Soundtracks: One Release, Months of Lawyering, and Music That Lives Forever
INTRODUCTION
We often discuss soundtracks with an eye toward the creative and with an air of nostalgia, but rarely through the eyes of a lawyer. It may be surprising to learn that there are many legal considerations from the perspective of a major studio, including grants of rights, as well as surprisingly complex deals associated with soundtracks for motion pictures.
We probably cannot imagine a two-hour feature film completely devoid of music, and why would we want to? Music plays such a significant role in the cinematic experience that accompanying songs and score often become inextricably linked to the film itself. Prince’s Purple Rain, for example, has become synonymous with the film of the same name in which he stars, as has Curtis Mayfield’s iconic Super Fly.[ii] And let us not forget quintessential ’90s works of art including the soundtracks for Waiting to Exhale, Sister Act 2: Back in the Habit, Space Jam and Selena. I am a millennial, born to baby boomers who shared their love for music with me at an early age. These albums were, as Clive Davis puts it, the soundtracks of my life.[iii] Indeed, my family has not celebrated a single Christmas since 1996 without Whitney Houston’s original soundtrack album for The Preacher’s Wife blasting in our living room.[iv]
AN OVERVIEW OF FILM MUSIC
Music transforms and colors a movie, and a great deal goes into this unique aspect of the filmmaking process. Look no further than a film’s end credits to grasp just how many individuals contribute to the music featured in our favorite pictures. On the creative side, there are composers, music supervisors, editors, mixers, remixers, consultants, artists, producers and many others, each critical in their own right. On the business side, there are label partners, publishing companies and various departments within the studio itself, such as business affairs, legal affairs, music finance and clearance that also play an important role in the final product. The annual Grammy Awards acknowledge the many contributions of these individuals in categories like Best Score Soundtrack for Visual Media, Best Song Written for Visual Media, and Best Compilation Soundtrack For Visual Media.[v] Likewise, the Academy Awards have categories for Best Original Score and Best Original Song.[vi] And while a desire to win awards may not be the sole force motivating creatives, studios and music business executives, these historic accolades and their accompanying prestige often do inform creative choices. Nearly everyone with a genuine passion for their work in entertainment wishes to create captivating, award-winning content each year.
Film music can generally be divided into two categories: pre-existing music and newly-created music. Pre-existing music consists of recordings[vii] that have been previously written or recorded for purposes unrelated to the film. There are, of course, numerous pieces of pre-existing music in almost every film. Some can have a particularly memorable impact. Think Promising Young Woman’s brilliant use of Paris Hilton’s 2006 “Stars Are Blind” in the endearing, foreshadowing drugstore scene between Carey Mulligan and Bo Burnham’s characters.[viii] The filmmakers felt this song fit well in the onscreen moment,[ix] and so the studio secured all relevant rights surrounding the existing composition and recording in order to synchronize the song with the picture.
Newly-created music consists of two sub-categories: underscore (often referred to simply as score) and original songs written or recorded for the film. Underscore tends to be orchestral, though it can be electronic or synthesized, and plays in the background of scenes behind the film’s dialogue and action.
The score itself sometimes becomes a hit in its own right, such as John Williams’ score to Jaws with its famously tense “dun dun” notes signaling the shark’s arrival,[x] and Hans Zimmer’s score to Inception with a notable bassy “bwaaam” sound that accompanies a trip to dreamland.[xi] With respect to original music, memorable examples include Isaac Hayes’ “Theme from Shaft,”[xii] “My Heart Will Go On” for Titanic[xiii] and “Shallow” for A Star is Born.[xiv]
The Right to Include Pre-Existing Music in the Picture
To use a pre-existing song in a movie, a film studio must license both the song’s composition and its master[xv] recording. To do so, it must track down the owner of the composition and secure a synchronization license, or sync license for short. The sync license grants a studio the right to synchronize the song or parts of the song with a visual image in the film and possibly the right to include the song in trailers, television advertisements and other marketing materials. There may be additional fees to include the song in certain types of marketing, such as in-context and out-of-context uses. When a song accompanies the same visual images in an advertisement that it accompanied in the film, for example, this is an in-context use. So, if a song plays in the movie during a lively cocktail party scene involving a pair of best friends chatting over drinks, the song has been used in-context if it appears over that same scene in a trailer for the film. Out-of-context refers to the opposite scenario, in which the studio uses the song in a different manner than it was used in the film. A recent real-world example of an out-of-context use includes David Bowie’s “Life On Mars” playing over a montage of various scenes in a trailer for Licorice Pizza, even though the song accompanies just one particular scene in the final cut of the film.[xvi] Often, the studio can successfully negotiate in-context use as a part of the fee, while out-of-context use typically costs extra.
