UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
PAUL BATISTE D/B/A * CIVIL ACTION NO.
ARTANG PUBLISHING LLC *
* 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., PITBULL’S 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. * ******************************************************************************
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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 Plaintiff’s 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 Plaintiff’s 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 Plaintiff’s catalog. Defendants have blatantly
poached beats, lyrics, melodies, and chords from Plaintiff’s 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 Plaintiff’s songs Freeze,
Download My Love, Overtime, and Bam There You Have It. Defendants have access to
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Plaintiff’s 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 other’s 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 Plaintiff’s
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 Plaintiff’s 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.
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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.
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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 Pitbull’s 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.
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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.
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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.” Plaintiff’s
“Freeze” was wholly original and is registered with the U.S. Copyright Office,
Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiff’s
“Freeze” (track) was recorded and released as part of the Batiste Brothers Band’s 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,”
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“Dancin’ Shoes,” “It’s All About the Family,” “Party Down,” “Can’t 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-Pain’s 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 Plaintiff’s copyrights in multiple tracks on the
“Freeze” album. Defendants’ “Freeze” infringes upon Plaintiff’s “Freeze” (track) as
parts of Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities are the melody and lyrics of Defendants’ “Freeze,” which
are nearly identical or similar to Plaintiff’s song “Freeze.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody and lyrics of
Plaintiff’s song.
50. Defendants’ “Freeze” infringes upon Plaintiff’s song “It’s All About the Family,” as parts
of Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “Freeze,” which is nearly identical
or similar to Plaintiff’s song “It’s All About the Family.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiff’s
song.
51. Defendants’ “Freeze” infringes upon Plaintiff’s song “Hooked on You,” as parts of
Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s song.
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Among these similarities are the chords of Defendants’ “Freeze,” which are nearly
identical or similar to Plaintiff’s song “Hooked on You.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords of Plaintiff’s
song.
52. Defendants’ “Freeze” infringes upon Plaintiff’s song “Dancin’ Shoes,” as parts of
Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the lyrics of Defendants’ “Freeze,” which are nearly
identical or similar to Plaintiff’s song “Dancin’ Shoes.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the lyrics of Plaintiff’s
song.
53. In or about 1997, Plaintiff authored music and lyrics in the track “When She Smiles.”
“When She Smiles” is included on Plaintiff’s “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 Plaintiff’s song “When She Smiles,” as parts of
Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the gliss of Defendants’ “Freeze,” which is nearly identical or
similar to Plaintiff’s song “When She Smiles.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the gliss of Plaintiff’s song.
55. In or about 1999, Plaintiff authored music and lyrics in the track “Sportsman’s Paradise.”
“Sportsman’s Paradise” is included on Plaintiff’s “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.
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56. Defendants’ “Freeze” infringes upon Plaintiff’s song “Sportsman’s Paradise,” as parts of
Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the beat of Defendants’ “Freeze,” which is nearly identical or
similar to Plaintiff’s song “Sportsman’s Paradise.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
57. Defendants’ “Freeze” infringes upon seven (7) of Plaintiff’s 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 “Sportsman’s Paradise.”
59. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s
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 Khaled’s 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 Plaintiff’s copyrights in multiple tracks
appearing on Plaintiff’s “Move That Body,” “World of Blues,” and “Spice” albums.
Defendants’ “All I Do Is Win” infringes upon Plaintiff’s “Ring Me” track as parts of
Defendants’ “All I Do Is Win” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the beat of Defendants’ “All I Do Is Win,” which is
nearly identical or similar to Plaintiff’s song “Ring Me.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
63. Defendants’ “All I Do Is Win” infringes upon Plaintiff’s “I Got the Rhythm On” track as
parts of Defendants’ “All I Do Is Win” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the melody of Defendants’ “All I Do Is
Win,” which is nearly identical or similar to Plaintiff’s 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 Plaintiff’s song.
64. Defendants’ “All I Do Is Win” infringes upon Plaintiff’s “Move That Body” track as
parts of Defendants’ “All I Do Is Win” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the lyrics of Defendants’ “All I Do Is
Win,” which are nearly identical or similar to Plaintiff’s song “Move That Body.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
lyrics of Plaintiff’s song.
65. Defendants’ “All I Do Is Win” infringes upon Plaintiff’s “Sportsman’s Paradise” track as
parts of Defendants’ “All I Do Is Win” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the lyrics of Defendants’ “All I Do Is
Win,” which are nearly identical or similar to Plaintiff’s song “Sportsman’s Paradise.”
Upon information and belief, Defendants wrongfully copied, among other parts of the
song, the lyrics of Plaintiff’s song.
66. Defendants’ “All I Do Is Win” infringes upon Plaintiff’s “Still (Singing the Blues)” track
as parts of Defendants’ “All I Do Is Win” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the melody of the introduction of
Defendants’ “All I Do Is Win,” which is nearly identical or similar to Plaintiff’s song
“Still (Singing the Blues).” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the melody of Plaintiff’s song.
67. Defendants’ “All I Do Is Win” infringes upon Plaintiff’s “Louisiana” track as parts of
Defendants’ “All I Do Is Win” copy and/or are strikingly similar to parts of Plaintiff’s
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 Plaintiff’s song “Louisiana.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords of Plaintiff’s
song.
68. Defendants’ “All I Do Is Win” infringes upon six (6) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – MOVE THAT BODY
69. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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 Nelly’s 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 Plaintiff’s copyrights in “Move That
Body” and “Love Fest” tracks. Defendants’ “Move That Body” infringes upon Plaintiff’s
“Move That Body” track as parts of Defendants’ “Move That Body” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities are the lyrics and
hooks of Defendants’ “Move That Body,” which are nearly identical or similar to
Plaintiff’s song “Move That Body.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the lyrics and hooks of Plaintiff’s
song.
73. Defendants’ “Move That Body” infringes upon Plaintiff’s “Love Fest” track as parts of
Defendants’ “Move That Body” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the beat of Defendants’ “Move That Body,” which is
nearly identical or similar to Plaintiff’s song “Love Fest.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
74. Defendants’ “Move That Body” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – OVERTIME
75. In or about 2002, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
album “Sportsman’s Paradise.” The “Sportsman’s Paradise” album was wholly original
and is registered with the U.S. Copyright Office, Registration Number SRu000502891.
The “Sportsman’s 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 Hood’s 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, Trac-
N-Field Entertainment, Nappypub Music, Byefall Productions, Inc., and Sony / ATV
Harmony as the Copyright Claimants.
77. Defendants’ “Overtime” infringes upon Plaintiff’s copyrights in “Overtime,” “Sudden
Death,” and “I Got the Rhythm On” tracks. Defendants’ “Overtime” infringes upon
Plaintiff’s “Overtime” track as parts of Defendants’ “Overtime” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities are the lyrics of
Defendants’ “Overtime,” which are nearly identical or similar to Plaintiff’s song
“Overtime.” Upon information and belief, Defendants wrongfully copied, among other
parts of the song, the lyrics of Plaintiff’s song.
78. Defendants’ “Overtime” infringes upon Plaintiff’s “Sudden Death” track as parts of
Defendants’ “Overtime” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “Overtime,” which is nearly
identical or similar to Plaintiff’s song “Sudden Death.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiff’s
song.
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79. Defendants’ “Overtime” infringes upon Plaintiff’s “I Got the Rhythm On” track as parts
of Defendants’ “Overtime” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the beat of Defendants’ “Overtime,” which is nearly identical
or similar to Plaintiff’s song “I Got the Rhythm On.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
80. Defendants’ “Overtime” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BLAME IT
81. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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 Plaintiff’s
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 Plaintiff’s
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, “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 Foxx’s album “Intuition.” Defendants’ “Blame It” is registered with
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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, It’s 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 Plaintiff’s copyrights in “Runnin’ Away,” “Do It
Right Now,” “Nothin’ But the Funk,” “Spice,” and “My Bad” tracks. Defendants’
“Blame It” infringes upon Plaintiff’s “Runnin’ Away” track as parts of Defendants’
“Blame It” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities is the melody of the rhythm section of Defendants’ “Blame It,” which is
nearly identical or similar to Plaintiff’s song “Runnin’ Away.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the melody of
Plaintiff’s song.
86. Defendants’ “Blame It” infringes upon Plaintiff’s “Do It Right Now” track as parts of
Defendants’ “Blame It” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the melody and lyrics of Defendants’ “Blame It,” which is
nearly identical or similar to Plaintiff’s song “Do It Right Now.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the melody and
lyrics of Plaintiff’s song.
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87. Defendants’ “Blame It” infringes upon Plaintiff’s “Nothin’ But the Funk” track as parts
of Defendants’ “Blame It” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords of Defendants’ “Blame It,” which is nearly
identical or similar to Plaintiff’s song “Nothin’ But the Funk.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords of
Plaintiff’s song.
88. Defendants’ “Blame It” infringes upon Plaintiff’s “Spice” track as parts of Defendants’
“Blame It” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the chords of Defendants’ “Blame It,” which are nearly identical or
similar to Plaintiff’s song “Spice.” Upon information and belief, Defendants wrongfully
copied, among other parts of the song, the chords of Plaintiff’s song.
89. Defendants’ “Blame It” infringes upon Plaintiff’s “My Bad” track as parts of Defendants’
“Blame It” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities is the melody of Defendants’ “Blame It,” which is nearly identical or similar
to Plaintiff’s song “My Bad.” Upon information and belief, Defendants wrongfully
copied, among other parts of the song, the melody of Plaintiff’s song.
90. Defendants’ “Blame It” infringes upon five (5) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – WHAT’S WRONG (GO AWAY)
91. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s album “Freeze.” Plaintiff’s “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, “Can’t 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 “What’s Wrong (Go Away)” by Jennifer Hudson featuring T-Pain, which was
released in 2008 as a single and as part of Jennifer Hudson’s album “Jennifer Hudson.”
