Case 2:22-cv-00810-RGK-JEM Document 1 Filed 02/07/22 Page 1 of 13 Page ID #:1
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`
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`Richard S. Busch (SBN 319881)
`E-Mail: rbusch@kingballow.com
`KING & BALLOW
`1999 Avenue of the Stars, Suite 1100
`Los Angeles, CA 90067
`Telephone: (424) 253-1255
`Facsimile: (888) 688-0482
`Attorney for Plaintiff
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`MAIN SEQUENCE, LTD.,
` Case Number: 22-cv-00810
`
`a corporation
`
`
`COMPLAINT FOR
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`COPYRIGHT INFRINGEMENT
`
`
`vs.
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`
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`PANDORA MEDIA, LLC,
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`a limited liability company
`DEMAND FOR JURY TRIAL
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`
`
` Defendant.
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`Plaintiff,
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`
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`Plaintiff MAIN SEQUENCE, LTD., by and through its attorneys of record,
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`alleges as follows:
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`JURISDICTION
`1.
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §
`1331 as the action arises under the original and exclusive jurisdiction of the federal
`court and 28 U.S.C. § 1338(a) as the controversy arises under the Copyright Act of
`1976 (17 U.S.C. § 101 et seq.).
`2.
`This Court has personal jurisdiction over Defendant as discussed fully
`below.
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`3.
`This Court has general personal jurisdiction over Pandora Media, LLC
`(“Pandora”) because Pandora’s principal place of business is in Oakland, California,
`while also having a substantial office in Santa Monica, California, meaning that
`Pandora is at home in the State of California. Furthermore:
`a. Upon information and belief, through January 28, 2022, Pandora was
`qualified to do business in California and was registered as a foreign
`corporation with the California Secretary of State.
`b. Pandora is also registered as a foreign limited liability company with
`the California Secretary of State.
`c. Pandora’s designated DMCA Copyright Agent identified in its
`“Intellectual Property Policy” on its website is located in California at
`2100 Franklin Street, 7th Floor, Oakland, California 94612.
`d. Pandora has previously admitted in other federal court filings that
`California has jurisdiction over it. See, Wixen Music Publishing, Inc.
`v. Pandora Media, Inc., Case No. 2:19-cv-5278-SVW (C.D. Cal.), Dkt.
`15 (Pandora Media, Inc.’s Answer) at ¶¶ 16-17 (“Pandora admits that
`[it] has availed itself of California law . . . and venue is proper in the
`[Central District of California]”).
`4.
`This Court has specific personal jurisdiction over Pandora because its
`suit-related conduct creates a substantial connection with the State of California
`and this Judicial District. Carlin is a copyright owner of properly registered literary
`works (the “Works” or “Carlin’s Works”) (see Exhibit A). Upon information and
`belief, Pandora has generated substantial revenue from exploitation of the Works
`in California, as further discussed below:
`a. Pandora actively and purposely does business in California, as
`evidenced by its (i) subscribers and users in California, which Pandora
`actively reaches out to through, at a minimum, its website
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`(www.pandora.com) and mobile app; (ii) contracts and other
`transactions that it has entered into in California; (iii) revenue
`generated from California residents and businesses in connection with
`its service; and (iv) advertisements that target California residents.
`b. Pandora has purposefully availed itself of California law and could
`and did reasonably anticipate being brought into this Court because,
`among other reasons, Pandora (i) has been engaged and is engaged in
`infringing conduct within the State of California and this District,
`including by knowingly, intentionally, and repeatedly streaming
`sound recordings and the Works over the Internet to California
`residents via its services; (ii) knew or should have known that the harm
`caused by its repeated unlicensed public performance of the Works
`over the Internet was aimed at comedy writers and comedy publishers,
`including Plaintiff, who control the Works and are managed and
`administered in or near Los Angeles County, California, a global hub
`of the entertainment industry; and (iii) knew or should have known
`that Plaintiff, an industry leading comedian, actor and comedy writer
`for nearly 40 years, would suffer, and in fact did suffer, the brunt of
`the harm caused by Pandora’s unauthorized acts in California and
`around the world.
