States enacted the original copyright law in the UnitedStates, but the Framers recognized the discrepancies among statelaws and urged for national copyright law during theConstitutional Convention.86 The issue of public performancerights arose in the context of music with an amendment to the1870 Copyright Act.87 When Congress wrote the 1909 CopyrightAct, it included the with the caveat thatthe public performance be “for profit