Salt-N-Pepa alleged that UMG removed their recordings from streaming and other commercial platforms after the duo tried to reclaim rights to early sound recordings. That is an allegation in Cheryl James and Sandra Denton’s 2025 complaint—not a court finding. A federal judge dismissed the case in January 2026, and the duo appealed. The Second Circuit heard argument on September 22, 2026, but argument reporting is not an appellate decision.
What Salt-N-Pepa says UMG did
Cheryl James and Sandra Denton, known as Salt-N-Pepa, sued UMG Recordings in federal court in New York in May 2025. Their complaint said they had served notices in 2022 seeking to terminate copyright grants for early recordings under Section 203 of the Copyright Act. They alleged that UMG refused to recognize the notices and then removed their music from streaming services and other commercial platforms in retaliation for asserting their rights. Those claims describe the plaintiffs’ account; the district court did not find that UMG acted in retaliation. The Associated Press summarized the complaint.
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The dispute concerns early recordings, including material associated with the duo’s 1986 debut album, Hot, Cool & Vicious, which includes the hit “Push It.” It is not simply a claim that UMG took physical tapes: copyright ownership, rights granted under a contract, and possession of master tapes are separate interests.
Why the district court dismissed the case
On January 8, 2026, U.S. District Judge Denise L. Cote granted UMG’s motion to dismiss. The court read the 1986 agreements identified by James and Denton as showing that Noise in the Attic Productions—not the artists personally—owned the relevant master recordings and copyrights. Because the court concluded the artists had not made the copyright transfers they sought to terminate, it held they could not terminate those transfers. Judge Cote wrote: “Plaintiffs can only terminate copyright transfers that they executed.” The court’s opinion and order set out the rationale.
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UMG argued that the artists had not executed a copyright grant that could be terminated; it also argued in the alternative that the recordings were works made for hire. The judge resolved the motion on the grant question and did not need to decide the alternative work-made-for-hire arguments. The case also included a conversion claim concerning master tapes, but the dismissal should not be reduced to a finding that UMG “took the masters.”
What Section 203 does—and does not—allow
Section 203 of the Copyright Act of 1976 gives authors a conditional right to terminate certain copyright grants after the statutory period, generally associated with a 35-year window. It is not an automatic rule that every recording returns to an artist after 35 years. The right depends on matters including who made the grant, whether the agreement actually transferred copyright, which works are covered, statutory timing and notice requirements, and applicable exceptions. The text of 17 U.S.C. § 203 describes the statutory requirements.
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That distinction was central here: before the court could consider whether the notices were timely or whether other defenses applied, it asked whether James and Denton had made a qualifying grant at all. It concluded they had not, based on the agreements before it. That is the district court’s ruling, not a final appellate resolution.
Timeline of the dispute
- 1986: Hot, Cool & Vicious was released.
- March–May 2022: The court’s account describes the artists’ efforts to serve and amend termination notices.
- July 12, 2024: The parties entered an agreement for UMG to continue exploiting recordings from the first two albums while attempting to resolve their dispute.
- May 2025: James and Denton filed suit in federal court in New York.
- January 8, 2026: Judge Cote dismissed the case.
- February 5, 2026: The appeal was opened as Second Circuit case 26-253.
- September 22, 2026: The Second Circuit heard oral argument. Law360 reported that a judge questioned the dismissal as to at least two albums; that exchange does not establish the panel’s decision.
Where the appeal stands
James and Denton appealed the dismissal. As of the latest cited argument reporting, the Second Circuit had heard the case but no appellate judgment was established. A judge’s questions or comments during oral argument do not tell readers how the panel will rule. The appeal is listed as case 26-253 on the Second Circuit docket.
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