News spread quickly last autumn when UK musician Kieran Hebden, who performs and produces under the name Four Tet, instigated legal action against his label of 20 years, Domino Records. "It was a timely challenge that amplifies artists' growing frustration in the streaming era," Aneesh Patel, Hebden's lawyer, told me of his decision to single-handedly take the indie giant to court. His plea received accolades across the music industry, and even among the ranks of UK parliament, whose MP Kevin Brennan shared Hebden's tweet from November 21st: "I believe there is an issue with the music industry on how the money is being shared out in the streaming era, and I think it's time for artists to be able to ask for a fairer deal," Hebden wrote. "It's time to try to make changes where we can. I'm not driven by the money, but I have to make a stand when I am experiencing something that's simply unfair."

Hebden's case began as a challenge to the pre-streaming era financial strictures imposed by his contract with Domino. According to their 2001 agreement, which predated streaming services, Hebden is entitled to an 18 percent royalty rate from physical sales and a 50 percent royalty rate from licensing income. The advent of Spotify, Pandora, Apple Music and Amazon Music, however, have added ambiguity to the terms of his remuneration in the years since he signed. With these new sources of revenue, Domino applied the same 18 percent royalty that it did to physical formats. Hebden argues that streaming is not comparable to physical sales, and in fact should be treated as licensing income. He is therefore seeking damages of up to £70,000 in a bid to receive the full 50 percent of streaming and download royalties he claims he's owed historically, and a declaration that this 50 percent be the correct royalty applied to the remaining time that Domino will own the rights to his albums. These rights, or the life of copyright, is another 50 years.

But the case became more convoluted this December when Domino responded to Hebden's litigation by removing three of his most popular albums—Rounds,Pause and Everything Ecstatic—from streaming services altogether, thus giving him no royalties from streams or downloads in perpetuity. "The act of depriving fans from accessing an artist's music in an attempt to quash a fair legal challenge is a sad and disappointing reflection of wider problems in the industry," said Patel. Domino's most recent move has widened the case's scope from considerations that are not only financial but existential, inherent to music culture's survival and our basic rights: will the twin monopolies of major labels and streaming services kill independent artistry? And as we press further across the digital marketplace's sprawling and unregulated threshold, will creative professionals be able to collectivize and reclaim their bargaining power?

Hebden's ongoing legal action, which is set to reconvene in early 2022 and go to trial at an unset date later in the year, has reignited a conversation around the streaming economy and major record label dominance that's been fulminating for years. While Hebden is not the first artist to dispute his label over royalty rates—Eminem, Enrique Iglesias, Kanye West and Taylor Swift are among other musicians who recently contested their labels in similar high-profile skirmishes—he could be the first to bring such a suit to public trial. His case also coincides with an intensifying debate over artist rights and remunerations heightened in the wake of Covid-19 and its attendant venue closures and layoffs, which cast the music industry's inequities—and the discrepancies between the incomes of major label and streaming execs with those of the artists whose creativity uphold them—in sudden and striking relief.

The axis of power has been steadily shifting towards a coterie of major record labels since the 1970s. The six original major imprints, or the "Big Six," were those that also owned their own manufacturing and distribution arms: Warner Music Group, EMI, Sony Music, BMG, Universal Music Group and Polygram. These companies rapidly absorbed smaller labels who lacked manufacturing and distribution, and then priced them out of the marketplace, receiving recriminations from critics and antitrust watchdogs by the end of the decade. "I'm fearful that things are consolidating so fast around such a small group of executives that those people might really wield an iron fist," Tom Modica, the owner of the Longhair Music record store in Portland, Oregon, told The New York Times in 1979. While the antitrust division of the Justice Department launched an inquiry into the snowballing industry, Ronald Reagan, who championed freewheeling neoliberal policies during his presidential term from 1981 through 1989, effectively cleared the path for the majors to more completely unify their resources and extend their control over the music marketplace. By the early '00s, the Big Six had merged into three. Universal, Sony and Warner now make up at least 80 percent of the music market, if not more, according to reports issued by JP Morgan, Citigroup and the Recording Industry Association of America.

