United States and Canada.28[28]Id. AFM exercised monopoly power between the 1930s and 1950s as a traditional craft union in a less complex entertainment industry, with fewer record labels, radio networks, and concert halls.29[29]Shaun Richman, When Labor Fought Rock-and-Roll, JACOBIN (Apr. 14, 2017), https://jacobin.com/2017/04/music-rock-and-roll-musicians-union-the-beatles. However, the emerging success of rock and roll and the consolidation of the “role of songwriter, producer, and artist”30[30]Leight, supra note 16. threatened the union’s control and undercut its bargaining power.31[31]Richman, supra note 29. Due to a combination of a “hostile reaction to rock-and-roll,”32[32]Id. the inability of many rock musicians to conform to traditional musicians’ standards (e.g., reading sheet music),33[33]Id. and the treatment of rock musicians as employers rather than workers,34[34]Id. the union found itself at odds with America’s newest form of popular music during the 1960s.35[35]Id. The AFM’s inability to adapt to an evolving music and entertainment industry alienated modern day “songwriters, bandleaders, rock stars, and pop icons” and deterred them from collective bargaining — “a loss of power that reverberates down the chain of production.”36[36]Id.
Due to the record labels’ “superior bargaining position,”37[37]Cordova, supra note 19, at 42. the substantial financial investment to generate the artists’ success,38[38]Id. at 43 (estimating in 2020, major record labels “invest[ed] up to $2 million” in new signed performing acts); See also, Martha Rooks, How Much Money Do Record Labels Spend on Marketing? (Nov. 5, 2021), INTERNATIONAL COUNCIL OF SOCIETIES OF INDUSTRIAL DESIGN, https://www.icsid.org/uncategorized/how-much-money-do-record-labels-spend-on-marketing/. (describing how The International Federation of the Phonographic Industry published a 2020 study finding that record labels spend approximately $500,000 to $2 million for an artist to break into a “major music industry”). and the industry standard of ownership of the master recording rights (which earn “a large amount of income … from licensing the copyrights”39[39]Cordova, supra note 19, at 40.), there is no incentive for the label to encourage artists to unionize.40[40]Id. at 58. While there are some lobbies41[41]Music Artists Coalition, https://www.musicartistscoalition.com/#!/who-we-are (last visited Oct. 19, 2023). and individuals represented by unions such as SAG–AFTRA or the AFM,42[42]See Leight, supra note 16 (describing how most AFM members are professional musicians, including members of orchestras and operas). the lack of a universal union for recording artists leaves many artists at the mercy of studio deals, which may contain unfavorable terms,43[43]Omar Anorga, Music Contracts Have Musicians Playing in the Key of Unconscionability, 24 WHITTIER L. REV. 739, 742, 756 (2003). or lack opportunities for artists to become a successful due to the industry’s high costs of entry.44[44]Id. at 756–757. For example, traditionally, recording artists assign the copyrights of their recordings to their record label when signing a deal.45[45]Helienne Lindvall, Why Artists Should Retain Ownership of Their Recordings, THE GUARDIAN (Jan. 29, 2009, 12:17 PM), https://www.theguardian.com/music/musicblog/2009/jan/29/recording-copyright-ownership. While many argue “[r]ecording artists should own the master recording rights to the music they create,”46[46]Cordova, supra note 19, at 40. the labels are not incentivized “to give them up because a large amount of income earned from the music is earned from licensing the copyrights to them.”47[47]Id.
Works for Hire and the Need for Union Support
Recording artists’ and songwriters’ lack of union support perpetuates unequal bargaining positions and power structures which enable record labels to retain substantial monetary benefits from artists’ and songwriters’ work.48[48]Joey La Neve DeFrancesco, Musicians Can and Should Organize to Improve Their Pay and Working Condition, JACOBIN (Feb. 1, 2020), https://jacobin.com/2020/02/musicians-working-conditions-afm-amazon-sxsw-nomusicforice.
