Case 2:17-cv-06882-MWF-AS Document 1 Filed 09/18/17 Page 1 of 12 Page ID #:1
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`GERARD FOX LAW P.C.
`Gerard P. Fox (SBN 151649)
`gfox@gerardfoxlaw.com
`Lauren M. Greene (SBN 271397)
`lgreene@gerardfoxlaw.com
`Banu S. Naraghi (SBN 312754)
`bnaraghi@gerardfoxlaw.com
`1880 Century Park East, Suite 1410
`Los Angeles, CA 90067
`Telephone: (310) 441-0500
`Facsimile: (310) 441-4447
`
`Attorneys for Plaintiffs
`SEAN HALL D.B.A. GIMME SOME HOT
`SAUCE MUSIC AND NATHAN BUTLER
`D.B.A. FAITH FORCE MUSIC
`
`
`SEAN HALL d.b.a. GIMME SOME
`HOT SAUCE MUSIC, an individual,
`and NATHAN BUTLER d.b.a. FAITH
`FORCE MUSIC, an individual,
`
`
`Plaintiffs,
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
` Case No.
`
`
`
`COMPLAINT FOR COPYRIGHT
`INFRINGEMENT
`
`
`DEMAND FOR JURY TRIAL
`
`
`
`
`
`
`
`v.
`
`TAYLOR SWIFT, an individual, KARL
`MARTIN SANDBERG, an individual,
`KARL JOHAN SCHUSTER, an
`individual, SONY/ATV MUSIC
`PUBLISHING, LLC a limited liability
`company, KOBALT MUSIC
`PUBLISHING AMERICA INC. a
`Delaware Corporation, BIG MACHINE
`LABEL GROUP, LLC, a limited
`liability company, UNIVERSAL
`MUSIC GROUP, INC., a California
`Corporation, and DOES 1-5,
`
`
`Defendants.
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`-1-
`COMPLAINT
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`Case 2:17-cv-06882-MWF-AS Document 1 Filed 09/18/17 Page 2 of 12 Page ID #:2
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`Plaintiffs, SEAN HALL D.B.A. GIMME SOME HOT SAUCE MUSIC and
`NATHAN BUTLER D.B.A. FAITH FORCE MUSIC hereby allege as follows:
`PARTIES
`Plaintiff SEAN HALL D.B.A. GIMME SOME HOT SAUCE MUSIC
`1.
`(“Hall”) is a songwriter and a resident of the State of California. Hall is a co-author
`of the musical composition entitled “Playas Gon’ Play” and a legal and/or beneficial
`owner of a copyright interest in and to that musical composition.
`Plaintiff NATHAN BUTLER D.B.A. FAITH FORCE MUSIC
`2.
`(“Butler”) is a songwriter and a resident of the State of Georgia. Butler is a co-author
`of the musical composition entitled “Playas Gon’ Play” and a legal and/or beneficial
`owner of a copyright interest in and to that musical composition.
`On information and belief, Defendant, TAYLOR SWIFT (“Swift”), is a
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`songwriter and a resident of the State of California and, at all material times, is and
`was doing business in the State of California and within this judicial district.
`On information and belief, Defendant KARL MARTIN SANDBERG
`4.
`aka Max Martin (“Sandberg”), is a songwriter and a resident of the State of
`California and, at all material times, is and was doing business in the State of
`California and within this judicial district.
`On information and belief, Defendant KARL JOHAN SCHUSTER aka
`5.
`Shellback (“Schuster”), is a songwriter and a resident of the State of California and,
`at all material times, is and was doing business in the State of California and within
`this judicial district.
`Defendant SONY/ATV MUSIC PUBLISHING, LLC (“Sony”) is a
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`limited liability company existing under the law of the State of Delaware, admitted
`and authorized to conduct business in the State of California, and with offices in the
`County of Los Angeles, State of California. On information and belief, Plaintiffs
`allege that Sony owns or co-owns the publishing rights in and to the infringing
`musical composition “Shake it Off”.
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`-2-
`COMPLAINT
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`Case 2:17-cv-06882-MWF-AS Document 1 Filed 09/18/17 Page 3 of 12 Page ID #:3
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`Defendant KOBALT MUSIC PUBLISHING AMERICA INC.
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`(“Kobalt”) is a Delaware corporation formed with its principal place of business in
`New York and doing business throughout the State of California including Los
`Angeles County. On information and belief, Plaintiffs allege that Kobalt owns or
`co-owns the publishing rights in and to the infringing musical composition “Shake
`it Off”.
