Civil Action - Copyright Infringement

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 1 of 118
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA PAUL BATISTE D/B/A ARTANG PUBLISHING LLC * CIVIL ACTION NO. * * SECTION: Plaintiff, * * JUDGE VERSUS * * MAGISTRATE FAHEEM RASHEED NAJM, P/K/A T-PAIN, KHALED * BIN ABDUL KHALED, P/K/A DJ KHALED, WILLIAM * ROBERTS II, P/K/A RICK ROSS, ANTOINE * MCCOLISTER P/K/A ACE HOOD, 4 BLUNTS LIT AT * ONCE PUBLISHING, ATLANTIC RECORDING * CORPORATION, BYEFALL MUSIC LLC, BYEFALL * PRODUCTIONS, INC., CAPITOL RECORDS LLC, * CASH MONEY RECORDS, INC., EMI APRIL MUSIC, * INC., EMI BLACKWOOD MUSIC, INC., * FIRST-N-GOLD PUBLISHING, INC., FUELED BY * RAMEN, LLC, NAPPY BOY, LLC, NAPPY BOY * ENTERPRISES, LLC, NAPPY BOY PRODUCTIONS, * LLC, NAPPY BOY PUBLISHING, LLC, NASTY BEAT * MAKERS PRODUCTIONS, INC., PHASE ONE * NETWORK, INC., PITBULLS LEGACY * PUBLISHING, RCA RECORDS, RCA/JIVE LABEL * GROUP, SONGS OF UNIVERSAL, INC., SONY * MUSIC ENTERTAINMENT DIGITAL LLC, * SONY/ATV MUSIC PUBLISHING, LLC, SONY/ATV * SONGS, LLC, SONY/ATV TUNES, LLC, THE ISLAND * DEF JAM MUSIC GROUP, TRAC-N-FIELD * ENTERTAINMENT, LLC, UMG RECORDINGS, INC., * UNIVERSAL MUSIC MGB SONGS, UNIVERSAL * MUSIC Z TUNES LLC, UNIVERSAL MUSIC * CORPORATION, UNIVERSAL MUSIC PUBLISHING, * INC., UNIVERSAL-POLYGRAM INTERNATIONAL * PUBLISHING, INC., WARNER-TAMERLANE * PUBLISHING CORP., WB MUSIC CORP., and * ZOMBA RECORDING LLC * * Defendants. * ******************************************************************************
COMPLAINT Plaintiff Paul Batiste, doing business as Artang Publishing, LLC, by and through his attorneys Koeppel Traylor LLC, alleges and complains as follows: INTRODUCTION 1. This is an action for copyright infringement. Plaintiff Paul Batiste is the founding member and owner of the Batiste Brothers Band, which was founded in 1976 in New Orleans, Louisiana. Plaintiff is considered a major influence of the current New Orleans jazz scene and has enjoyed immense success and recognition, both individually and through his work with the Batiste Brothers Band. The Batiste Family has been referred to as legendary and has had schools and marching bands bearing the Batiste name. This recognition stems from Plaintiffs hard work, dedication, and unique original music, which has all been authored exclusively by Plaintiff. As will be explained in more detail below, Plaintiff composed and released an extensive musical catalog over the course of his career, including multiple albums and singles. Defendants have wrongfully copied nearly every song in Plaintiffs catalog. 2. Defendants Faheem Rasheed Najm, professionally known as T-Pain, Khaled bin Abdul Khaled, professionally known as DJ Khaled, William Roberts II, professionally known as Rick Ross, and Antoine McColister, professionally known as Ace Hood, have released an immense number of songs infringing upon Plaintiffs catalog. Defendants have blatantly poached beats, lyrics, melodies, and chords from Plaintiffs songs. Defendants have even released five songs, Freeze (by T-Pain), Download, Overtime, Boom, and Freeze (by Young Cash), that have the same or nearly identical titles to Plaintiffs songs Freeze, Download My Love, Overtime, and Bam There You Have It. Defendants have access to
Plaintiffs music and have released identical and/or substantially similar songs. Upon information and belief, Defendants regularly work together to produce and record songs, often appearing on each others songs and songs by other artists. Upon information and belief, Defendant Khaled grew up in New Orleans. 3. Many of Defendants songs have been released multiple times in multiple versions. Each release constitutes an independent act or acts of infringement of each of Plaintiffs copyright or copyrights. The Defendants named in this action represent the artists, record labels, and publishing companies that are the copyright owners of the songs that infringe upon Plaintiffs music. Damages are believed to be in excess of $100,000,000. JURISDICTION AND VENUE 4. This Court has jurisdiction over this action pursuant to 28 U.S.C. 1331, 1332, 1338, and 17 U.S.C. 101, et seq. 5. Venue in the Eastern District of Louisiana is proper pursuant to 28 U.S.C. 1391(b) 1400(a) as a substantial part of the events giving rise to the claim occurried in this district. Defendants regularly conduct business in the State of Louisiana and substantial acts of infringement have occurred in this district. Defendants expected or should have reasonably expected their acts to have consequences in this district. THE PARTIES 6. Plaintiff Paul Andrea Batiste, doing business as Artang Publishing LLC, is a citizen of the State of Louisiana. Artang Publishing LLC is a Louisiana limited liability company with its principal place of business in Metairie, Louisiana. 7. Defendant Faheem Rasheed Najm, professionally known as T-Pain, is an individual, who is a citizen of the State of Florida.
8.
Defendant Khaled bin Abdul Khaled, professionally known as DJ Khaled, is an individual, who is a citizen of the State of Florida.
9.
Defendant William Roberts II, professionally known as Rick Ross, is an individual, who is a citizen of the State of Florida.
10.
Defendant Antoine McColister, professionally known as Ace Hood, is an individual, who is a citizen of the State of Florida.
11.
Defendant 4 Blunts Lit at Once Publishing, upon information and belief, is owned and operated by Sony/ATV Music Publishing, a Delaware corporation with its principal place of business in New York, New York.
12.
Defendant Atlantic Recording Corporation is a Delaware corporation with its principal place of business in New York, New York.
13.
Defendant Byefall Music LLC is a Georgia limited liability company with its principal place of business in Atlanta, Georgia.
14.
Defendant Byefall Productions, Inc. is a Georgia corporation with its principal place of business in Atlanta, Georgia.
15.
Defendant Capitol Records LLC is a California limited liability company with its principal place of business in Santa Monica, California.
16.
Defendant Cash Money Records, Inc. is a division of UMG Recordings, Inc., a Delaware corporation with its principal place of business in Santa Monica, California.
17.
Defendant EMI April Music, Inc. is a Connecticut corporation with its principal place of business in New York, New York.
18.
Defendant EMI Blackwood Music, Inc. is a Connecticut corporation with its principal place of business in New York, New York.
19.
Defendant First-N-Gold Publishing, Inc. is a Florida corporation with its principal place of business in Miami, Florida.
20.
Defendant Fueled By Ramen, LLC is a division of Atlantic Recording Corporation, a Delaware Corporation with its principal place of business in New York, New York.
21.
Defendant Nappy Boy, LLC is a Florida limited liability company with its principal place of business in Fort Lauderdale, Florida.
22.
Defendant Nappy Boy Enterprises, LLC is a Florida limited liability company with its principal place of business in Fort Lauderdale, Florida.
23.
Defendant Nappy Boy Productions, LLC is a Florida limited liability company with its principal place of business in Fort Lauderdale, Florida.
24.
Defendant Nappy Boy Publishing, LLC is a Florida limited liability company with its principal place of business in Fort Lauderdale, Florida.
25.
Defendant Nasty Beat Makers Productions, Inc. is a Florida corporation with its principal place of business in Orlando, Florida.
26.
Defendant Phase One Network, Inc. is a New Jersey corporation with its principal place of business in New York, New York.
27.
Defendant Pitbulls Legacy Publishing, upon information and belief, is owned and operated by Sony Music Entertainment, a Delaware corporation with its principal place of business in New York, New York.
28.
Defendant RCA Records is a division Sony Music Entertainment, a Delaware corporation with its principal place of business in New York, New York.
29.
Defendant RCA/JIVE Label Group is a division Sony Music Entertainment, a Delaware corporation with its principal place of business in New York, New York.
30.
Defendant Songs of Universal, Inc. is a California corporation with its principal place of business in Santa Monica, California.
31.
Defendant Sony Music Entertainment Digital LLC is a Delaware limited liability company with its principal place of business in New York, New York.
32.
Defendant Sony/ATV Music Publishing, LLC is a Delaware limited liability company with its principal place of business in New York, New York.
33.
Defendant Sony/ATV Songs, LLC is a Delaware limited liability company with its principal place of business in New York, New York.
34.
Defendant Sony/ATV Tunes, LLC is a Delaware limited liability company with its principal place of business in New York, New York.
35.
Defendant The Island Def Jam Music Group is a division of UMG Recordings, Inc., a Delaware corporation with its principal place of business in Santa Monica, California.
36.
Defendant Trac-N-Field Entertainment, LLC is a Florida limited liability company with its principal place of business in Hollywood, Florida.
37.
Defendant UMG Recordings, Inc. is a Delaware corporation with its principal place of business in Santa Monica, California.
38.
Defendant Universal Music MGB Songs is a division of Universal Music Group, Inc., a Delaware corporation with its principal place of business in Santa Monica, California.
39.
Defendant Universal Music Z Tunes LLC is a New York limited liability company with its principal place of business in New York, New York.
40.
Defendant Universal Music Corporation is a Delaware corporation with its principal place of business in Santa Monica, California.
41.
Defendant Universal Music Publishing, Inc. is a Delaware corporation with its principal place of business in Santa Monica, California.
42.
Defendant Universal-Polygram International Publishing, Inc. is a Delaware corporation with its principal place of business in Santa Monica, California.
43.
Defendant Warner-Tamerlane Publishing Corp. is a California corporation with its principal place of business in New York, New York.
44.
Defendant WB Music Corp. is a California corporation with its principal place of business in New York, New York.
45.
Defendant Zomba Recording LLC is a Delaware limited liability company with is principal place of business in New York, New York. Upon information and belief, Zomba Recording LLC is wholly owned and operated by Sony Music Corporation.
46.
Upon information and belief, Defendants have conducted significant business in the State of Louisiana and elsewhere in interstate commerce and derive substantial revenue from sales and licensing in this district. Defendants expected or should have reasonable
expected their acts to have consequences in the State of Louisiana. COPYRIGHT INFRINGEMENT FREEZE 47. In or about 1982, Plaintiff authored music and lyrics in the track Freeze. Plaintiffs Freeze was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiffs Freeze (track) was recorded and released as part of the Batiste Brothers Bands album Freeze. Freeze (album) was first published in 1982. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included Freeze (track), Shapely Lady,
Dancin Shoes, Its All About the Family, Party Down, Cant Get You Off My Mind, Hooked on You, and Never Leave You Baby. Plaintiff is the sole author of the music and lyrics in these tracks. 48. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Freeze by T-Pain featuring Chris Brown, which was released in 2008 as a single and as part of T-Pains album Thr33 Ringz. Defendants Freeze is registered with the U.S. Copyright Office, Registration Number PA0001702189. Universal Music Z Songs and Nappypub Music are the Copyright Claimants. 49. Defendants Freeze infringes upon Plaintiffs copyrights in multiple tracks on the Freeze album. Defendants Freeze infringes upon Plaintiffs Freeze (track) as parts of Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and lyrics of Defendants Freeze, which are nearly identical or similar to Plaintiffs song Freeze. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and lyrics of Plaintiffs song. 50. Defendants Freeze infringes upon Plaintiffs song Its All About the Family, as parts of Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Freeze, which is nearly identical or similar to Plaintiffs song Its All About the Family. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 51. Defendants Freeze infringes upon Plaintiffs song Hooked on You, as parts of Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song.
Among these similarities are the chords of Defendants Freeze, which are nearly identical or similar to Plaintiffs song Hooked on You. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 52. Defendants Freeze infringes upon Plaintiffs song Dancin Shoes, as parts of Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the lyrics of Defendants Freeze, which are nearly identical or similar to Plaintiffs song Dancin Shoes. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the lyrics of Plaintiffs song. 53. In or about 1997, Plaintiff authored music and lyrics in the track When She Smiles. When She Smiles is included on Plaintiffs Seductive Recital album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu0003785811. Plaintiff is the Copyright Claimant. 54. Defendants Freeze infringes upon Plaintiffs song When She Smiles, as parts of Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the gliss of Defendants Freeze, which is nearly identical or similar to Plaintiffs song When She Smiles. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the gliss of Plaintiffs song. 55. In or about 1999, Plaintiff authored music and lyrics in the track Sportsmans Paradise. Sportsmans Paradise is included on Plaintiffs Move That Body album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu000409184. Plaintiff is the Copyright Claimant.
56.
Defendants Freeze infringes upon Plaintiffs song Sportsmans Paradise, as parts of Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Freeze, which is nearly identical or similar to Plaintiffs song Sportsmans Paradise. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 57. Defendants Freeze infringes upon seven (7) of Plaintiffs copyrights. Upon information and belief, Defendants Freeze has been released as a single, as part of the album Thr33 Rings, as an instrumental, and as part of the I Am T-Pain voice correction mobile application. COPYRIGHT INFRINGEMENT ALL I DO IS WIN 58. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Ring Me, I Got the Rhythm On, Move That Body, and Sportsmans Paradise. 59. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues). 60. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Louisiana.
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61.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track All I Do Is Win by DJ Khaled featuring T-Pain, Ludacris, Snoop Dogg, and Rick Ross, which was released in 2010 as a single and as part of DJ Khaleds album Victory. Defendants All I Do Is Win is registered with the U.S. Copyright Office, Registration Numbers PA0001699760 and PA0001750015. Registration Number PA0001699760 lists Mollings Music / Nasty Beat Makers Productions Inc. Publishing, Irocnasty Music / Nasty Beat Makers Productions Inc. Publishing, DJ Khaled Publishing, Ludacris Worldwide Publishing, First and Gold Publishing, My Own Chit Publishing, Nappypub Music, and Sony/ATV Songs LLC as the Copyright Claimants. Registration Number PA0001750015 lists First N Gold Publishing, Sony/ATV Music Publishing LLC, and 4 Blunts Lit At Once as the Copyright Claimants.
62.
Defendants All I Do Is Win infringes upon Plaintiffs copyrights in multiple tracks appearing on Plaintiffs Move That Body, World of Blues, and Spice albums. Defendants All I Do Is Win infringes upon Plaintiffs Ring Me track as parts of Defendants All I Do Is Win copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants All I Do Is Win, which is nearly identical or similar to Plaintiffs song Ring Me. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
63.
