[Meg O’Neill] 0:08
Hello and welcome to the Berkeley Technology Law Journal podcast. My name is Meg O’Neill and I am one of the editors of the podcast.
Today, we are excited to share a conversation between Berkeley Law 2L student Krystle Malixi and Professor Judith Finell. Professor Finell is a musicologist and an adjunct professor at UCLA, where she teaches the only forensic musicology course in the country. She also is the president of Judith Finell Music Services Inc., a music consulting firm in New York and Los Angeles, through which she acts as a consultant and expert witness on music copyright infringement cases. Today, Krystle and Professor Finell will discuss how artificial intelligence impacts music copyright law. We hope you enjoy the podcast!
[Krystle Malixi] 1:08
Hi! I’m Krystle with the BTLJ Podcast Team. Professor Finell, we are so excited to have you join us today.
[Judith Finell] 1:15
Thank you for inviting me. I’m looking forward to it.
[Krystle Malixi] 1:18
Of course! Thank you for coming. Before jumping into the questions, I would love to learn about your music consulting firm and how you ended up working as a forensic musicologist.
[Judith Finell] 1:28
Oh, thank you for asking. Yes, well, my background is as a musicologist, not anything to do with law. There was not even a course named forensic musicology, nor a term like that at the time of my graduate study at Cal, at the musicology department of Cal Berkeley. I arrived in New York with a musicology degree and an interest in being involved somehow in scholarly work in music. And the majority of people with that kind of an educational background go into an academic field or some form of scholarship, and that’s what I expected to do. But shortly thereafter, I was first commissioned to conduct a study and then write a book for the New York State Council on the Arts, involving some areas of contemporary music. And from that, I was asked to begin consulting with many different artists in New York and then more broadly throughout the country. And through that, I started to receive calls over the years. It took many years for me to actually work at all in the legal area, but eventually I received some calls from attorneys who represented plaintiffs or defendants in copyright infringement lawsuits. And they wanted an expert who could analyze music, know music theory, testify about it to a lay jury, a lay person, meaning a non-musical jury, etc. And I had never heard of this, never aspired to do it, but it was very interesting. The first case I was involved in ended up being quite successful on the part of the attorneys who engaged me. But you know, I knew nothing about copyright law and had no background in law. But this developed into a referral after referral, and really over the course of over 25 years, I had to make a decision as to what part of music I wanted to remain in, because legal work continued to grow.
I built a team of six doctoral level musicologists who work for me today in New York, one’s in Europe, and two are in LA. We are asked for opinions on a wide range of music, that intersection of music law and technology. This is often before recordings or films are released, that involve music, to avoid copyright infringement and also often during disputes. And sometimes when legislation is being drafted. So different areas that deal with the intersection of music, law and protection, as well as technological developments that both threaten and enhance the musical universe.
[Krystle Malixi] 4:26
That’s amazing! We are truly honored to have you as our guest for this episode today. In your TED talk and presentation at the Music, Law, and AI Symposium at Eastman School of Music, you talk about this tension between embracing the sheer benefits that generative AI technology can bring to the music composition process, and the need to protect content creators and their rights over their music. What advice do you have for content creators dealing with this tension?
[Judith Finell] 5:51
Yes, well, it is important to distinguish between those two different forms as they have very different audiences and focal points. So the TED talk was actually a live talk that was given in Silicon Valley, not far from where you are. Many in the large audience were, you know, technologists, some attorneys, some medical doctors and all. I met many of them after speaking, and they were interested in the potential of AI in various forms of science, medicine and creativity. I was asked to speak on music creativity and the pluses and minuses, but the idea was the expansion of human potential through AI. And I did focus on that. And there is great potential in terms of how AI can improve access to music, improve in many ways, the dissemination and creation of music in a way that no technology before has done. At Eastman, the discussion was different, perhaps because it is one of the most renowned music conservatories in the United States. The audience varied but it was mostly people who were going into professional musical careers as either composers or musical performers, for example, so their concerns were very different. The challenges are on both sides of the equation, in terms of, yes, AI or any form of technology that can enhance the creative process, but also the ways in which it threatens creative content. The training mechanism, as you probably know for AI, is built on previous musical or non-musical works, depending on the art form. And from that, there is a concern in the music industry that copyright infringement is actually taking place in order to train AI.
