updated with link to article

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 </ul>
 
+<p><strong>Update:</strong> <a
+href="http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1111624">This
+article</a> by law professor Robert Brauneis has raised some important
+questions about the history of Happy Birthday. That said, copyright in
+the song continues to be enforced and Warner Brothers continues to
+collect more than $2 million each year in royalities. Until we hear a
+judge rule on Brauneis's suggestions, we'll continue to give Warner and
+the market the benefit of the doubt.</p>
+
+
 <h2>Is Singing <cite>Happy Birthday</cite> in Public Really Copyright
 Infringement?</h2>