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`VENUE
`5.
`Venue in this judicial district is proper pursuant to 28 U.S.C. § 1391(b),
`and § 1400(a), as a substantial part of the events or omissions giving rise to the
`claim occurred in this district, including for example, by the maintenance of
`Pandora LLC’s corporate office in Santa Monica, California. Plaintiff has its
`principal place of business in this District and has been injured in this District as a
`result of Pandora’s infringing conduct.
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`PARTIES
`6.
`Plaintiff, MAIN SEQUENCE, LTD. (“Carlin”) owns and represents
`the intellectual property rights of the late George Carlin, who was an actor and
`comedian who resided in California. MAIN SEQUENCE, LTD. is a corporation
`with its principal place of business located at 11911 SAN VICENTE #348
`LOS ANGELES CA 90049, and is in the care of Jerold Hamza, who is also the
`executor of the Estate of George Carlin.
`7.
`Defendant, Pandora, is a Delaware limited liability company with a
`principal place of business at 2100 Franklin Street, Suite 700, Oakland, California
`94612. According to its website, Pandora maintains another corporate office in
`California, located at 3000 Ocean Park Boulevard, Suite 3050, Santa Monica,
`California 90405.
`
`PRELIMINARY STATEMENT
`8.
`Just as there is with music, there are two copyrights involved in the
`recorded performance of a copyrighted literary work: a copyright in the sound
`recording (17 U.S.C. §102(a)(7)) and a separate copyright in the underlying spoken
`word composition, or “literary work” (17 U.S.C. §102(a)(1)). Pursuant to 17 U.S.C.
`§§ 106 and 204 of the Copyright Act of 1976, copyright owners have the exclusive
`right to, among other things, reproduce, distribute, license, and publicly perform
`their works. Anyone wishing to obtain the right to do so, must get a license from
`the respective copyright owner in both of these copyrights, and pay agreed upon
`royalties. The failure to do so constitutes copyright infringement. As discussed
`below, Pandora not only did not obtain any copyright in Carlin’s Works, but
`admitted that it did not do so in its filings with the Securities and Exchange
`Commission (“SEC), and admitted that it would very likely face copyright
`infringement liability as a result. But Pandora did what most goliaths do: it decided
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`it would infringe now to ensure it had this very valuable intellectual property on its
`platform to remain competitive, and deal with the consequences later. Later is now.
`
`STATEMENT OF FACTS
`9.
`Dubbed the Dean of Counterculture Comedians, the late George
`Carlin was known for his politically charged and dark comedy, as well as taboo
`subjects. There really wasn’t a topic or area of culture that Mr. Carlin wasn’t willing
`to tackle.
`10. For fifty-two (52) years, George Carlin was an active and integral part
`of the entertainment world, and his works even graced the hallowed halls of the
`United States Supreme Court. Mr. Carlin’s ever famous “seven dirty words”
`comedy routine was at the center of the 1978 Supreme Court case F.C.C. v. Pacifica
`Foundation, which set a precedent concerning government power to censor
`indecent material on public airwaves. George Carlin was able to express unique
`meaningful insights, observations and ideas through spoken word comedy
`impacting culture, society and millions of fans around the globe.
`11.
`In many ways George Carlin was a trailblazer in the comedy industry,
`filming fourteen (14) stand-up comedy specials for HBO. Today these types of
`stand-up routines are common on streaming services like Netflix, but had it not
`been for Carlin, these types of comedy specials may never have been popular.
`12. After George Carlin’s death in 2008, he was posthumously awarded
`the Mark Twain Prize for American Humor in 2008 and ranked by Rolling Stone
`magazine as the second-best stand-up comedian of all time out of fifty (50)
`comedians, and he continues to remain a relevant figure in the entertainment
`industry and has helped chart the way for countless comedians after him.