`Defendant BIG MACHINE LABEL GROUP, LLC (“Big Machine”) is
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`a limited liability company existing under the law of the State of Delaware with its
`principal place of business in the State of Tennessee and doing business throughout
`the State of California including Los Angeles County. On information and belief,
`Plaintiffs allege that Big Machine is the label of record for Defendant Swift and
`released the infringing musical composition “Shake it Off”.
`Defendant UNIVERSAL MUSIC GROUP, INC. (“Universal”) is a
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`California corporation formed with its principal place of business in Los Angeles
`County. On information and belief, Plaintiffs allege that Universal distributes the
`infringing musical composition “Shake it Off”.
`10. The true names and capacities, whether individual, corporate, or
`otherwise, of Defendants sued as Does 1 through 5 are unknown to Plaintiffs, who,
`therefore, sue them by such fictitious names. At such time as their true names and
`capacities have been ascertained, Plaintiffs will seek leave of the Court to amend
`this Complaint accordingly. On information and belief, Plaintiffs allege that each of
`Does 1 through 5 are liable to Plaintiffs in connection with one or more claims sued
`upon here and are responsible in some manner for the wrongful acts and conduct
`alleged here.
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`JURISDICTION
`11. This court has subject matter jurisdiction, pursuant to 28 U.S.C.
`§1388(a) because of this court’s exclusive jurisdiction over copyright cases.
`12. Venue is proper pursuant to 28 U.S.C. § 1400(a) because the
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`-3-
`COMPLAINT
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`Defendants reside or may be found within this district and personal jurisdiction may
`be properly obtained over the Defendants.
`GENERAL ALLEGATIONS
`Plaintiffs And 3LW’s “Playas Gon’ Play”
`13. Plaintiff Hall is a songwriter and music producer. Since roughly 1993,
`Hall has written and produced hundreds of songs for various artists such as Justin
`Bieber, Color Me Badd, Xscape, 98º, Lionel Richie, Pink!, and Maroon 5.
`14. Plaintiff Butler is a songwriter, music producer, vocal producer, and
`recording artist. He has worked with multi-platinum artists such as Luther
`Vandross, Victoria Beckham aka Posh Spice, Backstreet Boys, Christina
`Milian, Stacie Orrico, JoJo, Aaron Carter, and several others. To date, Butler has
`accounted for over 45 million records sold worldwide.
`In 2001, Plaintiffs Hall and Butler co-authored the song entitled
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`“Playas Gon’ Play”. “Playas Gon’ Play” was recorded by the girl group 3LW and
`released to the public in May 2001.
`16. After its release, “Playas Gon’ Play” became a hit. “Playas Gon’ Play”
`stayed on Billboard’s Hot 100 chart for weeks peaking at No. 81. “Playas Gon’
`Play” also reached No. 56 on Billboard’s Hot R&B/Hip-Hop Songs chart and No. 17
`on Billboard’s Rhythmic chart.
`“Playas Gon’ Play” helped springboard the career of 3LW – one of the
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`top girl groups of their era. The song “Playas Gon’ Play” served as the second single
`on 3LW’s self-titled debut album 3LW. That album reached No. 29 on the Billboard
`200 album chart, No. 19 on the Billboard Top R&B/Hip-Hop chart, and was
`certified platinum by the RIAA with over 1,000,000 units sold.
`In addition, on March 7, 2001 “Playas Gon’ Play” debuted at #7 on
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`TRL, MTV’s video countdown show which played the ten most requested music
`videos of the day. In the early 2000s, inclusion on the TRL top ten countdown was
`the benchmark for a top 40 song’s popularity.
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`-4-
`COMPLAINT
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`In addition, 3LW performed “Playas Gon’ Play” several times national
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`television including on Regis & Kelly, MTV, and Fox Family.
`“Playas Gon’ Play” includes the lyrical phrase “Playas, they gonna
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`play / And haters, they gonna hate.” The combination of playas/players playing
`along with hatas/haters1 hating may seem like common parlance today2, however, in
`2001 it was completely original and unique. Indeed, the combination had not been
`used in popular culture prior to Plaintiffs’ original use.
`21. While previous artists had used terms such as “playa hater(s)” or “playa
`hater(s) hate…” those do not make Plaintiffs’ phrase any less original. The term
`“playa hater(s)” was often used as a noun to describe a type of person. As commonly
`used “playa hater(s)” described just one person, a person who hates playas.
