Showing posts with label music. Show all posts
Showing posts with label music. Show all posts

Sunday, February 18, 2024

How AI Impacts the Valuation of IP Assets: Betas

Watching NYU Professor Aswath Damodaran's recent video, Catastrophic Risks in Business and Investing, reminded me of a music investors' conference I attended last summer in New York.

At the conference, every panel discussion among music investment experts dedicated a few minutes to the looming elephant in the room - artificial intelligence (AI) - and whether it poses a catastrophic threat to music earnings in the future and, thus, catalog values today.


There is a business tool called SWOT analysis, which identifies a subject's strengths, weaknesses, opportunities and threats. It was as if all of the conference speakers - music investing experts - had reached SWOT consensus on talking points that AI was an "opportunity," not a threat. 

However, beneath this facade of optimism, perhaps there was denial? A psychologically predictable reluctance to confront the existential threat posed by AI to the music industry? None of the speakers delved into the tangible impacts of low-probability catastrophic AI risk on the valuation of music rights interests.

Yet, markets were already adapting based on perceived greater-than-zero risks and opportunities created when AI increases the supply of music at less cost to users than human-made sources (i.e., composers and performers). The largest music companies and some individual artists were already hedging by investing in AI initiatives. Investors were already reassessing portfolio allocations, seeking to invest in AI to balance their portfolios, leaving less cash available for human made music investments. And my firm was already incorporating in valuation projects the music sector's relatively high exposure to AI-related risk in two respects:

  1. Decreased prices (buyers/investors required greater return to compensate for greater relative risk)
  2. Increased costs of equity for firms (since investors demand greater returns) 

As an astute expert on the value of music rights, I recognize the imperative of recalibrating risk premiums to reflect the evolving landscape. Therefore, I can not overlook the imminent specter of AI-induced disruption in the music industry, even if the probability is very low that the market for human-made music might erode catastrophically someday. 

Drawing from the insights I gleaned years ago from Professor Damodaran's teachings at NYU, sector-wide risk is coalesced in the "beta" component of risk premiums in the discount rates we use to value income streams. The beta is where we should ideally adjust for the risk to a sector relative to the entire market for all sectors. The average beta across all investments is equal to one. For sectors with above-average risk, the beta will be greater than one. For below-average risk sectors, the beta will be less than one. 

While my firm Boschan Corp.'s music sector research and beta calculations are confidential, here are Betas by Sector as well as a video from the Professor himself. Keep in mind, these betas might be used only for investors:

    • Using the capital asset pricing model
    • With diversified portfolios 

Unfortunately, conventional methods for estimating betas remain rooted in historical data. Thus, they fall short in capturing the forward-looking nature of catastrophic risks. Hence, the need for a nuanced approach—one that accounts for the interplay between AI and the music industry, leveraging industry expertise and stakeholder insights to inform risk assessment.

At Boschan Corp. we undertake rigorous analysis to gauge the extent of AI integration within music companies (i.e., how much music companies are hedging with investments in AI), how much AI companies are investing in music, and we solicit diverse perspectives to ascertain the likelihood and magnitude of AI-induced disruptions ("How likely is it that half of all music consumed by consumers is not artist created by humans in the next ten years?"). 

Also, we can explore the merits of an alternate approach to address catastrophic risk on an asset or company-specific basis (not on a sector-wide basis) with valuations based on two or more cash flow forecasts:

  1. Assuming no catastrophe and
  2. Assuming catastrophic outcome(s)

Then, we apply the buyer/investors' risk probability to each scenario and sum the results.

In this case, how shall an investor estimate probability of the risk posed to the music industry by AI?

Whether through sector-wide adjustments or asset-specific valuations, the weakness of both methods is the same: How to determine the temporal and qualitative dimensions of catastrophic risk (i.e., probability over time and magnitude of the catastrophe).

In either case, in confronting the specter of catastrophic AI risks, human expertise remains our most potent weapon in mitigating uncertainty and seizing opportunity amidst disruption.

For investors navigating the labyrinth of uncertainty, Professor Damodaran's comprehensive resources on betas and risk dynamics serve as invaluable compasses, offering nuanced insights and practical frameworks to navigate uncharted terrain. He and NYU also have made available the following resources:

Tuesday, December 12, 2023

Apple Music Podcast: Cedar Boschan on Music Royalties

Thank you to "Riches and Rhythms," for having me guest on your podcast.  It was a pleasure to speak with Stonebridge financial advisor Tyler Martin and Tristar business manager Peggy Stephens about music royalty audits, IP valuation and AI.