The majors began to forge tightly interlocking relationships with streaming services like Spotify and Amazon Music as soon as they emerged in 2007. Today, branded playlists are often owned by major record labels, who exclusively upload music from featured artists in their catalogues to these microsites for non-stop, algorithmically-generated autoplay. "The major label influence within Spotify is unsurprisingly vast," Liz Pelly wrote in a self-published blog post in 2017. "The majority of the so-called 'editorial' content is shaped by Spotify’s relationships with the major labels and if not directly, then indirectly, a way in which they uphold the marketing agreements within their deals."

Very little of the revenue collected from these streams is paid to artists; monthly subscriptions are pooled and distributed using a revenue-sharing model, meaning that the money is collected and then divided among the artists getting the most streams. With 52 percent going towards the labels with whom these platforms partner and 34 percent staying with the streaming services themselves, only 14 percent goes to musicians. With a 26 percent deflation rate over time, that's tantamount to approximately £0.0023 per stream in 2021. According to these calculations, it would take more than 325 streams for an artist to make £1 on Spotify.

Streaming platforms have become the predominant mode of music dissemination in the last ten years and have exploded in popularity during the pandemic, far surpassing growth projections from 2019. During one of the worst crises we've experienced during our time, Spotify's value has tripled, putting its current net worth at approximately £56 billion. Last month, Universal was valued at £38 billion, Warner at £19 billion and Sony Music at £52 billion. While Domino is not affiliated with these labels or their subsidiaries, it is still the seventh biggest corporate label with a 0.5 percent share of the streaming market. The Official Charts Company shows that Domino's total track streams increased 20 percent in the first half of 2021, putting them at 331 million streams per year.

With little or no money coming from live performance during the pandemic, the paltry allowance musicians are skimming from the surface of these entities' deep financial reservoirs is too meager to sustain a living. According to a survey taken by 5,800 artists in Europe, 90 percent of performers indicate that the streaming market has given them no meaningful return in income. Polls in the UK and Sweden reveal that one in three musicians are planning to quit their profession. "It's been really hard as someone who tours for 90 percent of my income," Detroit-based artist Shigeto, who is signed to indie label Ghostly, said in a recent roundtable with Congresswoman Rashida Tlaib. "I've had no stable income. I've had to rely on selling my gear." Julia Holter, another artist signed to Domino, echoed in the same interview: "The pandemic brought all of these problems around streaming into focus. At least in my world, musicians weren't talking about it and saying, 'Oh, actually how am I getting paid from streaming? What's going on here?'"

Hebden's case marks the apotheosis of an industry-wide effort to re-constellate music industry economics with more equitable laws and regulations, and to build a counterweight to the power exerted by streaming platforms and bloated labels that have full control over their artists' master rights. Its arrival in the UK's Intellectual Property Enterprise Court has dovetailed with a number of concurrent efforts to interrogate the lawfulness of streaming services' revenue-share models and the dominance of large labels. In October 2020, the UK Parliament's Digital, Culture, Media and Sport Select Committee (DCMS) launched a formal inquiry into the economics of music streaming, publishing a report last July that includes grievances over the music industry's infrastructure that will be investigated over the next year. There is still no consensus as to how streaming should be defined or regulated under British or international law, which is struggling to keep up with technology's rapid development and facilitating the exploitation of vulnerable players.

During the first evidence session of the DCMS's inquiry, in November 2020, committee chair Julian Pohl MP said, "While streaming has brought significant profits to the recorded music industry, the talent behind it—performers, songwriters and composers—are losing out. Only a complete reset of streaming that enshrines in law their rights to a fair share of the earnings will do." He added:

"However, the issues we've examined reflect much deeper and more fundamental problems within the structuring of the recorded music industry itself. We have real concerns about the way the market is operating, with platforms like YouTube able to gain an unfair advantage over competitors and the independent music sector struggling to compete against the dominance of the major labels. We've heard of witnesses being afraid to speak out in case they lose favour with record labels or streaming services. It's time for the government to order an investigation by the Competition and Markets Authority on the distortions and disparities we've uncovered."

Brennan, who also sits on the DCMS Committee, introduced a Private Members' copyright bill this past fall to further ensure that performers and composers are properly remunerated from label and streaming sources. "The major takeaway from the bill was that major labels need to be broken up," he told me over Zoom. Brennan presented the bill in front of Parliament on December 3rd. While it's now in a "deep freeze" after having been met with contrition from the leaders of various streaming services—when Brennan asked if Apple Music would be amenable to more equitably distributing income to the artists who support its platform, Global Senior Director Elena Segal replied, "'equitable' is a complex term"—he remains optimistic that it will pave the way for much-needed legislative reform in the next year.