`22. Similarly, the term “playa haters hate” or simply “haters hate” was
`often used to describe a certain thing that the playa hater or the hater actually held
`with discontent. When used in this way the term described one person, either a playa
`hater or a hater, who often engaged in hating.
`23. Through Plaintiffs’ own originality they created the original and unique
`lyrical phrase “Playas, they gonna play / And haters, they gonna hate” which is
`featured prominently in the chorus of Plaintiffs’ work. A version of this phrase “The
`playas gon’ play / Them haters gonna hate” appears in the introduction of the song.
`As created by Plaintiffs, the lyrical phrase describes two separate people – one playa
`who engages in playing and one hater who engages in hating.
`24. That Plaintiffs originated the linguistic combination of playas/players
`playing along with hatas/haters hating was recently espoused by the United States
`District Court for the Central District of Los Angeles in the case Jessie Braham v.
`Sony/ATV Music Publishing, et. al., United States District Court for the Central
`
`
`1 The terms’ spellings “playa”/”player” and “hater”/”hata” have been used interchangeably in
`popular and hip hop culture.
`2 In large part due to the success of the infringing song “Shake it Off”.
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`COMPLAINT
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`District of Los Angeles Case No. 2:15-cv-8422 MWF(GJSx). In its Memorandum
`Supporting Recommendation of Denial of Application to Proceed In Forma Pauperis
`the Court sets forth the history of the combination and noted that Plaintiffs’ work
`was the first use in public. Braham v. Sony/ATV Music Publ’g, No.
`215CV8422MWFGJSX, 2015 WL 7074571, at *4 (C.D. Cal. Nov. 10, 2015).
`25. The next line of “Playas Gon’ Play” furthers the linguistic sequence
`with the lyrical phrases “Ballers, they gonna ball” and “Shot callers, they gonna
`call.” In all, “Playas Gon’ Play” prominently features a sequence of four peoples
`(playas, haters, callers, and ballers) who engage in four activities (playing, hating,
`calling, and balling). Plaintiffs were the first to put such a sequence together using
`the terms playas and haters, and prior to Defendants’ use at issue herein, the
`combination had not since been used in popular music. Thus, this sequence created
`by Plaintiffs is unique and copyrightable.
`Defendants’ Infringement
`In 2014, Defendants Swift, Sandberg, and Schuster co-authored the
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`musical composition entitled “Shake it Off”. The composition was recorded and
`performed by Defendant Swift and was released to the general public in August
`2014.
`“Shake it Off” copies and includes Plaintiffs’ lyrical phrase “Playas,
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`they gonna play / And haters, they gonna hate” by featuring the lyrical phrase
`“Cause the players gonna play, play, play, play, play and the haters gonna hate, hate,
`hate, hate, hate” prominently throughout the chorus of “Shake it Off”. In all, the
`infringed copyrighted material accounts for roughly 20% of “Shake if Off”.
`Just like “Playas Gon’ Play”, “Shake it Off” continues into a four part
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`lyrical sequence with actors engaging in a type of activity. In Defendants’ version,
`the players and haters are followed by “Heartbreakers gonna break, break, break,
`break, break/And the fakers gonna fake, fake, fake, fake, fake.” The sequence is
`substantially similar to the sequence in “Playas Gon’ Play” created by Plaintiffs.
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`COMPLAINT
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`29. Defendants undoubtedly had access to “Playas Gon’ Play” prior to
`writing and releasing “Shake it Off” given its wide commercial success. Defendant
`Swift has admitted that she watched MTV’s TRL which promoted “Playas Gon’
`Play”. Defendants Sandberg and Schuster are music industry songwriters who
`specialize in popular music and who have had songs which were also featured on
`MTV’s TRL.
`30. Additionally, had Defendants searched Google for the intended lyrics of
`“Shake it Off” in 2014, “Playas Gon’ Play” would have appeared further informing
`Defendants of Plaintiffs’ copyrighted work.
`31. Defendants knew or should have known that “Playas Gon’ Play” could
`not be used in a musical work by Defendants without a license and/or songwriting
`credit, as is customary standard practice in the music industry. For example,
`Beyoncé’s song “Hold Up” features lyrics from two previous copyrighted works –
`the Yeah Yeah Yeahs’ “Maps” and Soulja Boy’s “Turn My Swag On”. The chorus in
`“Maps” includes the lyrics “Wait, they don’t love you like a love you.” “Hold Up”
`riffs off of these lyrics with the chorus “Hold up, they don’t love you like I love you
`/ Slow down, they don’t love you like I love you / Back up, they don’t love you like
`I love you / Step down, they don’t love you like I love you.”