Link to podcast: apple.co/3uL14Qu



Friday, January 8, 2021

So Much MMA and MLC Jargon!

When reading in the Federal Register the United States' recent interim ruling regarding the public musical works database and transparency of the mechanical licensing collective, I realized that it was so packed with jargon that it would be impossible for most people to comprehend.

Therefore, below is a mini-glossary of many terms one needs to understand in order to make sense of the new interim rule. If I missed one that you wish us to add, please request it in the comments below.



  • A2IM - The American Association of Independent Music (“A2IM”) is the U.S. trade organization of independent music labels.
  • API – An application programming interface, which enables the sharing of data between different software applications.
  • ARM - The Alliance for Recorded Music (“ARM”) is a nonprofit coalition of the RIAA and A2IM, which collectively represent the labels that own and/or distribute most of the sound recordings commercially produced and distributed in the United States.
  • ASCAP - American Society of Composers, Authors, and Publishers (“ASCAP”) is one of the two largest PROs in the United States.
  • BIEM - An international organization of mechanical rights CMOs
  • BMI - Broadcast Music, Inc. (“BMI”) is one of the two largest PROs in the United States.
  • CISAC - The International Confederation of Societies of Authors and Composers (“CISAC”) is an international network of authors’ societies.
  • CMO – A collective management organization
  • CWR – Common Works Registration (“CWR”) is a format used by publishers to provide musical works data to performing and mechanical rights organizations
  • DDEX – An organization with an internationally recognized standard for information in messages exchanged between DMPs and the MLC
  • DLC – In the entertainment industry this term ordinarily refers to “downloadable content,” but in the context of the MMA, it specifically means the licensee coordinator (“DLC”) designated by the Copyright Office to represent MLC licensees in proceedings before the Copyright Royalty Judges and the Office, to serve as a non-voting member of the MLC, and to carry out other functions.
  • DMP – A digital music provider
  • DQI – As used by the MLC, the Data Quality Initiative (“DQI”) is a way for rightsholders to compare their many musical works repertoire records to The MLC’s database and identify discrepancies that need to be resolved for both datasets to be accurate.
  • DPID – The DDEX Party Identifier is a unique code assigned by DDEX to each entity that sends or receives DDEX messages. The sender and recipient of a DDEX message are each identified via their respective DPIDs.
  • ERN – DDEX’s electronic release notification standard to enable record companies to inform DMPs about product releases
  • Ex parte communications - An ex parte communication is an oral or written communication made without proper notice to all parties and not on the public record, from an interested person outside the agency to a member of the agency, an administrative law judge, or an employee involved in the decision-making process.
  • Federal Register - The Federal Register is a daily Federal Government publication that provides a uniform system for publishing Presidential documents, all proposed and final regulations, notices of meetings, and other official documents issued by Federal departments and agencies.
  • FMC – In the music industry, this refers to the Future of Music Coalition (FMC), a US-based non-profit founded by musicians, artist advocates, technologists and legal experts to futher education, research and advocacy for musicians.
  • GEMA – A CMO based in Germany
  • Interim rule - When an agency finds that it has good cause to issue a final rule without first publishing a proposed rule, it often characterizes the rule as an “interim final rule,” or “interim rule.” This type of rule becomes effective immediately upon publication.
  • IPI - Interested Parties Information (“IPI”)is a unique code assigned worldwide to each stakeholder of a musical work by CISAC. Such IPIs identify interested parties such as authors, composers, adaptors, administrators, arrangers, publishers, subpublishers, associated performers, and translators.
  • ISNI - International Standard Name Identifier (“ISNI”) is a standardized unique code permanently assigned to a “contributor” to and distributor of creative works by an ISNI agency. Such ISNIs identify researchers, inventors, writers, artists, visual creators, performers, producers, publishers, aggregators, and others.
  • ISRC - The International Standard Recording Code (“ISRC”) is a somewhat standardized unique code permanently assigned to a recording by its first owner. Such ISRCs identify recordings across different exploitations.
  • ISWC - The International Standard Musical Work Code (“ISWC”) is a somewhat standardized unique code permanently assigned to a musical work by a local registration agency when a work is first registered. Such ISWCs identify songs or version thereof across different exploitations.
  • LabelName – DDEX metadata field to show the name of the record label for the relevant product release