Defendants’ “What’s 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’ “What’s Wrong (Go Away)” infringes upon Plaintiff’s copyrights in “I Like
Your Way” and “Can’t Get You Off My Mind” tracks. Defendants’ “What’s Wrong (Go
Away)” infringes upon Plaintiff’s “I Like Your Way” track as parts of Defendants’
“What’s Wrong (Go Away)” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the beat of Defendants’ “What’s Wrong (Go Away),”
which is nearly identical or similar to Plaintiff’s song “I Like Your Way.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
95. Defendants’ “What’s Wrong (Go Away)” infringes upon Plaintiff’s “Can’t Get You Off
My Mind” track as parts of Defendants’ “What’s Wrong (Go Away)” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities is the melody of
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Defendants’ “What’s Wrong (Go Away),” which is nearly identical or similar to
Plaintiff’s song “Can’t Get You Off My Mind.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody and lyrics of
Plaintiff’s song.
96. Defendants’ “What’s Wrong (Go Away)” infringes upon two (2) of Plaintiff’s 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 Band’s album “Freeze.” Plaintiff’s “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, “Can’t 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 Plaintiff’s copyrights in “Download My Love”
and “Can’t Get You Off My Mind” tracks. Defendants’ “Download” infringes upon
Plaintiff’s “Download My Love” track as parts of Defendants’ “Download” copy and/or
are strikingly similar to parts of Plaintiff’s song. Among these similarities is the melody
of Defendants’ “Download,” which is nearly identical or similar to Plaintiff’s song
“Download My Love.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the melody of Plaintiff’s song.
101. Defendants’ “Download” infringes upon Plaintiff’s “Can’t Get You Off My Mind” track
as parts of Defendants’ “Download” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the chords, melody, and beat of
Defendants’ “Download,” which is nearly identical or similar to Plaintiff’s song “Can’t
Get You Off My Mind.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the chords, melody, and beat of Plaintiff’s song.
102. Defendants’ “Download” infringes upon two (2) of Plaintiff’s 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 “Sportsman’s
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 Dogg’s 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 Plaintiff’s copyrights in “Bam There You Have It”
and “Sportsman’s Paradise” tracks. Defendants’ “Boom” infringes upon Plaintiff’s “Bam
There You Have It” track as parts of Defendants’ “Boom” copy and/or are strikingly
similar to parts of Plaintiff’s song. Among these similarities are the melody and beat of
Defendants’ “Boom,” which are nearly identical or similar to Plaintiff’s song “Bam
There You Have It.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the beat and melody of Plaintiff’s song.
106. Defendants’ “Boom” infringes upon Plaintiff’s “Sportsman’s Paradise” track as parts of
Defendants’ “Boom” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “Boom,” which is nearly identical
or similar to Plaintiff’s song “Sportsman’s Paradise.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the meldoy of Plaintiff’s
song.
107. Defendants’ “Boom” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – CYCLONE
108. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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
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“(Gon’ Be Dat) New Orleans Music” album included, among other tracks, “It’s 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), C’amore Music, Lil Jizzel Music, and Latin Velvet as
the Copyright Claimants.
110. Defendants’ “Cyclone” infringes upon Plaintiff’s copyrights in “It’s On (The Jam Is On)”
track as parts of Defendants’ “Cyclone” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the hooks, melody, and beat of
Defendants’ “Cyclone,” which are nearly identical or similar to Plaintiff’s song “It’s On
(The Jam Is On).” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the hooks, beat, and melody of Plaintiff’s song.
111. Defendants’ “Cyclone” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – U GOT ME
112. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s album “Freeze.” Plaintiff’s “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, “Can’t 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-Pain’s 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 Plaintiff’s copyrights in “Can’t Get You Off My
Mind” track as parts of Defendants’ “U Got Me” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities are the melody and beat of
Defendants’ “U Got Me,” which are nearly identical or similar to Plaintiff’s song “Can’t
Get You Off My Mind.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the melody and beat of Plaintiff’s song.
115. Defendants’ “U Got Me” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – RAP SONG
116. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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., Ain’t 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 Plaintiff’s copyrights in “Runnin’ Away” and
“Bam There You Have It.” Defendants’ “Rap Song” infringes upon Plaintiff’s “Runnin’
Away” track as parts of Defendants’ “Rap Song” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities are the melodies and bridge chords of
Defendants’ “Rap Song,” which are nearly identical or similar to Plaintiff’s song
“Runnin’ Away.” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the melodies and bridge chords of Plaintiff’s song.
120. Defendants’ “Rap Song” infringes upon Plaintiff’s “Bam There You Have It” track as
parts of Defendants’ “Rap Song” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the beat of Defendants’ “Rap Song,” which is nearly
identical or similar to Plaintiff’s 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
Plaintiff’s song.
121. Defendants’ “Rap Song” infringes upon two (2) of Plaintiff’s 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-Pain’s 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 Plaintiff’s copyrights in the
“Starlite” track as parts of Defendants’ “Turn All the Lights On” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities are the hooks,
melody, and beat of Defendants’ “Turn All the Lights On,” which are nearly identical or
similar to Plaintiff’s song “Starlite.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the hooks, melody and beat of
Plaintiff’s song.
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125. Defendants’ “Turn All the Lights On” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – REGULAR GIRL
126. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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.
127. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s
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, “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-Pain’s 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.
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130. Defendants’ “Regular Girl” infringes upon Plaintiff’s copyrights in “Runnin’ Away,”
“Nothin’ But the Funk,” and “My Bad” tracks. Defendants’ “Regular Girl” infringes
upon Plaintiff’s “Runnin’ Away” track as parts of Defendants’ “Regular Girl” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities is the
beat of Defendants’ “Regular Girl,” which is nearly identical or similar to Plaintiff’s song
“Runnin’ Away.” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the beat of Plaintiff’s song.
131. Defendants’ “Regular Girl” infringes upon Plaintiff’s “Nothin’ But the Funk” track as
parts of Defendants’ “Regular Girl” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the chords of Defendants’ “Regular Girl,”
which are nearly identical or similar to Plaintiff’s song “Nothin’ But the Funk.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
chords of Plaintiff’s song.
132. Defendants’ “Regular Girl” infringes upon Plaintiff’s “My Bad” track as parts of
Defendants’ “Regular Girl” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the hook of Defendants’ “Regular Girl,” which is nearly
identical or similar to Plaintiff’s song “My Bad.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the hook of Plaintiff’s
song.
133. Defendants’ “Regular Girl” infringes upon three (3) of Plaintiff’s copyrights.
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COPYRIGHT INFRINGEMENT – REALITY SHOW
134. In or about 1982, Plaintiff authored music and lyrics in the track “Freeze.” Plaintiff’s
“Freeze” was wholly original and is registered with the U.S. Copyright Office,
Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiff’s
“Freeze” (track) was recorded and released as part of the Batiste Brothers Band’s 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, “Can’t Get You Off
My Mind,” “It’s 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-Pain’s 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, Ahmad’s World,
Soul Child Music, as the Copyright Claimants.
136. Defendants’ “U Got Me” infringes upon Plaintiff’s copyrights in “Can’t Get You Off My
Mind,” “It’s All About the Family,” and “Hooked on You.” Defendants’ “Reality Show”
infringes upon Plaintiff’s “Can’t Get You Off My Mind” track as parts of Defendants’
“Reality Show” copy and/or are strikingly similar to parts of Plaintiff’s song. Among
these similarities are the chords and beat of Defendants’ “Reality Show,” which are
nearly identical or similar to Plaintiff’s song “Can’t Get You Off My Mind.” Upon
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information and belief, Defendants wrongfully copied, among other parts of the song, the
chords and beat of Plaintiff’s song.
137. Defendants’ “Reality Show” infringes upon Plaintiff’s “It’s All About the Family” track
as parts of Defendants’ “Reality Show” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the melody of Defendants’ “Reality Show,”
which is nearly identical or similar to Plaintiff’s song “It’s All About the Family.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody of Plaintiff’s song.
138. Defendants’ “Reality Show” infringes upon Plaintiff’s “Hooked on You” track as parts of
Defendants’ “Reality Show” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “Reality Show,” which is nearly
identical or similar to Plaintiff’s song “Hooked on You.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiff’s
song.
139. Defendants’ “Reality Show” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – COME AND GET IT
140. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s
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, “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 Plaintiff’s copyrights in “Love Horizon,”
“Shades of Wes,” and “Goin’ See the Man” tracks. Defendants’ “Come and Get It”
infringes upon Plaintiff’s “Love Horizon” track as parts of Defendants’ “Come and Get
It” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the melody and beat of Defendants’ “Come and Get It,” which are nearly
identical or similar to Plaintiff’s song “Love Horizon.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody and beat of
Plaintiff’s song.
144. Defendants’ “Come and Get It” infringes upon Plaintiff’s “Shades of Wes” track as parts
of Defendants’ “Come and Get It” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities are the chords of Defendants’ “Come and Get It,” which
are nearly identical or similar to Plaintiff’s song “Shades of Wes.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords of
Plaintiff’s song.
145. Defendants’ “Come and Get It” infringes upon Plaintiff’s “Goin’ See the Man” track as
parts of Defendants’ “Come and Get It” copy and/or are strikingly similar to parts of
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Plaintiff’s song. Among these similarities are the lyrics of Defendants’ “Come and Get
It,” which are nearly identical or similar to Plaintiff’s song “Come and Get It.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
lyrics of Plaintiff’s song.
146. Defendants’ “Come and Get It” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – I FUCKED MY AUNT
147. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Band’s 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 Island’s 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 Plaintiff’s copyrights in “Goin’ See the
Man” and “Runnin’ Away” tracks. Defendants’ “I Fucked My Aunt” infringes upon
Plaintiff’s “Goin’ See the Man” track as parts of Defendants’ “I Fucked My Aunt” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
horns and beat of Defendants’ “I Fucked My Aunt,” which are nearly identical or similar
to Plaintiff’s song “Goin’ See the Man.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the horns and beat of Plaintiff’s song.
151. Defendants’ “I Fucked My Aunt” infringes upon Plaintiff’s “Runnin’ Away” track as
parts of Defendants’ “I Fucked My Aunt” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the chords of Defendants’ “I Fucked My
Aunt,” which are nearly identical or similar to Plaintiff’s song “Runnin’ Away.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
chords of Plaintiff’s song.
152. Defendants’ “I Fucked My Aunt” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BOOTY WURK
153. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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.”
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
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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 Plaintiff’s “Space Station” track as parts of
Defendants’ “Booty Wurk” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the melody and beat of Defendants’ “Booty Wurk,” which
are nearly identical or similar to Plaintiff’s song “Space Station.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the melody and beat
of Plaintiff’s song.
