While music creators continue to struggle financially, and user privacy rights are exploited by music streaming services, the record labels continue to generate billions of dollars of revenue annually. “Having declined for 14 continuous years from 2001 to 2014, the recorded music industry began to grow again, from US$14.3 billion in the latter year to US$20.2 billion in 2019. This growth was driven entirely by MSS, which brought in US$1.9 billion in 2014, and US$11.4 billion in 2019.” (Hesmondhalgh, 2020, p. 3) After most of the income stream is taken by the Record Label and Interactive, the Songwriter is left with a portion of the compulsory mechanical license fees. “Low per-stream payment rates on MSS were first highlighted in 2009, when it was widely reported that Lady Gaga had earned only $167USD from over a million Spotify streams of her recording ‘Poker face’.” (Hesmondhalgh, 2020, p. 6) “Yet, more often than not, the copyright has been held by the person who made and published the recording, not by the person who created the song.” (Fosler-Lussier, 2020, p. 184) The growth of the music industry from 2001 to 2014 was not by accident, however. Record Labels and Interactives were investing millions of dollars in capital to reinvent the industry to survive in a new digital age. The software that runs music streaming platforms today was a huge investment, as well as a risk. Record labels also still invest millions in new artist promotion and development, as well as legal retainers for copyright protection and licensing. “Protecting a copyright involves significant resources of time and money. As the large record companies have the most at stake, they actively defend their copyrights through lawsuits and other means both in the US and internationally.” (Fosler-Lussier, 2020, p. 185) The end result has again left a profitable business with many today making their living in the music industry. Over the past twenty years the music industry has gone through a chaotic transition guided by over 100-year-old copyright law. As the industry struggled to secure income in a digital age, the first years of interactive music streaming were littered with lawsuits. Musicians were left alone to take on a world that the music industry controlled. The new Music Modernization Act of 2018 has in-fact updated copyright law, more specifically the mechanical license which has eliminated many of these lawsuits. However, it does not address the core issue of the two-part copyright law, leaving the legal loophole that the Record Labels exploit on a daily basis as the standard operating procedure.