The studio must also track down the owner of the master to secure a master use license. As with the composition, the studio must negotiate and pay a fee, which may or may not cover in-context and out-of-context marketing uses. Typically, the license fee for the master will be given “most favored nations” treatment with the license for the composition, meaning the fees will be the same amount.
The Right to Include Newly-Created Music in the Picture
When a studio commissions a composer to write and record a new score specifically for a film, the studio almost always owns the score compositions and recordings on a “work-for-hire” basis and obtains a very broad grant of rights set forth in the composer agreement. This allows the studio to include the music in the picture and exploit the music throughout the universe in perpetuity in all media in any manner now known or hereafter devised—every lawyer’s favorite phrase. In short, with a work for hire piece, the studio can do just about anything with the composer’s work, with rare exceptions.
In exchange for these rights, the studio typically offers two types of deals. One is a “fee plus budget” deal, where the studio covers all recording costs and separately pays the composer a creative fee. The second type of deal is a “package deal,” where the studio pays the composer one amount that covers all recording costs and fees. In a package deal, the composer is solely responsible for paying the recording costs, rather than the studio, and can usually keep the remainder if the recording ends up costing less than the total package amount. This arrangement incentivizes a composer to keep costs low and record the score efficiently. Package deals are usually offered to A-list composers with substantial experience scoring major motion pictures.
Although a studio maintains ownership of the compositions and recordings created by the composer, the composer receives record royalties related to the exploitation of the score on the soundtrack album, as well as songwriter royalties. These royalties are in addition to the creative fee or package. Royalties are complex in their own right,[xvii] but a simplified overview of record and songwriter royalties is as follows: record royalties are a percentage of revenue from the exploitation of recordings (e.g., streaming, downloads, and sales), while songwriter royalties are a percentage of revenue from exploitation of the compositions (e.g., mechanical royalties and synchronization licensing). Further, composers also retain their “writer’s share” of public performance royalties that come from whichever performance rights organization (PRO) they are affiliated with, such as ASCAP or BMI.[xviii] For example, if the Los Angeles Philharmonic performs the Harry Potter score live for an audience at the Hollywood Bowl, or a marching band salutes its opponent with the “Imperial March” from Star Wars, then John Williams earns public performance royalties.[xix]
John Williams. "DSC_0937.JPG" by Chris Devers is marked with CC BY-SA 2.0.
While there are many unique issues that can arise when negotiating and papering these composer deals, the deal structure is quite straightforward. The studio essentially owns everything, with few restrictions, and agrees to pay composers a fee or package for their services, as well as songwriter and record royalties.
SOUNDTRACK ALBUMS
Studios typically release a soundtrack album either on the same day as the movie’s release, or a week before the film’s release. But long before that, the filmmakers begin discussing preferred recording artists and songwriters for a particular film or soundtrack. Because soundtracks can be very exciting from a creative standpoint, lots of buzz surrounds who the studio will tap to perform, write and produce for the project. To maximize resources, studios often partner with record labels on films with substantial original music that is not score. As an added benefit, the studio might gain access to the label’s artists for a reasonable or discounted price while the artist’s profile will be raised by being featured on a potentially popular soundtrack album. Labels will pitch to music executives at the studio in order to secure a partnership, offering their most popular superstars as incentives for possible inclusion on the album. A few recent, prominent label-studio partnerships include Warner Bros. Entertainment and Atlantic Records on its soundtrack release for Suicide Squad,[xx] Warner and Interscope Records for A Star is Born,[xxi] and Warner and Republic Records for Space Jam: A New Legacy.[xxii]
While early conversations about music may be exciting and filled with promise, these lofty creative visions present several legal challenges along the journey from conception to release. To start, music often costs more than the filmmakers anticipate. The studio negotiates the sync license fee and master license fee with the composition owner and master owner, respectively, and those fees can get very high depending on the song and its desired use. And for compositions that have multiple writers or samples, that usually means separate negotiations with multiple publishers per song. In order to meet budget restrictions, the filmmakers often have to decide between reducing the amount of music and not getting their first choice.