[Krystle Malixi] 06:54
Thank you, Professor, that was very insightful. From your experience at your music consulting firm and from testifying at trial, have content creators leaned towards viewing AI as a beneficial tool or as a harm to their rights? Have content creators balanced this tension and additionally, have you observed differences in sentiment between budding content creators and more popular, well-established creators?
[Judith Finell] 7:17
That’s a wonderful question. Yes, I actually have seen a distinction, and I don’t know how it is in other art forms, such as literature, photography, and other forms of art that copyright law protects. But, in music, there, in a way, is a distinction in terms of the reaction to the potential threat. So I would say, in established content creators, otherwise known as composers in the music space or performing artists, there’s the concern that their material will be used without either attribution or permission or any form of payment or licensing. Part of that is because there is no present licensing mechanism for the use of another person’s musical recording or creation, even if it’s interfacing with AI. We’ve all heard about many examples of this, including the one involving Drake and The Weeknd, in which a recording was created, which was referred to in the industry as the fake Drake, and it was released online and basically without permission. It was meant to impersonate Drake and The Weeknd in terms of their musical creations and their vocal characteristics. And in fact, their publisher, the largest music publisher, I believe, in the world, if not, at least our country, Universal Music, sent a very stringent reaction to that, and within one day, it was removed from the internet and has basically never been seen or heard again. And that was to send that message that you did this without permission and we’re going to react. This has been the case of the music industry for over a century. Whenever a new technology has come along to enhance the dissemination of music—or the distribution or even the potential for copying music, such as the development of the printing press, which was, of course, developed for the Bible dissemination, but was used for sheet music too (and that was centuries ago), or the development of radio or recordings, or eventually, digital recordings such as CD—all of those new developments created a threat to the protection of music by the original creators. It enabled their music to be heard and received by a bigger audience, but it also enabled their music to be easily copied without permission. Before the age of AI, after much litigation, a licensing system started to exist in the industry involving songs that sampled from another recording, as done, you know, often in various forms of music. I’ve testified in many trials involving this procedure of lifting recordings from one recording and placing at least a short excerpt in another one deliberately. It became most rampant in the development of hip hop, but it has been done throughout the industry. The problem was there was no licensing mechanism for this at first, because the technology developed before the law did, before the law or music industry caught up to it. Litigation ensued, and eventually, an entire licensing mechanism now exists: if you want to use a sample from another recording, you need to obtain permission and a license and pay for it, basically. I think this will probably happen with AI, but the difference with AI is it can create music from the outset––essentially, taking a piece of music that already existed and using it in its final form, even if it’s built on previous music. The idea is to design something new or changed, and that’s where the threat comes in. Younger artists who are embracing technology or don’t have access to money or the ability to license music, say they want to use something from a Drake recording, for example. Well, the technology now is very sophisticated, and it would not be hard for an artist to take something off of another recording without permission and take a risk. So you do have both sides of that equation in terms of the wide spectrum of the standing in the industry, how powerful one is, how much one believes he or she has to protect, as well as innovators and newcomers.
[Krystle Malixi] 12:03
So just to clarify, Professor, you would say that more established creators generally view AI as a harm to their rights, whereas budding creators generally view AI as a tool in their composition process?
[Judith Finell] 12:15
Well, it’s an avenue, I think, to create music without the resources they might have later in their careers. For the younger ones, as far as they do, I’m sure that it’s not a monolith, and not all established creators see it as a threat. I’m sure some of them do see it as a tool, and I do work with some of those, including innovators at the MIT Media Lab and many others. But the concern is just that creators want their works respected. There was this kind of reaction, by the way, when photocopying machines became widely available to the general public and many other forms of technology that made it very, very easy, say, to copy, you know, 50 musical scores and distribute it to your high school chorus, which has a small budget, and you can’t go out and buy 50 pieces of sheet music for your singers. It’s tempting for a teacher to get one copy and photocopy the rest for free, and this was the worry in the industry. So there has to be some sort of recognition that the creators need to be compensated for their work.
[Krystle Malixi] 13:28
That’s very interesting, thank you, Professor. Apart from content creators, what role can lawyers and policy makers have in balancing this tension? What advice do you have for these lawyers or policy makers?