Defendants All I Do Is Win infringes upon Plaintiffs I Got the Rhythm On track as parts of Defendants All I Do Is Win copy and/or are strikingl y similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants All I Do Is Win, which is nearly identical or similar to Plaintiffs song I Got the Rhythm On.
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Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 64. Defendants All I Do Is Win infringes upon Plaintiffs Move That Body track as parts of Defendants All I Do Is Win copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the lyrics of Defendants All I Do Is Win, which are nearly identical or similar to Plaintiffs song Move That Body. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the lyrics of Plaintiffs song. 65. Defendants All I Do Is Win infringes upon Plaintiffs Sportsmans Paradise track as parts of Defendants All I Do Is Win copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the lyrics of Defendants All I Do Is Win, which are nearly identical or similar to Plaintiffs song Sportsmans Paradise. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the lyrics of Plaintiffs song. 66. Defendants All I Do Is Win infringes upon Plaintiffs Still (Singing the Blues) track as parts of Defendants All I Do Is Win copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of the introduction of
Defendants All I Do Is Win, which is nearly identical or similar to Plaintiffs song Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 67. Defendants All I Do Is Win infringes upon Plaintiffs Louisiana track as parts of Defendants All I Do Is Win copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants All I Do Is Win, which is
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nearly identical or similar to Plaintiffs song Louisiana. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 68. Defendants All I Do Is Win infringes upon six (6) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT MOVE THAT BODY 69. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Love Fest. 70. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Move That Body. 71. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Move That Body by Nelly featuring Akon and T-Pain, which was released in 2010 as a single and as part of Nellys album 5.0. Defendants Move That Body is registered with the U.S. Copyright Office, Registration Numbers PA0001777353 and PA00017505868. Registration Number PA0001777353 lists Universal Music - MGB Songs, Jackie Frost Music, Inc., Universal Music - Z Songs, and NappyPub Music as the Copyright Claimants. Registration Number PA00017505868 lists Sony/ATV Music
Publishing LLC and Byefall Productions Inc. as the Copyright Claimants.
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72.
Defendants Move That Body infringes upon Plaintiffs copyrights in Move That Body and Love Fest tracks. Defendants Move That Body infringes upon Plaintiffs Move That Body track as parts of Defendants Move That Body copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the lyrics and hooks of Defendants Move That Body, which are nearly identical or similar to Plaintiffs song Move That Body. Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the lyrics and hooks of Plaintiffs song. 73. Defendants Move That Body infringes upon Plaintiffs Love Fest track as parts of Defendants Move That Body copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Move That Body, which is nearly identical or similar to Plaintiffs song Love Fest. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 74. Defendants Move That Body infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT OVERTIME 75. In or about 2002, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Sportsmans Paradise. The Sportsmans Paradise album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000502891. The Sportsmans Paradise album included, among other tracks, Overtime and Sudden Death. 76. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Overtime by Ace Hood featuring Akon and T-Pain, which was released in 2009 as a single and as part of Ace Hoods album Ruthless. Defendants Overtime is
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registered with the U.S. Copyright Office, Registration Numbers PA0001784242, PA0001751797, and PA0001719370. Registration Number PA0001784242 lists
Universal Music - Z Songs, Dade Co. Project Music, Inc., Notting Dale Songs, Inc., Trac N Field Ent. LLC, and Nappypub Music as the Copyright Claimants. Registration Number PA0001751797 lists Sony/ATV Music Publishing, LLC and Byefall Productions, Inc. as the Copyright Claimants. Registration Number PA0001719370 lists Warner-Tamerlane Publishing Corp., YRP Music Publishing, Songs Of Universal, TracN-Field Entertainment, Nappypub Music, Byefall Productions, Inc., and Sony / ATV Harmony as the Copyright Claimants. 77. Defendants Overtime infringes upon Plaintiffs copyrights in Overtime, Sudden Death, and I Got the Rhythm On tracks. Defendants Overtime infringes upon Plaintiffs Overtime track as parts of Defendants Overtime copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the lyrics of Defendants Overtime, which are nearly identical or similar to Plaintiffs song Overtime. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the lyrics of Plaintiffs song. 78. Defendants Overtime infringes upon Plaintiffs Sudden Death track as parts of Defendants Overtime copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Overtime, which is nearly identical or similar to Plaintiffs song Sudden Death. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song.
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79.
Defendants Overtime infringes upon Plaintiffs I Got the Rhythm On track as parts of Defendants Overtime copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Overtime, which is nearly identical or similar to Plaintiffs song I Got the Rhythm On. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
80.
Defendants Overtime infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BLAME IT
81.
In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Runnin Away. 82. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Do It Right Now, Nothin But the Funk, and Spice. 83. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, My Bad. 84. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Blame It by Jamie Foxx featuring T-Pain, which was released in 2008 as a single and as part of Jamie Foxxs album Intuition. Defendants Blame It is registered with The Tone
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the U.S. Copyright Office, Registration Numbers PA0001738221, PA0001770185, and PA0001761059. Registration Number PA0001738221 lists Sony/ATV Music
Publishing, LLC as the Copyright Claimant. Registration Number PA0001770185 lists Songs of Peer, LTD. and March Ninth Music Publishing as the Copyright Claimants. Registration Number PA0001761059 lists Ultra International Music Publishing LLC, Sly as a Fox Music Inc., Songs of Universal, NappyPub, 2 Tha Moon Publishing, Tenyor Music, The Royalty Network, Its N8 Publishing, 2082 Music Publishing, WB Music Corp., EMI April Music, Gifted Source Music, March Ninth Music, Songs of Peer Ltd., and Chameleon Publishing as the Copyright Claimants. 85. Defendants Blame It infringes upon Plaintiffs copyrights in Runnin Away, Do It Right Now, Nothin But the Funk, Spice, and My Bad tracks. Defendants Blame It infringes upon Plaintiffs Runnin Away track as parts of Defendants Blame It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of the rhythm section of Defendants Blame It, which is nearly identical or similar to Plaintiffs song Runnin Away. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 86. Defendants Blame It infringes upon Plaintiffs Do It Right Now track as parts of Defendants Blame It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and lyrics of Defendants Blame It, which is nearly identical or similar to Plaintiffs song Do It Right Now. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and lyrics of Plaintiffs song.
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87.
Defendants Blame It infringes upon Plaintiffs Nothin But the Funk track as parts of Defendants Blame It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Blame It, which is nearly identical or similar to Plaintiffs song Nothin But the Funk. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
88.
Defendants Blame It infringes upon Plaintiffs Spice track as parts of Defendants Blame It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Blame It, which are nearly identical or similar to Plaintiffs song Spice. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
89.
Defendants Blame It infringes upon Plaintiffs My Bad track as parts of Defendants Blame It copy and/or are strikingly similar to parts of Plaintiffs song. Amon g these similarities is the melody of Defendants Blame It, which is nearly identical or similar to Plaintiffs song My Bad. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song.
90.
Defendants Blame It infringes upon five (5) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT WHATS WRONG (GO AWAY)
91.
In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. Plaintiffs Freeze was wholly original and is
registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The
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Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. 92. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, I Like Your Way. 93. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Whats Wrong (Go Away) by Jennifer Hudson featuring T-Pain, which was released in 2008 as a single and as part of Jennifer Hudsons album Jennifer Hudson. Defendants Whats Wrong (Go Away) is registered with the U.S. Copyright Office, Registration Number PA0001716289. Registration Number PA0001716289 lists Zomba Songs and Nappypub Music as the Copyright Claimants. 94. Defendants Whats Wrong (Go Away) infringes upon Plaintiffs copyrights in I Like Your Way and Cant Get You Off My Mind tracks. Defendants Whats Wrong (Go Away) infringes upon Plaintiffs I Like Your Way track as parts of Defendants Whats Wrong (Go Away) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Whats Wrong (Go Away), which is nearly identical or similar to Plaintiffs song I Like Your Way. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 95. Defendants Whats Wrong (Go Away) infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Whats Wrong (Go Away) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of
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Defendants Whats Wrong (Go Away), which is nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody and lyrics of Plaintiffs song. 96. Defendants Whats Wrong (Go Away) infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT DOWNLOAD 97. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Download My Love. 98. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. Plaintiffs Freeze was wholly origi nal and is
registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. 99. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Download by Lil Kim featuring T-Pain and Charlie Wilson, which was released in 2009 as a single. Upon information and belief, Defendants Download is not
registered with the U.S. Copyright Office. Brookland Media/Federal Distribution is listed as the copyright owner on the single. Upon information and belief, Nappy Boy Online has an ownership interest in the Download copyright.
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100.
Defendants Download infringes upon Plaintiffs copyrights in Download My Love and Cant Get You Off My Mind tracks. Defendants Download infringes upon Plaintiffs Download My Love track as parts of Defendants Download copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Download, which is nearly identical or similar to Plaintiffs song Download My Love. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song.
101.
Defendants Download infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Download copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords, melody, and beat of
Defendants Download, which is nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords, melody, and beat of Plaintiffs song. 102. Defendants Download infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BOOM 103. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It and Sportsmans Paradise. 104. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Boom by Snoop Dogg featuring T-Pain, which was released in 2011 as a single and as part of Snoop Doggs album Doggumentary. Defendants Boom is registered
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with
the
U.S.
Copyright
Office,
Registration
Numbers
SR0000679040
and
PA0001745570. Registration Number SR0000679040 lists Capitol Records LLC as the Copyright Claimant. Registration Number PA0001745570 lists Universal Music - Z Songs and Nappypub Music as the Copyright Claimants. 105. Defendants Boom infringes upon Plaintiffs copyrights in Bam There You Have It and Sportsmans Paradise tracks. Defendants Boom infringes upon Plaintiffs Bam There You Have It track as parts of Defendants Boom copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and beat of Defendants Boom, which are nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the beat and melody of Plaintiffs song. 106. Defendants Boom infringes upon Plaintiffs Sportsmans Paradise track as parts of Defendants Boom copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Boom, which is nearly identical or similar to Plaintiffs song Sportsmans Paradise. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the meldoy of Plaintiffs song. 107. Defendants Boom infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT CYCLONE 108. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Numbers SR0000194230 and PAu000735442. The
22
(Gon Be Dat) New Orleans Music album included, among other tracks, Its On (The Jam Is On). 109. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Cyclone by Baby Bash featuring T-Pain, which was released in 2007 as a single. Defendants Cyclone is registered with the U.S. Copyright Office, Registration Number PA0001591034. Registration Number PA0001591034 lists EMI Blackwood
Music Inc., Swizole Music (BME), Camore Music, Lil Jizzel Music, and Latin Velvet as the Copyright Claimants. 110. Defendants Cyclone infringes upon Plaintiffs copyrights in Its On (The Jam Is On) track as parts of Defendants Cyclone copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks, melody, and beat of
Defendants Cyclone, which are nearly identical or similar to Plaintiffs song Its On (The Jam Is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hooks, beat, and melody of Plaintiffs song. 111. Defendants Cyclone infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT U GOT ME 112. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. Plaintiffs Freeze was wholly original and is
registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks.
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113.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track U Got Me by T-Pain, which was released in 2005 as part of T-Pains album, Rappa Ternt Sanga. Defendants Rappa Ternt Sanga is registered with the U.S. Copyright Office, Registration Number SR0000381378. Registration Number
SR0000381378 lists Zomba Recording, LLC as the Copyright Claimant. 114. Defendants U Got Me infringes upon Plaintiffs copyrights in Cant Get You Off My Mind track as parts of Defendants U Got Me copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and beat of
Defendants U Got Me, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and beat of Plaintiffs song. 115. Defendants U Got Me infringes upon one (1) of Plaintiffs cop yrights. COPYRIGHT INFRINGEMENT RAP SONG 116. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Runnin Away. Runnin Away is registered with the U.S. Copyright Office, Registration Number SRu000278515. 117. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It.
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118.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Rap Song by T-Pain featuring Rick Ross, which was released in 2010 as a single. Defendants Rap Song is registered with the U.S. Copyright Office, Registration Number PA0001723124. Registration Number PA0001785456 lists Chrysalis Music,
Gnat Booty Music, Element 9 Hip Hop, First And Gold Publishing, Warner-Tamerlane Publishing Corp., Young Money Publishing, Inc., WB Music Corp., Aint Nothing But Funkin Music, Universal Music - Z Tunes, Jazz Merchants Music, Levegas Publishing Company, EMI April Music, Inc., Music Of Windswept, Blotter Music, Elvis Mambo Music, Universal Music Corporation, 50 Cent Music, Nappypub Music, 4 Blunts Lit At Once Publishing, Trac-N-Field Entertainment, Inc., and Shaffer Smith as the Copyright Claimants. 119. Defendants Rap Song infringes upon Plaintiffs copyrights in Runnin Away and Bam There You Have It. Defendants Rap Song infringes upon Plaintiffs Runnin Away track as parts of Defendants Rap Song copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melodies and bridge chords of Defendants Rap Song, which are nearly identical or similar to Plaintiffs song Runnin Away. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melodies and bridge chords of Plaintiffs song. 120. Defendants Rap Song infringes upon Plaintiffs Bam There You Have It track as parts of Defendants Rap Song copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Rap Song, which is nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and
25
belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 121. Defendants Rap Song infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT TURN ALL THE LIGHTS ON 122. In or about 1978, Plaintiff authored music and lyrics in the track Starlite, which was released as a single by the Batiste Brothers Band. Starlite was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000063512. 123. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Turn All the Lights On by T-Pain featuring Ne-Yo, which was released in 2011 as part of T-Pains album, Revolver. Defendants Turn All the Lights On is
registered with the U.S. Copyright Office, Registration Numbers PA0001785456 and PA0001792044. Registration Number PA0001785456 lists Universal Music - Z Songs, Pen In The Ground Publishing, Universal Music - Z Tunes LLC, and Nappypub Music as the Copyright Claimants. Registration Number PA0001792044 lists Oneirology
Publishing, Kasz Money Publishing, Nappypub Music, Universal Music Z Tunes LLC, Pen In The Ground Publishing, and Prescription Songs LLC as the Copyright Claimants. 124. Defendants Turn All the Lights On infringes upon Plaintiffs copyrights in the Starlite track as parts of Defendants Turn All the Lights On copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks, melody, and beat of Defendants Turn All the Lights On, which are nearly identical or similar to Plaintiffs song Starlite. Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the hooks, melody and beat of Plaintiffs song.