156. Defendants’ “Booty Wurk” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – SHO-TIME
157. In or about 1982, Plaintiff authored music and lyrics in the track “Freeze.” Plaintiff’s
“Freeze” was wholly original and is registered with the U.S. Copyright Office,
Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiff’s
“Freeze” (track) was recorded and released as part of the Batiste Brothers Band’s 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, “Can’t 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-Pain’s 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 Plaintiff’s “Can’t Get You Off My Mind” track
as parts of Defendants’ “Sho-Time” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the melody and beat of Defendants’ “Can’t
Get You Off My Mind,” which are nearly identical or similar to Plaintiff’s song “Can’t
Get You Off My Mind.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the melody and beat of Plaintiff’s song.
160. Defendants’ “Sho-Time” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – I’M SPRUNG
161. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Band’s 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, “Can’t 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 “I’m Sprung” by T-Pain, which was released in 2005 as part of T-Pain’s album,
“Rappa Ternt Sanga.” Defendants’ “Rappa Ternt Sanga” is registered with the U.S.
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Copyright Office, Registration Number SR0000381378. Registration Number
SR0000381378 lists Zomba Recording LLC as the Copyright Claimant.
164. Defendants’ “I’m Sprung” infringes upon Plaintiff’s copyrights in “Drowning in My
Blues” and “Can’t Get You Off My Mind” tracks. Defendants’ “I’m Sprung” infringes
upon Plaintiff’s “Drowning in My Blues” track as parts of Defendants’ “I’m Sprung”
copy and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities is
the beat and lyrics of Defendants’ “I’m Sprung,” which is nearly identical or similar to
Plaintiff’s song “Drowning in My Blues.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat and lyrics of Plaintiff’s song.
165. Defendants’ “I’m Sprung” infringes upon Plaintiff’s “Can’t Get You Off My Mind” track
as parts of Defendants’ “I’m Sprung” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the bridge chords of Defendants’ “I’m
Sprung,” which are nearly identical or similar to Plaintiff’s song “Can’t Get You Off My
Mind.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the bridge chords of Plaintiff’s song.
166. Defendants’ “I’m Sprung” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – CAN’T BELIEVE IT
167. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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
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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 Plaintiff’s
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 “Can’t Believe It” by T-Pain featuring Lil Wayne, which was released in 2008 as
part of T-Pain’s album, “Thr33 Ringz.” Defendants’ “Can’t 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’ “Can’t Believe It” infringes upon Plaintiff’s copyrights in “Hooked On You”
and “Can’t Get You Off My Mind” tracks. Defendants’ “Can’t Believe It” infringes
upon Plaintiff’s “Hooked On You” track as parts of Defendants’ “Can’t Believe It” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
beat and melody of Defendants’ “Can’t Believe It,” which are nearly identical or similar
to Plaintiff’s song “Hooked On You.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat and melody of Plaintiff’s
song.
171. Defendants’ “Can’t Believe It” infringes upon Plaintiff’s “Slow and Easy” track as parts
of Defendants’ “Can’t Believe It” copy and/or are strikingly similar to parts of Plaintiff’s
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song. Among these similarities are the chords of Defendants’ “Can’t Believe It,” which
are nearly identical or similar to Plaintiff’s song “Slow and Easy.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords of
Plaintiff’s song.
172. Defendants’ “Can’t Believe It” infringes upon two (2) of Plaintiff’s 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 Band’s 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 Plaintiff’s
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 Plaintiff’s copyrights in
“Runnin’ Away” and “Drowning in My Blues” tracks. Defendants’ “She Get It from Her
Mama” infringes upon Plaintiff’s “Runnin’ Away” track as parts of Defendants’ “She Get
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It from Her Mama” copy and/or are strikingly similar to parts of Plaintiff’s song. Among
these similarities are the chords and melody of Defendants’ “She Get It from Her Mama,”
which are nearly identical or similar to Plaintiff’s song “Runnin’ Away.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
chords and melody of Plaintiff’s song.
177. Defendants’ “She Get It from Her Mama” infringes upon Plaintiff’s “Drowning in My
Blues” track as parts of Defendants’ “She Get It from Her Mama” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities is the beat of
Defendants’ “She Get It from Her Mama,” which is nearly identical or similar to
Plaintiff’s song “Drowning in My Blues.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
178. Defendants’ “She Get It from Her Mama” infringes upon two (2) of Plaintiff’s
copyrights.
COPYRIGHT INFRINGEMENT – LOW
179. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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 Flo-
Rida’s album, “Mail on Sunday.” Defendants’ “Low” is registered with the U.S.
Copyright Office, Registration Number PA0001644879. Registration Number
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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 Plaintiff’s “Dancin’ Shoes” track as parts of
Defendants’ “Low” copy and/or are strikingly similar to parts of Plaintiff’s song. Among
these similarities are the chords, lyrics, beat and melody of Defendants’ “Low,” which is
nearly identical or similar to Plaintiff’s song “Dancin’ Shoes.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords, lyrics,
beat, and melody of Plaintiff’s song.
182. Defendants’ “Low” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – GOOD LIFE
183. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s album “Freeze.” Plaintiff’s “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, “Can’t 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 Plaintiff’s “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 appearing on Plaintiff’s
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 West’s 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 Plaintiff’s copyrights in “Can’t Get You Off My
Mind,” “Hip Jazz,” and “Spice” tracks. Defendants’ “Good Life” infringes upon
Plaintiff’s “Can’t Get You Off My Mind” track as parts of Defendants’ “Good Life” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
chords and melody of Defendants’ “Good Life,” which are nearly identical or similar to
Plaintiff’s song “Can’t Get You Off My Mind.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords and melody of
Plaintiff’s song.
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188. Defendants’ “Good Life” infringes upon Plaintiff’s “Hip Jazz” track as parts of
Defendants’ “Good Life” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the beat of Defendants’ “Good Life,” which is nearly
identical or similar to Plaintiff’s song “Hip Jazz.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
189. Defendants’ “Good Life” infringes upon Plaintiff’s “Spice” track as parts of Defendants’
“Good Life” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the lyrics of Defendants’ “Good Life,” which is nearly identical or similar
to Plaintiff’s song “Spice.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the lyrics of Plaintiff’s song.
190. Defendants’ “Good Life” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – I’M ON IT
191. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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, “It’s 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 “I’m On It” by Bei Meajor featuring T-Pain, which was released in 2011 and is
available online. Upon information and belief, Defendants’ “I’m On It” is not registered
with the U.S. Copyright Office. Upon information and belief, Nappypub Music owns the
copyright to “I’m On It.”
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193. Defendants’ “I’m On It” infringes upon Plaintiff’s copyrights in “It’s on (The Jam Is
On),” and “Space Station” tracks. Defendants’ “I’m On It” infringes upon Plaintiff’s
“It’s on (The Jam Is On)” track as parts of Defendants’ “I’m On It” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities are the beat and
melody of Defendants’ “I’m On It,” which are nearly identical or similar to Plaintiff’s
song “It’s on (The Jam Is On).” Upon information and belief, Defendants wrongfully
copied, among other parts of the song, the beat and melody of Plaintiff’s song.
194. Defendants’ “I’m On It” infringes upon Plaintiff’s “Space Station” track as parts of
Defendants’ “I’m On It” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “I’m On It,” which is nearly
identical or similar to Plaintiff’s song “Space Station.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiff’s
song.
195. Defendants’ “I’m On It” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – GO GIRL
196. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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.”
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 Ciara’s 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 Plaintiff’s “Space Station” track as parts of
Defendants’ “Go Girl” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the beat, chords, and melody of Defendants’ “Go Girl,”
which are nearly identical or similar to Plaintiff’s song “Space Station.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat, chords, and melody of Plaintiff’s song.
199. Defendants’ “Go Girl” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – MIND FUCKED
200. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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 Plaintiff’s
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, “It’s Time to Celebrate” and “I’ll 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-Pain’s 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 Plaintiff’s copyrights in “Never Leave You
Baby,” “It’s Time to Celebrate,” and “I’ll Be There” tracks. Defendants’ “Mind Fucked”
infringes upon Plaintiff’s “Never Leave You Baby” track as parts of Defendants’ “Mind
Fucked” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the chords and melody of Defendants’ “Mind Fucked,” which are nearly
identical or similar to Plaintiff’s song “Never Leave You Baby.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords and
melody of Plaintiff’s song.
204. Defendants’ “Mind Fucked” infringes upon Plaintiff’s “It’s Time to Celebrate” track as
parts of Defendants’ “Mind Fucked” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the beat and the lyrics of Defendants’
“Mind Fucked,” which are nearly identical or similar to Plaintiff’s song “It’s Time to
Celebrate.” Upon information and belief, Defendants wrongfully copied, among other
parts of the song, the beat and lyrics of Plaintiff’s song.
205. Defendants’ “Mind Fucked” infringes upon Plaintiff’s “I’ll Be There” track as parts of
Defendants’ “Mind Fucked” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords of Defendants’ “Mind Fucked,” which are nearly
identical or similar to Plaintiff’s song “I’ll Be There.” Upon information and belief,
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Defendants wrongfully copied, among other parts of the song, the chords of Plaintiff’s
song.
206. Defendants’ “Mind Fucked” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – SHAWTY GET LOOSE
207. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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 Mama’s 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 Plaintiff’s “Space Station” track as parts
of Defendants’ “Space Station” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities are the chords, beat, and melody of Defendants’ “Mind
Fucked,” which are nearly identical or similar to Plaintiff’s song “Space Station.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
chords, beat, and melody of Plaintiff’s song.
210. Defendants’ “Shawty Get Loose” infringes upon one (1) of Plaintiff’s 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 Band’s 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, “It’s On (The
Jam Is On).”
212. In or about 1999, Plaintiff authored music and lyrics in the track “Sportsman’s Paradise.”
“Sportsman’s Paradise” is included on Plaintiff’s “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 Brown’s 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 Plaintiff’s copyrights in “It’s On (The Jam is
On)” and “Sportsman’s Paradise” tracks. Defendants’ “Kiss Kiss” infringes upon
Plaintiff’s “It’s On (The Jam is On)” track as parts of Defendants’ “Kiss Kiss” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
melody and beat of Defendants’ “Kiss Kiss,” which are nearly identical or similar to
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Plaintiff’s song “It’s On (The Jam is On).” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the melody and beat of Plaintiff’s
song.
