In White-Smith Music Publ. Co. v. Apollo Co. (209 U.S. 1, 52 L. Ed. 655, 28 S. Ct. 319, 1908 Dec. Comm'r Pat. 562 [1908]), the United States Supreme Court was asked to determine whether the federal Copyright Act encompassed perforated rolls of music used in player pianos. Although acknowledging that the federal statute had been amended as far back as 1831 to include "musical compositions," the Court believed that only written works that could be "seen and read" met the requirement for filing with the Library of Congress--a prerequisite to securing federal copyright protection (id. at 17). Because the music rolls were incapable of being read by a person, the Court concluded that federal statutory protection for "copies or publications of the copyrighted music" did not extend to music rolls (id. at 18).