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125.
Defendants Turn All the Lights On infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT REGULAR GIRL
126.
Orleans Music album included, among other tracks, Runnin Away. Runnin Away is registered with the U.S. Copyright Office, Registration Number SRu000278515. 127. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Nothin But the Funk. Nothing But the Funk is registered with the U.S. Copyright Office, Registration Number SRu000215931. 128. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, My Bad. 129. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Regular Girl by T-Pain, which was released in 2011 as part of T-Pains album, Revolver. Defendants Regular Girl is registered with the U.S. Copyright Office, Registration Number SR0000697852. Registration Number SR0000697852 lists Sony Music Entertainment as the Copyright Claimant. The Tone
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130.
Defendants Regular Girl infringes upon Plaintiffs copyrights in Runnin Away, Nothin But the Funk, and My Bad tracks. Defendants Regular Girl infringes upon Plaintiffs Runnin Away track as parts of Defendants Regular Girl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Regular Girl, which is nearly identical or similar to Plaintiffs song Runnin Away. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
131.
Defendants Regular Girl infringes upon Plaintiffs Nothin But the Funk track as parts of Defendants Regular Girl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Regular Girl, which are nearly identical or similar to Plaintiffs song Nothin But the Funk. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
132.
Defendants Regular Girl infringes upon Plaintiffs My Bad track as parts of Defendants Regular Girl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the hook of Defendants Regular Girl, which is nearly identical or similar to Plaintiffs song My Bad. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the hook of Plaintiffs song. 133. Defendants Regular Girl infringes upon three (3) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT REALITY SHOW 134. In or about 1982, Plaintiff authored music and lyrics in the track Freeze. Plaintiffs Freeze was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiffs Freeze (track) was recorded and released as part of the Batiste Brothers Bands album Freeze. Freeze (album) was first published in 1982. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind, Its All About the Family, and Hooked on You. Plaintiff is the sole author of the music and lyrics in these tracks. 135. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Reality Show by T-Pain, which was released in 2008 as part of T-Pains album, Thr33 Ringz. Defendants Reality Show is registered with the U.S. Copyright
Office, Registration Number PA0001702944. Registration Number PA0001702944 lists Universal Music - Z Songs, Nappypub Music, Universal Music Corp., Nappy Boy Publ., Ahmadtajz Music, Veracity Music Publ., Universal Music - Z Tunes, Ahmads World, Soul Child Music, as the Copyright Claimants. 136. Defendants U Got Me infringes upon Plaintiffs copyrights in Cant Get You Off My Mind, Its All About the Family, and Hooked on You. Defendants Reality Show infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Reality Show copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and beat of Defendants Reality Show, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon
29
information and belief, Defendants wrongfully copied, among other parts of the song, the chords and beat of Plaintiffs song. 137. Defendants Reality Show infringes upon Plaintiffs Its All About the Family track as parts of Defendants Reality Show cop y and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Reality Show, which is nearly identical or similar to Plaintiffs song Its All About the Family. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 138. Defendants Reality Show infringes upon Plaintiffs Hooked on You track as parts of Defendants Reality Show copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Reality Show, which is nearly identical or similar to Plaintiffs song Hooked on You. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 139. Defendants Reality Show infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT COME AND GET IT 140. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. The Tone
Palette album included, among other tracks, Love Horizon and Shades of Wes. 141. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is
30
registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Goin See the Man. 142. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Come and Get It by T-Pain featuring Ace Hood and Busta Rhymes, which was released in 2013 as a single and is available online. Upon information and belief, Defendants Come and Get It is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to Come and Get It. 143. Defendants Come and Get It infringes upon Plaintiffs copyrights in Love Horizon, Shades of Wes, and Goin See the Man tracks. Defendants Come and Get It infringes upon Plaintiffs Love Horizon track as parts of Defendants Come and Get It copy and/or are strikingly similar to parts of Plaintiffs song. Among these
similarities are the melody and beat of Defendants Come and Get It, which are nearly identical or similar to Plaintiffs song Love Horizon. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and beat of Plaintiffs song. 144. Defendants Come and Get It infringes upon Plaintiffs Shades of Wes track as parts of Defendants Come and Get It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Come and Get It, which are nearly identical or similar to Plaintiffs song Shades of Wes. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 145. Defendants Come and Get It infringes upon Plaintiffs Goin See the Man track as parts of Defendants Come and Get It copy and/or are strikingly similar to parts of
31
Plaintiffs song. Among these similarities are the lyrics of Defendants Come and Get It, which are nearly identical or similar to Plaintiffs song Come and Get It. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the lyrics of Plaintiffs song. 146. Defendants Come and Get It infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT I FUCKED MY AUNT 147. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Goin See the Man. 148. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Runnin Away. Runnin Away is registered with the U.S. Copyright Office, Registration Number SRu000278515. 149. Upon information and belief, Defendants allegedly authored the music and lyrics in the track I Fucked My Aunt by The Lonely Island featuring T-Pain, which was released in 2013 as part of The Lonely Islands album The Whack Album. Upon information and belief, Defendants I Fucked My Aunt is not registered with the U.S. Copyright Office. Upon information and belief, Universal Republic Records, a division of UMG Recordings, Inc., owns the copyright to I Fucked My Aunt.
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150.
Defendants I Fucked My Aunt infringes upon Plaintiffs copyrights in Goin See the Man and Runnin Away tracks. Defendants I Fucked My Aunt infringes upon Plaintiffs Goin See the Man track as parts of Defendants I Fucked My Aunt copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the horns and beat of Defendants I Fucked My Aunt, which are nearly identical or similar to Plaintiffs song Goin See the Man. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the horns and beat of Plaintiffs song.
151.
Defendants I Fucked My Aunt infringes upon Plaintiffs Runnin Away track as parts of Defendants I Fucked My Aunt copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants I Fucked My Aunt, which are nearly identical or similar to Plaintiffs song Runnin Away. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
152.
Defendants I Fucked My Aunt infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BOOTY WURK
153.
Orleans Music album included, among other tracks, Space Station. 154. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Booty Wurk by T-Pain featuring T-Pain and Joey Galaxy, which was released in 2010 as a single. Upon information and belief, Defendants Booty Wurk is not
33
registered with the U.S. Copyright Office. RCA Records, a Division of Sony Music Entertainment, is listed as the copyright owner on the single. 155. Defendants Booty Wurk infringes upon Plaintiffs Space Station track as parts of Defendants Booty Wurk copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and beat of Defendants Booty Wurk, which are nearly identical or similar to Plaintiffs song Space Station. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and beat of Plaintiffs song. 156. Defendants Booty Wurk infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT SHO-TIME 157. In or about 1982, Plaintiff authored music and lyrics in the track Freeze. Plaintiffs Freeze was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiffs Freeze (track) was recorded and released as part of the Batiste Brothers Bands album Freeze. Freeze (album) was first published in 1982. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. 158. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Sho-Time by T-Pain, which was released in 2011 as part of T-Pains album, Revolver. Defendants Sho-Time is registered with the U.S. Copyright Office,
Registration Number PA0001785445. Registration Number PA0001785445 lists David
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Ahmad Balfour, Universal Music - Z Songs, Veracity Music Publishing, Nappypub Music, and Songs Of Universal, Inc. as the Copyright Claimants. 159. Defendants Sho-Time infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Sho-Time copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and beat of Defendants Cant Get You Off My Mind, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and beat of Plaintiffs song. 160. Defendants Sho-Time infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT IM SPRUNG 161. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Drowning in My Blues. 162. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. Plaintiff is the Copyright Claimant. 163. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Im Sprung by T-Pain, which was released in 2005 as part of T-Pains album, Rappa Ternt Sanga. Defendants Rappa Ternt Sanga is registered with the U.S.
35
Copyright Office, Registration Number SR0000381378.
Registration Number
SR0000381378 lists Zomba Recording LLC as the Copyright Claimant. 164. Defendants Im Sprung infringes upon Plaintiffs copyrights in Drowning in My Blues and Cant Get You Off My Mind tracks. Defendants Im Sprung infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants Im Sprung copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat and lyrics of Defendants Im Sprung, which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and lyrics of Plaintiffs song. 165. Defendants Im Sprung infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Im Sprung copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the bridge chords of Defendants Im Sprung, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the bridge chords of Plaintiffs song. 166. Defendants Im Sprung infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT CANT BELIEVE IT 167. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Hooked on You. Plaintiff is the sole author of the music and lyrics in these tracks. Hooked on You is registered with the
36
U.S. Copyright Office, Registration Numbers PAu000051656 and SR0000013672. Plaintiff is the Copyright Claimant. 168. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Slow and Easy. 169. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Cant Believe It by T-Pain featuring Lil Wayne, which was released in 2008 as part of T-Pains album, Thr33 Ringz. Defendants Cant Believe It is registered with the U.S. Copyright Office, Registration Number PA0001702228. Registration Number PA0001702228 lists Universal Music - Z Songs, Nappypub Music, Universal Music Corp., Ahmadtajz Music, Veracity Music, and Young Money Publ., Inc. as the Copyright Claimants. 170. Defendants Cant Believe It infringes upon Plaintiffs copyrights in Hooked On You and Cant Get You Off My Mind tracks. Defendants Cant Believe It infringes upon Plaintiffs Hooked On You track as parts of Defendants Cant Believe It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and melody of Defendants Cant Believe It, which are nearly identical or similar to Plaintiffs song Hooked On You. Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat and melody of Plaintiffs song. 171. Defendants Cant Believe It infringes upon Plaintiffs Slow and Easy track as parts of Defendants Cant Believe It copy and/or are strikingly similar to parts of Plaintiffs
37
song. Among these similarities are the chords of Defendants Cant Believe It, which are nearly identical or similar to Plaintiffs song Slow and Easy. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 172. Defendants Cant Believe It infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT SHE GET IT FROM HER MAMA 173. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Runnin Away. 174. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Drowning in My Blues. 175. Upon information and belief, Defendants allegedly authored the music and lyrics in the track She Get It from Her Mama by Bertell featuring T-Pain, which was released on July 30, 2013 as a single. Upon information and belief, Defendants She Get It from Her Mama is not registered with the U.S. Copyright Office. JBK Music Group/Nappy Boy Productions is listed as the copyright owner on the single. 176. Defendants She Get It from Her Mama infringes upon Plaintiffs copyrights in Runnin Away and Drowning in My Blues tracks. Defendants She Get It from Her Mama infringes upon Plaintiffs Runnin Away track as parts of Defendants She Get
38
It from Her Mama copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and melody of Defendants She Get It from Her Mama, which are nearly identical or similar to Plaintiffs song Runnin Away. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the chords and melody of Plaintiffs song. 177. Defendants She Get It from Her Mama infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants She Get It from Her Mama copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants She Get It from Her Mama, which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 178. Defendants She Get It from Her Mama infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT LOW 179. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Dancin Shoes. Plaintiff is the sole author of the music and lyrics in these tracks. Plaintiff is the Copyright Claimant. 180. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Low by Flo-Rida featuring T-Pain, which was released in 2008 as part of FloRidas album, Mail on Sunday. Defendants Low is registered with the U.S. Registration Number
Copyright Office, Registration Number PA0001644879.
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PA0001644879 lists Sony/ATV Tunes LLC/Mail On Sunday Music, Sony/ATV Songs LLC/Top Quality Publishing, and Universal Music Publishing as the Copyright Claimants. 181. Defendants Low infringes upon Plaintiffs Dancin Shoes track as parts of Defendants Low copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords, lyrics, beat and melody of Defendants Low, which is nearly identical or similar to Plaintiffs song Dancin Shoes. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords, lyrics, beat, and melody of Plaintiffs song. 182. Defendants Low infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT GOOD LIFE 183. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. Plaintiffs Freeze was wholly original and is
registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. 184. In or about 1997, Plaintiff authored music and lyrics in the track Hip Jazz. Hip Jazz is included on Plaintiffs Seductive Recital album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu0003785811. Plaintiff is the Copyright Claimant.
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185.
In or about 1991, Plaintiff authored music and lyrics in the tracks app earing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Louisiana.
186.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Good Life by Kanye West featuring T-Pain, which was released in 2007 as a single and as part of Kanye Wests album, Graduation. Defendants Good Life is registered with the U.S. Copyright Office, Registration Numbers PA0001636567 and PA0001591305. Registration Number PA0001636567 lists Cherry Lane Music
Publishing Company, Inc., John Legend Publishing, EMI Blackwood Music Inc., Please Gimme My Publishing Inc., Universal Music Z Songs, Nappypub Music, and Michael Dean Publishing as the Copyright Claimants. Registration Number PA0001591305 lists EMI Blackwood Music Inc., Toompstone Publishing, Please Gimme My Publishing, Inc., James Ingram Pub., Zomba Music Publishers, Cherry Lane Music Publishing, and Still N The Water Publishing as the Copyright Claimants. 187. Defendants Good Life infringes upon Plaintiffs copyrights in Cant Get You Off My Mind, Hip Jazz, and Spice tracks. Defendants Good Life infringes upon
Plaintiffs Cant Get You Off My Mind track as parts of Defendants Good Life copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and melody of Defendants Good Life, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords and melody of Plaintiffs song.
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188.
Defendants Good Life infringes upon Plaintiffs Hip Jazz track as parts of Defendants Good Life copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Good Life, which is nearly identical or similar to Plaintiffs song Hip Jazz. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 189. Defendants Good Life infringes upon Plaintiffs Spice track as parts of Defendants Good Life copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the lyrics of Defendants Good Life, which is nearly identical or similar to Plaintiffs song Spice. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the lyrics of Plaintiffs song. 190. Defendants Good Life infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT IM ON IT 191. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Numbers SR0000194230 and PAu000735442. The
(Gon Be Dat) New Orleans Music album included, among other tracks, Its On (The Jam Is On) and Space Station. Plaintiff is the Copyright Claimant. 192. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Im On It by Bei Meajor featuring T-Pain, which was released in 2011 and is available online. Upon information and belief, Defendants Im On It is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to Im On It.
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193.