With respect to newly created music, having a song by a superstar like Rihanna in the end credits might sound incredible in theory, and sometimes becomes a reality, but getting commitments from all applicable parties almost always proves difficult. Specifically, the process can be time-consuming given the numerous parties involved in the deal-making. Not only does Rihanna herself have to agree, but her label has to allow her to participate in the project. Similarly, if the studio wants a certain songwriter, it will have to strike a deal with the songwriter’s publisher. Plus, there are other key players necessary to bring a new song to life—producers, mixers, feature vocalists and more—each of whom require a separate contract negotiation. The pure volume of deals involved makes the process more complex than most would imagine.
The Deals — Pre-Existing Music
When a studio obtains the rights to use a pre-existing song in a film, the studio does not automatically gain the right to put that song on the soundtrack album. Thus, if the studio plans to put a song on the soundtrack album, it (or its record label partner) must negotiate additional soundtrack rights with the publisher and record label that own the song’s composition and master. One might assume that a studio can just negotiate soundtrack album rights at the same time as the sync and master use licenses to save time. Unfortunately, this is not how the process works, as it would not be practical. First, a studio typically clears compositions and masters well before the filmmakers decide which tracks they will even use in the final version of the film Second, a film usually includes substantially more recordings than could possibly be included on any soundtrack album. Thus, the soundtrack generally includes only a small portion of the songs in the film and sometimes only includes score. Accordingly, it would not make sense to negotiate and pay for rights that the studio will never use..
To put a master recording on a soundtrack album, the label releasing the soundtrack[xxiii] needs permission from the master’s owner. But United States copyright laws say the label does not need any permission from the composition’s owner to include that composition on the album, assuming it meets the requirements set forth in the compulsory license statute.[xxiv] The compulsory license statute requires a publisher to grant a mechanical license to a requesting party for a preset royalty. The publisher must grant the license and does not have the option to decline. There is an exception to the compulsory license statute for first uses—one is not entitled to a compulsory license for the first recording of a composition, meaning the publisher can maintain control over who may release it the first time.[xxv] But this scenario is inapplicable to the use of pre-existing songs in film because by definition, the song has already been released and therefore will never constitute a first use. So, using the earlier example of Paris Hilton’s “Stars Are Blind” in Promising Young Woman, the studio did not need permission from the songwriter or publisher to include the song on the soundtrack album because it could do so under the compulsory license statute. And the first use exception did not apply because the song first came out well before the film’s 2020 release. The studio did, however, need to get permission from the owner of the master recording of “Stars Are Blind.”
Streaming’s Effect on the Soundtrack
Over the years, we have seen a move from physical sales to downloads to streaming service subscriptions, with each transition directly affecting the soundtrack business. But the most recent move to streaming, which now accounts for over 80 percent of music consumption,[xxvi] has had the most significant impact on the soundtrack album. This is in large part due to the notorious difficulty of securing streaming rights, i.e., the right to collect revenue on the streaming of an individual pre-existing recording. Labels tend to offer studios the right to include a song on its soundtrack album through a digital service provider, or DSP, such as Spotify solely on a “bundled only” basis. This means the studio can only collect revenue on downloads of the album (and physical sales of vinyl and CD), and not when individually streamed, as shown in the figures below.
Record labels are very reluctant to grant a studio streaming rights because allowing a studio to stream from a soundtrack album would significantly displace streams from the label’s artist album. But without streaming rights, the recording has extremely limited value to the studio’s soundtrack album. A studio will therefore argue that the label gets added value and exposure by securing a placement on the soundtrack album, especially if the recording is much older. Ultimately, because over 80 percent of revenue comes from streaming, a studio that does not get streaming rights to a particular recording often decides it is not worth having the track on the final album at all because it has essentially been told that 80 percent or more of its potential revenue has been eliminated. This represents a new issue for music lawyers—when physical album sales were the primary avenue for consumer consumption, having the recording on the soundtrack album alone proved lucrative; now, much less so.