`32. Similarly, “Turn My Swag On” includes the lyrics “Hopped up out the
`bed turn my swag on / Took a look in the mirror said what’s up” while “Hold Up”
`interpolates this lyric with “I hop up out the bed and get my swag on / I look in the
`mirror, say, ‘What’s up?’” Similar to how “Shake if Off” repeats the words “play,”
`“hate,” “break,” and “fake” at the end of the phrase, the lyrics in “Hold Up” repeat
`the phrase “What’s Up” three times at the end of the phrase.
`33. Even though “Hold Up” did not use the lyrics from “Turn My Swag
`On” or “Maps” verbatim, the use of the lyrics from both of these songs was still
`cleared in advance with the copyright owners. This demonstrates the industry
`standard practice to clear such lyrical similarities.
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`COMPLAINT
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`Case 2:17-cv-06882-MWF-AS Document 1 Filed 09/18/17 Page 8 of 12 Page ID #:8
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`34. Despite this industry standard practice, Defendants never sought a
`license or other permission from Plaintiffs.
`35. Upon release “Shake it Off” debuted at No. 1 on Billboard’s Hot 100
`chart. The song went on to become a massive worldwide hit for Swift. “Shake it Off”
`stayed on the Hot 100 for fifty weeks – 24 of them on the top 10. “Shake it Off” has
`been certified 9x Platinum by the RIAA with over 9,000,000 copies sold. The music
`video for “Shake it Off” featuring the song debuted on August 18, 2014 and has
`approximately 2,380,831,410 views on YouTube.3 Indeed, “Shake it Off” is the
`seventh most viewed video of all time on YouTube.4
`36. Swift’s album 1989, for which “Shake it Off” was the lead single, has
`been certified 6x Multi-Platinum by the RIAA with over 6,000,000 certified units
`sold in the United States. In addition, 1989 has sold over 10,000,000 units
`worldwide.
`37. Defendants’ infringing acts include, but are not limited to, unlawfully
`creating, recording, manufacturing, producing, selling, licensing marketing and/or
`distributing the musical composition and sound recording of “Shake it Off”.
`Defendants’ infringement amounts to the unlawful appropriation of Plaintiffs’
`copyrighted material including the lyrical phrase “Playas, they gonna play/And
`haters, they gonna hate.”
`38. “Shake it Off” has also been extensively licensed by Defendants to
`various third parties for commercial and advertising uses including film,
`advertisements, television, and video games.
`39. On information and belief, Defendants have exploited, and continue to
`exploit, “Shake it Off” in this District, the State of California, and throughout the
`United States and the World by reproducing, preparing derivative works,
`
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`3 See https://www.youtube.com/watch?v=nfWlot6h_JM (last accessed September 18, 2017).
`4 See https://www.youtube.com/playlist?list=PLirAqAtl_h2r5g8xGajEwdXd3x1sZh8hC (last
`accessed September 18, 2017).
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`-8-
`COMPLAINT
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`

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`Case 2:17-cv-06882-MWF-AS Document 1 Filed 09/18/17 Page 9 of 12 Page ID #:9
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`distributing, licensing, publically performing and otherwise exploiting “Shake it
`Off”.
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`40. Defendants’ infringement is continuing as “Shake it Off” continues to
`be sold and licensed by Defendants. Plaintiffs informed Defendants of the
`infringement, yet, nevertheless, Defendants have persisted in their infringement.
`FIRST CLAIM FOR RELIEF
`(For Copyright Infringement Against All Defendants)
`41. Plaintiffs restate and incorporate by reference paragraphs 1 through 40
`as if fully set forth herein.
`42. Plaintiffs’ composition “Playas Gon’ Play” contains copyrightable
`subject matter under the copyright laws of the United States. At all relevant times
`herein, Plaintiffs were the owners of the copyright to “Playas Gon’ Play” which is
`the subject of a valid Certificate of Copyright Registration issued by the Register of
`Copyrights.
`43. The lyrical phrase “Playas, they gonna play / And haters, they gonna
`hate” along with the four part sequence of actors engaging in a specific activity
`detailed above is unique and original, and as such, is properly the subject of
`copyright protection.