Defendants Im On It infringes upon Plaintiffs copyrights in Its on (The Jam Is On), and Space Station tracks. Defendants Im On It infringes upon Plaintiffs Its on (The Jam Is On) track as parts of Defendants Im On It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and melody of Defendants Im On It, which are nearly identical or similar to Plaintiffs song Its on (The Jam Is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and melody of Plaintiffs song.
194.
Defendants Im On It infringes upon Plaintiffs Space Station track as parts of Defendants Im On It copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Im On It, which is nearly identical or similar to Plaintiffs song Space Station. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song.
195.
Defendants Im On It infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT GO GIRL
196.
Orleans Music album included, among other tracks, Space Station. 197. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Go Girl by Ciara featuring T-Pain, which was released in 2008 as a single and as part of Ciaras album, Fantasy Ride. Defendants Go Girl is registered with the U.S.
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Copyright Office, Registration Number PA0001640177.
Registration Number
PA0001640177 lists LaFace Records LLC as the Copyright Claimant. Upon information and belief, LaFace Records LLC is a wholly owned division of Sony Music Entertainment. 198. Defendants Go Girl infringes upon Plaintiffs Space Station track as parts of Defendants Go Girl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat, chords, and melody of Defendants Go Girl, which are nearly identical or similar to Plaintiffs song Space Station. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the beat, chords, and melody of Plaintiffs song. 199. Defendants Go Girl infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT MIND FUCKED 200. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. Plaintiff is the Copyright Claimant. The Freeze album included, among other tracks, Never Leave You Baby. Never Leave You Baby is registered with the U.S. Copyright Office, Registration Number SR0000013673. Plaintiff is the Copyright Claimant. 201. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. The Tone
Palette album included, among other tracks, Its Time to Celebrate and Ill Be There.
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202.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Mind Fucked by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants Mind Fucked is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to Mind Fucked.
203.
Defendants Mind Fucked infringes upon Plaintiffs copyrights in Never Leave You Baby, Its Time to Celebrate, and Ill Be There tracks. Defendants Mind Fucked infringes upon Plaintiffs Never Leave You Baby track as parts of Defendants Mind Fucked copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and melody of Defendants Mind Fucked, which are nearly identical or similar to Plaintiffs song Never Leave You Baby. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords and melody of Plaintiffs song.
204.
Defendants Mind Fucked infringes upon Plaintiffs Its Time to Celebrate track as parts of Defendants Mind Fucked copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and the lyrics of Defendants Mind Fucked, which are nearly identical or similar to Plaintiffs song Its Time to Celebrate. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and lyrics of Plaintiffs song.
205.
Defendants Mind Fucked infringes upon Plaintiffs Ill Be There track as parts of Defendants Mind Fucked copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Mind Fucked, which are nearly identical or similar to Plaintiffs song Ill Be There. Upon information and belief,
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Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 206. Defendants Mind Fucked infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT SHAWTY GET LOOSE 207. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Space Station. 208. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Shawty Get Loose by Lil Mama featuring T-Pain and Chris Brown, which was released in 2008 as a single and as part of Lil Mamas album, VYP (Voice of the Young People). Defendants Shawty Get Loose is registered with the U.S. Copyright Office, Registration Number PA0001669337. Registration Number PA0001669337 lists N
Kirkland Publ., Universal Music - Z Songs, and Nappypub Music as the Copyright Claimants. 209. Defendants Shawty Get Loose infringes upon Plaintiffs Space Station track as parts of Defendants Space Station copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords, beat, and melody of Defendants Mind Fucked, which are nearly identical or similar to Plaintiffs song Space Station. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords, beat, and melody of Plaintiffs song. 210. Defendants Shawty Get Loose infringes upon one (1) of Plaintiffs copyrights.
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COPYRIGHT RIGHT INFRINGEMENT KISS KISS 211. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Numbers SR0000194230 and PAu000735442. The
(Gon Be Dat) New Orleans Music album included, among other tracks, Its On (The Jam Is On). 212. In or about 1999, Plaintiff authored music and lyrics in the track Sportsmans Paradise. Sportsmans Paradise is included on Plaintiffs Move That Body album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu000409184. Plaintiff is the Copyright Claimant. 213. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Kiss Kiss by Chris Brown featuring T-Pain, which was released in 2007 as a single and as part of Chris Browns album, Exclusive. Defendants Kiss Kiss is registered with the U.S. Copyright Office, Registration Number PA0001395675. Registration Number PA0001395675 lists Songs of Universal, Inc., Culture Beyond Ur Experience Publishing, Universal Music Z Songs, and Nappypub Music as the Copyright Claimants. 214. Defendants Kiss Kiss infringes upon Plaintiffs copyrights in Its On (The Jam is On) and Sportsmans Paradise tracks. Defendants Kiss Kiss infringes upon
Plaintiffs Its On (The Jam is On) track as parts of Defendants Kiss Kiss copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and beat of Defendants Kiss Kiss, which are nearly identical or similar to
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Plaintiffs song Its On (The Jam is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and beat of Plaintiffs song. 215. Defendants Kiss Kiss infringes upon Plaintiffs Sportsmans Paradise track as parts of Defendants Kiss Kiss copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the chant of Defendants Kiss Kiss, which is nearly identical or similar to Plaintiffs song Sportsmans Paradise. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chant of Plaintiffs song. 216. Defendants Kiss Kiss infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT WOOL OVER MY EYES 217. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Do It Right Now. 218. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Wool Over My Eyes by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants Wool Over My Eyes is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to Wool Over My Eyes. 219. Defendants Wool Over My Eyes infringes upon Plaintiffs Do It Right Now track as parts of Defendants Wool Over My Eyes copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat, melody, and chords of
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Defendants Wool Over My Eyes, which are nearly identical or similar to Plaintiffs song Do It Right Now. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat, melody, and chords of Plaintiffs song. 220. Defendants Wool Over My Eyes infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT GOING OFF 221. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Ring Me and Download My Love. 222. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Going Off by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants Going Off is not registered with the U.S. Copyright Office. copyright to Going Off. 223. Defendants Going Off infringes upon Plaintiffs copyrights in Ring Me and Download My Love tracks. Defendants Going Off infringes upon Plaintiffs Ring Me track as parts of Defendants Going Off copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Going Off, which is nearly identical or similar to Plaintiffs song Ring Me. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 224. Defendants Going Off infringes upon Plaintiffs Download My Love track as parts of Defendants Going Off copy and/or are strikingly similar to parts of Plaintiffs song. Upon information and belief, Nappypub Music owns the
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Among these similarities are the chords and melody of Defendants Going Off, which is nearly identical or similar to Plaintiffs song Download My Love. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords and melody of Plaintiffs song. 225. Defendants Going Off infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT THE CHAMP 226. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Numbers SR0000194230 and PAu000735442. The
(Gon Be Dat) New Orleans Music album included, among other tracks, Its On (The Jam Is On). 227. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Fur Elise. 228. Upon information and belief, Defendants allegedly authored the music and lyrics in the track The Champ by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants The Champ is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to The Champ. 229. Defendants The Champ infringes upon Plaintiffs copyrights in Its On (The Jam is On) and Fur Elise tracks. Defendants The Champ infringes upon Plaintiffs Its The Tone
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On (The Jam is On) track as parts of Defendants The Champ copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and hooks of Defendants The Champ, which are nearly identical or similar to Plaintiffs song Its On (The Jam is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and hooks of Plaintiffs song. 230. Defendants The Champ infringes upon Plaintiffs Fur Elise track as parts of Defendants The Champ copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants The Champ, which are nearly identical or similar to Plaintiffs song Fur Elise. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 231. Defendants The Champ infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT DONT YOU QUIT 232. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. Orleans Music album included, among other tracks, Kids. 233. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Dont You Quit by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants Dont You Quit is not The (Gon Be Dat) New
registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to Dont You Quit.
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234.
Defendants Dont You Quit infringes upon Plaintiffs Kids track as parts of Defendants Dont You Quit copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and melody of Defendants Dont You Quit, which are nearly identical or similar to Plaintiffs song Kids. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and melody of Plaintiffs song.
235.
Defendants Dont You Quit infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT FAIRY TALE
236.
In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Drowning in My Blues.
237.
In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. Plaintiff is the Copyright Claimant. The Freeze album included, among other tracks, Never Leave You Baby. Never Leave You Baby is registered with the U.S. Copyright Office, Registration Number SR0000013673. Plaintiff is the Copyright Claimant. 238. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Fairy Tale by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants Fairy Tale is not registered with the U.S. Copyright Office. copyright to Fairy Tale. Upon information and belief, Nappypub Music owns the
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239.
Defendants Fairy Tale infringes upon Plaintiffs copyrights in Drowning in My Blues and Never Leave You Baby tracks. Defendants Fairy Tale infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants Fairy Tale copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and chords of Defendants Fairy Tale, which are nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and chords of Plaintiffs song.
240.
Defendants Fairy Tale infringes upon Plaintiffs Never Leave You Baby track as parts of Defendants Fairy Tale copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Fairy Tale, which is nearly identical or similar to Plaintiffs song Never Leave You Bab y. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 241. Defendants Fairy Tale infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT RHOCK EN ROLLAH 242. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. The Tone
Palette album included, among other tracks, Romantic Sequence and Tiger (Travis). 243. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Rhock En Rollah by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants Rhock En Rollah is not
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registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to Rhock En Rollah. 244. Defendants Rhock En Rollah infringes upon Plaintiffs copyrights in Romantic Sequence and Tiger (Travis) tracks. Defendants Rhock En Rollah infringes upon Plaintiffs Romantic Sequence track as parts of Defendants Rhock En Rollah copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and chords of Defendants Rhock En Rollah, which are nearly identical or similar to Plaintiffs song Romantic Sequence. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody and chords of Plaintiffs song. 245. Defendants Rhock En Rollah infringes upon Plaintiffs Tiger (Travis) track as parts of Defendants Rhock En Rollah copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Rhock En Rollah, which is nearly identical or similar to Plaintiffs song Tiger (Travis). Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 246. Defendants Rhock En Rollah infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BLAPPER 247. In or about 1997, Plaintiff authored music and lyrics in the track Hip Jazz. Hip Jazz is included on Plaintiffs Seductive Recital album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu0003785811. Plaintiff is the Copyright Claimant.
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248.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Blapper by T-Pain, which was released in 2012 as part of T-Pains mix tape, Stoic. Upon information and belief, Defendants Blapper is not registered with the U.S. Copyright Office. copyright to Blapper. Upon information and belief, Nappypub Music owns the
249.
Defendants Blapper infringes upon Plaintiffs Hip Jazz track as parts of Defendants Blapper copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and melody of Defendants Blapper, which are nearly identical or similar to Plaintiffs song Hip Jazz. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and melody of Plaintiffs song.
250.
Defendants Blapper infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BODY LANGUAGE
251.
252.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Body Language by Jesse McCartney featuring T-Pain, which was released in 2009 as a single and as part of Jesse McCartneys album, Departure: Recharged. Defendants Body Language is registered with the U.S. Copyright Office, Registration Number PA0001667353. Registration Number PA0001667353 lists Jambition Music,
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Holy Corron, Move J B Songs, Nappypub Music, Universal Music - MGB Songs, Universal Music Z Songs, and Songs of Universal, Inc. as the Copyright Claimants. 253. Defendants Body Language infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants Body Language copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and beat of Defendants Body Language, which are nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and beat of Plaintiffs song. 254. Defendants Body Language infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT U AND DAT 255. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Spice. 256. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Numbers SR0000194230 and PAu000735442. The
(Gon Be Dat) New Orleans Music album included, among other tracks, Its On (The Jam Is On). 257. Upon information and belief, Defendants allegedly authored the music and lyrics in the track U and Dat by E40 featuring T-Pain and Kandi Girl, which was released in 2006 as a single and as part of E40s album, My Ghetto Report Card. Defendants U and
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Dat is registered with the U.S. Copyright Office, Registration Numbers PA0001163993 and PA0001352600. Registration Number PA0001163993 lists Zomba Songs, Nappy Boy Publishing, Inc., and EMI April Music, Inc. as the Copyright Claimants. Registration Number PA0001352600 lists Air Control Music, Kandacy Music, Zomba Songs, Nappy Boy Publishing, Inc., and EMI April Music, Inc. as the Copyright Claimants. 258. Defendants U and Dat infringes upon Plaintiffs copyrights in Spice and Its On (The Jam Is On) tracks. Defendants U and Dat infringes upon Plaintiffs Spice track as parts of Defendants U and Dat copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants U and Dat, which is nearly identical or similar to Plaintiffs song Spice. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 259. Defendants U and Dat infringes upon Plaintiffs Its On (The Jam Is On) track as parts of Defendants U and Dat copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants U and Dat, which i s nearly identical or similar to Plaintiffs song Its On (The Jam Is On). Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 260. Defendants U and Dat infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT HEY BABY (DROP IT TO THE FLOOR) 261. In or about 1978, Plaintiff authored music and lyrics in the single Starlite. The
Starlite single was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000063512. Plaintiff is the Copyright Claimant.
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262.
In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Love Horizon. The Tone
263.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Hey Baby (Drop it to the Floor) by Pitbull featuring T-Pain, which was released in 2011 as a single and as part of Pitbulls album, Planet Pit. Defendants Hey Baby (Drop it to the Floor) is registered with the U.S. Copyright Office, Registration Numbers PA0001719812 and PA0001820419. Registration Number PA0001719812 lists Pitbulls Legacy Music Publishing, Universal Music Publishing, and Ultra International Music Publishing LLC as the Copyright Claimants. Registration Number PA0001820419 lists Universal Music - Z Songs, Nappypub Music, and Pitbulls Legacy as the Copyright Claimants.
264.