Streaming has both changed and wounded the traditional soundtrack business in that we no longer see as many albums functioning as compilations of pre-existing music. Some have even gone so far as to say the iconic soundtrack albums of the past are no more— when discussing her 2019 film, Queen and Slim, Grammy award winning director Melina Matsoukas told Time that her team “wanted to bring the soundtrack back.” Indeed, the film boasted an incredible soundtrack album.[xxvii] Nevertheless, studios, labels and publishers are still making great and successful soundtracks, including those containing newly-recorded music like A Star is Born, as well as score-only albums.[xxviii]
The Deals — Newly-Created Songs
There is also a market for soundtrack albums that solely feature score created for a film, such as Hildur Guðnadóttir’s groundbreaking score for Joker[xxix] or Michael Abels’ Us (Original Motion Picture Soundtrack).[xxx] These albums are more straightforward from a legal perspective because the studio owns virtually everything. Releasing a score album requires fewer complex deals, especially when a studio has its own in-house record label that releases its own albums.
"The movie. The orchestra. 'It's moving! It's alive!'" by OldOnliner is marked with CC BY-NC-ND 2.0.
Soundtrack albums that contain pre-existing songs and newly-created, non-score songs, like 2018’s Black Panther: The Album, are more complex.[xxxi] When a studio commissions a new song for a film, the studio’s music business and legal affairs teams must make and formalize deals with every individual who will be involved in the song’s creation. This primarily includes producers, the performers and their label, and the songwriters and their publishers, but can also include mixers, vocal producers, an executive music producer and others depending on what the track requires. Also, artists and songwriters may want to see a cut of the unfinished film to decide whether they are interested in the project. This calls for non-disclosure agreements since the studio needs to keep the film’s content confidential.
For newly-recorded masters, the studio will almost always explicitly obtain the right to include the recording of the song on the soundtrack album. And while this language does not guarantee that the recording will make the final soundtrack album, newly-created music almost always does. This makes a lot of sense given that the studio has put huge amounts of money, time and resources into the project. In fact, there have been several instances where new songs commissioned by the studio make the soundtrack but do not actually appear in the finished film. Agreements for these newly-recorded masters typically include the fee, advances and royalties due, and indicate how the individual who is hired will be credited on the album’s back cover or liner notes (either on the physical album or in the metadata on DSPs), as well as in the film’s end credits.
For artists signed to record labels, the studio must also secure permission from, and deal with, the artist’s label. Music lawyers refer to this permission as a “waiver of exclusivity” and it provides that the label waives its exclusive rights to the artist’s recording services for this one specific instance, thereby allowing the studio to exploit the master recording containing the artist’s performance. One of the most fundamental and common battles between the studio and a record label concerns ownership of the recording. The studio of course wants to treat the music as work-for-hire, thus, owning the recording entirely. The label will almost always push back, insisting it owns the recording, and offering to license it to the studio. After all, the label in many cases has invested a lot of time and money into developing its artist. The winner of this battle depends on numerous factors, including the amount of money the studio is willing to pay, how interested the artist is in the project and the expected marketing advantages to the artist.
With respect to newly-written compositions, the studio similarly prefers to include work-for-hire language in the songwriter agreement, but these deals often include partial ownership for the studio. This kind of split ownership of the publishing rights is much more common than split ownership of master recordings. Another item specific to songwriter agreements for newly-written compositions is a “first use” mechanical license. Recall that for pre-existing music and catalogue recordings, the studio relies on the compulsory license statute. The first use of a song represents an exception to that statute. In such instances, the studio will preemptively include a first use mechanical license in their agreement in order to secure the necessary soundtrack rights at the outset.
Conclusion
Securing and negotiating the necessary rights associated with film soundtracks can get complicated, and no single article will cover every scenario that might arise during this process. The above therefore represents a general overview of the album’s progression from start to finish and offers a glimpse into the various deals critical to the album’s release. Studios recognize that streaming has greatly and, in some ways, negatively impacted the business of soundtracks, especially those that include pre-existing masters. Nevertheless, soundtracks still have potential to reach commercial success, particularly those featuring newly-recorded songs. Billboard chart-topping album Encanto (Original Motion Picture Soundtrack) serves as a recent example.[xxxii] The landscape is undoubtedly very different than it once was, but fans’ appetites for great film music appears to remain just as strong.
Upon winning the American Film Institute’s Lifetime Achievement Award, John Williams modestly said, “[in] the initial stage of writing any of these things, one never imagines that they will be popular or even be around a week after they’re done.” He goes on, “[e]verything was written in the service of some film function. . . .[Y]ou never write a theme for a movie thinking, ‘this will live forever.’” [xxxiii] The beauty of film music lies in this exact sentiment: everyone—from the composer to the editor, from creative executives to the lawyers, the artist to the mixer—dives into the project in line with orders from the studio and filmmakers. Unbeknownst to anyone at the outset, what comes from that hard work might just turn out to be magical.
