The copyright specifically applied to the combination of the lyrics and the melody speaking or printing out the lyrics was fine, and so was using the melody if it had different lyrics or was instrumental. To avoid fees and/or lawsuits, productions typically either substituted a public domain folk song - "For He's a Jolly Good Fellow" is one example (British shows may use "A Fine Old English Gentleman" instead) - or they just made up their own lyrics, which may or may not use the actual melody. As a result, in media prior to 2016, it was rare to hear the actual "Happy Birthday" song. WMG aggressively enforced the copyright, too, which netted them around $2 million per year in royalty fees. note It's worth mentioning that the melody itself comes from "Good Morning to All", a much older song which everyone agrees has been in the public domain for close to a century. Its copyright in the United States and Continental Europe was held by Warner/Chappell Music, a division of Warner Music Group, which had acquired it in 1988 from its takeover of the original holder. note Canada and New Zealand were major exceptions the "Happy Birthday" copyright expired in Canada in 1985 and NZ in 1997. It's the most-recognized song in the English language (and quite possibly the entire world), but before September 22, 2015, the lyrics to "Happy Birthday to You" weren't in the public domain in most countries. Sports Night episode 1x04, " Intellectual Property"
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