For recording artists, “record labels have made an industry practice to include boilerplate language in recording agreements that the works created under the contract are works made for hire…. [T]his was a result of greater negotiation power of the record labels and a mechanism to mitigate financial risk inherent in the music industry.”49[49]Shane P. Nix, Don’t Sing the Tax Man’s Blues, (May 2022) https://www.willkie.com/-/media/files/publications/2022/los_angeles_lawyer_may_2022_shane-nix.pdf. Works created on a work for hire basis enable the commissioning party to own the copyright upon creation.50[50]Id.; See also, 17 U.S.C. § 101. This arrangement removes from recording artists and songwriters statutory copyright termination rights.51[51]Id. More successful songwriters and artists find themselves in a stronger bargaining position to “retain more control over the copyright and retain a larger portion of the royalties.”52[52]Id. When the recording artists and/or songwriters are the author for copyright purposes, they are able to “reclaim ownership of the U.S. copyrights to the master recordings (or copyright to the musical works) … previously assigned to the record company after 35 to 40 years from the date of assignment.”53[53]Id.; See also, Shane Nix, Taxing the Terminator, L.A. LAWYER, May 2020, at 18. The work for hire scheme is just one example of how industry standards can leave newer, more vulnerable artists in weaker bargaining positions, forcing them to either accept deals with reduced or potentially nonexistent compensation in exchange for an uncertain possibility of future success.54[54]Arditi, supra note 20.
In comparison, the existence of a unified WGA has enabled writers, through the union, to protect vulnerable and new members of the industry55[55]Gili Malinsky, ‘I got a check the other day for $8’: TV and film writers share why they’re on strike, CNBC (May 13, 2023, 10:00 AM), https://www.cnbc.com/2023/05/13/why-are-tv-and-film-writers-striking.html. and monitor industry legal trends and practices that may be detrimental to the health of the profession.56[56]David Robb, WGA West Issues “Call to Action” To Curb Media Consolidation: “One Of The Root Causes” Of The Strike, DEADLINE (Aug. 18, 2023, 7:10PM), https://deadline.com/2023/08/writers-strike-media-consolidation-1235523183/ (describing WGA-West’s push against media consolidation by “urging members to file public comments with the Federal Trade Commission and the Department of Justice in support of proposed revisions to their Merger Guidelines – a policy document designed to guide law enforcement around consolidation”). Over the summer, the WGA and SAG-AFTRA pushed state lawmakers to give striking workers the right to receive unemployment benefits.57[57]Gene Maddaus, WGA and SAG-AFTRA Push for Unemployment Benefits for Striking Workers, VARIETY (Sept. 7, 2023, 4:31 PM), https://variety.com/2023/film/news/wga-sag-aftra-unemployment-benefits-striking-workers-1235716984/. Though California Governor Gavin Newsome vetoed the bill,58[58]Shawn Hubler, Newsom Vetoes Bill Allowing Workers to Collect Unemployment Pay While Striking, THE N.Y. TIMES (Sept. 30, 2023, updated Oct. 2, 2023), https://www.nytimes.com/2023/09/30/us/newsom-veto-unemployment-pay-strikes.html?smid=url-share. the bill’s introduction and passage in both California Houses speaks to the current political power of labor unions.59[59]Lisa Anna Walter (@LisaAnnWalter), TWITTER (Oct. 1, 2023, 12:27 AM), https://twitter.com/LisaAnnWalter/status/1708337889275523421?s=20. During the 2007-2008 Writers’ strike, “DVD sales and video on demand were quickly replacing rerun syndication as the places where the real money was made.”60[60]Alan Sepinwall, How the 2007-08 Writers’ Strike Changed ‘The Office’ and ‘Breaking Bad’, ROLLING STONE (May 3, 2023), https://www.rollingstone.com/tv-movies/tv-movie-features/writers-strike-2007-2008-wga-change-tv-breaking-bad-the-office-friday-night-lights-1234727839/. The WGA and the studios “hammered out an agreement that doubled residual payments”61[61]Meg James, Tensions from the last Writer’s Strike Cast a Shadow over Current Labor Fight, L.A. TIMES (Apr. 10, 2023), https://www.latimes.com/entertainment-arts/business/story/2023-04-10/la-et-ct-2007-hollywood-writers-strike-lessons. for online film and TV shows while securing the union’s jurisdiction over internet shows – helping to demonstrate the union’s continuous commitment to representing the contemporary interests of the profession.62[62]Id.
