theJasmineBRAND.comtheJasmineBRAND.com Case 2:14-cv-07714-SS Document 1 Filed 10/03/14 Page 1 of 15 Page ID #:1 1 SHAWN AZIZZADEH (SBN 227558) [email protected] 2 BEDFORD LAW GROUP, PLC 3 1925 Century Park East, Suite 2120 Los Angeles, CA 90067 4 Tel: (310)507-7900 5 Fax:(310)507-7910 6 OLIVIER A. TAILLIEU (SBN 206546) [email protected] 7 TAILLIEU LAW FIRM LLP 8 450 N. Roxbury Dr., Suite 700 Beverly Hills, California 90210 9 Tel: (310)651-2440theJasmineBRAND.comtheJasmineBRAND.com 10 Fax:(310)651-2439 11 Attorneys for Plaintiffs MAHAD DAR and CREATIVE DREAM PRODUCTIONS LLC. 12 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 15 16 MAHAD DAR, an individual and CASE NO. CREATIVE DREAM 17 PRODUCTIONS, LLC a California COMPLAINT FOR: 18 Limited Liability Company; 1. COPYRIGHT INFRINGEMENT; 19 Plaintiff, 2. CONTRIBUTIRY COPYRIGHT INFRINGEMENT 20 3. VICARIOUS COPYRIGHT theJasmineBRAND.com INFRINGEMENT 21 4. INDUCEMENT OF COPYRIGHT JORDAN HOUSTON p/k/a "JUICY J"; INFRINGEMENT 5. BREACH OF CONTRACT 22 COLUMBIA RECORDS a business 23 entity ofform unknown; SONY MUSIC JURY TRIAL DEMAND ENTERTAINMENT a Delaware 24 corporation; SONY CORPORATION OF AMERICA, INC. a New York 25 corporation; 26 Defendant. 27 28 COMPLAINT theJasmineBRAND.com Case 2:14-cv-07714-SS Document 1 Filed 10/03/14 Page 2 of 15 Page ID #:2 1 Mahad Dar and Creative Dream Production, for their Complaint against 2 COLUMBIA RECORDS; SONY MUSIC ENTERTAINMENT; and JUICY J 3 (collectively "Defendants"), allege as follows: 4 NATURE OF THE ACTION 5 1. This lawsuit concerns the unlawful misappropriation ofthe creative 6 work ofCreative Dream Production and his ChiefExecutive and ChiefCreative 7 Officer, Mahad Dar (collectively, "CDP" or "Plaintiffs"). 8 2. Following the old adage that "no good deed goes unpunished," CDP 9 performed abovetheJasmineBRAND.comand beyond the call ofduty to create, produce, edit, and deliver a 10 music video for Juicy J on a moment's notice. 11 3. The video was an instant success and garnered millions ofview on 12 various websites, generated significant revenue, and received critical acclaim. Yet, 13 neither Juicy J nor his representation ever negotiated, paid for, nor obtained, the 14 rights in the video. 15 4. Adding insult to injury, Juicy J and his representation have engaged in 16 a campaign to strip CDP ofits rightful ownership ofthe video by threatening legal 17 action for CDP's lawful use ofits own work. This is irony at its best. Neither Juicy 18 J, Columbia, Sony Music, nor Sony Corporation own any rights in the music video 19 Bandz A Make Her Dance and their use and widespread dissemination ofthe Video theJasmineBRAND.com20 is a flagrant violation ofPlaintiffs' rights. 21 JURISDICTION AND VENUE 22 5. This is a copyright case and thus this Court has subject matter 23 jurisdictionpursuant to 17 U.S.C. § 501, et seq. (copyright infringement) and 28 24 U.S.C. §§1331 (federal question jurisdiction), 1338(a) and 1338(b). 25 6. The Defendants are subject to personal jurisdiction in this Court based 26 on continuous and systematic contacts within this judicial district. All the 27 defendants have significant contact with the state ofCalifornia in general, and the 28 city ofLos Angeles in particular. COMPLAINT theJasmineBRAND.com Case 2:14-cv-07714-SS Document 1 Filed 10/03/14 Page 3 of 15 Page ID #:3 1 7. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b), (c) 2 because a substantial amount of the events and injury occurred in this judicial 3 district. 4 PARTIES 5 8. Plaintiff Mahad Dar as an individual, and as the creative force behind 6 Creative Dream Production LLC ( collectively "CDP"), produces, shoots, and edits 7 music Videos (among other things) for recording artists and other celebrities. 8 CDP's Chief Executive Officer is Mr. Mahad Dar, who is responsible for all 9 creative and businesstheJasmineBRAND.comdecisions ofthe company. 10 9. Defendant Jordan Houston is a recording artist professionally known as 11 "Juicy J" and will be referred herein as "Juicy J" or collectively with the other 12 defendants as "Defendants." Juicy J achieved commercial success as a performing 13 member ofthe Three 6 Mafia group and has since focused on his solo career. 14 10. Defendant Columbia Records (Columbia) is a recording label, under 15 the ownership ofSony Music Entertainment. Columbia has signed Juicy J to a 16 recording contract on or about August 2012 and has represented Juicy J as a 17 recording artist since that time. 18 11. Defendant Sony Music ("Sony Music") Entertainment is a music 19 corporation owned and operated by Sony Corporation ofAmerica. theJasmineBRAND.com20 12. Sony Corporation ofAmerica ("Sony Corporation") is the United 21 States subsidiary ofJapan's Sony Corporation, headquartered in Tokyo. It is the 22 umbrella company under which all Sony companies operate in the United States. 