Utilize the input text as a context reference, choose the right relationship between Vivendi and Universal Music Group from the options. Options: product/material produced, manufacturer, distributed by, industry, position held, original broadcaster, owned by, founded by, distribution format, headquarters location, stock exchange, currency, parent organization, chief executive officer, director/manager, owner of, operator, member of, employer, chairperson, platform, subsidiary, legal form, publisher, developer, brand, business division, location of formation, creator.

Circuit Court of Appeals in San Francisco made it tougher for content providers such as Vivendi SA's Universal Music Group to force Internet service providers to remove material.

Answer: subsidiary