Similar protections for the music profession could exist, were there a collective bargaining unit empowered to represent current and future members of the industry’s interests.63[63]DeFrancesco, supra note 48.
Conclusion
For recording artists and songwriters to achieve collective gains, it currently requires high profile artists to make grand gestures, which hopefully have a trickle-down effect to everyday musicians. For example, Taylor Swift threatening to pull her music from Apple Music to force them to pay artists’ royalties during free trials.64[64]Ryan Faughnder, Taylor Swift: ‘I’ve decided to put 1989 on Apple Music … and happily so’, L.A. TIMES (June 25, 2015, 9:31 AM), https://www.latimes.com/entertainment/envelope/cotown/la-et-ct-taylor-swift-i-ve-decided-to-put-1989-on-apple-music-20150625-story.html. However, like most industries across the American workforce, the most effective means of achieving collective gains come from asserting continuous pressure on employers through labor unions.65[65]DeFrancesco, supra note 48. So long as recording artists and songwriters’ either have disjointed representation through partial SAG-AFTRA or AFM membership, or potentially no representation at all, musicians will continue to suffer from unequal deals and an inability to negotiate on a level playing field.
Written by: Anike Tella-Martins
Anike is a 2L at Brooklyn Law School.
1 Tim Ryan, Labor Sees Potential for Gains in ‘Summer of Strikes’, Law 360 Employment Authority (Sept. 1, 2023, 6:45 PM), https://www.law360.com/employment-authority/articles/1717462.
2 Tyler Foggatt & E. Tammy Kim, The Historic Battles of ‘Hot Labor Summer’, The New Yorker (July 27, 2023), https://www.newyorker.com/podcast/political-scene/the-historic-battles-of-hot-labor-summer.
3 Tim Ryan, Teamsters Members Ratify UPS Contract, Averting Strike, Law360 (Aug. 22, 2023, 4:30 PM), https://www.law360.com/articles/1713880/teamsters-members-ratify-ups-contract-averting-strike.
4 Linda Chiem, Auto Cos. Warn of Supply Chain Woes as UAW Strike Grows, Law360 (Sept. 29, 2023, 7:06 AM), https://www.law360.com/articles/1727068/auto-cos-warn-of-supply-chain-woes-as-uaw-strike-grows.
5 Helen Li, Hot Labor Summer, by the Numbers, L. A. Times (Sept. 1, 2023, 6:30 AM), https://www.latimes.com/california/newsletter/2023-09-01/hot-labor-summer-by-the-numbers-essential-california.
6 Megan McCluskey, What Happened When SAG and the WGA Went on Strike in 1960, Time (July 14, 2023, 4:10 PM), https://time.com/6294777/sag-wga-strike-1960/.
7 Dani Anguiano & Lois Beckett, How Hollywood writers triumphed over AI – and why it matters, The Guardian(Oct. 1, 2023, 7:00 AM), https://www.theguardian.com/culture/2023/oct/01/hollywood-writers-strike-artificial-intelligence.
8 Id.
9 Rick Porter, How the Writers Guild’s New Streaming Residual Will Work, The Hollywood Reporter(Sept. 27, 2023, 3:25 PM), https://www.hollywoodreporter.com/business/business-news/how-wga-streaming-residual-will-work-1235602660/.
