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What is the US copyright status of musical compositions recorded on piano rolls (as distinct from the copyright status of the recorded piano performances)?

Let's say we have a piano roll that was recorded in 1923. Lets say this piano roll was copyrighted and the copyright on the roll was renewed when the time to renew arrived. The roll recorded a performance of an original piano composition by someone other than the pianist on the roll. However, that composition was never published as sheet music. Consequently, no sheetmusic of this piece was ever copyrighted in the US.

As I see it, my question hinges on whether or not a paper piano roll, with its punched holes, can be considered a publication of the notation of the music. This is separate from a roll's ability to record the sound of the piano in a fixed medium and an artistic performance of a pianist. If one draws a grid over a piano roll, it is easy to read it visually as musical notation - as those who use MIDI sequencers know. Even though MIDI was not around in 1923, the notation of the musical notation was fixed in 1923.

There were many compositions recorded on piano rolls that were never published and copyrighted as sheetmusic.

MS

I expect it would take a court case to determine what the status of such a work was. There was a 1908 Supreme Court decision, White-Smith vs. Apollo, which held that publication of a piano roll did not constitute publication of the musical work contained therein. One of the reasons for the enactment of the 1909 law was to counteract some of the provisions of that decision. With the 1978 law, it's certainly clear that publishing a recording does constitute publication of the embodied musical work. The situation for items issued between issued before 1978 is quite ambiguous. Is a piano roll a sound recording, or is it a form of mechanical music notation?