But a songbird isn't really singing - or making music. What it's doing is communicating - "talking" if you will - and it's only we who ascribe it as being "music" since its (usually) pleasant and organized sounds are "musical" to our cultural sensibilities. A bird's singing is really no different from a dog's barking, but aside from a few annoying Christmas songs few would consider barking to be musical.
So, intent is necessary. I think you're right, Ray. But, do birds sing and dogs bark for the same reason? After I posted the above I was thinking that birds singing is akin to pheromones emitted from horny moths or something. Do dogs bark to find their mates, or is it scent-oriented..? I guess that's another discussion.
I agree, that's why I tried to modify it.