FRL
On appeal2d Cir. (on appeal from S.D.N.Y.)· filed 2025-05

Salt-N-Pepa v. UMG, copyright termination / masters reclaim

Whether hip-hop artists who signed to an intermediary label in the 1980s can invoke Section 203 of the Copyright Act to terminate UMG's ownership of master recordings including 'Push It'; broader precedent on who controls catalog originating from work-for-hire and third-party-signed deals.

Latest development

As of May 5, 2026, UMG filed its response brief with the Second Circuit, arguing Salt-N-Pepa's termination bid 'lacks legal foundation' because the duo never themselves executed the original copyright transfer; the duo can still file a reply brief before oral argument is scheduled.

Tracker entry updated 2026-06-04

Background

In 2025, Cheryl "Salt" James and Sandra "Pepa" Denton sued Universal Music Group, arguing they are entitled under Section 203 of the Copyright Act of 1976 to terminate UMG's copyright grant in their master recordings, including the 1987 anthem "Push It." Section 203 allows creators to recapture copyrights assigned away more than 35 years ago, providing a second-chance window that was a cornerstone of the 1976 Act's artist-protection design.

The catch: Salt-N-Pepa's original recording agreements were executed not by the duo themselves but by NITA, a third-party production company. U.S. District Judge Denise Cote dismissed the case on January 8, 2026, finding that Section 203 only permits termination of transfers that the artists themselves executed, not transfers made by a third party on their behalf. In an appeal brief filed March 31, 2026, Salt-N-Pepa argued the dismissal was "riddled with error" and that the ruling would leave many artists from the pre-digital era permanently locked out of reclamation. UMG filed its response on May 5, 2026, insisting the statutory text is unambiguous.

Why It Matters for Artists and Fans

Thousands of artists from the 1980s and 1990s signed through production companies or management entities rather than directly with labels, making this a potentially sweeping precedent. If the Second Circuit affirms, it could permanently foreclose catalog reclamation for a generation of artists whose rights were originally transferred through intermediaries. A reversal, by contrast, would open the door for a wave of termination claims across the catalog holdings of every major label.

Primary sources

  1. [1]Salt-N-Pepa lose bid to reclaim their masters after judge dismisses lawsuit against UMG, TheGrio (2026-01-09)
  2. [2]UMG Fires Back Against Salt-N-Pepa Appeal in Masters Lawsuit, Digital Music News (2026-05-06)
  3. [3]Salt-N-Pepa Files Appeal Brief in UMG Termination Battle, Criticizes District Court Dismissal As 'Riddled With Error', Digital Music News (2026-04-01)
  4. [4]Universal Music Further Refutes Salt-N-Pepa's Arguments in Appeals Court, Variety (2026-05-05)
  5. [5]UMG tells appeals court Salt-N-Pepa termination bid lacks legal foundation, Music Business Worldwide (2026-05-05)