But the procedure to win a compulsory license can be slow and costly.
Potter was the first to raise the idea of compulsory licenses.
The stars may be beginning to align for compulsory licenses, but there are still a couple of significant hurdles.
"I hope we don't go to a system of compulsory licenses," she told Ars last year.
Using compulsory licenses, a government may force a patent proprietor to grant use to the state or others.
With this action, however, Congress mandated that all musical compositions would be subject to what is called a compulsory license.
"I hope we don't go to a system of compulsory licenses," she said.
"I don't see how any creator benefits from a compulsory license."
The law provided for "free uses" and also for compulsory licenses.
Both the free uses and the compulsory licenses were subject only to the proper attribution of the author.