  • LAD – January 1, 2021, the license availability date of the MMA’s first blanket licensing regime.
  • Library of Congress - The Library of Congress is the largest library in the world, with millions of books, recordings, photographs, newspapers, maps and manuscripts in its collections. The Library is the main research arm of the U.S. Congress and the home of the U.S. Copyright Office.
  • MAC – The Music Artists Coalition (MAC) is a digital rights advocacy organization for musical artists.
  • Marginal Cost – The cost for the supplier to produce one more unit of a good or service.
  • Metadata – Information about information or accompanying files
  • MIC – An American coalition of associations whose members use and perform music over airwaves, through the internet and in retailers, theaters, hotels, restaurants, and bars.
  • MLC – In the music industry, this refers to a mechanical licensing collective (“MLC”) established by the MMA (defined below) to administer the blanket license, receive notices and reports from digital music providers, create and maintain a publicly accessible database containing information relating to musical works, collect and distribute royalties, and identify musical works and their owners for payment. The U.S. Copyright Office (defined below) designated Mechanical Licensing Collective, Inc. as such MLC.
  • MMA – In the music industry, this refers to the United States’ Musical Works Modernization Act, title I of the Orrin G. Hatch-Bob Goodlatte Music Modernization Act, H.R. 1551. The law establishes a new blanket compulsory license that will be administered by a mechanical licensing collective, which will make available a public musical works database as part of its statutory duties.
  • NOI – Usually in the music industry, NOI refers to “notice of intent” to use a copyright. However, in other instances, including the recent Interim Rule that inspired this post, it refers to a “notification of inquiry” from the U.S. Copyright Office, which is basically a notice of The Office’s quest for information and/or commentary from stakeholders.
  • NPRM – A notice of proposed rulemaking or NPRM is the official document that announces and explains the agency’s plan to address a problem or accomplish a goal. All proposed rules must be published in the Federal Register to notify the public and to give them an opportunity to submit comments.  The proposed rule and the public comments received on it form the basis of the final rule.
  • The Office – In the context of the MMA, this refers to Copyright Office.
  • PII - Personally identifiable information
  • PLine – DDEX metadata field to indicate the year of first
  • release of an audio-only sound recording followed by the name of the entity that owns the phonographic copyright thereto.
  • PRO – In the music industry, this refers to a copyright performance rights organization or society, which licenses rights to publicly perform musical works.
  • Public Musical Works Database – Under the MMA, The MLC must establish and maintain a free-of-charge public database of musical work ownership information that also identifies the sound recordings in which the musical works are embodied, a function expected to provide transparency across the music industry.
  • Recording Academy – A U.S.-based society of music professionals including performers, songwriters, producers, and engineers.
  • Register of Copyrights - The Register of Copyrights is the Director of the U.S. Copyright Office and a recognized leader and lawyer within the U.S. government. By statute, the Register works under the general direction of the Librarian of Congress and carries out a variety of legal and policy functions that are enumerated throughout Title 17.
  • RIAA - The Recording Industry Association of America (“RIAA”) is the U.S. trade organization of major music labels.
  • U.S. Copyright Office - The Copyright Office administers the national copyright system and provides advice on copyright law to congress, federal agencies, the courts and the public.
  • SCL - Society of Composers & Lyricists (“SCL”) seeks to advance the interests of composers and lyricists working in the visual arts (e.g., film, TV, video games).
  • SFTP – Secure file transfer protocol
  • SGA - Songwriters Guild of America (and its predecessor-in-interest the Songwriters Protective Association (“SPA”)) have represented the rights of songwriters since 1931.
  • SNBL – A DMP that is a significant non-MMA blanket licensee because it obtained one or more voluntary, or direct, licenses from copyright owners and is therefore subject to earnings and usage reporting obligations which are separate from those under the MMA.
  • SoundExchange – The agent designated by the Librarian of Congress to administer sound recording performance rights in the United States, the organization collects and distributes royalties on behalf of recording artists and master rights owners.
  • SRCO – A sound recording copyright owner.
  • Statute – a law
  • UPC – A Universal Product Code is a unique code assigned to physical products in the United States by the GS1 global standards organization, which is headquartered in Belgium. Such UPCs convey data when scanned by retailers and marketplaces.