[Judith Finell] 13:42
Well, in terms of the music law intersection, I can give some advice in that area, and I would just say that there’s a role for lawyers as representatives of artists on both sides of this argument, as I say, if there is ever litigation. But I think another role for attorneys is to guide their artists and the innovators who are using technology to avoid litigation by doing what they can to obtain permission and showing some kind of acknowledgement. But the problem here is in terms of the huge technology industries that are racing to the finish line with AI development. The United States Copyright Office does not recognize machine-made content. Now you’ve got—in music, you have something, you know, where you could say that you collaborated as an artist. You wrote the vocal lines and sang them, and AI did all the drum tracks, or the guitar, piano parts or whatever. And so it’s a collaboration. But right now, the only part that you would be sure that you could have a copyright on was the part that the human wrote. So this is a challenge. And part of the reason why this is a problem is that, if innovators want to use the technology and make it grow, there’s an incentive to, let’s say, disguise the source or fight hard to get regulations to cover machine created artistic works. And I think there will be a very, very strong reluctance and reaction on the part of a large percentage of at least the music industry if that goes forward.
[Krystle Malixi] 15:27
Thank you, Professor, that was very insightful. So as an expert witness, you have testified in numerous copyright infringement trials, such as the “Blurred Lines” case.1 Could you speak about some of these cases that you believe gave more clarity and instruction on how to deal with this tension between utilizing technology as an aid in composing versus protecting creators from its potential harm?
[Judith Finell] 15:49
Well, that’s a great question. Of course, the “Blurred Lines” case had nothing to do with the technology. It was what you might think of as a lawsuit, as a classic copyright infringement music lawsuit involving substantial similarity of two music compositions. I’m not saying technology didn’t exist in the recording studio, but that wasn’t the issue. The issue was whether or not the composition of Marvin Gaye was copied, or at least closely imitated by the composition of Pharrell Williams and Robin Thicke. And the jury decided—and so did two appeals attempts, resoundingly—that yes, they had copied it, and I was honored to be on the Marvin Gaye estate site as their testifying musicologist. But I would say this in terms of what, that was the farthest any music copyright case has gone so far to protecting the original creators of a work, and it did send shudders—or shuddering, you might think—through the music industry. Because this meant that the other side of the equation, meaning the defendants in this case, and those who might become future defendants, were concerned that they would be the subject of future lawsuits because the jury gave such a high financial award to Marvin Gaye’s side, and it was verified by two other courts. It was not brought down. And there was a lot of mythology about it, as if it’s, you know, supposedly, just to do with two songs of the same vibe, etc. That wasn’t at all the case, especially since the recording by Marvin Gaye was not permitted in the courtroom. So it was really about two musical compositions that had several specific musical compositional elements in common to a large degree. But why is that going to impact it? Well, it has impacted subsequent, well-known cases too, like the Led Zeppelin case and others, where the judges have referred to the “Blurred Lines” precedent and then reactively further cases such as the Katy Perry case reversal and all again, trying to pull it back from that what they see as an extreme position of the “Blurred Lines” case. And it has also led to the abolishment of the inverse ratio rule, which you might be familiar with in at least the California courts, as opposed to the Tennessee courts, which still support the inverse ratio rule and also the concept of extrinsic and intrinsic musical opinions. Technology before this though, was challenged, for example, not only when digital recordings were invented, but eventually when digital sampling was invented. The reason why that liberated and democratized music creation for people who perhaps had fewer resources and no connections yet in the music industry was because the way hip hop developed was by young teenagers, mostly in the Bronx in New York to start with, who were able, through the use of compact discs and other technology, to lift, deliberately, lift sections of previous, older recordings and place them into their new recording, and then wrap over them, etc, etc, as you probably know, and that goes back almost 50 years. This was done without permission, and before hip hop made any money, the music industry ignored it, until it started to make money. And as I’m sure you know of the Grand Upright case2 that changed everything in terms of sampling. I did testify in a lot of these key cases. But again, when technology comes along, it both improves access, often for people who don’t have a manager, who don’t own or have access to a sophisticated recording apparatus and studio. But it also tends to take the creations of others who do have those resources, and it always starts, it seems to start with violating the copyright law, but it doesn’t end there, and that happened with ringtones. For example, when people were using ringtones, they were designing their own ringtones from the hook of their favorite song. They could lift it and they could pay for it for $4 or $5 and they buy themselves a ringtone of their favorite Lady Gaga song or Beyonce or whatever song they like. But the catch was that the only individual entities who were gaining financially from that were the record labels. They weren’t willing to share it with the music publishers who owned half that copyright. Because, as you know, music has two copyrights, recordings and compositions, meaning the C in the circle and the P in the circle. I was asked to testify on behalf of the National Music Publishers organization against the Recording Industry Association on the ringtones in front of the Copyright Royalty Board because the position of the record industry was, well we already paid for the use of that for our master full recording, and the ringtone is just a slight excerpt from our recording. Why do we have to share the money with the music publishers from whom we obtain this right? Music publishers did not agree with that, and again, it was litigated, and it was decided that they deserved a portion of the earnings. So the courts are very important, and then it gets sort of built into the laws, the protection of the instruments that protect musical creations.