`13. Since then, Main Sequence, Ltd., has been and continues to be the
`legal and beneficial owner of the exclusive rights to the literary works of George
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`Carlin, including the Works Pandora has exploited without a license. Subsequently,
`Main Sequence, Ltd., has the sole right to protect those copyrights and pursue any
`and all remedies.1
`14. According to www.pandora.com, Pandora is the largest digital
`broadcast and streaming music provider in the U.S. “providing a highly-
`personalized listening experience to approximately 70 million listeners and users
`each month” through “its mobile app, the web, and integrations with more than
`2,000 connected products.”
`15. One would think that entertainment giants like Pandora would honor
`the legacy of such an amazing talent, but instead it has chosen to illegally profit
`from the creative mind and literary/comedic works of George Carlin.
`16.
`In fact, Defendant has made fifty-six (56) of the Works available for
`dissemination to the public via their digital broadcast radio service knowing full
`well that it did not possess a valid license to publicly perform the Works. (see
`Exhibit A). In addition to no license, it also made no royalty payments for the
`Works. The Works are contained on the albums “An Evening with Wally Londo”,
`“Class Clown”, “Classic Gold”, “George Carlin on Comedy”, “On the Road”,
`“SOFA - Comedy Clips”, “The George Carlin Collection”, “Toledo Window Box”,
`and “You Are All Diseased”. Plaintiff has duly complied with all required
`provisions of the copyright laws of the United States applicable to the Works,
`including but not limited to, registering copyrights in and to said Works with the
`United States Copyright Office (see Exhibit A for applicable copyright registration
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` A non-exclusive license has been granted to Laugh.com, Inc. which
`digitally distributes sound recordings, embodying George Carlin’s literary works,
`on an exclusive basis, and which serves as an advisor and the collection agent for
`any revenues arising from that exploitation.
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`numbers) on or about October 4, 1972, January 8, 1973, September 19, 1974,
`September 11, 1975, and February 28, 1977, respectively.
`17. Further, it is required by law, and fully understood, that digital service
`providers, like Pandora, must also get a mechanical digital reproduction license
`from the owner of the underlying composition in order to make the underlying
`composition of a recording available for reproduction and distribution through
`interactive streaming. This is true even where the digital service provider has a
`license to interactively stream a sound recording. Pandora made eleven (11) of
`these Works available via its Pandora Premium interactive streaming service, also
`knowing full well that it did not possess a valid license to not only publicly perform
`his works but also no license to distribute and reproduce the Works. Pandora made
`no royalty payments for the public performance and no royalty payments for the
`reproduction of the Works. The end result is Pandora took Carlin’s Works, gained
`listeners, subscribers and market share with full knowledge it did not have licenses
`and making no royalty payments, to increase their stock price helping them to enter
`into a merger with Sirius XM (although the two companies remain to this day
`completely separate corporations) for billions all while depriving the George Carlin
`Estate and his child the legacy her father left her.
`18. As of January 28, 2022, www.pandora.com advertised that George
`Carlin had 81,000 monthly listeners. If each listener listened to only one (1)
`available work per month, that’s 972,000 broadcasts or/interactive streams per year
`at a minimum. Unfortunately, Carlin has not received a fraction of a penny for any
`of these broadcasts or streams of the Works from Pandora.
`19. For years therefore Pandora has illegally made reproductions and
`digital broadcasts on its servers and provided streaming access to its users without
`a proper public performance license and, when applicable, a reproduction right
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`license. This infringement is continuing as the Works all remain available for
`streaming on Pandora, and stream on a daily basis.
`20. While it is commonplace in the music industry for companies like
`Pandora to enter into public performance licensing agreements with performance
`rights organizations like BMI and ASCAP for musical compositions, these entities
`do not license literary works. Therefore, it was the responsibility of Pandora to seek
`out the copyright owners and obtain valid licenses.
`21. Pandora only needed to contact one entity, Carlin, to obtain the
`required licenses. Or Pandora could have chosen not to use Carlin’s Works,
`particularly since it knew it did not have a license. Instead, Pandora chose to
`infringe.
