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Re:Happy Public Domain Day: Gershwin’s “Rhapsody in Blue” Is... by vilhelm_s on Wednesday January 01, 2020 @09:09PM (#21932398)
The linked document explains this, but it's because there is no federal copyright law for pre-1972 sound recordings. Before 1972 there was no federal copyright law for sound recordings, and then congress did not want to change the state-law copyright status of recordings made before the federal law was passed, so it was intentionally left non-preempted so that state law applies.

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