Tuesday, December 1, 2015

Calendar: Wednesday, December 9, 2015: Talk on Royalty & Participation Audits

The Beverly Hills Bar Association will present on Wednesday, December 9, 2015 a program on royalty and profit participation audits:


Our founder, auditor and forensic accountant Cedar Boschan, will lead top accounting and legal audit professionals in discussion about:
  • Drafting accounting, objection and audit provisions in contracts
  • Making the call to audit, hiring an auditor and issuing audit and objection notices
  • Working closely with accountants to smoothly complete audits
  • Negotiating tolling agreements, settlements and, at times, litigating
Forensic accountant and royalty auditor Cedar Boschan Moderates Panel at Lawry's
The panelists will discuss these and other elements of modern royalty and profit participation audits to empower attorneys in attendance to optimize settlements for your clients.  
Speakers include an auditor and a litigator who mutually represent plaintiffs including Richard Dreyfuss in a current case against Walt Disney Pictures, as well as an executive from MGM:

  • Neville Johnson, Esq.; Partner at Johnson & Johnson LLP
  • Edward Slizewski, Esq.; Senior Vice President at Metro-Goldwyn-Mayer Studios Inc.
  • David Robinson, CPA; Owner at Robinson & Company
  • Moderator: Cedar Boschan; Founder, Boschan Corp.
Attorneys who attend the lunch at Lawry's The Prime Rib in Beverly Hills (or who watch the program online) may receive 1.5 hours of MCLE credit.

Registration is now open - click here to register!

Monday, October 19, 2015

Visualizing Decimated Revenue in the Record Business

Since 1999, the old "record business" (i.e., of manufacturing and distributing physical consumer products) has dropped over 70%.  See charts below based on RIAA data:






Record companies collectively lost control of music distribution, albums unbundled into tracks, and downloads have had their day (note: downloads are declining in market share at this point). 

A small number of digital music services have seized control of music distribution; YouTube, Spotify, Amazon and Pandora compete with Apple to offer consumers better, faster and/or cheaper experiences, making streaming one of few recorded music market segments with strong growth.

Losing control of distribution to digital companies has weighed heavily on music license fees, resulting in controversially low royalty rates, which are often based on subscriber or ad revenues. See Boschan Corp.’s estimates below of roughly how many digital downloads or streams are required to achieve $1 Million in US recorded music revenue on many of the popular services:

Note that actual rates do vary based on the services deals with record companies and/or SoundExchange as well as the type of exploitation (e.g., subscriptions vs. ad-supported).

Also, it is important to note that while recorded music revenues have dropped, so have costs (e.g., for physical product), and that record companies have a multitude of other income streams that they classify as "investment" or other types of income or offsets to costs.  As a result of these and other factors, the profitability picture is not quite as grim as it appears when we focus solely on revenues of the recorded music sector.

Tuesday, May 26, 2015

Los Angeles Calendar: June 25, 2015 Music Publishing Valuation Panel


The Association of Independent Music Publishers will present music valuation panel discussion on June 25 at Lawry's in Beverly Hills, California.
Registration is now open - click here to register!


AIMP Catalog Valuation Panel:  Beyond the MultipleThursday, June 25 at 11:30 amLawry's Restaurant in Beverly Hills, CaliforniaTickets & Information: Click Here
Join the AIMP for lunch as speakers delve beyond the multiple to reveal how parties from buyers to banks price music assets.  Music valuation expert and AIMP Treasurer Cedar Boschan will moderate this highly informative discussion among world class valuation experts, so mark your calendars for June 25.
Speakers:


Jason Somerville, Managing Partner, EIG




Josh Gruss, CEO, Round Hill Music

Dan Coleman, Managing Partner, Modern Works Music Publishing



Derek Crownover, Esq.Partner & Entertainment Law Practice Leader, Dickinson Wright 


Cedar Boschan, Founder, Boschan Corp

Friday, January 9, 2015

Five Things to Consider Before Filing a Music Copyright Case

By Gerard P. Fox, Esq.

Gerard P. Fox, Esq. and his firm
handle general business, contract
and IP litigation across the
entertainment industry and
beyond.

Attorney Gerard P. Fox has acted as lead trial counsel for corporate clients such as Vivendi and Clear Channel. Mr. Fox has also represented high profile entertainers including Madonna, Anita Baker and the Isley Brothers.  