23 GENERAL ALLEGATIONS 24 13. CDP is a world-wide cutting-edge production company that works 25 closely with the entertainment professionals to creatively produce some ofthe best 26 content for use with music videos, television shows, movies, commercials, 27 documentaries, interviews and event coverage. 28 COMPLAINT theJasmineBRAND.com Case 2:14-cv-07714-SS Document 1 Filed 10/03/14 Page 4 of 15 Page ID #:4 1 14. CDP prides itselfon delivering to recording artists from all genres the 2 latest technology in Videos, working with a range of budgets and creating the hottest 3 concepts the seen to date. CDP has earned a solid reputation workingwith several 4 major label recording artists and celebrities, all ofwhom have become CDP's 5 satisfied clients over the years. 6 15. CDP also works closely with clients in capturing raw and behind-the- 7 scenes footage for any event that capture the Zeitgeist so desperately sought afterby 8 all recordingartists. CDP's work is all inclusive, providing all clients top to bottom 9 service for alltheJasmineBRAND.com projects, ensuring a complete product in the end with the highest 10 production quality possible. CDP also puts together creative treatments for all 11 projects to guarantee that they are tailored to suit each individual client. Finally, 12 CDP provides services in post-production work, making sure that the final product 13 is as near perfection as possible. 14 EVENTS LEADING UP TO THIS LAWSUIT 15 16. CDP's reputation and its ability to get the job done is the reason that, 16 on or about August 4,2012, Juicy J called upon CDP to shoot his then new video for 17 the lead single title on his third solo album, "Bandz A Make Her Dance" ("the 18 Video"). Juicy J insisted that CDP produce the Video "within two days." The Video 19 was to feature Juicy J, Lil Wayne, and 2 Chainz—which added significantly to the theJasmineBRAND.com20 difficulties in logistics. 21 17. The next day, on or about August 5, 2012, CDP created a full original 22 treatment for the Video and the entire production crew immediately flew from Los 23 Angeles to Miami for preparations. Phase 1 would be shot there to capture the 24 footage ofLil' Wayne (who owns a residence in Miami) while phase 2 would be 25 shot in Atlanta to capture the footage of2 Chainz (who owns a residence in the 26 Atlanta area). 27 18. Once in Miami, on or about August 6, 2012, CDP undertook the entire 28 pre-production process, including location scouting, casting, hiring other off-camera 4 COMPLAINT theJasmineBRAND.com Case 2:14-cv-07714-SS Document 1 Filed 10/03/14 Page 5 of 15 Page ID #:5 1 personnel, obtaining lighting for the shoot, secure the trailers for the shoot, obtain 2 props, recruit school band, organize food and craft services, obtain insurance and 3 provide all other needed functions to produce Phase 1 ofthe Video. 4 19. On or about August 7,2012, all aspects ofthe production had been 5 organized and ready to move forward. Unfortunately, Lil Wayne informed CDP 6 that he would not appear for the shoot and thus everyone believed that the 7 production had been terminated indefinitely. 8 20. However, about an hour later, Lil Wayne's representatives reached out 9 to CDP and informedtheJasmineBRAND.com them that Lil Wayne would participate in the Video and that 10 arrangements needed to be made immediately. 11 21. As a result ofthe cancellation, CDP lost the venue that had been 12 secured and CDP had now less than an hour to find an alternate location. CDP also 13 had to secure a trailer that could accommodate Lil Wayne's request that a television 14 set be on location so that he could watch the Olympics. 15 22. Over the next fifteen hours, CDP produced and shot Phase 1 ofthe 16 Video that they had conceived. 17 23. On or about August 9,2012, Mr. Dar returned to Los Angeles and 18 began to organize Phase 2 ofthe Video, which was to take place in Atlanta and 19 feature 2 Chainz. theJasmineBRAND.com20 24. On or about August 24,2012, Mr. Dar and a crew from CDP flew to 21 Atlanta. 22 25. On or about August 25,2012, CDP undertook the entire pre-production 23 process, including location scouting; casting; hiring other off-camera personnel; 24 obtaining lighting for the shoot; secure trailers for the shoot; obtain props; recruit 25 school band; organize food and craft services; obtain insurance and provide all other 26 needed functions to produce Phase 2 ofthe Video. 27 26. On or about August 26,2012, CDP began principal photography, 28 which lasted through August 27.