10 Christy Hoffman, How the Hollywood Writer’s Strike Will Impact the Wider World of Work, Fast Company(Oct. 3, 2023), https://www.fastcompany.com/90961199/how-the-hollywood-writers-strike-will-impact-the-wider-world-of-work.
11 Id.
12 Id.
13 Id.
14 29 U.S.C.A. § 157.
15 Collective Bargaining, Black’s Law Dictionary (11th ed. 2019).
16 See Elias Leight, There’s a Musician’s Union. Many Musicians Are Unaware – or Unable to Join, Rolling Stone (May 6, 2019), https://www.rollingstone.com/music/music-features/theres-a-musicians-union-many-musicians-are-unaware-or-unable-to-join-831574/ (describing how major label vocalists are the recording artists who automatically qualify for SAG-AFTRA membership).
17 SAG-AFTRA, https://www.sagaftra.org/about (last visited Oct. 19, 2023).
18 Leight, supra note 16.
19 L. Camille Cordova, “Stronger” Together: Kanye Could Have Owned His Masters by Engaging in Collective Bargaining, 22 Pepp. Dis. Res. L.J. 39, 57 (2022); Leight, supra note 16.
20 See, David Arditi, How record contracts musicians and how we can fix it | Opinion, The Tennessean (Nov. 24, 2020, 6:19PM), https://www.tennessean.com/story/opinion/2020/11/24/kanye-west-right-record-labels-exploit-musicians-how-fix/6062315002/ (discussing how artists are often treated as independent contractors and can be susceptible to being “stuck” when labels decide against distributing an album, leaving the artist unable to sell their album to the public or sell it with another label).
21 29 U.S.C.A. § 152 (3).
22 SAG-AFTRA, supra note 17; See e.g., Cordova, supra note19, at 57; August Brown & Kenan Draughorne, Musicians deal with stingy streamers and AI threats, too. So why aren’t they on strike?, L.A. Times (July 26, 2023, 9:10 AM), https://www.latimes.com/entertainment-arts/music/story/2023-07-26/musicians-sag-aftra-strike-wga-actors-writers.
23 Cordova, supra note 19, at 57; SAG-AFTRA, https://www.sagaftra.org/production-center/contract/806/getting-started (last visited Oct. 3, 2023).
24 Dick Weissman, The Viability of the American Federation of Musicians in the 21st Century, 28 (Music & Ent. Indus. Educ. Ass’n. 2019), https://doi.org/10.25101/19.17.
25 See 29 USC § 158(b).; Robert A. Gorman, The Recording Musician and Union Power: A Case Study of the American Federation of Musicians, 37 Sw. L. J. 697, 722 (1983)(discussing how the Taft-Hartley Act of 1947 made secondary boycotts and other AFM tactics illegal).
26 Weissman, supra, note 24, at 29.
27 Id.
28 Id.
29 Shaun Richman, When Labor Fought Rock-and-Roll, Jacobin (Apr. 14, 2017), https://jacobin.com/2017/04/music-rock-and-roll-musicians-union-the-beatles.
30 Leight, supra note 16.
31Richman, supra note 29.
32 Id.
33 Id.
34 Id.
35 Id.
36 Id.
37 Cordova, supra note 19, at 42.
38 Id. at 43 (estimating in 2020, major record labels “invest[ed] up to $2 million” in new signed performing acts); See also, Martha Rooks, How Much Money Do Record Labels Spend on Marketing? (Nov. 5, 2021), International Council of Societies of Industrial Design, https://www.icsid.org/uncategorized/how-much-money-do-record-labels-spend-on-marketing/. (describing how The International Federation of the Phonographic Industry published a 2020 study finding that record labels spend approximately $500,000 to $2 million for an artist to break into a “major music industry”).
39 Cordova, supra note 19, at 40.
40 Id. at 58.
41 Music Artists Coalition, https://www.musicartistscoalition.com/#!/who-we-are (last visited Oct. 19, 2023).
42 See Leight, supra note 16 (describing how most AFM members are professional musicians, including members of orchestras and operas).
