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h|NG, MOLMES,

A1ERNO
ERL|NER,1L
1 Blurred Iines," copies their" compositions. In the case oI the Marvin Caye-
Z related deIendants (the Caye deIendants"), it`s a song called Cot Jo Cive Hp."
Tor me ovner oITunkadelic`s songs, Bridgeport Music, Inc. (Bridgeport"), it`s a
4 song called Sexy Yays." But there are no similarities betveen plaintiIIs`
D composition and those the claimants allege they ovn, other than commonplace
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musical elements. PlaintiIIs created a hit and did it vithout copying anyone else`s
composition.
2. Jhe basis oI the Caye deIendants` claims is that Bluoed Iines" and
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Cot Jo Cive It p" Ieel" or sound" the same. Being reminiscent oI a sound" is
1 not copyright inLingement. Jhe intent in producing Blurred Iines" vas to evoke
11 an era. In reality, the Caye deIendants are claiming ovnership oI an entire genre, as
1Z opposed to a speciIic vork, and Bridgeport is claiming the same vork.
1 J. Jhe reality is that the songs themselves are starkly diIIerent. Since that
14 is the salient Iactor in a claim Ior copyright inLingement, in the Iace oI the threats oI
1D deIendants to commence lavsuits, plaintiIIs must seek declaatory relieI Lom mis
1b Court that conrms plaintiIIs' unIettered right to exploit Blurred Iines" Lee oI
1 deIendants' claims.
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4. Jhis action is brought, and this Court has subect matter urisdiction,
pursuant to 28 .S.C. Sections 1JJ1, 1JJ8 and 22O1. Jhis Court has Iederal
question urisdiction in this matter in that plaintiIIs seek a declaration oI rights under
the Copyright Act oI 1976, 17 .S.C. ] 1O1 l8g.
5. Venue lies vithin this Court pursuant to 28 .S.C. Sections
1J91(b)(2)-(J), (c), (d) and 14OO(a) in that deIendants Trankie Chistian Caye and
Marvin Caye are domiciled and reside Ior venue purposes and ae subect to
personal urisdiction in this district, that, on inIormation and belieI, deIendant ona
Marvisa Caye is a part-time resident oI this district, and that she and deIendant
Bridgeport Music, Inc. (Bridgeport") regularly and systematically conduct business
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fING, MOLES,
ATERNO
ERLNER,1Lr
1 in this district and, thereIore, are subect to personal urisdiction in this district.
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6.
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PlaintiIIs are me composers oI me multinational hit song Blurred
4 Iines," vhich vas released in or about March ZJ. Blurred Iines" has gzered
D more tha J m!!on vievs on YouJube.com.
b 7. On inIormation and belieI, Bridgeport is and at all times material herein
has been a corporation organized and existing under me lavs oI the State oI
Michigan and is in the business oI acquiring and exploiting copyright interests in
V musical compositions, and in the business oI uolling Ior opportunities to threaten to
1 sue and to sue musicians, perIormers, producers and others in the music industry Ior
11 inLingement oI its copyrights. Bridgeport regularly and systematicaIly does
1Z business in the state oI CaliIoma by, among other things, negotiating and granting
1 Iicenses to use the songs in vhich it has a copyright interest to licensees in
14 CaliIomia and resorting to the CaliIomia courts. Bridgeport has claimed an
1D ovnership interest in the copyright to the composition Sexy Yays" vritten by
1b Ceorge Clinton ad Crace Cook.
1 8. On inIormation and belieI, deIendat Trankie Christian Caye is and at
1 alI times material herein has been an individual residing in Ios Angeles County,
1V CaIiIomia.
Z 9. On inIormation and belieI, deIendant Marvin Caye III is and at all
Z1 times materiaI herein has been an individual residing in Ios Angeles County,
ZZ CaliIomia.
Z J. On inIormation and beIieI, deIendant ona Marvisa Caye is and at alI
Z4 times materiaI herein has been an individual residing in Ios Angeles County
ZD CaliIoma and the State oI Rhode Islad, vho regularIy conducts business as an
Zb entertainer in the County oI Ios AngeIes, CaliIomia. eIendants Trankie Christian
Z Caye, Marvin Caye III ad Mona Marvisa Caye are reIerred to collectively
Z hereinaher as the Cayes."
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f|NG, MOLMES,
ATRNO
ERL|NER, LLP
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J. PlaintiIIs ae inIormed and believe that the Cayes claim an ovnership
Z interest in the composition Cot Jo Cive It p" by Marvin Caye.
Z. eIendant oes through J, inclusive, are sued herein under
4 ctitious names. Jheir uue names and capacities are unknovn to plaintiIIs. Yhen
D their uue names and capacities are ascertained, plaintiIIs vill amend this complaint
b by inserting their true names and capacities herein.

