What is the relationship between Vivendi and Universal Music Group in the context of the input sentence. Choose an answer from: 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