Defendants Hey Baby (Drop it to the Floor) infringes upon Plaintiffs copyrights in Starlite and Love Horizon tracks. Defendants Hey Baby (Drop it to the Floor) infringes upon Plaintiffs Starlite track as parts of Defendants Hey Baby (Drop it to the Floor) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Hey Baby (Drop it to the Floor), which is nearly identical or similar to Plaintiffs song Starlite. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 265. Defendants Hey Baby (Drop it to the Floor) infringes upon Plaintiffs Love Horizon track as parts of Defendants Hey Baby (Drop it to the Floor) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of
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Defendants Hey Baby (Drop it to the Floor), which is nearly identical or similar to Plaintiffs song Love Horizon. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 266. Defendants Hey Baby (Drop it to the Floor) infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT TAKE YOUR SHIRT OFF 267. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It and Move That Body. 268. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Take Your Shirt Off by T-Pain, which was released in 2009 as a single. Upon information and belief, Defendants Take Your Shirt Off is not registered with the U.S. Copyright Office. Upon information and belief, RCA/JIVE Label Group, a unit of Sony Music Entertainment, owns the copyright to Take Your Shirt Off. 269. Defendants Take Your Shirt Off infringes upon Plaintiffs copyrights in Bam There You Have It and Move That Body tracks. Defendants Take Your Shirt Off
infringes upon Plaintiffs Bam There You Have It track as parts of Defendants Take Your Shirt Off copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Take Your Shirt Off, which is nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and
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belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 270. Defendants Take Your Shirt Off infringes upon Plaintiffs Move That Body track as parts of Defendants Take Your Shirt Off copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Take Your Shirt Off, which is nearly identical or similar to Plaintiffs song Move That Body. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 271. Defendants Take Your Shirt Off infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT SHAKE SENORA 272. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. The Tone
Palette album included, among other tracks, Tropical Blue and Ill Be There. 273. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Shake Senora by Pitbull featuring T-Pain and Sean Paul, which was released in 2010 as a single and as part of Pitbulls album, Planet Pit. Defendants Shake Senora is registered with the U.S. Copyright Office, Registration Number PA0001820421. Registration Number PA0001719812 lists Pitbulls Legacy, Universal Music - Z Songs, and Nappypub Music as the Copyright Claimants. 274. Defendants Shake Senora infringes upon Plaintiffs copyrights in Tropical Blue and Ill Be There tracks. Defendants Shake Senora infringes upon Plaintiffs Tropical Blue track as parts of Defendants Shake Senora copy and/or are strikingly s imilar to
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parts of Plaintiffs song. Among these similarities are the beat and chords of Defendants Shake Senora, which are nearly identical or similar to Plaintiffs song Tropical Blue. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and chords of Plaintiffs song. 275. Defendants Shake Senora infringes upon Plaintiffs Ill Be There track as parts of Defendants Shake Senora copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of the introduction of Defendants Shake Senora, which is nearly identical or similar to Plaintiffs song Ill Be There. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 276. Defendants Shake Senora infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT IM DANCING 277. In or about 1978, Plaintiff authored music and lyrics in the single Starlite. The
Starlite single was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000063512. Plaintiff is the Copyright Claimant. 278. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Numbers SR0000194230 and PAu000735442. The
(Gon Be Dat) New Orleans Music album included, among other tracks, Its On (The Jam Is On). 279. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Im Dancing by T-Pain featuring Flo-Rida, which was released in 2011 as a
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single and is available online. Upon information and belief, Defendants Im Dancing is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to Im Dancing. 280. Defendants Im Dancing infringes upon Plaintiffs copyrights in Starlite and Its On (The Jam Is On) tracks. Defendants Im Dancing infringes upon Plaintiffs Starlite track as parts of Defendants Im Dancing copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Im Dancing, which is nearly identical or similar to Plaintiffs song Starlite. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 281. Defendants Im Dancing infringes upon Plaintiffs Its On (The Jam Is On) track as parts of Defendants Im Dancing copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and melody of Defendants Im Dancing, which are nearly identical or similar to Plaintiffs song Its On (The Jam Is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and melody of Plaintiffs song. 282. Defendants Im Dancing infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BEAM ME UP 283. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Space Station.
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284.
registered with the U.S. Copyright Office, Registration Number SR0000324875. Plaintiff is the Copyright Claimant. The Freeze album included, among other tracks, Party Down. Never Leave You Baby is registered with the U.S. Copyright Office,
Registration Number PAu000390551. Plaintiff is the Copyright Claimant. 285. In or about 1978, Plaintiff authored music and lyrics in the track Starlite, which was released as a singly by the Batiste Brothers Band. Starlite was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000063512. 286. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Beam Me Up by Tay Dizm featuring T-Pain and Rick Ross, which was released in 2008 as a single and is available online. Upon information and belief, Defendants Beam Me Up is not registered with the U.S. Copyright Office. Upon information and belief, Nappy Boy Online owns the copyright to Im Dancing. 287. Defendants Beam Me Up infringes upon Plaintiffs copyrights in Space Station, Party Down, and Starlite tracks. Defendants Beam Me Up infringes upon
Plaintiffs Starlite track as parts of Defendants Beam Me Up copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and hooks of Defendants Beam Me Up, which are nearly identical or similar to Plaintiffs song Starlite. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and hooks of Plaintiffs song. 288. Defendants Beam Me Up infringes upon Plaintiffs Party Down track as parts of Defendants Beam Me Up copy and/or are strikingly similar to parts of Plaintiffs song.
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Among these similarities are the chords of Defendants Beam Me Up, which are nearly identical or similar to Plaintiffs song Party Down. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 289. Defendants Beam Me Up infringes upon Plaintiffs Starlite track as parts of Defendants Beam Me Up copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of the introduction of Defendants Beam Me Up, which are nearly identical or similar to Plaintiffs song Starlite. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the melody of the introduction of Plaintiffs song. 290. Defendants Im Dancing infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BILLIONAIRE 291. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Reggae Music and Download My Love. 292. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Louisiana. 293. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is
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registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues). 294. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Billionaire by Travie McCoy, which was released in 2010 as a single and as part of Travie McCoys album, Lazarus. Upon information and belief, T-Pain was a
producer of Lazarus. Upon information and belief, Travie McCoy is signed to T-Pains record label, Nappy Boy. Defendants Billionaire is registered with the U.S. Copyright Office, Registration Numbers PA0001740847 and PA0001697965. Registration Number PA0001740847 lists Thou Art The Hunger & Northside Independent Music Publishing and Mars Force Music, Music Famamanem, Toy Plane Music, & Epileptic Caesar Music as the Copyright Claimants. Registration Number PA0001697965 lists Bughouse,
Northside Independent Music Publishing, Mars Force Music, Toy Plane Music, Art For Arts Sake, Music Famamanem, and Epileptic Caesar as the Copyright Claimants. Lazarus is registered with the U.S. Copyright Office, Registration Number SR0000706137. Registration Number SR0000706137 lists Fueled by Ramen, LLC C/O Atlantic Recording Corp. as the Copyright Claimant. 295. Defendants Billionaire infringes upon Plaintiffs copyrights in Reggae Music, Download My Love, Louisiana, and Still (Singing the Blues) tracks. Defendants Billionaire infringes upon Plaintiffs Reggae Music track as parts of Defendants Billionaire copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and chords of Defendants Billionaire, which are nearly identical or similar to Plaintiffs song Reggae Music. Upon information and belief,
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Defendants wrongfully copied, among other parts of the song, the beat and chords of Plaintiffs song. 296. Defendants Billionaire infringes upon Plaintiffs Download My Love track as parts of Defendants Billionaire copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and chords of Defendants Billionaire, which are nearly identical or similar to Plaintiffs song Download My Love. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the melody and chords of Plaintiffs song. 297. Defendants Billionaire infringes upon Plaintiffs Louisiana track as parts of Defendants Billionaire copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Billionaire, which is nearly identical or similar to Plaintiffs song Louisiana. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 298. Defendants Billionaire infringes upon Plaintiffs Still (Singing the Blues) track as parts of Defendants Billionaire copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of the bridge of Defendants Billionaire, which is nearly identical or similar to the melody of the introduction of Plaintiffs song Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 299. Defendants Billionaire infringes upon four (4) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT CHURCH 300. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Space Station. 301. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Fur Elise. 302. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Sportsmans Paradise. 303. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Church by T-Pain, which was released in 2007 as a single and as part of T-Pains album, Epiphany. Defendants Church is registered with the U.S. Copyright Office, Registration Numbers PA0001629727, PA0001649974 and PA0001167778. Registration Number PA0001629727 lists Zomba Recording LLC as the Copyright Claimant. Registration Number PA0001649974 lists Nappypub Music and Universal Music - Z Songs as the Copyright Claimants. Registration Number PA0001167778 lists Zomba Songs and Nappypub Music as the Copyright Claimants. The Tone
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304.
Defendants Church infringes upon Plaintiffs copyrights in Space Station, Fur Elise, and Sportsmans Paradise tracks. Defendants Church infringes upon
Plaintiffs Space Station track as parts of Defendants Church copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Church, which is nearly identical or similar to Plaintiffs song Space Station. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 305. Defendants Church infringes upon Plaintiffs Fur Elise track as parts of Defendants Church copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Church, which are nearly identical or similar to Plaintiffs song Fur Elise. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 306. Defendants Church infringes upon Plaintiffs Sportsmans Paradise track as parts of Defendants Church copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks of Defendants Church, which are nearly identical or similar to Plaintiffs song Sportsmans Paradise. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hooks of Plaintiffs song. 307. Defendants Church infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT SAVE ME 308. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. Plaintiffs Freeze was wholly original and is
registered with the U.S. Copyright Office, Registration Number PAu000390579.
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Plaintiff is the Copyright Claimant. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. 309. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Runnin Away. 310. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Save You by T-Pain featuring One Chance, which was released in 2010 as part of T-Pains album, Freaknik: The Musical. Defendants Save You is recorded with the U.S. Copyright Office, Document Number V3594D671. Upon information and belief, JIVE Records, a unit of Sony Music Entertainment, Songs of Universal, Inc., Henderworks Publishing Company, and Nappypub Music own the copyright to Save You. 311. Defendants Save You infringes upon Plaintiffs copyrights in Cant Get You Off My Mind and Runnin Away tracks. Defendants Save You infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Save You copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Save You, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
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312.
Defendants Save You infringes upon Plaintiffs Runnin Away track as parts of Defendants Save You copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and beat of Defendants Save You, which are nearly identical or similar to Plaintiffs song Runnin Away. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and beat of Plaintiffs song.
313.
Defendants Save You infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT FREAKNIK IS BACK
314.
In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Fur Elise. The Tone
315.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Freaknik Is Back by T-Pain, which was released in 2010 as part of T-Pains album, Freaknik: The Musical. Defendants Freaknik Is Back is recorded with the U.S. Copyright Office, Document Number V3594D671. Upon information and belief, JIVE Records, a unit of Sony Music Entertainment, Songs of Universal, Inc., Henderworks Publishing Company, and Nappypub Music own the copyright to Freaknik Is Back.
316.
Defendants Freaknik Is Back infringes upon Plaintiffs Fur Elise track as parts of Defendants Freaknik Is Back copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and beat of Defendants Freaknik Is Back, which are nearly identical or similar to Plaintiffs song Fur Elise. Upon
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information and belief, Defendants wrongfully copied, among other parts of the song, the chords and beat of Plaintiffs song. 317. Defendants Freaknik Is Back infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BUY YOU A DRANK (SHAWTY SNAPPIN) 318. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Drowning in My Blues. 319. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Ill Be There. 320. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Buy You A Drank (Shawty Snappin) by T-Pain featuring Yung Joc, which was released in 2007 as a single and as part of T-Pains album, Epiphany. Defendants Buy You A Drank (Shawty Snappin) is registered with the U.S. Copyright Office, Registration Numbers PA0001649953 and PA0001601621. Registration Number The Tone
PA0001649953 lists Nappypub Music, 30318 Underground Music Publ., Universal Music - Z Songs, and Warner-Tamerlane Publ. Corp. as the Copyright Claimants. Registration Number PA0001601621 lists NappyPub Music, Granny Man Publishing, Malik/Mehi Music, Basement Funk South, and TVT Music Enterprises, LLC as the Copyright Claimants.
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321.
Defendants Buy You A Drank (Shawty Snappin) infringes upon Plaintiffs copyrights in Drowning in My Blues and Ill Be There tracks. Defendants Buy You A Drank (Shawty Snappin) infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants Buy You A Drank (Shawty Snappin) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Buy You A Drank (Shawty Snappin), which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
322.
Defendants Buy You A Drank (Shawty Snappin) infringes upon Plaintiffs Ill Be There track as parts of Defendants Buy You A Drank (Shawty Snappin) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melody and chords of Defendants Buy You A Drank (Shawty Snappin), which are nearly identical or similar to Plaintiffs song Ill Be There. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody and chords of Plaintiffs song.
323.
Defendants Buy You A Drank (Shawty Snappin) infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT SHOW U HOW
324.
In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues).
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325.
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Hooked on You and Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. Hooked on You is registered with the U.S. Copyright Office, Registration Numbers PAu000051656 and SR0000013672. Plaintiff is the Copyright Claimant. 326. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Show U How by T-Pain, which was released in 2007 as a single and as part of TPains album, Epiphany. Defendants Show U How is registered with the U.S. Copyright Office, Registration Numbers PA0001649977 and PA0001167780.
Registration Number PA0001649977 lists Nappypub Music and Universal Music - Z Songs as the Copyright Claimants. Registration Number PA0001167780 lists Zomba Songs and Nappypub Music as the Copyright Claimants. 327. Defendants Show U How infringes upon Plaintiffs copyrights in Still (Singing the Blues), Hooked on You, and Cant Get You Off My Mind. Defendants Show U How infringes upon Plaintiffs Still (Singing the Blues) track as parts of Defendants Show U How copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Show U How, which are nearly identical or similar to Plaintiffs song Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
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328.
Defendants Show U How infringes upon Plaintiffs Hooked on You track as parts of Defendants Show U How copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Show U How, which is nearly identical or similar to Plaintiffs song Hooked on You. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
329.
Defendants Show U How infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Show U How copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Show U How, which is nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song.
330.
Defendants Show U How infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT PUT IT DOWN
331.
In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, I Like Your Way.
332.
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Pl aintiff is the sole author of the music and lyrics in these tracks.
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333.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Put It Down by T-Pain, which was released in 2007 as part of T-Pains album, Epiphany. Defendants Put It Down is registered with the U.S. Copyright Office, Registration Numbers PA0001649989 and PA0001167783. Registration Number
PA0001649989 lists Nappypub Music and Universal Music - Z Songs as the Copyright Claimants. Registration Number PA0001167783 lists Zomba Songs and Nappypub
Music as the Copyright Claimants. 334. Defendants Put It Down infringes upon Plaintiffs copyrights in I Like Your Way and Cant Get You Off My Mind. Defendants Put It Down infringes upon
Plaintiffs I Like Your Way track as parts of Defendants Put It Down copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and melody of Defendants Put It Down, which are nearly identical or similar to Plaintiffs song I Like Your Way. Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat and melody of Plaintiffs song. 335. Defendants Put It Down infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants Put It Down copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Put It Down, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 336. Defendants Put It Down infringes upon three (3) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT IM A FREAK 337. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Drowning in My Blues. 338. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Im a Freak by Young Cash, which was released in 2009 as a single and is available online. Upon information and belief, Defendants Im a Freak is not
registered with the U.S. Copyright Office. Upon information and belief, Nappy Boy Digital owns the copyright to Im a Freak. 339. Defendants Im a Freak infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants Im a Freak copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat, melody, and hooks of
Defendants Im a Freak, which are nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat, melody, and hooks of Plaintiffs song. 340. Defendants Im a Freak infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT FREAKY SONG 341. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues).
