The U.S. Supreme Court case White-Smith Music Publishing Company v. Apollo Company in 1907 revolved around the issue of copyright infringement related to music rolls for player pianos. The plaintiff, White-Smith Music Publishing Company, argued that the defendant, Apollo Company had violated their copyrights by producing and selling piano rolls containing their copyrighted musical compositions without permission or payment of royalties. However, the court ruled in favor of Apollo company stating that piano rolls were not copies of musical compositions but rather parts of a machine which interprets music. Therefore they did not infringe upon any copyright laws as per existing legislation at that time because they didn't reproduce sheet music or other readable forms for humans directly from these piano rolls.

In the dissenting opinion for White-Smith Music Publishing Company v. Apollo Company, Justice Oliver Wendell Holmes Jr. argued that a piano roll should be considered a copy of sheet music under copyright law because it serves the same purpose: to produce musical sounds when used in conjunction with an instrument. He contended that if someone were to transcribe the holes on a piano roll back into traditional notation, they would have effectively copied the original piece of music without permission from its creator or publisher, which is precisely what copyright laws are designed to prevent. Therefore, he believed that selling and distributing these rolls constituted infringement upon White-Smith's exclusive rights as holders of copyrights for those pieces of music.