`22. Carlin, over the course of his career entered into numerous recording
`and record distribution contracts with Atlantic Recording Corporation (“Atlantic”),
`and its affiliates from August 21, 1981, to October 15, 2005. Carlin retained the
`rights to digitally distribute his sound recordings which it exploits on an exclusive
`basis through an alternative distribution channel.
`23. Carlin retained all of his exclusive rights in the Works.
`24. Pandora’s failure to obtain the necessary licenses for the Works, or
`pay any royalties for the Works, but nonetheless fully exploit the Works, has been
`willful. In Pandora’s own SEC 10K public filing with the Security and Exchange
`Commission from 2011 to 2017, three quarters of a decade, Pandora admitted in its
`Risk Factors every year that it performs spoken-word comedy content “absent a
`specific license from any [] performing rights organization” and it has never
`obtained a license for the underlying literary works for the sound recordings of
`spoken-word comedy content that it streams. Pandora further admitted that it
`“could be subject to significant liability for copyright infringement and may no
`longer be able to operate under [their] existing licensing regime.” This admission
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`was only removed, not so coincidentally, after Pandora’s transaction with Sirius
`XM Radio.
`25. Pandora nonetheless did not even take the simplest of steps to ask
`Carlin or his representatives for a license for the Works. To the contrary, beginning
`in or about August of 2020, Word Collections (“WC”), a Spoken Word/Literary
`Works Collection Agency contacted Pandora in an effort to negotiate a licensing
`agreement for various copyright owners. From that initial contact and on an
`ongoing basis over the course of the following year, WC made numerous efforts
`on behalf of WC’s other spoken word/literary works clients, including on behalf of
`Carlin beginning in April 2021, to engage Pandora in good faith negotiations, to no
`avail.
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`26. While Pandora’s counsel, on September 14, 2021, more than a year
`after Carlin’s representatives contacted them, wrote to advise that counsel would
`respond with Pandora’s position, no response from Pandora or its counsel has been
`sent or received.
`27. While Carlin would have been thrilled for his Works to live on through
`valid licenses and payments, he would have seven dirty words to say about
`Pandora’s actions and willful copyright infringement no doubt.
`CAUSE OF ACTION
`(Copyright Infringement – 17 U.S.C. § 501)
`28. Plaintiff repeats and re-alleges the foregoing paragraphs as if fully set
`forth herein.
`29. Plaintiff is the legal and beneficial owner of the United States
`copyrights in the Works, duly registered with the United States Copyright Office,
`(See Exhibit A), as discussed above.
`30. Defendant has directly, vicariously, and/or contributorily infringed
`and/or induced infringement of Plaintiff’s copyright in violation of 17 U.S.C. § 501.
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`31. Defendant has publicly performed, broadcasted, and provided its
`listeners/users of the Works, as discussed hereinabove.
`32. Defendant’s acts were performed without authorization, license, or
`consent. Defendant’s unauthorized and unlicensed reproduction, distribution,
`public performance and display of the Works infringes Plaintiff’s exclusive rights
`in violation of the Copyright Act, 17 U.S.C. § 106 et. seq.
`33. Defendant’s infringement has been and continues to be, willful,
`intentional, purposeful, and with complete disregard to Plaintiff’s rights.
`34. As a direct and proximate result of Defendant’s infringement, Plaintiff
`has been irreparably harmed.
`35. Defendant has infringed Plaintiff’s copyright interest in the Works by
`making reproductions and digital broadcasts on its servers and provided streaming
`access to its users without a proper public performance and, when applicable,
`reproduction rights license.
`36. Plaintiff has received no royalties or payments from Defendant or
`from any third party on Defendant’s behalf for Defendant’s unauthorized,
`unlicensed, and infringing use of the Works embodied in the sound recording of
`the underlying literary compositions.
`37. Defendant has continued to market, exploit, reproduce, distribute, and
`perform the Works which violates Plaintiff’s copyrights and are at issue in this
`lawsuit.
`38. Defendants had knowledge and have admitted that it did not and does
`not possess a valid public performance license for the Works at issue, and with that
`knowledge of infringement, continued to infringe upon Plaintiff’s copyrights.