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342.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Freaky Song by Notty Black featuring T-Pain, which was released in 2010 as a single and is available online. Upon information and belief, Defendants Freaky Song is not registered with the U.S. Copyright Office. Upon information and belief, Phase One Network owns the copyright to Freaky Song.
343.
Defendants Freaky Song infringes upon Plaintiffs Still (Singing the Blues) track as parts of Defendants Freaky Song copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and melody of Defendants Freaky Song, which are nearly identical or similar to Plaintiffs song Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords and melody of Plaintiffs song.
344.
Defendants Freaky Song infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT REGGAE NIGHT
345.
In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Blues Man.
346.
In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It.
347.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Reggae Night by T-Pain, which was released in 2007 as part of T-Pains album,
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Epiphany. Defendants Reggae Night is registered with the U.S. Copyright Office, Registration Number PA0001649960. Registration Number PA0001649960 lists
Nappypub Music and Universal Music - Z Songs as the Copyright Claimants. 348. Defendants Reggae Night infringes upon Plaintiffs copyrights in Blues Man and Bam There You Have It. Defendants Reggae Night infringes upon Plaintiffs
Blues Man track as parts of Defendants Reggae Night copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of
Defendants Reggae Night, which is nearly identical or similar to Plaintiffs song Blues Man. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 349. Defendants Reggae Night infringes upon Plaintiffs Bam There You Have It track as parts of Defendants Reggae Night copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Reggae Night, which is nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 350. Defendants Reggae Night infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT STRESSIN 351. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Romantic Sequence. The Tone
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352.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Stressin by Ace Hood, which was released in 2008 as part of the album, DJ Khaled Presents Ace Hood Gutta. Defendants DJ Khaled Presents Ace Hood Gutta is registered with the U.S. Copyright Office, Registration Number SR0000619580. Registration Number SR0000619580 lists The Island Def Jam Music Group, a division of UMG Recordings, Inc., as the Copyright Claimant.
353.
Defendants Stressin infringes upon Plaintiffs Romantic Sequence track as parts of Defendants Stressin copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and chords of Defendants Stressin, which is nearly identical or similar to Plaintiffs song Romantic Sequence. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and chords of Plaintiffs song.
354.
Defendants Stressin infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT HOLLA HOLLA
355.
In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, My Bad. The Tone
356.
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357.
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Its All About the Family. Plaintiff is the sole author of the music and lyrics in these tracks. Plaintiffs Its All About the Family was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000390611. Plaintiff is the Copyright Claimant. 358. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Holla Holla by Akon and T-Pain, which was released in 2008 as part of Akons album, Freedom. Defendants Holla Holla is registered with the U.S. Copyright Office, Registration Numbers PA0001699596 and PA0001754356. Registration Number PA0001699596 lists Universal Music Corp., Nappy Boy Publ., Ahmadtajz Music, Veracity Music Publ., Universal Music - Z Songs, and Nappypub Music as the Copyright Claimants. Registration Number PA0001754356 lists Sony/ATV Music Publishing LLC and Byefall Productions, Inc. as the Copyright Claimants. 359. Defendants Holla Holla infringes upon Plaintiffs copyrights in My Bad, Drowning in My Blues and Its All About the Family. Defendants Holla Holla infringes upon Plaintiffs My Bad track as parts of Defendants Holla Holla copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the hook of Defendants Holla Holla, which is nearly identical or similar to Plaintiffs song My Bad. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hook of Plaintiffs song.
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360.
Defendants Holla Holla infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants Holla Holla copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Holla Holla, which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
361.
Defendants Holla Holla infringes upon Plaintiffs Its All About the Family track as parts of Defendants Holla Holla copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Holla Holla, which are nearly identical or similar to Plaintiffs song Its All About the Family. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
362.
Defendants Holla Holla infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT 69
363.
In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Download My Love.
364.
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks.
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365.
366.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track 69 by Akon and T-Pain featuring J Lyriq, which was released in 20078 as part of T-Painss album, Epiphany. Defendants 69 is registered with the U.S. Copyright Office, Registration Numbers PA0001597116, PA0001649957 and PA0001167786. Registration Number PA0001597116 lists Chrysalis Music Publishing LLC, Gnat Booty Music, Zomba Songs, Inc, Nappypub Songs, Hitco South, Drugstore Publishing, Ghetto Street Funk Music, Nothing Dale Songs, and Music of Windswept as the Copyright Claimants. Registration Number PA0001649957 lists Nappypub Music, Ghetto Street Funk Music, Drugstore Publ., Gnat Booty Music, Chrysalis Music, Universal Music - Z Songs, and Hitco South as the Copyright Claimants. Registration Number
PA0001167786 lists Zomba Songs and Nappypub Music as the Copyright Claimants. 367. Defendants 69 infringes upon Plaintiffs copyrights in Download My Love, Cant Get You Off My Mind, and Drowning in My Blues. Defendants 69 infringes upon Plaintiffs Download My Love track as parts of Defendants 69 copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the hook of Defendants 69, which is nearly identical or similar to Plaintiffs song Download My Love. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hook of Plaintiffs song.
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368.
Defendants 69 infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants 69 copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants 69, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
369.
Defendants 69 infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants 69 copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants 69, which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
370.
Defendants 69 infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT 5 OCLOCK
371.
In or about 1997, Plaintiff authored music and lyrics in the track Just You and I. Just You and I is included on Plaintiffs Seductive Recital album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu0003785811. Plaintiff is the Copyright Claimant.
372.
373.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track 5 OClock by T-Pain featuring Wiz Khalifa and Lily Allen, which was released in
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2011 as a single and as part of T-Pains album, Revolver. Defendants 5 OClock is registered with the U.S. Copyright Office, Registration Numbers PA0001846695 and PA0001785443. Registration Number PA0001846695 lists Mark Owen, Wiz Khalifa Publishing, Warner Tamerlane Publishing Corp., Nappypub Music, EMI Music Publishing Ltd., Songs of Polygram International Inc., Kurstin Music, Sony ATV Music Publishing LTD, Universal Music Publishing Ltd, and Universal Polygram International Pub as the Copyright Claimants. Registration Number PA0001846695 lists Universal Music - Z Songs, Universal Music Publishing Ltd., Universal Music Publishing MGB Ltd, and Nappypub Music as the Copyright Claimants. 374. Defendants 5 OClock infringes upon Plaintiffs copyrights in Just You and I and Drowning in My Blues. Defendants 5 OClock infringes upon Plaintiffs Just You and I track as parts of Defendants 5 OClock copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and melody of
Defendants 5 OClock, which are nearly identical or similar to Plaintiffs song Just You and I. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords and melody of Plaintiffs song. 375. Defendants 5 OClock infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants 5 OClock copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants 5 OClock, which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 376. Defendants 5 OClock infringes upon two (2) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT YOU KNOW WHAT IT IS 377. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. 378. Upon information and belief, Defendants allegedly authored the music and lyrics in the track You Know What It Is by T-Pain and Lil Wayne, which was released in 2010 as a single and is available online. Upon information and belief, Defendants You Know What It Is is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the copyright to You Know What It Is. 379. Defendants You Know What It Is infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants You Know What It Is copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords, beat, and hook of Defendants You Know What It Is, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords, beat, and hook of Plaintiffs song. 380. Defendants You Know What It Is infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BANG BANG POW POW 381. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. The
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Freeze album included, among other tracks, Its All About the Family. Plaintiff is the sole author of the music and lyrics in these tracks. Plaintiffs Its All About the Family was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000390611. Plaintiff is the Copyright Claimant. 382. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Nothin But the Funk. Nothing But the Funk is registered with the U.S. Copyright Office, Registration Number SRu000215931. 383. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Oh Carnival. 384. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Bang Bang Pow Pow by T-Pain and Lil Wayne, which was released in 2011 as part of T-Pains album, Revolver. Defendants Turn All the Lights On is registered with the U.S. Copyright Office, Registration Numbers PA0001846692 and
PA0001846692. Registration Number PA0001846692 lists Young Money Publishing Inc., Warner Tamerlane Publishing Corp., Brother Bagz Publishing, Nappypub Music, and EMI Blackwood as the Copyright Claimants. Registration Number PA0001785435 lists Nappypub Music, Universal Music - Z Songs, Bling Bling Music Publishing, and Beamer Boy Publishing as the Copyright Claimants.
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385.
Defendants Bang Bang Pow Pow infringes upon Plaintiffs copyrights in Its All About the Family, Nothin But the Funk, and Oh Carnival. Defendants Bang Bang Pow Pow infringes upon Plaintiffs Its All About the Family track as parts of Defendants Bang Bang Pow Pow copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Bang Bang Pow Pow, which are nearly identical or similar to Plaintiffs song Its All About the Family. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song.
386.
Defendants Bang Bang Pow Pow infringes upon Plaintiffs Nothin But the Funk track as parts of Defendants Bang Bang Pow Pow copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the hook of Defendants Bang Bang Pow Pow, which is nearly identical or similar to Plaintiffs song Nothin But the Funk. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hook of Plaintiffs song.
387.
Defendants Bang Bang Pow Pow infringes upon Plaintiffs Oh Carnival track as parts of Defendants Bang Bang Pow Pow copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Bang Bang Pow Pow, which is nearly identical or similar to Plaintiffs song Oh Carnival. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song.
388.
Defendants Bang Bang Pow Pow infringes upon three (3) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT BEST LOVE SONG 389. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Do It Right Now. 390. In or about 2002, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Sportsmans Paradise. The Sportsmans Paradise album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000502891. The Sportsmans Paradise album included, among other tracks, Overtime. 391. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Best Love Song by T-Pain featuring Chris Brown, which was released in 2011 as a single and as part of T-Pains album, Revolver. Defendants Best Love Song is registered with the U.S. Copyright Office, Registration Numbers SR0000706396, PA0001785455, and SR0000673712. Registration Number SR0000706396 lists Sony Music Entertainment as the Copyright Claimant. Registration Number PA0001785455 lists Universal Music - Z Songs, Culture Beyond Ur Experience Publishing, Songs Of Universal, Inc., and Nappypub Music as the Copyright Claimants. Registration Number SR0000673712 lists Sony Music Entertainment as the Copyright Claimant. 392. Defendants Best Love Song infringes upon Plaintiffs copyrights in Do It Right Now and Overtime. Defendants Best Love Song infringes upon Plaintiffs Do It Right Now track as parts of Defendants Best Love Song copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the melodies of
Defendants Best Love Song, which are nearly identical or similar to Plaintiffs song
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Do It Right Now. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melodies of Plaintiffs song. 393. Defendants Best Love Song infringes upon Plaintiffs Overtime track as parts of Defendants Best Love Song copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and chords of Defendants Best Love Song, which are nearly identical or similar to Plaintiffs song Overtime. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the beat and chords of Plaintiffs song. 394. Defendants Best Love Song infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT NUTHIN 395. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Its On (The Jam is On) and Kids. 396. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Nuthin by T-Pain featuring E40 and Detail, which was released in 2011 as part of T-Pains album, Revolver. Defendants Revolver is registered with the U.S. Copyright Office, Registration Number SR0000697852. Registration Number
SR0000697852 lists Sony Music Entertainment as the Copyright Claimant. 397. Defendants Nuthin infringes upon Plaintiffs copyrights in Its On (The Jam is On) and Kids. Defendants Nuthin infringes upon Plaintiffs Its On (The Jam is On)
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track as parts of Defendants Nuthin copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Nuthin, which is nearly identical or similar to Plaintiffs song Its On (The Jam is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 398. Defendants Nuthin infringes upon Plaintiffs Kids track as parts of Defendants Nuthin copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Nuthin, which is nearly identical or similar to Plaintiffs song Kids. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 399. Defendants Nuthin infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT IM SO HOOD 400. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Its On (The Jam is On). 401. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Im So Hood by DJ Khaled featuring T-Pain, Trick Daddy, Rick Ross, and Plies, which was released in 2007 as a single and is registered with the U.S. Copyright Office, Registration Number PA0001811287. Registration Number PA0001811287 lists
Sony/ATV Music Publishing LLC, First N Gold Publishing, Algernod Washington Publishing, Andrew Harr Publishing, Faheem Najm Publishing, Jermaine Jackson
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Publishing, Khaled M. Khaled Publishing, Maurice Young Publishing, and 4 Blunts Lit At Once as the Copyright Claimants. 402. Defendants Im So Hood infringes upon Plaintiffs Its On (The Jam is On) track as parts of Defendants Im So Hood copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beats and melodies of Defendants Im So Hood, which are nearly identical or similar to Plaintiffs song Its On (The Jam is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beats and melodies of Plaintiffs song. 403. Defendants Im So Hood infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT WELCOME TO MY HOOD 404. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Its On (The Jam is On). 405. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Ring Me. 406. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Welcome to My Hood by DJ Khaled featuring Rick Ross, Plies, Lil Wayne and T-Pain, which was released in 2011 as a single and as part of DJ Khaleds album, We the Best Forever. Welcome to My Hood is registered with the U.S. Copyright Office,
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Registration Numbers PA0001844126, PA0001840262 and SR0000671260. Registration Number PA0001844126 lists Young Money Publishing, Inc. and Warner-Tamerlane Publishing Corp. as the Copyright Claimants. Registration Number PA0001840262 lists Bryan Johnson, Khaled Khaled, Faheem Najm, Dwayne Carter, Mevin Reviere, Mollings Music, Nasty Beat Makers Productions Inc., Irocnasty Music, and First N Gold Publishing, Inc. as the Copyright Claimants. Registration Number SR0000671260 lists Cash Money Records, Inc. as the Copyright Claimant. 407. Defendants Welcome to My Hood infringes upon Plaintiffs copyrights in Its On (The Jam is On) and Ring Me. Defendants Welcome to My Hood infringes upon Plaintiffs Its On (The Jam is On) track as parts of Defendants Welcome to My Hood copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Welcome to My Hood, which is nearly identical or similar to Plaintiffs song Its On (The Jam is On). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 408. Defendants Welcome to My Hood infringes upon Plaintiffs Ring Me track as parts of Defendants Welcome to My Hood copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the hook of Defendants Welcome to My Hood, which is nearly identical or similar to Plaintiffs song Ring Me. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the hook of Plaintiffs song. 409. Defendants Welcome to My Hood infringes upon two (2) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT DREAMGIRL 410. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Space Station. 411. In or about 1997, Plaintiff authored music and lyrics in the track Just You and I. Just You and I is included on Plaintiffs Seductive Recital album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu0003785811. Plaintiff is the Copyright Claimant. 412. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Romantic Sequence. 413. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Dreamgirl by Tay Dizm featuring Akon, which was released in 2009 as a single. Upon information and belief, Defendants Dreamgirl is not registered with the U.S. Copyright Office. Nappy Body Digital is listed as the copyright owner on the single. 414. Defendants Dreamgirl infringes upon Plaintiffs copyrights in Space Station, Just You and I, and Romantic Sequence. Defendants Dreamgirl infringes upon The Tone