215. Defendants’ “Kiss Kiss” infringes upon Plaintiff’s “Sportsman’s Paradise” track as parts
of Defendants’ “Kiss Kiss” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the chant of Defendants’ “Kiss Kiss,” which is nearly
identical or similar to Plaintiff’s song “Sportsman’s Paradise.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chant of
Plaintiff’s song.
216. Defendants’ “Kiss Kiss” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – WOOL OVER MY EYES
217. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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-Pain’s
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 Plaintiff’s “Do It Right Now” track as
parts of Defendants’ “Wool Over My Eyes” copy and/or are strikingly similar to parts of
Plaintiff’s 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 Plaintiff’s
song “Do It Right Now.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the beat, melody, and chords of Plaintiff’s song.
220. Defendants’ “Wool Over My Eyes” infringes upon one (1) of Plaintiff’s 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-Pain’s mix tape,
“Stoic.” Upon information and belief, Defendants’ “Going Off” is not registered with the
U.S. Copyright Office. Upon information and belief, Nappypub Music owns the
copyright to “Going Off.”
223. Defendants’ “Going Off” infringes upon Plaintiff’s copyrights in “Ring Me” and
“Download My Love” tracks. Defendants’ “Going Off” infringes upon Plaintiff’s “Ring
Me” track as parts of Defendants’ “Going Off” copy and/or are strikingly similar to parts
of Plaintiff’s song. Among these similarities is the beat of Defendants’ “Going Off,”
which is nearly identical or similar to Plaintiff’s song “Ring Me.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the beat of
Plaintiff’s song.
224. Defendants’ “Going Off” infringes upon Plaintiff’s “Download My Love” track as parts
of Defendants’ “Going Off” copy and/or are strikingly similar to parts of Plaintiff’s song.
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Among these similarities are the chords and melody of Defendants’ “Going Off,” which
is nearly identical or similar to Plaintiff’s song “Download My Love.” Upon information
and belief, Defendants wrongfully copied, among other parts of the song, the chords and
melody of Plaintiff’s song.
225. Defendants’ “Going Off” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – THE CHAMP
226. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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, “It’s On (The
Jam Is On).”
227. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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, “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-Pain’s 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 Plaintiff’s copyrights in “It’s On (The Jam is
On)” and “Fur Elise” tracks. Defendants’ “The Champ” infringes upon Plaintiff’s “It’s
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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 Plaintiff’s song. Among these similarities are the beat and
hooks of Defendants’ “The Champ,” which are nearly identical or similar to Plaintiff’s
song “It’s On (The Jam is On).” Upon information and belief, Defendants wrongfully
copied, among other parts of the song, the beat and hooks of Plaintiff’s song.
230. Defendants’ “The Champ” infringes upon Plaintiff’s “Fur Elise” track as parts of
Defendants’ “The Champ” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords of Defendants’ “The Champ,” which are nearly
identical or similar to Plaintiff’s song “Fur Elise.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords of Plaintiff’s
song.
231. Defendants’ “The Champ” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – DON’T YOU QUIT
232. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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, “Kids.”
233. Upon information and belief, Defendants allegedly authored the music and lyrics in the
track “Don’t You Quit” by T-Pain, which was released in 2012 as part of T-Pain’s mix
tape, “Stoic.” Upon information and belief, Defendants’ “Don’t You Quit” is not
registered with the U.S. Copyright Office. Upon information and belief, Nappypub
Music owns the copyright to “Don’t You Quit.”
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234. Defendants’ “Don’t You Quit” infringes upon Plaintiff’s “Kids” track as parts of
Defendants’ “Don’t You Quit” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities are the beat and melody of Defendants’ “Don’t You
Quit,” which are nearly identical or similar to Plaintiff’s song “Kids.” Upon information
and belief, Defendants wrongfully copied, among other parts of the song, the beat and
melody of Plaintiff’s song.
235. Defendants’ “Don’t You Quit” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – FAIRY TALE
236. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Band’s 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-Pain’s mix tape,
“Stoic.” Upon information and belief, Defendants’ “Fairy Tale” is not registered with the
U.S. Copyright Office. Upon information and belief, Nappypub Music owns the
copyright to “Fairy Tale.”
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239. Defendants’ “Fairy Tale” infringes upon Plaintiff’s copyrights in “Drowning in My
Blues” and “Never Leave You Baby” tracks. Defendants’ “Fairy Tale” infringes upon
Plaintiff’s “Drowning in My Blues” track as parts of Defendants’ “Fairy Tale” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
beat and chords of Defendants’ “Fairy Tale,” which are nearly identical or similar to
Plaintiff’s song “Drowning in My Blues.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat and chords of Plaintiff’s song.
240. Defendants’ “Fairy Tale” infringes upon Plaintiff’s “Never Leave You Baby” track as
parts of Defendants’ “Fairy Tale” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the melody of Defendants’ “Fairy Tale,” which is
nearly identical or similar to Plaintiff’s song “Never Leave You Baby.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody of Plaintiff’s song.
241. Defendants’ “Fairy Tale” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – RHOCK EN ROLLAH
242. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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-Pain’s 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 Plaintiff’s copyrights in “Romantic
Sequence” and “Tiger (Travis)” tracks. Defendants’ “Rhock En Rollah” infringes upon
Plaintiff’s “Romantic Sequence” track as parts of Defendants’ “Rhock En Rollah” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
melody and chords of Defendants’ “Rhock En Rollah,” which are nearly identical or
similar to Plaintiff’s song “Romantic Sequence.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody and chords of
Plaintiff’s song.
245. Defendants’ “Rhock En Rollah” infringes upon Plaintiff’s “Tiger (Travis)” track as parts
of Defendants’ “Rhock En Rollah” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the beat of Defendants’ “Rhock En Rollah,”
which is nearly identical or similar to Plaintiff’s song “Tiger (Travis).” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
246. Defendants’ “Rhock En Rollah” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BLAPPER
247. In or about 1997, Plaintiff authored music and lyrics in the track “Hip Jazz.” “Hip Jazz”
is included on Plaintiff’s “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-Pain’s mix tape,
“Stoic.” Upon information and belief, Defendants’ “Blapper” is not registered with the
U.S. Copyright Office. Upon information and belief, Nappypub Music owns the
copyright to “Blapper.”
249. Defendants’ “Blapper” infringes upon Plaintiff’s “Hip Jazz” track as parts of Defendants’
“Blapper” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the beat and melody of Defendants’ “Blapper,” which are nearly identical
or similar to Plaintiff’s song “Hip Jazz.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat and melody of Plaintiff’s
song.
250. Defendants’ “Blapper” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BODY LANGUAGE
251. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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.”
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 McCartney’s 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 Plaintiff’s “Drowning in My Blues” track
as parts of Defendants’ “Body Language” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the melody and beat of Defendants’ “Body
Language,” which are nearly identical or similar to Plaintiff’s song “Drowning in My
Blues.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the melody and beat of Plaintiff’s song.
254. Defendants’ “Body Language” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – U AND DAT
255. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Band’s 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, “It’s 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 E40’s 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 Plaintiff’s copyrights in “Spice” and “It’s On
(The Jam Is On)” tracks. Defendants’ “U and Dat” infringes upon Plaintiff’s “Spice”
track as parts of Defendants’ “U and Dat” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the beat of Defendants’ “U and Dat,” which
is nearly identical or similar to Plaintiff’s song “Spice.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
259. Defendants’ “U and Dat” infringes upon Plaintiff’s “It’s On (The Jam Is On)” track as
parts of Defendants’ “U and Dat” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the melody of Defendants’ “U and Dat,” which is
nearly identical or similar to Plaintiff’s song “It’s On (The Jam Is On).” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody of Plaintiff’s song.
260. Defendants’ “U and Dat” infringes upon two (2) of Plaintiff’s 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 Plaintiff’s
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.”
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 Pitbull’s 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 Pitbull’s
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 Pitbull’s Legacy as the Copyright
Claimants.
264. Defendants’ “Hey Baby (Drop it to the Floor)” infringes upon Plaintiff’s copyrights in
“Starlite” and “Love Horizon” tracks. Defendants’ “Hey Baby (Drop it to the Floor)”
infringes upon Plaintiff’s “Starlite” track as parts of Defendants’ “Hey Baby (Drop it to
the Floor)” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities is the beat of Defendants’ “Hey Baby (Drop it to the Floor),” which is nearly
identical or similar to Plaintiff’s song “Starlite.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
265. Defendants’ “Hey Baby (Drop it to the Floor)” infringes upon Plaintiff’s “Love Horizon”
track as parts of Defendants’ “Hey Baby (Drop it to the Floor)” copy and/or are strikingly
similar to parts of Plaintiff’s 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
Plaintiff’s song “Love Horizon.” Upon information and belief, Defendants wrongfully
copied, among other parts of the song, the melody of Plaintiff’s song.
266. Defendants’ “Hey Baby (Drop it to the Floor)” infringes upon two (2) of Plaintiff’s
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 Plaintiff’s copyrights in “Bam There
You Have It” and “Move That Body” tracks. Defendants’ “Take Your Shirt Off”
infringes upon Plaintiff’s “Bam There You Have It” track as parts of Defendants’ “Take
Your Shirt Off” copy and/or are strikingly similar to parts of Plaintiff’s song. Among
these similarities is the beat of Defendants’ “Take Your Shirt Off,” which is nearly
identical or similar to Plaintiff’s 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
Plaintiff’s song.
270. Defendants’ “Take Your Shirt Off” infringes upon Plaintiff’s “Move That Body” track as
parts of Defendants’ “Take Your Shirt Off” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the melody of Defendants’ “Take Your Shirt
Off,” which is nearly identical or similar to Plaintiff’s song “Move That Body.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody of Plaintiff’s song.
271. Defendants’ “Take Your Shirt Off” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – SHAKE SENORA
272. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 “I’ll 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 Pitbull’s album, “Planet Pit.” Defendants’ “Shake Senora”
is registered with the U.S. Copyright Office, Registration Number PA0001820421.
Registration Number PA0001719812 lists Pitbull’s Legacy, Universal Music - Z Songs,
and Nappypub Music as the Copyright Claimants.