From hiring experts to damage awards, in his post below, Mr. Fox shares some very useful tips from his years of copyright litigation experience.  For a personalized consultation, contact the Law Offices of Gerard Fox and also check out his Fox's Litigation Strategies Blog.

1.      In my opinion the Federal District Courts have been improperly applying a quantitative and not qualitative copyright analysis in music and film cases. This means that they take the totality of your copyrighted work which you claim has been infringed, and hold it up against the totality of the infringing work and actively look for dissimilarities.  This is incorrect under the law because in truth a song often includes many small, integrated and unique copyrightable works. Unfortunately, because the courts are taking this approach, it is much harder to win a copyright case in district court.  I tried one of the last published wins where I represented an artist claiming a part of their song was infringed. See Three Boys Music (Ronald Isley) v. Michael Bolton.  It’s not common.
2.     You will need to hire a musicologist up front.  If you want to have any chance of negotiating an early settlement or defeating an early motion for summary judgment (see below), you will need to retain an accomplished and respected musicologist. First, you should secure their independent opinion as a consultant, then if their opinion is one you respect and one that supports your contentions you should retain them as a formal expert.  Good musicologists, who are respected by defense counsel and the court, will usually ask for an up front retainer of no less than $5,000 or $10,000. Keep in mind that this retainer is not a cap of their total billings.  If the case proceeds through to depositions, summary judgment and trial, the musicologist would likely charge you upwards of $25,000. 
3.     Another consideration is that the defendants will most assuredly make an early motion for summary judgment wherein they will argue that the infringed elements of your song are common and not unique, and that the two musical works are not substantially similar.  They may make other arguments that are common to these type cases, but these are the two most likely arguments.  In making these arguments, they will put forth cases that move away from the proper application of Copyright law to a quantitative analysis of the works.  It is imperative that you retain attorneys who have a deep and up to date understanding of the case law, legislative history and this process to have any chance of defeating this type of motion.  This is no area for a general practitioner.  Defeating this summary judgment motion is essential, because if you do, which is rare in these cases, you will have all the leverage, as the defendants would be left to face a public jury trial.
4.     The prevailing party may be awarded their attorney’s fees under Copyright law.  Under 17 U.S.C. § 505 “the court may also award reasonable attorney’s fees to the prevailing party” in a copyright infringement case.  This is a huge issue to consider if you are the artist because if you lose, you could be ordered to pay hundreds of thousands of dollars of defense fees.  Now, awarding attorney’s fees and costs is discretionary with the district court judge, and many of these judges will NOT award the defendants their fees even if they win, on account of their very human concern about the financial devastation such an award would cause the artist, but this is a risk.
5.     Finally, when it comes to estimating your damages, you will not be awarded all of the infringing defendants’ net profits from the infringing distribution and use of the song, but an apportioned amount.  17 U.S.C. § 504(b) provides that the defendants are entitled to prove that certain elements of the profits are “attributable to factors other than the copyrighted work.” See Mackie v. Rieser, 296 F.3d 909, 915–16 (9th Cir.2002) (In the Ninth Circuit, on a claim to recover profits that are attributable to the copyright infringement, a plaintiff must show that the infringement itself, that is, the use of the plaintiff's work, was causally linked to the gross revenue claimed.).  This means that the defendants will argue that their notoriety, other songs on an album, the marketing behind them and their songs, the market that pre-exited for their music and other non-infringing parts of the song at issue were responsible for most of the profits earned, and that you should only be awarded a small apportioned amount of the net profits.  Of course, most defendants are not truthful about their actual net profits and will try to hide the true amount of their profits. To combat this it is important that you hire a forensic accountant who is knowledgeable about the music industry, such as Green Hasson Janks, to figure out the actual net profits, and then use your musicologist and maybe another music industry expert to argue that the piece of music stolen from you drove the sales and as a result defendants’ profits.
# # #

Gerard ("Gerry") Fox graduated from Georgetown Law School, magna cum laude, and earned an accounting degree from the University of Richmond. Mr. Fox acted as lead trial counsel for clients such as Vivendi, Clear Channel and Dow Chemical.

Gerry started his career at Covington & Burling, followed by Kaye, Scholer, before forming Fox & Spillane, where Mr. Fox honed his trial skills for twelve years. Four years ago, Gerry began the Law Offices of Gerard Fox.