`44. Among the exclusive rights granted to each Plaintiff under the
`Copyright Act are the exclusive rights to reproduce and distribute the copyrighted
`materials to the public and prepare derivative works.
`45. Defendants have continued to copy and publicly perform Plaintiffs’
`copyrighted material and have authorized the making or distribution of phonorecords
`substantially utilizing Plaintiffs’ copyrighted material in and as part of “Shake it Off”
`throughout the world.
`46. Defendants’ exploitation of “Playas Gon’ Play” was made without
`Plaintiffs’ knowledge or consent constitutes a violation of Sections 106 and 501 of
`the Copyright Act, 17 U.S.C. §§ 106 and 501.
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`COMPLAINT
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`47. Plaintiffs are informed and believe, and based thereon allege, that the
`foregoing acts of infringement have been willful and intentional, in disregard for and
`indifference to Plaintiffs’ rights.
`48. Defendants have profited substantially from their infringing activities,
`have collected, and continue to collect, fees, and royalties from the sale of the
`infringing work or any derivatives thereof, and have retained a portion of those fees
`and royalties without submitting any amount to Plaintiffs. Defendants should be held
`jointly and severally liable for all profits derived as a result of their infringing
`activities, whether or not collected and retained by them, as practical partners.
`49. As a result of Defendants’ willful infringement of Plaintiffs’ copyrights
`and exclusive rights under copyright, Plaintiffs are entitled to maximum statutory
`damages pursuant to 17 U.S.C. § 504(c), or to recover their actual damages and
`profits attributable to the infringement pursuant to 17 U.S.C. § 504(b), at Plaintiffs’
`election, and such other relief as is provided by law. Plaintiffs are further entitled to
`their attorney’s fees and full costs pursuant to 17 U.S.C. § 505.
`50. The conduct of Defendants is causing and, unless enjoined and
`restrained by this Court, will continue to cause Plaintiffs great and irreparable injury
`that cannot fully be compensated or measured in money. Plaintiffs have no adequate
`remedy at law. Pursuant to 17 U.S.C. §§ 502 and 503, Plaintiffs are entitled to
`injunctive relief prohibiting Defendants from further infringing Plaintiffs’
`copyrights, and ordering Defendants to destroy all copies of the infringing work
`and/or other material made in violation of Plaintiffs’ exclusive rights.
`WHEREFORE, Plaintiffs SEAN HALL D.B.A. GIMME SOME HOT
`SAUCE MUSIC and NATHAN BUTLER D.B.A. FAITH FORCE MUSIC pray for
`relief as follows:
`For a judicial determination that Plaintiffs’ copyright has been infringed
`1.
`upon by Defendants.
`For damages in such amount as may be found, or as otherwise
`2.
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`-10-
`COMPLAINT
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`

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`Case 2:17-cv-06882-MWF-AS Document 1 Filed 09/18/17 Page 11 of 12 Page ID #:11
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`permitted by law.
`For attorney’s fees and costs pursuant to 17 U.S.C. §505.
`3.
`4.
`For any such other and further relief as the Court may deem just and
`proper.
`
`DATED: September 18, 2017
`
`
`
`
`
`
` BY: GERARD FOX LAW P.C.
`
`
`
`
`
`/s/ Gerard P. Fox
`Gerard P. Fox
`Lauren M. Greene
`Banu S. Naraghi
`Attorneys for Plaintiffs
`SEAN HALL D.B.A. GIMME SOME
`HOT SAUCE MUSIC and NATHAN
`BUTLER D.B.A. FAITH FORCE
`MUSIC
`
`-11-
`COMPLAINT
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`Case 2:17-cv-06882-MWF-AS Document 1 Filed 09/18/17 Page 12 of 12 Page ID #:12
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`DEMAND FOR JURY TRIAL
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`
`Plaintiffs respectfully demand a trial by jury in this action.
`
`
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`
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`DATED: September 18, 2017
`
`
` BY: GERARD FOX LAW P.C.
`
`
`
`/s/ Gerard P. Fox
`Gerard P. Fox
`Lauren M. Greene
`Banu S. Naraghi
`Attorneys for Plaintiffs
`SEAN HALL D.B.A. GIMME SOME
`HOT SAUCE MUSIC and NATHAN
`BUTLER D.B.A. FAITH FORCE
`MUSIC
`
`
`
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`-12-
`COMPLAINT
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