274. Defendants’ “Shake Senora” infringes upon Plaintiff’s copyrights in “Tropical Blue” and
“I’ll Be There” tracks. Defendants’ “Shake Senora” infringes upon Plaintiff’s “Tropical
Blue” track as parts of Defendants’ “Shake Senora” copy and/or are strikingly similar to
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parts of Plaintiff’s song. Among these similarities are the beat and chords of Defendants’
“Shake Senora,” which are nearly identical or similar to Plaintiff’s song “Tropical Blue.”
Upon information and belief, Defendants wrongfully copied, among other parts of the
song, the beat and chords of Plaintiff’s song.
275. Defendants’ “Shake Senora” infringes upon Plaintiff’s “I’ll Be There” track as parts of
Defendants’ “Shake Senora” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the melody of the introduction of Defendants’ “Shake
Senora,” which is nearly identical or similar to Plaintiff’s song “I’ll Be There.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody of Plaintiff’s song.
276. Defendants’ “Shake Senora” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – I’M 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 Band’s 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, “It’s On (The
Jam Is On).”
279. Upon information and belief, Defendants allegedly authored the music and lyrics in the
track “I’m 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’ “I’m Dancing”
is not registered with the U.S. Copyright Office. Upon information and belief, Nappypub
Music owns the copyright to “I’m Dancing.”
280. Defendants’ “I’m Dancing” infringes upon Plaintiff’s copyrights in “Starlite” and “It’s
On (The Jam Is On)” tracks. Defendants’ “I’m Dancing” infringes upon Plaintiff’s
“Starlite” track as parts of Defendants’ “I’m Dancing” copy and/or are strikingly similar
to parts of Plaintiff’s song. Among these similarities is the beat of Defendants’ “I’m
Dancing,” which is nearly identical or similar to Plaintiff’s song “Starlite.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
281. Defendants’ “I’m Dancing” infringes upon Plaintiff’s “It’s On (The Jam Is On)” track as
parts of Defendants’ “I’m Dancing” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the beat and melody of Defendants’ “I’m
Dancing,” which are nearly identical or similar to Plaintiff’s song “It’s On (The Jam Is
On).” Upon information and belief, Defendants wrongfully copied, among other parts of
the song, the beat and melody of Plaintiff’s song.
282. Defendants’ “I’m Dancing” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BEAM ME UP
283. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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, “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 “I’m Dancing.”
287. Defendants’ “Beam Me Up” infringes upon Plaintiff’s copyrights in “Space Station,”
“Party Down,” and “Starlite” tracks. Defendants’ “Beam Me Up” infringes upon
Plaintiff’s “Starlite” track as parts of Defendants’ “Beam Me Up” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities are the beat and
hooks of Defendants’ “Beam Me Up,” which are nearly identical or similar to Plaintiff’s
song “Starlite.” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the beat and hooks of Plaintiff’s song.
288. Defendants’ “Beam Me Up” infringes upon Plaintiff’s “Party Down” track as parts of
Defendants’ “Beam Me Up” copy and/or are strikingly similar to parts of Plaintiff’s song.
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Among these similarities are the chords of Defendants’ “Beam Me Up,” which are nearly
identical or similar to Plaintiff’s song “Party Down.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords of Plaintiff’s
song.
289. Defendants’ “Beam Me Up” infringes upon Plaintiff’s “Starlite” track as parts of
Defendants’ “Beam Me Up” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of the introduction of Defendants’ “Beam Me
Up,” which are nearly identical or similar to Plaintiff’s song “Starlite.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody of the introduction of Plaintiff’s song.
290. Defendants’ “I’m Dancing” infringes upon three (3) of Plaintiff’s 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 Plaintiff’s
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 Plaintiff’s
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 McCoy’s album, “Lazarus.” Upon information and belief, T-Pain was a
producer of “Lazarus.” Upon information and belief, Travie McCoy is signed to T-Pain’s
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
Art’s 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 Plaintiff’s copyrights in “Reggae Music,”
“Download My Love,” “Louisiana,” and “Still (Singing the Blues)” tracks. Defendants’
“Billionaire” infringes upon Plaintiff’s “Reggae Music” track as parts of Defendants’
“Billionaire” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the beat and chords of Defendants’ “Billionaire,” which are nearly
identical or similar to Plaintiff’s 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
Plaintiff’s song.
296. Defendants’ “Billionaire” infringes upon Plaintiff’s “Download My Love” track as parts
of Defendants’ “Billionaire” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the melody and chords of Defendants’ “Billionaire,” which
are nearly identical or similar to Plaintiff’s song “Download My Love.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody and chords of Plaintiff’s song.
297. Defendants’ “Billionaire” infringes upon Plaintiff’s “Louisiana” track as parts of
Defendants’ “Billionaire” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “Billionaire,” which is nearly
identical or similar to Plaintiff’s song “Louisiana.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiff’s
song.
298. Defendants’ “Billionaire” infringes upon Plaintiff’s “Still (Singing the Blues)” track as
parts of Defendants’ “Billionaire” copy and/or are strikingly similar to parts of Plaintiff’s
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 Plaintiff’s song
“Still (Singing the Blues).” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the melody of Plaintiff’s song.
299. Defendants’ “Billionaire” infringes upon four (4) of Plaintiff’s 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 Band’s 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 Plaintiff’s
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, “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, “Sportsman’s 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-Pain’s
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.
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304. Defendants’ “Church” infringes upon Plaintiff’s copyrights in “Space Station,” “Fur
Elise,” and “Sportsman’s Paradise” tracks. Defendants’ “Church” infringes upon
Plaintiff’s “Space Station” track as parts of Defendants’ “Church” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities is the beat of
Defendants’ “Church,” which is nearly identical or similar to Plaintiff’s song “Space
Station.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the beat of Plaintiff’s song.
305. Defendants’ “Church” infringes upon Plaintiff’s “Fur Elise” track as parts of Defendants’
“Church” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the chords of Defendants’ “Church,” which are nearly identical or similar
to Plaintiff’s song “Fur Elise.” Upon information and belief, Defendants wrongfully
copied, among other parts of the song, the chords of Plaintiff’s song.
306. Defendants’ “Church” infringes upon Plaintiff’s “Sportsman’s Paradise” track as parts of
Defendants’ “Church” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the hooks of Defendants’ “Church,” which are nearly
identical or similar to Plaintiff’s song “Sportsman’s Paradise.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the hooks of
Plaintiff’s song.
307. Defendants’ “Church” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – SAVE ME
308. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s album “Freeze.” Plaintiff’s “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, “Can’t 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 Band’s 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-Pain’s 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 Plaintiff’s copyrights in “Can’t Get You Off My
Mind” and “Runnin’ Away” tracks. Defendants’ “Save You” infringes upon Plaintiff’s
“Can’t Get You Off My Mind” track as parts of Defendants’ “Save You” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities are the chords of
Defendants’ “Save You,” which are nearly identical or similar to Plaintiff’s song “Can’t
Get You Off My Mind.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the chords of Plaintiff’s song.
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312. Defendants’ “Save You” infringes upon Plaintiff’s “Runnin’ Away” track as parts of
Defendants’ “Save You” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the melody and beat of Defendants’ “Save You,” which are
nearly identical or similar to Plaintiff’s song “Runnin’ Away.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the melody and beat
of Plaintiff’s song.
313. Defendants’ “Save You” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – FREAKNIK IS BACK
314. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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, “Fur Elise.”
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-Pain’s
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 Plaintiff’s “Fur Elise” track as parts of
Defendants’ “Freaknik Is Back” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities are the chords and beat of Defendants’ “Freaknik Is
Back,” which are nearly identical or similar to Plaintiff’s 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 Plaintiff’s song.
317. Defendants’ “Freaknik Is Back” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BUY YOU A DRANK (SHAWTY SNAPPIN’)
318. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s
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, “I’ll 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-Pain’s album, “Epiphany.” Defendants’
“Buy You A Drank (Shawty Snappin’)” is registered with the U.S. Copyright Office,
Registration Numbers PA0001649953 and PA0001601621. Registration Number
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 Plaintiff’s copyrights
in “Drowning in My Blues” and “I’ll Be There” tracks. Defendants’ “Buy You A Drank
(Shawty Snappin’)” infringes upon Plaintiff’s “Drowning in My Blues” track as parts of
Defendants’ “Buy You A Drank (Shawty Snappin’)” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities is the beat of Defendants’ “Buy You A
Drank (Shawty Snappin’),” which is nearly identical or similar to Plaintiff’s song
“Drowning in My Blues.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the beat of Plaintiff’s song.
322. Defendants’ “Buy You A Drank (Shawty Snappin’)” infringes upon Plaintiff’s “I’ll Be
There” track as parts of Defendants’ “Buy You A Drank (Shawty Snappin’)” copy and/or
are strikingly similar to parts of Plaintiff’s song. Among these similarities are the melody
and chords of Defendants’ “Buy You A Drank (Shawty Snappin’),” which are nearly
identical or similar to Plaintiff’s song “I’ll Be There.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody and chords of
Plaintiff’s song.
323. Defendants’ “Buy You A Drank (Shawty Snappin’)” infringes upon one (1) of Plaintiff’s
copyrights.
COPYRIGHT INFRINGEMENT – SHOW U HOW
324. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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” and “Can’t 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 T-
Pain’s 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 Plaintiff’s copyrights in “Still (Singing the
Blues),” “Hooked on You,” and “Can’t Get You Off My Mind.” Defendants’ “Show U
How” infringes upon Plaintiff’s “Still (Singing the Blues)” track as parts of Defendants’
“Show U How” copy and/or are strikingly similar to parts of Plaintiff’s song. Among
these similarities are the chords of Defendants’ “Show U How,” which are nearly
identical or similar to Plaintiff’s song “Still (Singing the Blues).” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords of
Plaintiff’s song.
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328. Defendants’ “Show U How” infringes upon Plaintiff’s “Hooked on You” track as parts of
Defendants’ “Show U How” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the beat of Defendants’ “Show U How,” which is nearly
identical or similar to Plaintiff’s song “Hooked on You.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
329. Defendants’ “Show U How” infringes upon Plaintiff’s “Can’t Get You Off My Mind”
track as parts of Defendants’ “Show U How” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the melody of Defendants’ “Show U How,”
which is nearly identical or similar to Plaintiff’s song “Can’t Get You Off My Mind.”
