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Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 1 of 118

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

PAUL BATISTE D/B/A * 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. * ******************************************************************************

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 2 of 118

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

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.

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.

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.

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.

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.

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

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.

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.

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.

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.

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.

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

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 19 of 118

“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.

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.

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

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 22 of 118

with the U.S. Copyright Office, Registration Numbers SR0000679040 and

PA0001745570. Registration Number SR0000679040 lists Capitol Records LLC as the

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.

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.

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 23 of 118

“(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.

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.

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.

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.

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.”

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 25 of 118

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.

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.

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.

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.

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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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.

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.

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.

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.

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.

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.

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

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 35 of 118

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.

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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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.

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.

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.

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.

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.

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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.

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.

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.

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.

“(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

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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.

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.

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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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.

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

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.

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.

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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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.

“(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

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.

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.

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.

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

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.

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.

“(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

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.

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.

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.

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

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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.

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.

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

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.

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.

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.

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.

“(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.

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.

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.

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.

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.

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.

“(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.

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.

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.

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.

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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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.

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.

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.

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.

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.

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

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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.

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).”

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 73 of 118

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.

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.

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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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.

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).”

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 77 of 118

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.

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,

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 78 of 118

“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.

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.

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.”

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 80 of 118

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.

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.

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 82 of 118

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.

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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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.

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.

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.

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 87 of 118

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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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.

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.

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.

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.

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.

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.

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.

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.

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,

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 92 of 118

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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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.

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.

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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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.

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.

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

Case 2:13-cv-05463-KDE-SS Document 1 Filed 08/16/13 Page 96 of 118

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.

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.

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.

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.

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

100

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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.

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.

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.

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.

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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.

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

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.

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.

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

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.

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.

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.

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.

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.

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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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.

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.

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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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) [email protected] MARK N. MELASKY (#34326) [email protected] 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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