43 Omar Anorga, Music Contracts Have Musicians Playing in the Key of Unconscionability, 24 Whittier L. Rev. 739, 742, 756 (2003).
44 Id. at 756–757.
45 Helienne Lindvall, Why Artists Should Retain Ownership of Their Recordings, The Guardian (Jan. 29, 2009, 12:17 PM), https://www.theguardian.com/music/musicblog/2009/jan/29/recording-copyright-ownership.
46 Cordova, supra note 19, at 40.
47Id.
48 Joey La Neve DeFrancesco, Musicians Can and Should Organize to Improve Their Pay and Working Condition, Jacobin (Feb. 1, 2020), https://jacobin.com/2020/02/musicians-working-conditions-afm-amazon-sxsw-nomusicforice.
49 Shane P. Nix, Don’t Sing the Tax Man’s Blues, (May 2022) https://www.willkie.com/-/media/files/publications/2022/los_angeles_lawyer_may_2022_shane-nix.pdf.
50 Id.; See also, 17 U.S.C. § 101.
51 Id.
52 Id.
53 Id.; See also, Shane Nix, Taxing the Terminator, L.A. Lawyer, May 2020, at 18.
54 Arditi, supra note 20.
55 Gili Malinsky, ‘I got a check the other day for $8’: TV and film writers share why they’re on strike, CNBC (May 13, 2023, 10:00 AM), https://www.cnbc.com/2023/05/13/why-are-tv-and-film-writers-striking.html.
56 David Robb, WGA West Issues “Call to Action” To Curb Media Consolidation: “One Of The Root Causes” Of The Strike, Deadline (Aug. 18, 2023, 7:10PM), https://deadline.com/2023/08/writers-strike-media-consolidation-1235523183/ (describing WGA-West’s push against media consolidation by “urging members to file public comments with the Federal Trade Commission and the Department of Justice in support of proposed revisions to their Merger Guidelines – a policy document designed to guide law enforcement around consolidation”).
57 Gene Maddaus, WGA and SAG-AFTRA Push for Unemployment Benefits for Striking Workers, Variety (Sept. 7, 2023, 4:31 PM), https://variety.com/2023/film/news/wga-sag-aftra-unemployment-benefits-striking-workers-1235716984/.
58 Shawn Hubler, Newsom Vetoes Bill Allowing Workers to Collect Unemployment Pay While Striking, The N.Y. Times (Sept. 30, 2023, updated Oct. 2, 2023), https://www.nytimes.com/2023/09/30/us/newsom-veto-unemployment-pay-strikes.html?smid=url-share.
59 Lisa Anna Walter (@LisaAnnWalter), Twitter (Oct. 1, 2023, 12:27 AM), https://twitter.com/LisaAnnWalter/status/1708337889275523421?s=20.
60Alan Sepinwall, How the 2007-08 Writers’ Strike Changed ‘The Office’ and ‘Breaking Bad’, Rolling Stone(May 3, 2023), https://www.rollingstone.com/tv-movies/tv-movie-features/writers-strike-2007-2008-wga-change-tv-breaking-bad-the-office-friday-night-lights-1234727839/.
61 Meg James, Tensions from the last Writer’s Strike Cast a Shadow over Current Labor Fight, L.A. Times (Apr. 10, 2023), https://www.latimes.com/entertainment-arts/business/story/2023-04-10/la-et-ct-2007-hollywood-writers-strike-lessons.
62 Id.
63 DeFrancesco, supra note 48.
64 Ryan Faughnder, Taylor Swift: ‘I’ve decided to put 1989 on Apple Music … and happily so’,L.A. Times (June 25, 2015, 9:31 AM), https://www.latimes.com/entertainment/envelope/cotown/la-et-ct-taylor-swift-i-ve-decided-to-put-1989-on-apple-music-20150625-story.html.
65 DeFrancesco, supra note 48.