Upon information and belief, Defendants wrongfully copied, among other parts of the
song, the melody of Plaintiff’s song.
330. Defendants’ “Show U How” infringes upon three (3) of Plaintiff’s 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. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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, “Can’t Get You Off My Mind.” Plaintiff
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-Pain’s 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 Plaintiff’s copyrights in “I Like Your Way”
and “Can’t Get You Off My Mind.” Defendants’ “Put It Down” infringes upon
Plaintiff’s “I Like Your Way” track as parts of Defendants’ “Put It Down” copy and/or
are strikingly similar to parts of Plaintiff’s song. Among these similarities are the beat
and melody of Defendants’ “Put It Down,” which are nearly identical or similar to
Plaintiff’s song “I Like Your Way.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat and melody of Plaintiff’s
song.
335. Defendants’ “Put It Down” infringes upon Plaintiff’s “Can’t Get You Off My Mind”
track as parts of Defendants’ “Put It Down” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the chords of Defendants’ “Put It Down,”
which are nearly identical or similar to Plaintiff’s song “Can’t Get You Off My Mind.”
Upon information and belief, Defendants wrongfully copied, among other parts of the
song, the chords of Plaintiff’s song.
336. Defendants’ “Put It Down” infringes upon three (3) of Plaintiff’s copyrights.
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COPYRIGHT INFRINGEMENT – I’M A FREAK
337. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 “I’m a Freak” by Young Cash, which was released in 2009 as a single and is
available online. Upon information and belief, Defendants’ “I’m a Freak” is not
registered with the U.S. Copyright Office. Upon information and belief, Nappy Boy
Digital owns the copyright to “I’m a Freak.”
339. Defendants’ “I’m a Freak” infringes upon Plaintiff’s “Drowning in My Blues” track as
parts of Defendants’ “I’m a Freak” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the beat, melody, and hooks of
Defendants’ “I’m a Freak,” which are nearly identical or similar to Plaintiff’s song
“Drowning in My Blues.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the beat, melody, and hooks of Plaintiff’s song.
340. Defendants’ “I’m a Freak” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – FREAKY SONG
341. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s “Still (Singing the Blues)” track as
parts of Defendants’ “Freaky Song” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the chords and melody of Defendants’
“Freaky Song,” which are nearly identical or similar to Plaintiff’s song “Still (Singing the
Blues).” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the chords and melody of Plaintiff’s song.
344. Defendants’ “Freaky Song” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – REGGAE NIGHT
345. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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-Pain’s 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 Plaintiff’s copyrights in “Blues Man” and
“Bam There You Have It.” Defendants’ “Reggae Night” infringes upon Plaintiff’s
“Blues Man” track as parts of Defendants’ “Reggae Night” copy and/or are strikingly
similar to parts of Plaintiff’s song. Among these similarities is the melody of
Defendants’ “Reggae Night,” which is nearly identical or similar to Plaintiff’s song
“Blues Man.” Upon information and belief, Defendants wrongfully copied, among other
parts of the song, the melody of Plaintiff’s song.
349. Defendants’ “Reggae Night” infringes upon Plaintiff’s “Bam There You Have It” track as
parts of Defendants’ “Reggae Night” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the beat of Defendants’ “Reggae Night,”
which is nearly identical or similar to Plaintiff’s song “Bam There You Have It.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
350. Defendants’ “Reggae Night” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – STRESSIN
351. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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.”
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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 Plaintiff’s “Romantic Sequence” track as parts of
Defendants’ “Stressin” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the beat and chords of Defendants’ “Stressin,” which is
nearly identical or similar to Plaintiff’s song “Romantic Sequence.” Upon information
and belief, Defendants wrongfully copied, among other parts of the song, the beat and
chords of Plaintiff’s song.
354. Defendants’ “Stressin” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – HOLLA HOLLA
355. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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, “My Bad.”
356. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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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357. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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, “It’s All About the Family.” Plaintiff is
the sole author of the music and lyrics in these tracks. Plaintiff’s “It’s 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 Akon’s
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 Plaintiff’s copyrights in “My Bad,” “Drowning
in My Blues” and “It’s All About the Family.” Defendants’ “Holla Holla” infringes upon
Plaintiff’s “My Bad” track as parts of Defendants’ “Holla Holla” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities is the hook of
Defendants’ “Holla Holla,” which is nearly identical or similar to Plaintiff’s song “My
Bad.” Upon information and belief, Defendants wrongfully copied, among other parts of
the song, the hook of Plaintiff’s song.
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360. Defendants’ “Holla Holla” infringes upon Plaintiff’s “Drowning in My Blues” track as
parts of Defendants’ “Holla Holla” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the beat of Defendants’ “Holla Holla,”
which is nearly identical or similar to Plaintiff’s song “Drowning in My Blues.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
361. Defendants’ “Holla Holla” infringes upon Plaintiff’s “It’s All About the Family” track as
parts of Defendants’ “Holla Holla” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the chords of Defendants’ “Holla Holla,”
which are nearly identical or similar to Plaintiff’s song “It’s All About the Family.”
Upon information and belief, Defendants wrongfully copied, among other parts of the
song, the chords of Plaintiff’s song.
362. Defendants’ “Holla Holla” infringes upon three (3) of Plaintiff’s 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. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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, “Can’t Get You Off My Mind.” Plaintiff
is the sole author of the music and lyrics in these tracks.
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365. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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.”
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-Pains’s 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 Plaintiff’s copyrights in “Download My Love,” “Can’t
Get You Off My Mind,” and “Drowning in My Blues.” Defendants’ “69” infringes upon
Plaintiff’s “Download My Love” track as parts of Defendants’ “69” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities is the hook of
Defendants’ “69,” which is nearly identical or similar to Plaintiff’s song “Download My
Love.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the hook of Plaintiff’s song.
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368. Defendants’ “69” infringes upon Plaintiff’s “Can’t Get You Off My Mind” track as parts
of Defendants’ “69” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords of Defendants’ “69,” which are nearly identical
or similar to Plaintiff’s song “Can’t Get You Off My Mind.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords of
Plaintiff’s song.
369. Defendants’ “69” infringes upon Plaintiff’s “Drowning in My Blues” track as parts of
Defendants’ “69” copy and/or are strikingly similar to parts of Plaintiff’s song. Among
these similarities is the beat of Defendants’ “69,” which is nearly identical or similar to
Plaintiff’s song “Drowning in My Blues.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
370. Defendants’ “69” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – 5 O’CLOCK
371. In or about 1997, Plaintiff authored music and lyrics in the track “Just You and I.” “Just
You and I” is included on Plaintiff’s “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. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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.”
373. Upon information and belief, Defendants allegedly authored the music and lyrics in the
track “5 O’Clock” 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-Pain’s album, “Revolver.” Defendants’ “5 O’Clock” 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 O’Clock” infringes upon Plaintiff’s copyrights in “Just You and I” and
“Drowning in My Blues.” Defendants’ “5 O’Clock” infringes upon Plaintiff’s “Just You
and I” track as parts of Defendants’ “5 O’Clock” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities are the chords and melody of
Defendants’ “5 O’Clock,” which are nearly identical or similar to Plaintiff’s song “Just
You and I.” Upon information and belief, Defendants wrongfully copied, among other
parts of the song, the chords and melody of Plaintiff’s song.
375. Defendants’ “5 O’Clock” infringes upon Plaintiff’s “Drowning in My Blues” track as
parts of Defendants’ “5 O’Clock” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities is the beat of Defendants’ “5 O’Clock,” which is nearly
identical or similar to Plaintiff’s song “Drowning in My Blues.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the beat of
Plaintiff’s song.
376. Defendants’ “5 O’Clock” infringes upon two (2) of Plaintiff’s 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 Band’s 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, “Can’t 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 Plaintiff’s “Can’t Get You Off My
Mind” track as parts of Defendants’ “You Know What It Is” copy and/or are strikingly
similar to parts of Plaintiff’s song. Among these similarities are the chords, beat, and
hook of Defendants’ “You Know What It Is,” which are nearly identical or similar to
Plaintiff’s song “Can’t Get You Off My Mind.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords, beat, and hook
of Plaintiff’s song.
380. Defendants’ “You Know What It Is” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BANG BANG POW POW
381. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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, “It’s All About the Family.” Plaintiff is
the sole author of the music and lyrics in these tracks. Plaintiff’s “It’s 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 Plaintiff’s
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 Plaintiff’s
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-Pain’s 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 Plaintiff’s copyrights in “It’s All
About the Family,” “Nothin’ But the Funk,” and “Oh Carnival.” Defendants’ “Bang
Bang Pow Pow” infringes upon Plaintiff’s “It’s All About the Family” track as parts of
Defendants’ “Bang Bang Pow Pow” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the chords of Defendants’ “Bang Bang
Pow Pow,” which are nearly identical or similar to Plaintiff’s song “It’s All About the
Family.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the chords of Plaintiff’s song.
386. Defendants’ “Bang Bang Pow Pow” infringes upon Plaintiff’s “Nothin’ But the Funk”
track as parts of Defendants’ “Bang Bang Pow Pow” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities is the hook of Defendants’ “Bang
Bang Pow Pow,” which is nearly identical or similar to Plaintiff’s song “Nothin’ But the
Funk.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the hook of Plaintiff’s song.
387. Defendants’ “Bang Bang Pow Pow” infringes upon Plaintiff’s “Oh Carnival” track as
parts of Defendants’ “Bang Bang Pow Pow” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the beat of Defendants’ “Bang Bang Pow
Pow,” which is nearly identical or similar to Plaintiff’s song “Oh Carnival.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
388. Defendants’ “Bang Bang Pow Pow” infringes upon three (3) of Plaintiff’s 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 Plaintiff’s
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 Plaintiff’s
album “Sportsman’s Paradise.” The “Sportsman’s Paradise” album was wholly original
and is registered with the U.S. Copyright Office, Registration Number SRu000502891.
The “Sportsman’s 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-Pain’s 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 Plaintiff’s copyrights in “Do It Right
Now” and “Overtime.” Defendants’ “Best Love Song” infringes upon Plaintiff’s “Do It
Right Now” track as parts of Defendants’ “Best Love Song” copy and/or are strikingly
similar to parts of Plaintiff’s song. Among these similarities are the melodies of
Defendants’ “Best Love Song,” which are nearly identical or similar to Plaintiff’s 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 Plaintiff’s song.