End Notes
[i] Cara would like to thank her bosses, Ray Gonzalez and Ari Taitz, for taking a chance on a former litigation associate, ultimately fulfilling her yearslong dream of becoming a music lawyer. She appreciates their patience and guidance over the past two-and-a-half years, as well as their notes, edits and corrections throughout the writing process. She would also like to thank the student staff members of USC’s Entertainment Law Spotlight for inviting her to contribute to this year’s publication, and for their helpful feedback and flexibility. As a transactional attorney, Cara has forgotten how to properly cite sources in the Bluebook format, so she is especially grateful to the publication’s editors.
[ii] The Super Fly soundtrack actually out-grossed its own movie—one of the few soundtracks to have ever done so. ‘Men in Black’ to ‘Footloose’: The Most Memorable Soundtrack Songs That Name-Check Their Movies, MTV News (Jun. 27, 2008), http://www.mtv.com/news/1590123/men-in-black-to-footloose-the-most-memorable-soundtrack-songs-that-name-check-their-movies.
[iii] Clive Davis and Anthony DeCurtis. The Soundtrack of My Life (2013).
[iv] The Preacher’s Wife (1996) – Soundtracks, Internet Movie Database, https://imdb.com/title/tt0117372/
soundtrack (last visited May 4, 2022).
[v] Recording Academy, 64th Grammy Awards Rules and Guidelines, https://www.recordingacademy.com/sites/com/files/rulesandguidelines_2021_update_11.25.pdf.
[vi] Clayton Davis, 2022 Oscars Predictions Hub: All Award Categories, Variety (Jan. 13, 2022, 4:00 PM), https://variety.com/feature/2022-oscars-predictions-academy-awards-nominations-1234965583.
[vii] Note that for purposes of copyright law, there are two parts to every piece of music: the underlying composition (i.e., the sheet music and lyrics) and the recording (i.e., the finished audio file enjoyed by listeners). The term “master(s)” is interchangeable with “recording(s).”
[viii] Promising Young Woman (2020) – Soundtracks, Internet Movie Database, https://imdb.com/title/tt962
0292/soundtrack (last visited May 4, 2022).
[ix] Joey Nolfi, How Promising Young Woman got Paris Hilton’s ‘Stars Are Blind’ for the best dance of 2020, Entertainment Weekly (Dec. 23, 2020), https://ew.com/movies/promising-young-woman-stars-are-blind-paris-hilton-scene.
[x] Jaws (1975) – Full Cast & Crew, Internet Movie Database, https://www.imdb.com/title/tt0073195/
fullcredits (last visited May 4, 2022).
[xi] Inception (2010) – Full Cast & Crew, Internet Movie Database, https://www.imdb.com/title/tt137566
6/fullcredits (last visited May 4, 2022).
[xii] Shaft (1971) – Soundtracks, Internet Movie Database, https://www.imdb.com/title/tt0067741/
soundtrack (last visited May 4, 2022).
[xiii] Titanic (1997) – Soundtracks, Internet Movie Database, https://www.imdb.com/title/tt0120338/
soundtrack (last visited May 4, 2022).
[xiv] A Star Is Born (2018) – Soundtracks, Internet Movie Database, https://www.imdb.com/title/tt1517451/
soundtrack (last visited May 4, 2022).
[xv] See, Shirley Halperin & Jeremy Helligar, The Big Payback: How Pharrell Williams Is Breaking the Chains of the Music Industry’s Troubled Past, Variety (Aug. 11, 2020, 11:00 AM), https://variety.com/2020/music/news/pharrell-williams-master-slave-industry-contracts-1234729237/ (explaining that while using the term "master" to describe the sound recording is the established industry norm, it carries with it the vestiges of slavery, and that for this reason the artist Pharrell is leading a charge to favor the term "sound recording" over "master" going forward).
[xvi] LICORICE PIZZA | Official Trailer | MGM Studios, YouTube, https://www.youtube.com/watch?v=ofnXPwUPE
No (last visited May 4, 2022).
[xvii] Jeff Brabec & Todd Brabec, Music Royalties 101, 1 USC Entertainment Law Spotlight, 41 (2017).