[Krystle Malixi] 21:36
Thank you for going through those cases, Professor. In light of that tension that those cases bring up, I’d like to ask your thoughts on a couple recent AI laws. The California legislature passed the AI Transparency Act this past September. The act imposes requirements around AI detection tools and disclosure of AI-generated content, covering providers with a generative AI system that is both publicly accessible in California and receives over a million monthly visitors. The Act provides a civil penalty of $5,000 per violation. Do you think the requirements of this Act are too stringent or do they allow enough breathing room for users to generate musical content?
[Judith Finell] 22:15
Well, if you’re talking about creators, corporations that, you know, that have those kinds of assets or more, I would say that it isn’t too stringent, because frankly, it seems like this is what they’ve done from the invention of piano rolls to the present. All of these have had litigation or, you know, wax cylinders for music. That’s sort of how it was played before their recording technology, or listening technology, such as gramophones, as they were called at the time. And so they created something called the compulsory license rule, and if you did not get a license, you were required to create your musical work based on an earlier work. Basically, there was $150,000 per violation, and that’s still in place today. And because of the reach of technology and the internet, the power of the internet and other forms of virtual connection is so big that you can reach so many listeners and so many users so quickly and by such a huge number, it seems that $5,000 is not out of proportion. This will definitely make it be taken seriously, because eventually, I would think that these companies would, to some degree, charge that back to some user, you know. Eventually, it would have an impact on their pricing or their behavior.
[Krystle Malixi] 23:43
Thank you for the insight. So California plays a prominent role on the music and entertainment global stage. What impacts do you foresee the California AI Transparency Act having on these industries in California?
[Judith Finell] 23:56
Well, of course, the tech companies are on both sides of the equation. They create the platform. They create the technology. In many cases, they also receive income from the use of that technology, you know, whether it’s through creative works or streaming or many different ways. But in other words, they’re both the recipients of the earnings of the technology and the content that the technology wants or creates, but they’re also the creator of the tools, so they benefit on both sides, in a way I would think, and are motivated to work things out eventually. There may be, you know, monopolistic investigations into the fact that they control so much of the industry, but I don’t know. I would just say for now, it needs to be taken seriously on a lot of levels. It’s not only threatening or enhancing creativity, but there are some other, you know, safety and attribution and other elements of intellectual property that would have to be considered as well.
[Krystle Malixi] 25:03
And apart from California, another music capital in the United States is Tennessee. Tennessee signed into law in March of this year, the Ensuring Likeness Voice and Image Security Act. Otherwise known as the ELVIS Act, the Act provides protection against the unauthorized use of artists’ voices in AI. Do you believe these protections are adequate or overprotective to the point of impeding the potential of AI technology to aid music creation?
[Judith Finell] 25:29
No, I think they are needed. I actually do speak about the ELVIS Act in some of my presentations. They are needed. They are not the same as protecting copyrights. These are protecting some of the related rights, such as likeness, you know, the right of publicity, as it was called in the Bette Midler case3 many years ago, when her own voice was impersonated pre-AI. But the concept would be that, you know, you can use someone’s voice or imitate them and do an impersonation if you obtain a form of permission to do so. And in fact, it’s also a big source of income for creators. And big Hollywood agencies, for example, have created all kinds of what they call, I mean, in one case, in CAA4, I think it’s called the “Vault,” where they are basically creating a huge library of, you know, speaking voices and others with AI. So those can be licensed long after an artist either retires or passes away, and the studios, including Disney, have signed deals, for example, with James Earl Jones for the Mandalorian series. And very recently, unfortunately, he passed away, but they have the right to reproduce or, in essence, sort of imply his voice. The same would be true of a visual image. But the idea is not to have the music, in the case of music, be used without any form of control on the part of the original creator, which isn’t an inalienable right for music creators. It’s not something that even ends at the end of their life, whereas other things, such as copyrights, are over a certain term, you know. Eventually, they go into the public domain, but say, implying that this is The Beatles recording when it isn’t, as opposed to getting permission and then using AI to complete an unfinished Beatles’ recording or a duet between a deceased artist and a living artist. There are many wonderful, interesting uses of AI and other forms of technology, but there has to be some recognition of the rights of the artist or creator who’s being brought into it.