Gerry handles General Business Litigation, Contract Litigation and Intellectual Property Litigation across the entertainment industry and beyond.

Gerry is admitted to practice in Maryland, Washington, D.C., California, has served as a media commentator, and wrote the book “Sue the Bastards.”

Saturday, December 13, 2014

Listen Here

The Auditrix on music and game royalties:

 MusicBizCast with Kelly Castor Episode 29 with Cedar Boschan
Music Royalties - Audio Interview of Cedar Boschan by Kelly Castor - #Free on MusicBizCast

Royalty Audits: What You Need to Know - International Game Developers' Association (IGDA) Webinar: Distinguished Lawyer Tom Buscaglia Interviews Cedar Boschan - #Free on YouTube

Video Game Dealmaking: Playing to Win (DVD): The Beverly Hills Bar Association Panel Discussion with International Legal and Business Professionals (Receive 1 Hour CLE Credit, $179).  Cedar Boschan Moderates:

Royalty Income Meets Marital Dissolution: Dividing, Managing & Accounting (DVD) @ The Beverly Hills Bar Association (Receive 1 Hour CLE Credit, $179), Featuring Presenters:

Business Managers Brainstorm on Royalties - SXSW and Association of Independent Music Publishers Panel Discussions (@AIMPorg video #free for #membersonly) Featuring:




Tuesday, October 21, 2014

All the Ways One Can "Buy a Record"

My favorite octogenarian attorney recently asked me:
"Please give me a list of all the ways someone can buy a record."
I came up with the following and included uses that may not strictly constitute sales or phonorecords under the U.S. Copyright Act:

1 – Consumers can purchase permanent copies of recordings in various configurations, such as:
a.      From retailers (online like Amazon.com or brick and mortar like Target and Walmart) or directly from an artists’ website or at a concert (e.g., together with merchandise):
i.      Vinyl Record
ii.     Compact Disc
iii.    DVD
iv.    Embodied on video games
b.     Permanent downloads from music services (e.g., from iTunes and Amazon.com) and video game console manufacturers (e.g., Sony’s PlayStation network and Microsoft’s Xbox store)

2 – Also, consumers pay for access to listen to recordings by subscribing to a music service such as the following:
a.   Interactive services like Spotify and Beats (where users can stream on demand)
b.  So-called "non-interactive" services like Pandora and Sirius XM (which offer users less control over programming)

3 – Alternately, companies pay to advertise to listeners or viewers of free programming on services like YouTube, Vevo, MTV and the services mentioned in #2 above.  In this case, access to the recording is “free” to the consumer because the advertiser subsidizes the cost, but the consumer must watch or listen to ads in exchange for such free access.

4 – Finally, consumers who purchase electronics devices such as a Samsung phone or iPhone may find that music has been bundled with the device by the hardware seller, which pays the music rights holders for the right to do this (and thusly must build in the music cost in the device's price).

What ways to buy a record did I forget?

Please tell me what I failed to mention below!

Monday, March 5, 2012

March 20, 2012 @ The CCC: Financial Strategies for Copyright Stakeholders


Are you a writer, publisher, artist or attorney in the music industry?  If so, your livelihood is dependent on the values of copyrights and you may wish to join me for dinner at the California Copyright Conference ("CCC") on March 20, which will feature a panel discussion on "Financial Strategies for Copyright Stakeholders."

My co-moderator Cheryl Hodgson, Esq. and I are excited to ask the experts about the following topics:
• Hedging Against Decline in Copyright Values
• Raising Cash - Is Now a Good Time to Buy/Sell/Borrow Against Music Assets?
• Valuation of Copyrights
• Minimizing Taxes
• Protecting Your Business and Your Heirs

Scheduled panelists:
• David Renzer, Entrepreneur, Former Chairman/CEO of Universal Music Publishing Group
• Curtis Vega, Senior Vice President - Media & Entertainment, HSBC Bank USA, N.A.
• Joseph Rust, CPA, CFP, Partner at Prager and Fenton LLP
• Michael Morris, Esq., Partner at Valensi Rose, PLC, Past President, California Copyright Conference
• Sara Qazi, Financial Advisor, Guided Portfolio Manager, Morgan Stanley Smith Barney LLC

Please reserve your seat now at: http://www.theccc.org 

Hope to see you there!  RSVP by 10am Friday, March 16.