393. Defendants’ “Best Love Song” infringes upon Plaintiff’s “Overtime” track as parts of
Defendants’ “Best Love Song” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities are the beat and chords of Defendants’ “Best Love
Song,” which are nearly identical or similar to Plaintiff’s song “Overtime.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat and chords of Plaintiff’s song.
394. Defendants’ “Best Love Song” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – NUTHIN’
395. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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, “It’s 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-Pain’s 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 Plaintiff’s copyrights in “It’s On (The Jam is On)”
and “Kids.” Defendants’ “Nuthin’” infringes upon Plaintiff’s “It’s On (The Jam is On)”
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track as parts of Defendants’ “Nuthin’” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the melody of Defendants’ “Nuthin’,” which
is nearly identical or similar to Plaintiff’s song “It’s On (The Jam is On).” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
melody of Plaintiff’s song.
398. Defendants’ “Nuthin’” infringes upon Plaintiff’s “Kids” track as parts of Defendants’
“Nuthin’” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities is the beat of Defendants’ “Nuthin’,” which is nearly identical or similar to
Plaintiff’s song “Kids.” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the beat of Plaintiff’s song.
399. Defendants’ “Nuthin’” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – I’M SO HOOD
400. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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, “It’s On (The Jam is On).”
401. Upon information and belief, Defendants allegedly authored the music and lyrics in the
track “I’m 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’ “I’m So Hood” infringes upon Plaintiff’s “It’s On (The Jam is On)” track as
parts of Defendants’ “I’m So Hood” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the beats and melodies of Defendants’
“I’m So Hood,” which are nearly identical or similar to Plaintiff’s song “It’s On (The Jam
is On).” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the beats and melodies of Plaintiff’s song.
403. Defendants’ “I’m So Hood” infringes upon one (1) of Plaintiff’s 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 Band’s 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, “It’s 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 Khaled’s 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 Plaintiff’s copyrights in “It’s On
(The Jam is On)” and “Ring Me.” Defendants’ “Welcome to My Hood” infringes upon
Plaintiff’s “It’s On (The Jam is On)” track as parts of Defendants’ “Welcome to My
Hood” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities is the beat of Defendants’ “Welcome to My Hood,” which is nearly identical
or similar to Plaintiff’s song “It’s On (The Jam is On).” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
408. Defendants’ “Welcome to My Hood” infringes upon Plaintiff’s “Ring Me” track as parts
of Defendants’ “Welcome to My Hood” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the hook of Defendants’ “Welcome to My
Hood,” which is nearly identical or similar to Plaintiff’s song “Ring Me.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
hook of Plaintiff’s song.
409. Defendants’ “Welcome to My Hood” infringes upon two (2) of Plaintiff’s 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 Band’s 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 Plaintiff’s “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 Plaintiff’s
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.”
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 Plaintiff’s copyrights in “Space Station,” “Just
You and I,” and “Romantic Sequence.” Defendants’ “Dreamgirl” infringes upon
Plaintiff’s “Space Station” track as parts of Defendants’ “Dreamgirl” copy and/or are
strikingly similar to parts of Plaintiff’s song. Among these similarities is the beat of
Defendants’ “Dreamgirl,” which is nearly identical or similar to Plaintiff’s song “Space
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Station.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the beat of Plaintiff’s song.
415. Defendants’ “Dreamgirl” infringes upon Plaintiff’s “Just You and I” track as parts of
Defendants’ “Dreamgirl” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “Dreamgirl,” which is nearly
identical or similar to Plaintiff’s song “Just You and I.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiff’s
song.
416. Defendants’ “Dreamgirl” infringes upon Plaintiff’s “Just You and I” track as parts of
Defendants’ “Dreamgirl” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the melody of Defendants’ “Dreamgirl,” which is nearly
identical or similar to Plaintiff’s song “Just You and I.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melody of Plaintiff’s
song.
417. Defendants’ “Dreamgirl” infringes upon Plaintiff’s “Romantic Sequence” track as parts
of Defendants’ “Dreamgirl” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords of Defendants’ “Dreamgirl,” which are nearly
identical or similar to Plaintiff’s song “Romantic Sequence.” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the chords of
Plaintiff’s song.
418. Defendants’ “Dreamgirl” infringes upon three (3) of Plaintiff’s 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 T-
Pain’s album, “Thr33 Ringz.” Defendants’ “Thr33 Ringz” is registered with the U.S.
Copyright Office, Registration Numbers SR0000619901 and SR0000621421. Both
registrations list Zomba Recording LLC as the Copyright Claimant.
421. Defendants’ “Karaoke” infringes upon Plaintiff’s “Ring Me” track as parts of
Defendants’ “Karaoke” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the beat, chords, and melody of Defendants’ “Karaoke,”
which are nearly identical or similar to Plaintiff’s song “Ring Me.” Upon information
and belief, Defendants wrongfully copied, among other parts of the song, the beat,
chords, and melody of Plaintiff’s song.
422. Defendants’ “Karaoke” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – NO NEW FRIENDS
423. In or about 1982, Plaintiff authored music and lyrics in the appearing on the Batiste
Brothers Band’s 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, “It’s All About the Family.” Plaintiff is
the sole author of the music and lyrics in these tracks. Plaintiff’s “It’s 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 Band’s 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, “Can’t 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 Plaintiff’s copyrights in “It’s All About
the Family,” “Can’t Get You Off My Mind,” and “Bam There You Have It.”
Defendants’ “No New Friends” infringes upon Plaintiff’s “It’s All About the Family”
track as parts of Defendants’ “No New Friends” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities are the hooks of Defendants’ “No
New Friends,” which are nearly identical or similar to Plaintiff’s song “It’s All About the
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Family.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the hooks of Plaintiff’s song.
428. Defendants’ “No New Friends” infringes upon Plaintiff’s “Can’t Get You Off My Mind”
track as parts of Defendants’ “No New Friends” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities are the chords of Defendants’ “No
New Friends,” which are nearly identical or similar to Plaintiff’s song “Can’t Get You
Off My Mind.” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the chords of Plaintiff’s song.
429. Defendants’ “No New Friends” infringes upon Plaintiff’s “Bam There You Have It” track
as parts of Defendants’ “No New Friends” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the beat of Defendants’ “No New Friends,”
which is nearly identical or similar to Plaintiff’s song “Bam There You Have It.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
430. Defendants’ “No New Friends” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – WE TAKIN’ OVER
431. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Khaled’s album,
“We the Best.” “We Takin’ Over” is registered with the U.S. Copyright Office,
Registration Numbers PA0001811285 and PA0001589109. Registration Number
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 Plaintiff’s copyrights in “Still (Singing the
Blues)” and “Move That Body.” Defendants’ “We Takin’ Over” infringes upon
Plaintiff’s “Still (Singing the Blues)” track as parts of Defendants’ “We Takin’ Over”
copy and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities is
the melody of the introduction of Defendants’ “We Takin’ Over,” which is nearly
identical or similar to Plaintiff’s song “Still (Singing the Blues).” Upon information and
belief, Defendants wrongfully copied, among other parts of the song, the melody of the
introduction of Plaintiff’s song.
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435. Defendants’ “We Takin’ Over” infringes upon Plaintiff’s “Move That Body” track as
parts of Defendants’ “We Takin’ Over” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the beat and hook of the introduction of
Defendants’ “We Takin’ Over,” which are nearly identical or similar to Plaintiff’s song
“Move That Body.” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the beat and hook of Plaintiff’s song.
436. Defendants’ “We Takin’ Over” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – OUT HERE GRINDIN’
437. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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.”
438. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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
Khaled’s album, “We Global.” “Out Here Grindin’” is registered with the U.S.
Copyright Office, Registration 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 Plaintiff’s copyrights in “Space Station”
and “Still (Singing the Blues).” Defendants’ “Out Here Grindin’” infringes upon
Plaintiff’s “Space Station” track as parts of Defendants’ “Out Here Grindin’” copy and/or
are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
melodic effects and the beat of Defendants’ “Out Here Grindin’,” which are nearly
identical or similar to Plaintiff’s song “Space Station.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the melodic effects and the
beat of Plaintiff’s song.
441. Defendants’ “Out Here Grindin’” infringes upon Plaintiff’s “Still (Singing the Blues)”
track as parts of Defendants’ “Out Here Grindin’” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities is the hook of the introduction of
Defendants’ “Out Here Grindin’,” which is nearly identical or similar to Plaintiff’s 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 Plaintiff’s song.
442. Defendants’ “Out Here Grindin’” infringes upon two (2) of Plaintiff’s 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 Plaintiff’s
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 Khaled’s 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 Plaintiff’s copyrights in “Bam There
You Have It” and “Still (Singing the Blues).” Defendants’ “I Wish You Would”
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infringes upon Plaintiff’s “Bam There You Have It” track as parts of Defendants’ “I Wish
You Would” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities is the beat of Defendants’ “I Wish You Would,” which is nearly identical or
similar to Plaintiff’s song “Bam There You Have It.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
447. Defendants’ “I Wish You Would” infringes upon Plaintiff’s “Still (Singing the Blues)”
track as parts of Defendants’ “I Wish You Would” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities are the hook and chords of
Defendants’ “I Wish You Would,” which are nearly identical or similar to Plaintiff’s
song “Still (Singing the Blues).” Upon information and belief, Defendants wrongfully
copied, among other parts of the song, the hook and chords of Plaintiff’s song.
448. Defendants’ “I Wish You Would’” infringes upon two (2) of Plaintiff’s 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 Band’s 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 Plaintiff’s
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 Khaled’s
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 Don’t 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 Plaintiff’s copyrights in “Never Leave
You Baby” and “Drowning in My Blues.” Defendants’ “Take It to the Head” infringes
upon Plaintiff’s “Never Leave You Baby” track as parts of Defendants’ “Take It to the
Head” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities are the hooks and chords of Defendants’ “Take It to the Head,” which are
nearly identical or similar to Plaintiff’s 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 Plaintiff’s song.
453. Defendants’ “Take It to the Head” infringes upon Plaintiff’s “Drowning in My Blues”
track as parts of Defendants’ “Take It to the Head” copy and/or are strikingly similar to
parts of Plaintiff’s song. Among these similarities is the beat of Defendants’ “Take It to
the Head,” which is nearly identical or similar to Plaintiff’s song “Drowning in My
Blues.” Upon information and belief, Defendants wrongfully copied, among other parts
of the song, the beat of Plaintiff’s song.