[Krystle Malixi] 27:46
That’s very interesting. Thank you, Professor. Moving on to the NO FAKES Act, standing for the Nourish Originals, Foster Art, and Keep Entertainment Safe Act of 2024, this act was introduced to the Senate this past July. The NO FAKES Act protects against unauthorized digital replicas in audiovisual works, recordings, and images. Do you think a federal statute like the NO FAKES Act would be better positioned to address AI music technology than state-specific legislation?
[Judith Finell] 28:15
Yes, I do, actually, because it’ll vary. I think the states are, there’s too much internal pressure to have something uniform, and music, like most art forms, is now, you know, it just has no boundaries worldwide, in fact. But I think it’s more practical, since music, for example, under copyright which is a federal law, you know, is protected by the Constitution of the United States. So this is sort of, I think, in line with that. I think it’s better. I mean, some regional laws could apply to specific circumstances. But I think something like this is a way of protecting people. I mean, of course, it’s been used for politics and all well outside of music: for example, in vocal impersonation or when implying that a particular athlete or a particular artist or a particular actor is endorsing a product or endorsing a political philosophy without that person’s permission. There have been many, many lawsuits, especially during the election, about uses of artists’ songs or the message on their songs or their image. And Taylor Swift brought a circumstance like that legally in terms of Donald Trump’s mention of her. And so you have a lot of artists, and this goes right back to the fake Drake,Weeknd lawsuit too. I think.
[Krystle Malixi] 29:36
Thank you, Professor. Moving away from Acts, I would love to hear your opinion on the music copyright lawsuits various record companies have brought against Suno and Udio (AI music generators). In response to these allegations, both companies argued “fair use” and that these lawsuits restrain competition.5 Given your extensive experience as a consultant and expert witness in music copyright, how do you foresee these cases playing out?
[Judith Finell] 29:59
Well, I think that “fair use” is very big right now, certainly since the Supreme Court’s Warhol decision.6 The last “fair use” case involving music anyway, was over 20 years ago, with the Pretty Woman case7 in terms of it reaching the Supreme Court. And that had to do with the parody of a song of the famous Ray Orbison song, Pretty Woman, which is also the theme song of the famous Julia Roberts movie. Richard Gere and Julia Roberts, I believe, were two “Live Crew” who wanted to do what they considered a parody of the work. They were not given permission to do so, but they did it anyway, on the grounds that a parody does, in a way, critique another work, and by changing the words to “hairy woman” and other terms that the Orbison estate felt were vulgar. In fact, it was a form of parody, and that was one of the first times that I know of in music, at least, where those four factors of “fair use” came in. And this was one of the possible exceptions. That allowed for the finding of “fair use.” And after Warhol, which mostly focused on really the commercial circumstance and whether or not the shared use of the photograph in similar media at all were [“fair use,”] it skirted the main factors of “fair use” that need deciding and still need deciding. But I would say that “fair use” is used, maybe more broadly than is applicable, but there’s two sides to that, and “fair use” is important to allow the public enough access to commentary and for other forms of free speech. I would give you a good example of music where maybe an artist could easily claim “fair use”, but chooses not to and that’s weird. Al Yankovic, the famous, you know, satirist or parodist, depending on how you describe him, who takes famous songs and reworks them for humor. And he licenses almost all of the songs he uses. Now, maybe he could get away with “fair use,” but his choice was not to do that. And of course, he’s made an entire career out of building music based on other music, and has been very successful. So I’d say it’s really a matter of degree and when it goes too far. Claiming something’s “fair use” when in fact, it isn’t really fair. The idea of “fair use” is that it is used fairly, being fair to all parties, and it doesn’t mean it’s a free for all. So it’s really a matter of interpreting that concept in a reasonable and meaningful way, in my opinion.