[xviii] What is the Difference Between the Writer’s Share and Publisher’s Share?, TuneCore, https://support.tunecore.com/hc/en-us/articles/115006689148-What-is-the-Difference-Between-the-Writer-s-Share-and-Publisher-s-Share- (last visited Feb. 3, 2022).
[xix] Harry Potter and the Sorcerer’s Stone (2001) – Full Cast & Crew, Internet Movie Database, https://www.imd
b.com/title/tt0241527/fullcredits (last visited May 4, 2022); Star Wars: Episode V – The Empire Strikes Back – Full Cast & Crew, Internet Movie Database, https://www.imdb.com/title/tt0080684/fullcredits (last visited May 4, 2022).
[xx] Suicide Squad (2016) – Soundtracks, Internet Movie Database, https://www.imdb.com/title/tt1386697/
soundtrack (last visited May 4, 2022).
[xxi] A Star Is Born (2018) – Soundtracks, supra note 14.
[xxii] Space Jam: A New Legacy (2021) – Soundtracks, Internet Movie Database, https://www.imdb.com/title/tt355
4046/soundtrack (last visited May 4, 2022).
[xxiii] Many studios have in-house labels that put out the studio’s soundtracks. For example, Warner Bros. Entertainment has WaterTower Music and Disney has Hollywood Records.
[xxiv] See 17 U.S.C. § 115; see also Compulsory License for Making and Distributing Phonorecords, U.S. Copyright Off., https://www.copyright.gov/circs/circ73.pdf (last visited Feb. 3, 2022).
[xxv] Donald S. Passman. All You Need to Know About the Music Business 216, 239 (10th ed. 2019).
[xxvi] Murray Stassen. US Recorded Music Revenues Grew $1.5BN in H1 2021 Compared to the First Half of Last Year, Music business worldwide (Sep. 13, 2021), https://www.musicbusinessworldwide.com/us-recorded-music-revenues-grew-1-5bn-in-h1-2021-compared-to-last-year/.
[xxvii] Andrew R. Chow, How Queen & Slim’s Filmmakers Captured the Past, Present and Future of Black Music, Time (Nov. 22, 2019, 2:19 PM), https://time.com/5733530/queen-and-slim-music/.
[xxviii] A Star Is Born (2018) – Soundtracks, supra note 14.
[xxix] Joker (2019) – Full Cast & Crew, Internet Movie Database, https://www.imdb.com/title/tt7286456/fullcredits (last visited May 4, 2022).
[xxx] Us (2019) – Full Cast & Crew, Internet Movie Database, https://www.imdb.com/title/tt6857112/fullcredits (last visited May 4, 2022).
[xxxi] Black Panther (2018) – Full Cast & Crew, Internet Movie Database, https://www.imdb.com/title/tt1825683/
soundtrack (last visited May 4, 2022).
[xxxii] Keith Caulfield, ‘Encanto’ Makes It Nine Weeks Atop Billboard 200 Albums Chart, Billboard (Mar. 13, 2022), https://www.billboard.com/music/chart-beat/encanto-billboard-200-chart-ninth-week-1235043470/.
[xxxiii] Catrina Dennis. John Williams Receives AFI Lifetime Achievement Award; Highlights From the Evening. Invoice (June 9, 2016), https://www.inverse.com/article/16824-john-williams-receives-afi-lifetime-achievement-award-highlights-from-the-evening.
About the writer…
Cara Adams serves as Counsel, Business & Legal Affairs, Music for Warner Bros. Entertainment Inc. where she drafts and negotiates a variety of music related contracts for WB and HBO Max productions and their soundtracks. Additionally, she advises and supports the studio’s in-house record label, WaterTower Music. Prior to joining Warner Bros. in 2019, Cara was an associate at Pillsbury Winthrop Shaw Pittman in Downtown Los Angeles. Cara graduated from New York University in 2014 and USC Gould School of Law in 2017 where she was a quarterfinalist in the Hale Moot Court Honors Program and a member of the Intellectual Property and Technology Law Clinic. While in law school, she also studied abroad for a semester in Brazil. Cara maintains an active pro bono practice representing student survivors of sexual violence in their Title IX campus proceedings as a volunteer attorney with social justice organization, Equal Rights Advocates (ERA). When not working, Cara enjoys traveling, reading novels, going to sports games and concerts, having 3+ hour meals with her friends, and pilates.