Recently, recording artist Taylor Swift made a business decision. She chose not to allow the music-streaming service Spotify to use songs from her new album, "1989." Taylor has that right, as do other American recording artists and their record labels. Songwriters don't. Rules established by Congress in 1909 created what is called a "compulsory license" for songwriters who must allow interactive digital streaming services use of their creations. American Society of Composers, Authors and Publishers and Broadcast Music, Inc. consent decrees from World War II contain similar rules for streaming music. So, songwriters have no authority in the music marketplace to deny use of songs even if the royalty rates are ridiculously low. Services such as Spotify pay micro-pennies to songwriters and composers that can amount to just a few dollars for millions of plays. Such dismal royalty earnings have resulted in the profession of American songwriter headed toward extinction.