454. Defendants’ “Take It to the Head” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – THE BOSS
455. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s copyrights in “Still (Singing the
Blues),” “Drowning in My Blues,” and “Ring Me.” Defendants’ “The Boss” infringes
upon Plaintiff’s “Still (Singing the Blues)” track as parts of Defendants’ “The Boss” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
hooks of Defendants’ “The Boss,” which are nearly identical or similar to Plaintiff’s song
“Still (Singing the Blues).” Upon information and belief, Defendants wrongfully copied,
among other parts of the song, the hooks of Plaintiff’s song.
459. Defendants’ “The Boss” infringes upon Plaintiff’s “Drowning in My Blues” track as parts
of Defendants’ “The Boss” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities is the beat of Defendants’ “The Boss,” which is nearly identical
or similar to Plaintiff’s song “Drowning in My Blues.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
460. Defendants’ “The Boss” infringes upon Plaintiff’s “Ring Me” track as parts of
Defendants’ “The Boss” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords of Defendants’ “The Boss,” which are nearly
identical or similar to Plaintiff’s song “Ring Me.” Upon information and belief,
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Defendants wrongfully copied, among other parts of the song, the chords of Plaintiff’s
song.
461. Defendants’ “The Boss” infringes upon three (3) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – FREEZE
462. In or about 1982, Plaintiff authored music and lyrics in the track “Freeze.” Plaintiff’s
“Freeze” was wholly original and is registered with the U.S. Copyright Office,
Registration Number PAu000390579. Plaintiff is the Copyright Claimant. Plaintiff’s
“Freeze” (track) was recorded and released as part of the Batiste Brothers Band’s 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 Cash’s 2008 album, “Scared Money Don’t 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 Plaintiff’s copyrights in “Freeze” and “Bam There
You Have It.” Defendants’ “Freeze” infringes upon Plaintiff’s “Freeze” track as parts of
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Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the hooks of Defendants’ “Freeze,” which are nearly
identical or similar to Plaintiff’s song “Freeze.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the hooks of Plaintiff’s song.
466. Defendants’ “Freeze” infringes upon Plaintiff’s “Bam There You Have It” track as parts
of Defendants’ “Freeze” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the beat and chords of Defendants’ “Freeze,” which are
nearly identical or similar to Plaintiff’s song “Bam There You Have It.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat and chords of Plaintiff’s song.
467. Defendants’ “Freeze” infringes upon two (2) of Plaintiff’s 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 Band’s 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 Plaintiff’s
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 Plaintiff’s copyrights in
“Never Leave You Baby” and “Drowning in My Blues.” Defendants’ “All the Money in
the World” infringes upon Plaintiff’s “Never Leave You Baby” track as parts of
Defendants’ “All the Money in the World” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities are the hooks and chords of Defendants’ “All
the Money in the World,” which are nearly identical or similar to Plaintiff’s song “Never
Leave You Baby.” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the hooks and chords of Plaintiff’s song.
472. Defendants’ “All the Money in the World” infringes upon Plaintiff’s “Drowning in My
Blues” track as parts of Defendants’ “All the Money in the World” copy and/or are
strikingly similar to parts of Plaintiff’s 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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Plaintiff’s song “Drowning in My Blues.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
473. Defendants’ “All the Money in the World” infringes upon two (2) of Plaintiff’s
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 Plaintiff’s
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.”
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
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 Plaintiff’s copyrights in “Bam There
You Have It” and “Romantic Sequence.” Defendants’ “Aston Martin Music” infringes
upon Plaintiff’s “Bam There You Have It” track as parts of Defendants’ “Aston Martin
Music” copy and/or are strikingly similar to parts of Plaintiff’s song. Among these
similarities is the beat of Defendants’ “Aston Martin Music,” which is nearly identical or
similar to Plaintiff’s song “Bam There You Have It.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the beat of Plaintiff’s song.
478. Defendants’ “Aston Martin Music” infringes upon Plaintiff’s “Romantic Sequence” track
as parts of Defendants’ “Aston Martin Music” copy and/or are strikingly similar to parts
of Plaintiff’s song. Among these similarities are the chords of Defendants’ “Aston
Martin Music,” which are nearly identical or similar to Plaintiff’s song “Romantic
Sequence.” Upon information and belief, Defendants wrongfully copied, among other
parts of the song, the chords of Plaintiff’s song.
479. Defendants’ “Aston Martin Music” infringes upon two (2) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – B.M.F. (BLOWIN’ MONEY FAST)
480. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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, “Fur Elise.”
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481. In or about 2001, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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, “My Bad.”
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 Plaintiff’s copyrights in “Fur
Elise” and “My Bad.” Defendants’ “B.M.F. (Blowin’ Money Fast)” infringes upon
Plaintiff’s “Fur Elise” track as parts of Defendants’ “B.M.F. (Blowin’ Money Fast)” copy
and/or are strikingly similar to parts of Plaintiff’s song. Among these similarities are the
chords of Defendants’ “B.M.F. (Blowin’ Money Fast),” which are nearly identical or
similar to Plaintiff’s song “Fur Elise.” Upon information and belief, Defendants
wrongfully copied, among other parts of the song, the chords of Plaintiff’s song.
484. Defendants’ “B.M.F. (Blowin’ Money Fast)” infringes upon Plaintiff’s “My Bad” track
as parts of Defendants’ “B.M.F. (Blowin’ Money Fast)” copy and/or are strikingly
similar to parts of Plaintiff’s 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 Plaintiff’s song
“My Bad.” Upon information and belief, Defendants wrongfully copied, among other
parts of the song, the beat of Plaintiff’s song.
485. Defendants’ “B.M.F. (Blowin’ Money Fast)” infringes upon two (2) of Plaintiff’s
copyrights.
COPYRIGHT INFRINGEMENT – CAN’T STOP
486. In or about 1999, Plaintiff authored music and lyrics in the track “Sportsman’s Paradise.”
“Sportsman’s Paradise” is included on Plaintiff’s “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 “Can’t Stop” by Ace Hood featuring Akon, which was released in 2008 as part of
the album, “DJ Khaled Presents Ace Hood – Gutta.” Defendants’ “Can’t 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’ “Can’t Stop” infringes upon Plaintiff’s “Sportsman’s Paradise” track as parts
of Defendants’ “Can’t Stop” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords, melodies, and beat of Defendants’ “Can’t Stop,”
which are nearly identical or similar to Plaintiff’s song “Sportsman’s Paradise.” Upon
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information and belief, Defendants wrongfully copied, among other parts of the song, the
chords, melodies, and beat of Plaintiff’s song.
489. Defendants’ “Can’t Stop” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – CASH FLOW
490. In or about 1999, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s “Blues Man” track as parts of
Defendants’ “Cash Flow” copy and/or are strikingly similar to parts of Plaintiff’s song.
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Among these similarities are the hook and beat of Defendants’ “Cash Flow,” which are
nearly identical or similar to Plaintiff’s song “Blues Man.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the hook and beat of
Plaintiff’s song.
493. Defendants’ “Cash Flow” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – TOP OF THE WORLD
494. In or about 1991, Plaintiff authored music and lyrics in the tracks appearing on Plaintiff’s
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 Plaintiff’s “Louisiana” track as parts of
Defendants’ “Top of the World” copy and/or are strikingly similar to parts of Plaintiff’s
song. Among these similarities are the chords and beat of Defendants’ “Top of the
World,” which are nearly identical or similar to Plaintiff’s song “Louisiana.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
chords and beat of Plaintiff’s song.
497. Defendants’ “Top of the World” infringes upon one (1) of Plaintiff’s 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 Band’s 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 Hood’s 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 Plaintiff’s “Runnin’ Away” track as parts of
Defendants’ “ErrryThang” copy and/or are strikingly similar to parts of Plaintiff’s song.
Among these similarities are the chords of Defendants’ “ErrryThang,” which are nearly
identical or similar to Plaintiff’s song “Runnin’ Away.” Upon information and belief,
Defendants wrongfully copied, among other parts of the song, the chords of Plaintiff’s
song.
501. Defendants’ “ErrryThang” infringes upon one (1) of Plaintiff’s copyrights.
COPYRIGHT INFRINGEMENT – BODY 2 BODY
502. In or about 1984, Plaintiff authored music and lyrics in the tracks appearing on the
Batiste Brothers Band’s 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 Hood’s 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 Plaintiff’s copyrights in “Runnin’ Away” and
“Bam There You Have It.” Defendants’ “Body 2 Body” infringes upon Plaintiff’s
“Runnin’ Away” track as parts of Defendants’ “Body 2 Body” copy and/or are strikingly
similar to parts of Plaintiff’s song. Among these similarities are the chords of
Defendants’ “Body 2 Body,” which are nearly identical or similar to Plaintiff’s song
“Runnin’ Away.” Upon information and belief, Defendants wrongfully copied, among
other parts of the song, the chords of Plaintiff’s song.
506. Defendants’ “Body 2 Body” infringes upon Plaintiff’s “Bam There You Have It” track as
parts of Defendants’ “Body 2 Body” copy and/or are strikingly similar to parts of
Plaintiff’s song. Among these similarities is the beat of Defendants’ “Body 2 Body,”
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which is nearly identical or similar to Plaintiff’s song “Bam There You Have It.” Upon
information and belief, Defendants wrongfully copied, among other parts of the song, the
beat of Plaintiff’s song.
507. Defendants’ “Body 2 Body” infringes upon two (2) of Plaintiff’s copyrights.
508. 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 Plaintiff’s 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. This Complaint be deemed good and sufficient by this Honorable Court;
2. 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 Plaintiff’s songs;
4. For the issuance of a permanent injunction which shall enjoin Defendants from taking
any action which would further infringe Plaintiff’s rights;
5. For the issuance of a permanent injunction which shall restraining Defendants from using
any infringing material without Plaintiff’s 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. For a trial by jury; and
9. For all other relief allowed by law.
Dated: August 16, 2013.
Respectfully submitted:
KOEPPEL TRAYLOR LLC
/s/ Mark N. Melasky
____________________________________
PETER S. KOEPPEL (#1465)
MARK N. MELASKY (#34326)
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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