Plaintiffs Space Station track as parts of Defendants Dreamgirl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Dreamgirl, which is nearly identical or similar to Plaintiffs song Space
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Station. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 415. Defendants Dreamgirl infringes upon Plaintiffs Just You and I track as parts of Defendants Dreamgirl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Dreamgirl, which is nearly identical or similar to Plaintiffs song Just You and I. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 416. Defendants Dreamgirl infringes upon Plaintiffs Just You and I track as parts of Defendants Dreamgirl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of Defendants Dreamgirl, which is nearly identical or similar to Plaintiffs song Just You and I. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of Plaintiffs song. 417. Defendants Dreamgirl infringes upon Plaintiffs Romantic Sequence track as parts of Defendants Dreamgirl copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Dreamgirl, which are nearly identical or similar to Plaintiffs song Romantic Sequence. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 418. Defendants Dreamgirl infringes upon three (3) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT KARAOKE 419. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Ring Me. 420. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Karaoke by T-Pain featuring DJ Khaled, which was released in 2008 as part of TPains album, Thr33 Ringz. Defendants Thr33 Ringz is registered with the U.S. Copyright Office, Registration Numbers SR0000619901 and SR0000621421. registrations list Zomba Recording LLC as the Copyright Claimant. 421. Defendants Karaoke infringes upon Plaintiffs Ring Me track as parts of Defendants Karaoke copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat, chords, and melody of Defendants Karaoke, which are nearly identical or similar to Plaintiffs song Ring Me. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat, chords, and melody of Plaintiffs song. 422. Defendants Karaoke infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT NO NEW FRIENDS 423. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is Both
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Its All About the Family. Plaintiff is the sole author of the music and lyrics in these tracks. Plaintiffs Its All About the
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Family was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000390611. Plaintiff is the Copyright Claimant. 424. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Cant Get You Off My Mind. Plaintiff is the sole author of the music and lyrics in these tracks. 425. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It. 426. Upon information and belief, Defendants allegedly authored the music and lyrics in the track No New Friends by DJ Khaled featuring Drake, Rick Ross and Lil Wayne, which was released in 2013 as a single. Upon information and belief, Defendants No New Friends is not registered with the U.S. Copyright Office. Cash Money Records, Inc. is listed as the copyright owner on the single. 427. Defendants No New Friends infringes upon Plaintiffs copyrights in Its All About the Family, Cant Get You Off My Mind, and Bam There You Have It. Defendants No New Friends infringes upon Plaintiffs Its All About the Family track as parts of Defendants No New Friends copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks of Defendants No New Friends, which are nearly identical or similar to Plaintiffs song Its All About the
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Family. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hooks of Plaintiffs song. 428. Defendants No New Friends infringes upon Plaintiffs Cant Get You Off My Mind track as parts of Defendants No New Friends copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants No New Friends, which are nearly identical or similar to Plaintiffs song Cant Get You Off My Mind. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 429. Defendants No New Friends infringes upon Plaintiffs Bam There You Have It track as parts of Defendants No New Friends copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants No New Friends, which is nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 430. Defendants No New Friends infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT WE TAKIN OVER 431. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues). 432. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered
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with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Move That Body. 433. Upon information and belief, Defendants allegedly authored the music and lyrics in the track We Takin Over by DJ Khaled featuring Akon, Birdman, Fat Joe, Lil Wayne and Rick Ross, which was released in 2007 as a single and as part of DJ Khaleds album, We the Best. We Takin Over is registered with the U.S. Copyright Office, Registration Number
Registration Numbers PA0001811285 and PA0001589109.
PA0001811285 lists Sony/ATV Music Publishing LLC, ByeFall Productions Inc., 4 Blunts at Once, First N Gold Publishing, Brian Williams Publishing, Clifford Haris Publishing, Dwayne Carter Publishing, Joseph Cartagena Publishing, Khaled M. Khaled Publishing, Nathanial Hills Publishing, and 4 Blunts Lit At Once as the Copyright Claimants. Registration Number PA0001589109 lists William Roberts, Bryan Williams, Khaled Hussein, Nate Hills, Famous Music LLC, Byefall Music, Joseph Cartagena Music, and Money Mack Music as the Copyright Claimants. 434. Defendants We Takin Over infringes upon Plaintiffs copyrights in Still (Singing the Blues) and Move That Body. Defendants We Takin Over infringes upon
Plaintiffs Still (Singing the Blues) track as parts of Defendants We Takin Over copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the melody of the introduction of Defendants We Takin Over, which is nearly identical or similar to Plaintiffs song Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melody of the introduction of Plaintiffs song.
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435.
Defendants We Takin Over infringes upon Plaintiffs Move That Body track as parts of Defendants We Takin Over copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and hook of the introduction of Defendants We Takin Over, which are nearly identical or similar to Plaintiffs song Move That Body. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat and hook of Plaintiffs song.
436.
Defendants We Takin Over infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT OUT HERE GRINDIN
437.
Orleans Music album included, among other tracks, Space Station. 438. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues). 439. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Out Here Grindin by DJ Khaled featuring Akon, Rick Ross, Plies, Lil Boosie, Trick Daddy, and Ace Hood, which was released in 2008 as a single and as part of DJ Khaleds album, We Global. Copyright Office, Registration Out Here Grindin is registered with the U.S. Numbers PA0001694518 and PA0001669776.
Registration Number PA0001694518 lists Sony/ATV Music Publishing LLC, Byefall
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Music, 4 Blunts Lit At Once, First-N-Gold, Notting Hill Music, Inc., DJ Khaled Publishing, Zomba Songs, Inc., Nappypub Music, Warner Chappell, Trill Productions, LLC, Ya Daddy Publishing, Trac N Field, and Notting Dale as the Copyright Claimants. Registration Number PA0001669776 lists Antoine McColister, First And Gold c/o Warner-Tamerlane Publishing Corp., Boosie Bad Azz Publishing LLC & Trill Productions c/o WB Music Corp., First And Gold Publishing c/o Warner-Tamerlane Publishing Corp., 4 Blunts Lit At Once Publishing & Sony/ATV Songs, LLC., DJ Khaled Publishing, Nappypub Music & Universal Music Z Songs, Byefall Productions Inc. & Sony/ATV Harmony, Ya Daddy Publishing LLC, and Trac-N-Field Entertainment LLC & Notting Dale Songs Inc. as the Copyright Claimants. 440. Defendants Out Here Grindin infringes upon Plaintiffs copyrights in Space Station and Still (Singing the Blues). Defendants Out Here Grindin infringes upon
Plaintiffs Space Station track as parts of Defendants Out Here Grindin copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the
melodic effects and the beat of Defendants Out Here Grindin, which are nearly identical or similar to Plaintiffs song Space Station. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the melodic effects and the beat of Plaintiffs song. 441. Defendants Out Here Grindin infringes upon Plaintiffs Still (Singing the Blues) track as parts of Defendants Out Here Grindin copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the hook of the introduction of Defendants Out Here Grindin, which is nearly identical or similar to Plaintiffs song
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Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hook of the introduction of Plaintiffs song. 442. Defendants Out Here Grindin infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT I WISH YOU WOULD 443. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It. 444. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues). 445. Upon information and belief, Defendants allegedly authored the music and lyrics in the track I Wish You Would by DJ Khaled featuring Kanye West and Rick Ross, which was released in 2012 as a single and as part of DJ Khaleds album, Kiss the Ring. I Wish You Would is registered with the U.S. Copyright Office, Registration Numbers PA0001845136 and SR0000710302. Registration Number PA0001845136 lists Khaled Khaled, Kanye West, Chauncey Hollis, First N Gold Publishing, Inc., and Songs of Kobalt Music Publishing as the Copyright Claimants. Registration Number
SR0000710302 lists Cash Money Records Inc., c/o Universal Republic Records, a Div. of UMG Recordings, Inc., as the Copyright Claimants. 446. Defendants I Wish You Would infringes upon Plaintiffs copyrights in Bam There You Have It and Still (Singing the Blues). Defendants I Wish You Would
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infringes upon Plaintiffs Bam There You Have It track as parts of Defendants I Wish You Would copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants I Wish You Would, which is nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 447. Defendants I Wish You Would infringes upon Plaintiffs Still (Singing the Blues) track as parts of Defendants I Wish You Would copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hook and chords of
Defendants I Wish You Would, which are nearly identical or similar to Plaintiffs song Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hook and chords of Plaintiffs song. 448. Defendants I Wish You Would infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT TAKE IT TO THE HEAD 449. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. Plaintiff is the Copyright Claimant. The Freeze album included, among other tracks, Never Leave You Baby. Never Leave You Baby is registered with the U.S. Copyright Office, Registration Number SR0000013673. Plaintiff is the Copyright Claimant. 450. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Drowning in My Blues.
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451.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track Take It to the Head by DJ Khaled featuring Chris Brown, Rick Ross, Nicki Minaj, and Lil Wayne, which was released in 2012 as a single and as part of DJ Khaleds album, Kiss the Ring. Take It to the Head is registered with the U.S. Copyright Office, Registration Numbers PA0001844665, PA0001840395, SR0000698479, and SR0000309716. Registration Number PA0001844665 lists Kevin Cossuro, Dwayne
Carter, Khaled Khaled, Andrew Harr, Jermaine Jackson, Chris Brown, Onika Maraj, EMI Blackwood Music Inc., and 4 Blunts Lit At Once Publishing as the Copyright Claimants. Registration Number PA0001840395 lists Dwayne Carter, Andrew Harr, Christopher Brown, Jermaine Jackson, Onika Maraj, Khaled Khaled, Kevin Cossom, First N Gold Publishing, Inc., c/o Songs of Kobalt Music Publishing, Numbers Never Lie, and Numbers Dont Lie LLC as the Copyright Claimants. Registration Number
SR0000698479 lists Cash Money Records Inc., c/o Universal Republic Records, a Div. of UMG Recordings, Inc., as the Copyright Claimant. Registration Number SR0000309716 lists Island Def Jam Music Group, a division of UMG Recordings, Inc., as the Copyright Claimant. 452. Defendants Take It to the Head infringes upon Plaintiffs copyrights in Never Leave You Baby and Drowning in My Blues. Defendants Take It to the Head infringes upon Plaintiffs Never Leave You Baby track as parts of Defendants Take It to the Head copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks and chords of Defendants Take It to the Head, which are nearly identical or similar to Plaintiffs song Never Leave You Baby. Upon
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information and belief, Defendants wrongfully copied, among other parts of the song, the hooks and chords of Plaintiffs song. 453. Defendants Take It to the Head infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants Take It to the Head copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Take It to the Head, which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 454. Defendants Take It to the Head infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT THE BOSS 455. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Still (Singing the Blues) and Drowning in My Blues. 456. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Ring Me. 457. Upon information and belief, Defendants allegedly authored the music and lyrics in the track The Boss by Rick Ross featuring T-Pain, which was released in 2008 as a single and as part of Rick Ross album, Trilla. The Boss is registered with the U.S. Copyright Office, Registration Numbers SR0000642192, SR0000642146, and
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PA0001661300. Registration Number SR0000642192 lists The Island Def Jam Music Group, a Div. of MG Recordings, Inc. as the Copyright Claimant. Registration Number SR0000642146 lists The Island Def Jam Music Group, a Div. of MG Recordings, Inc. as the Copyright Claimant. Registration Number PA0001661300 lists Sony/ATV Songs LLC, Jonathan Rotem Music, 4 Blunts Lit At Once, First-N-Gold, and Universal Music Publishing as the Copyright Claimants. 458. Defendants The Boss infringes upon Plaintiffs copyrights in Still (Singing the Blues), Drowning in My Blues, and Ring Me. Defendants The Boss infringes upon Plaintiffs Still (Singing the Blues) track as parts of Defendants The Boss copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks of Defendants The Boss, which are nearly identical or similar to Plaintiffs song Still (Singing the Blues). Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hooks of Plaintiffs song. 459. Defendants The Boss infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants The Boss copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants The Boss, which is nearly identical or similar to Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 460. Defendants The Boss infringes upon Plaintiffs Ring Me track as parts of Defendants The Boss copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants The Boss, which are nearly identical or similar to Plaintiffs song Ring Me. Upon information and belief,
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Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 461. Defendants The Boss infringes upon three (3) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT FREEZE 462. In or about 1982, Plaintiff authored music and lyrics in the track Freeze. Plaintiffs Freeze was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiffs Freeze (track) was recorded and released as part of the Batiste Brothers Bands album Freeze. Freeze (album) was first published in 1982. The Freeze album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000324875. The Freeze album included, among other tracks, Freeze. 463. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It. 464. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Freeze by Young Cash, which was released in 2007 as a single and as part of Young Cashs 2008 album, Scared Money Dont Make Money. Freeze is registered with the U.S. Copyright Office, Registration Number SR0000623011. Registration
Number SR0000623011 lists Universal Records, a Div. of UMG Recordings Inc., as the Copyright Claimant. 465. Defendants Freeze infringes upon Plaintiffs copyrights in Freeze and Bam There You Have It. Defendants Freeze infringes upon Plaintiffs Freeze track as parts of
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Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks of Defendants Freeze, which are nearly identical or similar to Plaintiffs song Freeze. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hooks of Plaintiffs song. 466. Defendants Freeze infringes upon Plaintiffs Bam There You Have It track as parts of Defendants Freeze copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the beat and chords of Defendants Freeze, which are nearly identical or similar to Plaintiffs song Bam There You Have It. Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the beat and chords of Plaintiffs song. 467. Defendants Freeze infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT ALL THE MONEY IN THE WORLD 468. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste Brothers Bands album Freeze. The Freeze album was wholly original and is
registered with the U.S. Copyright Office, Registration Number SR0000324875. Plaintiff is the Copyright Claimant. The Freeze album included, among other tracks, Never Leave You Baby. Never Leave You Baby is registered with the U.S. Copyright Office, Registration Number SR0000013673. Plaintiff is the Copyright Claimant. 469. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Drowning in My Blues.
