Court of Appeal Dismisses Blur Drummer Dave Rowntrees Black Box Royalties Appeal Against PRS for Music
Rowntree’s case hinged on the so‑called "black box" pool—a sum PRS for Music collects but cannot tie to a specific work or recipient because of data gaps. He argued that the society’s pro‑rata distribution of these funds disproportionately benefits publishers over songwriters, and that the disputed amount was roughly £200 million (about $265 million). The appeal sought to revive the claim and force a reallocation of the black‑box pool.
The CAT had rejected the class action in August 2025, finding that Rowntree had not presented a viable alternative distribution scheme. The Court of Appeal upheld that finding, stating that PRS had taken "reasonable and proportionate steps to achieve accuracy" in matching and paying out black‑box royalties. Lord Justice Miles described Rowntree’s argument as a "manifest oversimplification" of a complex data‑failure problem.
In its judgment, the court explained that PRS, as a non‑profit collecting society, must distribute black‑box revenues in some way. The pro‑rata rule is the society’s best attempt to approximate fairness when data is incomplete. The court rejected the idea that a per‑capita payment would be more equitable, noting that such a scheme would disadvantage many songwriter members. It also found that Rowntree had failed to propose a better distribution method, either in general terms or with a concrete model.
The judge highlighted that the average writer is more likely to suffer from data errors than the average publisher, but that this fact does not justify an inherently unfair distribution. The court concluded that, under the pro‑rata system, members receive a share of black‑box revenues that they would not otherwise obtain, and that PRS could have chosen to donate the funds to charity but opted to distribute them to its members.
PRS for Music issued a statement following the ruling. The spokesperson said the Court of Appeal had "once again recognised that this claim has no reasonable prospect of success" and that the society’s longstanding position was vindicated. The statement called the class action a "complete misrepresentation of our policies from the outset" and said PRS would continue to focus on delivering value for its members and protecting their rights.
The case has drawn attention to the broader issue of how collecting societies handle unmatched royalties. Black‑box payments arise when a society receives money but cannot identify the work or the rightful recipient because of missing or incorrect metadata. The dispute highlighted the tension between publishers, who often have more robust data systems, and songwriters, who may be less able to verify payments.
While the Court of Appeal’s decision ends Rowntree’s legal challenge, the debate over the fairness of pro‑rata distribution of black‑box royalties remains. Industry observers note that the ruling affirms the current practice of PRS and other societies, but it also underscores the need for improved data quality and transparency in royalty accounting.
At present, no further appeals are expected. PRS for Music will continue its standard operations, and the case will not affect the society’s ongoing collection and distribution activities. The ruling is final, and the legal dispute over the £200 million claim is closed.