. On inIormation and belieI at all times material herein each oI the


deIendants vas the agent and employee oI some or all oI the other deIendants, and
V in doing me things hereinaer alleged, vas acting vithin the course and scope oI
1 such agency and employment.
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J. PlaintiIIs are inIormed and believe that Bridgeport ovns some or all oI
1 the copyright in the composition Sexy Yays" and that Bridgeport alleges that
14 plaintiIIs have inLinged that composition by including elements oI it in Blurred
1D Iines" vithout Bridgeport`s knovledge or consent. Representatives oI Bridgeport
1b have recently notied plaintiIIs that, iI plaintiIIs do not pay a monetay settlement oI
1 Bridgeport's claim, Bridgeport intends to initiate litigation Ior copyright
1 inLingement against plaintiIIs and others.
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J3. PlaintiIIs did not incorporate or othervise use the composition Sexy
Yays" in Blurred Iines." PlaintiIIs did not inLinge any copyright in Sexy
Yays."
JD. PlaintiIIs are inIormed and believe that the Cayes claim that they ovn
and have standing to pursue claims Ior inLingement oI the copyright in the
composition Cot Jo Cive Hp" by Marvm Caye, and that plaintiIIs have inLinged
that composition by including elements oI it in Blurred Iines" vithout the Caye`s
knovledge or consent. Representatives oI the Cayes have recently notied
plaintiIIs that, iI plaintiIIs do not pay a monetary settlement oI the Cayes` claim, the
Cayes intend to initiate litigation Ior copyright inLingement against plaintiIIs and
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f|NG, MOUES,
ATERNO
ERLNER,1L
1 others.
Z J. PlaintiIIs did not incorporate or othervise use the composition Cot Jo
Cive p" in Blurred Iines." PlaintiIIs did not inLinge any copyright in Cot Jo
4 Cive p."
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J. Jhere is an actual and usticiable controversy betveen plaintiIIs and
b Bridgeport in that Bridgeport claims that Blurred Iines" inLinges Sexy Yays,"
and that the exploitation oI Blurred Iines" violates Bridgeport's rights as herein
alleged. Conversely, plaintiIIs deny Bridgeport's claims and contend that Blurred
V Iines" does not inLinge Sexy Yays."
1 JV. Jhere also is an actual and usticiable conuoversy betveen plaintiIIs
11 and the Cayes in that the Cayes claim that they have an ovnership interest in the
1Z composition Cot Jo Cive p" and standing to pursue claims oI inLingement oI
1 that composition, that the Cayes claim that Blurred Iines" inLinges Cot Jo Cive
14 p," and that the exploitation oIBlurred Iines" violates the Caye's alleged
1D rights, as herein alleged.
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Z. PlaintiIIs did not incorporate or othervise use the composition Cot Jo
Cive It p" in Blurred Iines." PlaintiIIs did not inLinge any copyright in Cot Jo
Cive p."
Z. A udicial declaation oI the parties' respective rights and obligations
vith respect to Blurred Iines" is necessary and appropriate.
ZZ. PlaintiIIs seek a udgment declaring the parties' respective rights vith
regard to Blurred Iines," including a declaration that (a) Blurred Iines" does not
inLinge Sexy Yays" or othervise violate Bridgeport's rights, (b) the Cayes do not
have an interest in the copyright to the composition Cot Jo Cive p" suIcient
to conIer standing on them to pursue claims oI inLingement oI that composition, or
altematively (c) that Blurred Lines" does not inLinge Cot Jo Cive It p" or
othervise violate the Cayes' rights.
/JJ
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h|NG, MOLJES,
rA1ERNO
ERLNER, 1Lr
1 YHRITORI, plaintiIIs respectlIy request udgment against deIendant as
Z Iollovs:
J. A declaration that (a) "Blurred Iines" does not inLinge "Sexy Yays"
4 or othervise vioIate Bridgeport's rights, (b) the Cayes do not have an interest in the
D copyright to the composition "Cot Jo Cive Hp" suIIicient to conIer stading on
b them to pursu

claims oI inLingement oI that composition, or altematively (c) that
"Blurred Iines" does not inLinge "Cot Jo Cive It p" or othervise violate the
Cayes' rights,
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Tor costs and attomey Iees incurred herein, and
Tor such other and rther relieI as the court deems ust and proper.
1Z AJI: August J3 ZJ
KINC, HOIMS, PAJIRNO BIRIINIR, IIP
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By:

J
\
OWAI. 1LU
S1B!HN O
Attomeys Ior PlaintiIIs PHARRIII Y0IIAS,
ROBIN JHCKI and CIBTOR H^RIS, J.
D

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