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470.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track All the Money in the World by Rick Ross featuring Raphael Saadiq, which was released in 2010 as part of Rick Ross album, Teflon Don. All the Money in the World is registered with the U.S. Copyright Office, Registration Numbers PA0001821914 and PA0001740695. Registration Number PA0001821914 lists
Sony/ATV Music Publishing LLC, 4 Blunts Lit At Once, Jesse James Publishing, Keith Miller Publishing, Brian Parker Publishing, Brian Wicker Publishing, David Stokes Publishing, and Charles Ray Wiggins Publishing as the Copyright Claimants. Registration Number PA0001740695 lists Ugmoe Music, c/o Universal PolyGram Int. Publishing, Inc., as the Copyright Claimant. 471. Defendants All the Money in the World infringes upon Plaintiffs copyrights in Never Leave You Baby and Drowning in My Blues. Defendants All the Money in the World infringes upon Plaintiffs Never Leave You Baby track as parts of Defendants All the Money in the World copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the hooks and chords of Defendants All the Money in the World, which are nearly identical or similar to Plaintiffs song Never Leave You Baby. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hooks and chords of Plaintiffs song. 472. Defendants All the Money in the World infringes upon Plaintiffs Drowning in My Blues track as parts of Defendants All the Money in the World copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants All the Money in the World, which is nearly identical or similar to
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Plaintiffs song Drowning in My Blues. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 473. Defendants All the Money in the World infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT ASTON MARTIN MUSIC 474. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It. 475. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Romantic Sequence. 476. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Aston Martin Music by Rick Ross featuring Drake and Chrisette Michele, which was released in 2010 as a single and as part of Rick Ross album, Teflon Don. All the Money in the World is registered with the U.S. Copyright Office, Registration Numbers PA0001821912, PA0001739154, and PA0001715493. Registration Number The Tone
PA0001821912 lists First N Gold Publishing, Sony/ATV Music Publishing LLC, 4 Blunts Lit At Once, Kevin Crowe Publishing, Erik Ortiz Publishing, EMI Blackwood Music, and Chrisette Payne Publishing Designee as the Copyright Claimants. Registration Number PA0001739154 lists Colione Rook Barto & Warner-Tamerlane Publishing Corp, 4 Blunts Lit At Once & Sony/ATV Songs, LLC., Chrisette Michele
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Music, and Live Write & EMI Music Publishing Canada, as the Copyright Claimants. Registration Number PA0001715493 lists Live Write LLC, EMI Blackwood Music Inc., Four Kings Productions Inc., Chrisette Michele Music, EMI Foray Music as the Copyright Claimants. 477. Defendants Aston Martin Music infringes upon Plaintiffs copyrights in Bam There You Have It and Romantic Sequence. Defendants Aston Martin Music infringes upon Plaintiffs Bam There You Have It track as parts of Defendants Aston Martin Music copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Aston Martin Music, which is nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 478. Defendants Aston Martin Music infringes upon Plaintiffs Romantic Sequence track as parts of Defendants Aston Martin Music copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants Aston Martin Music, which are nearly identical or similar to Plaintiffs song Romantic Sequence. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 479. Defendants Aston Martin Music infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT B.M.F. (BLOWIN MONEY FAST) 480. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, Fur Elise. The Tone
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481.
In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Tone Palette. The Tone Palette album was wholly original and is registered with the U.S. Copyright Office, Registration Number PAu002628735. Palette album included, among other tracks, My Bad. The Tone
482.
Upon information and belief, Defendants allegedly authored the music and lyrics in the track B.M.F. (Blowin Money Fast) by Rick Ross featuring Styles P, which was released in 2010 as a single and as part of Rick Ross album, Teflon Don. B.M.F. (Blowin Money Fast) is registered with the U.S. Copyright Office, Registration Numbers PA0001821909 and PA0001739152. Registration Number PA0001821914 lists First N Gold Publishing, Sony/ATV Music Publishing LLC, 4 Blunts Lit At Once, and EMI April Music as the Copyright Claimants. Registration Number PA0001739152 lists D. Styles, Kimani Music & Warner-Tamerlane Publishing Corp, and 4 Blunts Lit At Once & Sony/ATV Songs, LLC as the Copyright Claimants.
483.
Defendants B.M.F. (Blowin Money Fast) infringes upon Plaintiffs copyrights in Fur Elise and My Bad. Defendants B.M.F. (Blowin Money Fast) infringes upon Plaintiffs Fur Elise track as parts of Defendants B.M.F. (Blowin Money Fast) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants B.M.F. (Blowin Money Fast), which are nearly identical or similar to Plaintiffs song Fur Elise. Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 484. Defendants B.M.F. (Blowin Money Fast) infringes upon Plaintiffs My Bad track as parts of Defendants B.M.F. (Blowin Money Fast) copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants
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B.M.F. (Blowin Money Fast), which is nearly identical or similar to Plaintiffs song My Bad. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 485. Defendants B.M.F. (Blowin Money Fast) infringes upon two (2) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT CANT STOP 486. In or about 1999, Plaintiff authored music and lyrics in the track Sportsmans Paradise. Sportsmans Paradise is included on Plaintiffs Move That Body album, which is wholly original, and is registered with the U.S. Copyright Office, Registration Number SRu000409184. Plaintiff is the Copyright Claimant. 487. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Cant Stop by Ace Hood featuring Akon, which was released in 2008 as part of the album, DJ Khaled Presents Ace Hood Gutta. Defendants Cant Stop is registered with the U.S. Copyright Office, Registration Numbers PA0001750813 and PA0001703656. Registration Number PA0001750813 lists Sony/ATV Music Publishing LLC and Byefall Productions Inc. as the Copyright Claimants. Registration Number PA0001703656 lists Notting Dale Songs, Inc. c/o Universal Music Corp. and Trac N Field Ent. LLC c/o Universal Music Corp as the Copyright Claimants. 488. Defendants Cant Stop infringes upon Plaintiffs Sportsmans Paradise track as parts of Defendants Cant Stop copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords, melodies, and beat of Defendants Cant Stop, which are nearly identical or similar to Plaintiffs song Sportsmans Paradise. Upon
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information and belief, Defendants wrongfully copied, among other parts of the song, the chords, melodies, and beat of Plaintiffs song. 489. Defendants Cant Stop infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT CASH FLOW 490. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album World of Blues. The World of Blues album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000187088. The World of Blues album included, among other tracks, Blues Man. 491. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Cash Flow by Ace Hood featuring Rick Ross and T-Pain, which was released in 2008 as a single and part of the album, DJ Khaled Presents Ace Hood Gutta. Defendants Cash Flow is registered with the U.S. Copyright Office, Registration Numbers PA0001750812, PA0001655017, and SR0000613224. Registration Number PA0001750812 lists First N Gold Publishing, Sony/ATV Music Publishing LLC, and 4 Blunts Lit At Once as the Copyright Claimants. Registration Number PA0001655017 lists Universal Music - Z Songs, Nappypub Music, Notting Dale Songs, Inc., Trac N Field Ent. LLC, Notting Hill Music, Inc., DJ Khaled Publ., Mr. Cash Flow Publ., Warner/Tamerlane Publ. Corp., Y R P Music Publ., Sony/ATV Songs LLC, 4 Blunts Lit At Once Publ., and First And Gold Publ. as the Copyright Claimants. Registration Number SR0000613224 lists The Island Def Jam Music Group, a division of UMG Recordings, Inc. as the Copyright Claimant. 492. Defendants Cash Flow infringes upon Plaintiffs Blues Man track as parts of Defendants Cash Flow copy and/or are strikingly similar to parts of Plaintiffs song.
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Among these similarities are the hook and beat of Defendants Cash Flow, which are nearly identical or similar to Plaintiffs song Blues Man. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the hook and beat of Plaintiffs song. 493. Defendants Cash Flow infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT TOP OF THE WORLD 494. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiffs album Spice. The Spice album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000214434. The Spice album included, among other tracks, Louisiana. 495. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Top of the World by Ace Hood, which was released in 2008 as part of the album, DJ Khaled Presents Ace Hood Gutta. Defendants DJ Khaled Presents Ace Hood Gutta is registered with the U.S. Copyright Office, Registration Number SR0000619580. Registration Number SR0000619580 lists The Island Def Jam Music Group, a division of UMG Recordings, Inc., as the Copyright Claimant. 496. Defendants Top of the World infringes upon Plaintiffs Louisiana track as parts of Defendants Top of the World copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords and beat of Defendants Top of the World, which are nearly identical or similar to Plaintiffs song Louisiana. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords and beat of Plaintiffs song. 497. Defendants Top of the World infringes upon one (1) of Plaintiffs copyrights.
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COPYRIGHT INFRINGEMENT ERRRYTHANG 498. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S. Copyright Office, Registration Number SR0000194230. The (Gon Be Dat) New
Orleans Music album included, among other tracks, Runnin Away. 499. Upon information and belief, Defendants allegedly authored the music and lyrics in the track ErrryThang by Ace Hood featuring Yo Gotti, which was released in 2011 as part of Ace Hoods album, Blood, Sweat & Tears. Defendants Blood, Sweat & Tears is registered with the U.S. Copyright Office, Registration Number SR0000681567. Registration Number SR0000681567 lists The Island Def Jam Music Group, a division of UMG Recordings, Inc., as the Copyright Claimant. 500. Defendants ErrryThang infringes upon Plaintiffs Runnin Away track as parts of Defendants ErrryThang copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of Defendants ErrryThang, which are nearly identical or similar to Plaintiffs song Runnin Away. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 501. Defendants ErrryThang infringes upon one (1) of Plaintiffs copyrights. COPYRIGHT INFRINGEMENT BODY 2 BODY 502. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the Batiste Brothers Bands album (Gon Be Dat) New Orleans Music. The (Gon Be Dat) New Orleans Music album was wholly original and is registered with the U.S.
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Copyright Office, Registration Number SR0000194230.
The (Gon Be Dat) New
Orleans Music album included, among other tracks, Runnin Away. Runnin Away is registered with the U.S. Copyright Office, Registration Number SRu000278515. 503. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on the album Move That Body. The Move That Body album was wholly original and is registered with the U.S. Copyright Office, Registration Number SRu000409184. The Move That Body album included, among other tracks, Bam There You Have It. 504. Upon information and belief, Defendants allegedly authored the music and lyrics in the track Body 2 Body by Ace Hood featuring Chris Brown, which was released in 2011 as a single and as part of Ace Hoods album, Blood, Sweat & Tears. Defendants Body 2 Body is registered with the U.S. Copyright Office, Registration Number PA0001774743. Registration Number PA0001774743 lists Songs Of Universal, Inc. and Culture Beyond Ur Experience Publishing as the Copyright Claimants. 505. Defendants Body 2 Body infringes upon Plaintiffs copyrights in Runnin Away and Bam There You Have It. Defendants Body 2 Body infringes upon Plaintiffs
Runnin Away track as parts of Defendants Body 2 Body copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities are the chords of
Defendants Body 2 Body, which are nearly identical or similar to Plaintiffs song Runnin Away. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the chords of Plaintiffs song. 506. Defendants Body 2 Body infringes upon Plaintiffs Bam There You Have It track as parts of Defendants Body 2 Body copy and/or are strikingly similar to parts of Plaintiffs song. Among these similarities is the beat of Defendants Body 2 Body,
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which is nearly identical or similar to Plaintiffs song Bam There You Have It. Upon information and belief, Defendants wrongfully copied, among other parts of the song, the beat of Plaintiffs song. 507. 508. Defendants Body 2 Body infringes upon two (2) of Plaintiffs copyrights. As indicated above, Defendants have made a vast career out of misappropriating songs from Plaintiff. Defendants actions indicate a pattern of willful infringement of multiple parts of Plaintiffs songs. Plaintiff represents that the above list of songs is likely
incomplete, as Plaintiff continues to discover infringing works by Defendants at the time of filing this suit. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment as follows: 1. 2. This Complaint be deemed good and sufficient by this Honorable Court; For an award of actual damages and Defendants profits, or in the alternative, statutory damages per count of infringement, as a result of their acts of copyright infringement; 3. For the imposition of a constructive trust and accounting of all monies derived from the infringement of Plaintiffs songs; 4. For the issuance of a permanent injunction which shall enjoin Defendants from taking any action which would further infringe Plaintiffs rights; 5. For the issuance of a permanent injunction which shall restraining Defendants from using any infringing material without Plaintiffs permission; 6. For an order directing Defendants to credit Plaintiff with authorship of the infringing songs and paying Plaintiff royalties from future sales; 7. For prejudgment interest at the legal rate;
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8. 9.
For a trial by jury; and For all other relief allowed by law.
Dated: August 16, 2013. Respectfully submitted: KOEPPEL TRAYLOR LLC /s/ Mark N. Melasky ____________________________________ PETER S. KOEPPEL (#1465) psk@koeppeltraylor.com MARK N. MELASKY (#34326) mmelasky@koeppeltraylor.com 2030 St. Charles Avenue New Orleans, Louisiana 70130 Telephone: (504) 598-1000 Facsimile: (504) 524-1024 Attorneys for Plaintiff, Paul Batiste d/b/a Artang Publishing LLC
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Publishing LLC and Byefall Productions Inc. as the Copyright Claimants.

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Registration Number PA0001785445. Registration Number PA0001785445 lists David

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Copyright Office, Registration Number SR0000381378.

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Copyright Office, Registration Number PA0001644879.

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Copyright Office, Registration Number PA0001640177.

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