"British copyright law is seen as a bastion of IP law," he said, "so the bill has attracted interest abroad. There's no way it wouldn't have ramifications elsewhere if it were changed." He attested that the need for this legislation was urgent. "Universal's CEO, Lucien Grainge, was paid a £153 million bonus this year," he told me. "That's more than any songwriter in the country earned from streaming last year, including the big famous names like Elton John. There's something wrong."

There have been a myriad of solutions proffered across legal and activist spheres. In addition to the antitrust laws being discussed by Brennan and the DCMS, the UN has also advanced practical recommendations to counterbalance the inequalities ingrained in today's streaming economy; these include the kind of user-centric royalty reconfigurations being debated in Hebden's case against Domino, as well as a moratorium on the standard life-of-copyright record label contract.

Some critics have suggested moving towards community-owned streaming platforms (like Peter Harris's Resonate) or creative alternatives to major labels (like the artistic venture capital platform Rattle). Still others are urging that systemic overhaul will only occur with collective action. Organizations like Britain's Musicians' Union and America's United Musicians and Allied Workers (UMAW) have orchestrated musicians' strikes and pushed for collectivization in tandem with legal proceedings and seemingly utopic entrepreneurial experiments.

Joey DeFrancesco, a co-founder of UMAW and the musician behind the drag-punk project La Neve, coordinated protests in front of Spotify offices in the US and Europe throughout the past two years. When I asked him for his take on Hebden's case, he replied that it was "extremely important" for musicians' cause, however it could only happen in conjunction with movements on the ground. "It has a lot of broader implications for what we've been trying to do, and it could help change the concentration of power in the music industry," he said. "But it's just a start."

Over the last two decades, we've grown accustomed to an insidious lineage of exploitative practices in the arts that privilege consumption over compensation. Can it really go on forever? One's chances of reaping financial rewards from a piece of music are slim to none, even for successful solo acts like Hebden who don't bear the added economic burdens of supporting musicians and recording studios, and especially for artists beyond the Anglo-American mainstream or from otherwise marginalized backgrounds. Tom Gray, a Mercury Prize-winning musician who launched the social media campaign #BrokenRecord at the outset of the pandemic, has gone so far as to say that the existing remuneration system is leading us to a "cultural vanishing point." In a piece Gray wrote for Music Business Worldwide, he explains that of all the people working in the arts, musicians are the most likely to hold a second job. "Twice as many musicians need secondary sources of income compared to photographers and actors," he writes. The UN's World Intellectual Property Organization agency (WIPO) released an overview of the streaming economy in June affirming that its embedded inequities are not only a threat to creative professions and the proliferation of musical diversity, but a violation of human rights.

Our devaluation of music in the streaming era is thus a tragedy for the musicians whose work benefits our society and an injustice to all of the arts. Today's creators are forced to adapt to an environment that actively threatens their survival and the proliferation of their work, regardless of the fact that art and music are cherished by almost everyone—there are countless people who have found immense salutary benefits from music during moments of personal (and global) strife. Domino's removal of Hebden's albums from streaming platforms is a case in point, as is the accelerating suppression of creative careers due to the venue closures and gig cancellations that have accompanied Covid-19.

Still, the pandemic offers the opportunity for a reset that Hebden, among other allied workers in the arts, has been instrumental in bringing to fruition. While the artist has been unavailable for interviews during his legal proceedings, he exudes restrained idealism in his coverage of the case online despite its corresponding personal and financial solicitudes. The trial's next steps are uncertain (Hebden's barrister, Sam Carter, said in the December 16th hearing that if it were to move from the Intellectual Property Court to the High Court, Hebden would no longer be able to shoulder the legal costs). Nonetheless, it feels like a bellwether for the music economy during a time of whiplash openings and re-closings. Should Hebden win, he could set a precedent for how the other artists on his label, and likely all other independent labels, are paid for their streams and digital downloads as well as the ownership rights they have over their own music. If he loses, he may make an even more salient case for laws and regulations that confer artists with more agency and decision power. Such a post-Covid-19 world could usher in a systemic shift that empowers artists to make the work we collectively value. That, rather than the predatory market forces that rule today's music economy, is the paradigm we should endorse.