[Krystle Malixi] 32:46
Thank you for your opinion on that, Professor. Lastly, you have a blog post on your firm’s website about the ranking of elements you consider when evaluating substantial similarity in music. Some of these elements are the melody through pitch and rhythm, harmony, and metric placement. As a musicologist, could you speak more about how AI might create substantial similarities in music?
[Judith Finell] 33:10
That’s a great question. And I’m sure that we’ll be seeing litigation in the next two to five years, lots of it, most likely, if history is here again today with technology. So what I would say is that, first of all, music elements—and the way in which music is structured—are so mathematical in their outward presentation that they become easier candidates for AI to learn from. Some other art forms would be harder to imitate and then compose something new. You could certainly copy a photograph, but how far can you get away from that? Well, there are possibilities, but the patterns in music are all measurable externally. It doesn’t mean that the inner expression and the personal love story or personal pain, emotional pain of an artist is measurable. But, everything else in the music, all the attributes, the speed, the volume, the length, the number of beats per minute, the range from the lowest to the highest of any instrument, the timbre of instruments, the sound quality of the vocalist and all. Even where they’re singing from in their body, are they singing from their, you know, chest? This is all evaluable through a scientific and mathematical analysis, and from that, AI can learn and recognize those patterns. So that, if you fed enough, say, Beatles’ songs into it, it could reasonably compose a Beatles’ song with certain lyrics and using some of the unusual modes, for example, that the Beatles use that are different from any music in that genre that came before them in some ways and became ground breakers. So if it wanted to, it could learn all those. Could it be as good a composer as John Lennon? Well, not yet, but one of these days, it might be able to. But I would say that in terms of your question, I think that generation two of AI, meaning when it’s not built on pre-existing music, the next version of AI would most likely train on its own creations. And I’m not a technologist, so I may be inaccurate in that way, but in my observation of other technologies, the first level is more crude. It’s built on pre-existing works, and then as time goes on, it gets better and better at its own deviations from that to the point where you really can’t trace it back to the original source material. But so far right now, we’re still at a point where the source material is part of the development of music, and because of that, the way in which music is quantifiable makes it more of a target than most other forms of music. And those elements need to be created because so far, traditionally, for three centuries now, music was a combination of melodic pitch, rhythm, harmony, which means a combination of multiple pitches at once, for example, and some of the other elements, like structure in terms of different sections of a musical work, or the alternating chorus and verse of a song and the lyrics, and all of those elements are copyright protected when they come together to create a musical composition. So if there were litigations on substantial similarity, which is still where the law is today, regardless of who or what created it, the music is still going to be built on that hierarchy, at least as I see it in my musical training and analysis of those musical elements. It doesn’t mean that there won’t be, you know, analyses of lifting. For example, when I’m asked to opine on musical sampling, I do use that hierarchy in the end, because that is what the courts are looking at in terms of substantial similarity of protectable musical elements from the legal standpoint. But we use something called a “spectrogram analysis” to compare sound waves, and that’s a different kind of analysis, and it is more scientific in that way, and less based on musical training. But, it’s more scientific in comparing the sound waves and the possible derivation of something in one recording compared to an earlier recording for proof.
[Krystle Malixi] 37:44
That’s very interesting. Profesor Finell, thank you so much for speaking with me today! I had a wonderful time listening to your background, your prior case experience, and your thoughts on various statutes, upcoming cases, and the future of AI in music creation. We are all so excited to see the upcoming work you and your firm will do in this field! Thank you.
[Judith Finell] 38:02
Thank you for inviting me and please give my best to Berkeley. I miss it.
[Meg O’Neill] 38:15
You have been listening to the Berkeley Technology Law Journal podcast. This episode was created by Dakshina Hazarika, Krystle Malixi, Xuan Xie, and Joy Fu. The BTLJ podcast is brought to you by Podcast Co-editors Juliette Draper and Meg O’Neill, and Junior Podcast Editors Braxdon Cannon, Joy Fu, Lucy Huang, and Paul Wood. Our Executive Producer is BTLJ Senior Online Content Editor, Linda Chang. BTLJ’s Editor-in-Chiefs are Edlene Miguel and Bani Sapra. If you enjoyed our podcasts, please support us by subscribing and rating us on Apple Podcasts, Spotify, or wherever you listen to your podcasts. Write to us at btljpodcast@gmail.com with questions or suggestions of who we should interview next. This interview was recorded on October 30, 2024. The information presented here does not constitute legal advice. This podcast is intended for academic entertainment purposes only.