`39. The infringement is continuing as the Works continue to be exploited,
`performed, broadcast, and streamed across Defendant’s applicable platforms,
`and/or their agents.
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`40. As a direct and proximate result of Defendant’s infringement,
`pursuant to 17 U.S.C. § 504(a)(1) and (b), Plaintiff is entitled to actual damages in
`addition to Defendant’s profits both domestically and relating to foreign sales of
`other exploitation of the Works that were distributed, performed, broadcast, or
`otherwise infringed domestically. Further, Plaintiff is entitled to a running royalty
`on all future exploitations of the Works following judgement in an amount to be
`determined.
`41.
`In the alternative to profits and actual damages, pursuant to 17 U.S.C.
`§ 504(c), Plaintiff is entitled to the maximum amount of statutory damages,
`$150,000 per copyrighted work for each act of copyright infringement, for a total
`of $8,400,000 ($150,000 times 56 registered Works).
`42. As a direct and proximate result of Defendant’s infringement, Plaintiff
`has incurred attorneys’ fees and costs which are recoverable pursuant to 17 U.S.C.
`§ 505.
`43. Defendant’s conduct has caused, is continuing to cause, and will
`further cause great damage to Plaintiff, which damages cannot be accurately
`measured in monetary terms, and therefore, unless enjoined by the Court, Plaintiff
`will suffer irreparable injury, for which Plaintiff is without adequate remedy at all.
`Accordingly, Plaintiff is entitled to a permanent injunction pursuant to 17 U.S.C. §
`502
`following
`judgment, prohibiting
`further
`infringement,
`reproduction,
`distribution, sale public performance, other use, or exploitation of Plaintiff’s
`copyright without a proper license.
`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff prays for judgment and relief, as follows:
`44. For Judgment in favor of Plaintiff and against Defendant.
`45. For a declaration and finding that Defendant has willfully infringed
`Plaintiff’s copyrighted work in violation of the Copyright Act;
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`46. For declaration and finding that Defendant is directly, vicariously,
`and/or contributorily liable for copyright infringement pursuant to 17 U.S.C. §
`504(a)(1) and (b), including a finding that Defendant is liable for actual damages,
`as well as for Defendant’s profits;
`47. For an accounting of all profits, income, receipts, or other benefits
`derived by Defendant from the production, copying, display, promotion,
`distribution, broadcast, public performance, or sale of products and services or
`other media, either now known or hereafter devised, that improperly or unlawfully
`infringe Plaintiff’s copyright pursuant to 17 U.S.C. § 504(a)(1) and (b);
`48. For statutory damages, upon election prior to final judgment in the
`alternative to actual damages and profits, for willful copyright infringement
`pursuant to 17 U.S.C. § 504(c);
`49. For costs of suit herein, including an award of attorneys’ fees pursuant
`to 17 U.S.C. § 505;
`50. For pre-judgment and post-judgment interest;
`51. For a running royalty and/or ownership share in the Infringing Work
`following judgment in an amount to be proven at trial, or in the alternative, for the
`entry of an injunction requiring Defendants, their officers, agents, servants,
`employees, representatives, successors, licensees, partners, attorneys, and assigns,
`and all persons acting in concert or participation with each or any one of them to
`be permanently enjoined from directly or indirectly infringing, reproducing,
`displaying, promoting, advertising, distributing, or selling any work that infringes,
`contributorily infringes, or vicariously infringes Plaintiff’s rights in the work
`protected by the Copyright Act;
`52.
` For such other and further relief as the Court may deem just and
`proper.
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`DEMAND FOR JURY TRIAL
`Pursuant to Federal Rule of Civil Procedure 38(b), and otherwise, Plaintiff
`respectfully demands a jury trial on all issues raised in this complaint.
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`PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 38(b), AND
`OTHERWISE, PLAINTIFF DEMANDS A JURY TRIAL ON ALL ISSUES
`RAISED IN THIS COMPLAINT.
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`Dated: February 7, 2022
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`Respectfully submitted,
`By: /s/ Richard S. Busch
`Richard S. Busch
`Attorney for Plaintiff
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