For a long time in American copyright law, sound recordings enjoyed all of the exclusive rights granted by copyright, except for the performance right. A variety of reasons existed for this exclusion, including the fact that sound recordings did not even receive any copyright protection until 1972, and radio broadcasters' unwillingness to pay two copyright fees each time a music recording was played over-the-air. However, in 1995, Congress passed the Digital Performance Right in Sound Recordings Act, which created a limited performance right for sound recordings. Digital broadcasts of recorded music remained exempt, but interactive services providing subscribers with digital transmission of recorded music were subject to the performance right. In addition, certain noninteractive digital subscription services (typically music services delivered over cable and satellite television systems) were subject to the performance right, but were granted a compulsory license for their performances of sound recordings. To take advantage of this compulsory license, found in section 114 of the Copyright Act, one must comply with a number of limitations on the frequency and identification of the music performed by the service. These limitations are designed to discourage subscribers from engaging in home taping of the music performed in digital format. See 17 U.S.C. 114(d)(2)(C) (1995).