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Decision of the Court of Justice of the EU Broadcasting a musical work as background music in a means of passenger transport is a presentation to the public within the meaning of EU law

In this case, two Romanian collective management organizations handling copyright and related rights over musical works brought actions against the air transport company Blue Air Aviation and the CFR, a Romanian rail transport company, seeking payment of remuneration still due and of penalties for the broadcasting, without a license, of musical works on board aircraft and passenger carriages.

The competent court of Bucharest asked the Court of Justice to identify in particular:

  1. a) whether the broadcasting, inside a commercial aircraft occupied by passengers, of a musical work or a fragment of a musical work on take-off, on landing or at any time during a flight, via the aircraft’s public address system, constitutes a communication to the public; and
  2. b) whether a rail carrier which uses train carriages in which sound systems intended for the communication of information to passengers are installed thereby makes a communication to the public.

The Court held that the broadcasting in a means of passenger transport of a musical work as background music constitutes a communication to the public within the meaning of EU law. The mere installation, on board a means of transport, of sound equipment and, where appropriate, of software enabling the broadcasting of background music does not, however, constitute one. Consequently, EU law precludes national legislation which establishes a rebuttable presumption that musical works are communicated to the public because of the presence of sound systems in means of transport.

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