`
`
`
`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
`
`ROBIN WILLIAMS TRUST,
` Case Number: 22-cv-00815
`
`
`
`
`COMPLAINT FOR
`
`COPYRIGHT INFRINGEMENT
`
`
`vs.
`
`
`
`PANDORA MEDIA, LLC,
`
`a limited liability company
`DEMAND FOR JURY TRIAL
`
`
`
` Defendant.
`
`
`Plaintiff,
`
`
`
`Plaintiff ROBIN WILLIAMS TRUST, by and through its attorneys of record,
`
`alleges as follows:
`
`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. ROBIN WILLIAMS TRUST (hereinafter “Williams”) is
`a copyright owner of properly registered literary works (the “Works” or
`“Williams’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
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`actively reaches out to through, at a minimum, its website
`(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.
`5.
`Finally,
`the ROBIN WILLIAMS TRUST
`administered in Los Angeles, California.
`VENUE
`6.
`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
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`Pandora’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.
`
`PARTIES
`7.
`Plaintiff, ROBIN WILLIAMS TRUST, represents the intellectual
`property rights of the late Robin Williams, who was an actor and comedian and
`resided in California. The ROBIN WILLIAMS TRUST is in the care of Trustee,
`Arnold D. Kassoy, of Manatt, Phelps & Phillips, LLP, located in Los Angeles,
`California.
`8.
`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 like with music, there are two copyrights involved in the recorded
`performance of a literary copyrighted work: a copyright in the sound recording,
`and a separate copyright in the underlying spoken word composition (Williams’
`compositions, as noted, are referred to herein as “the Works” or “Williams’s
`Works”). 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 to royalties. The failure to do so constitutes
`copyright infringement. As discussed below, Pandora not only did not obtain any
`copyright in Williams’s Works but admitted that it did not do so in SEC filings,
`and admitted that it would very likely face copyright infringement liability as a
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`result. But Pandora did what most goliaths do: it decided 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.
`Throughout history, comedy and spoken word have been the bedrock
`of entertainment. From Shakespearian comedies to modern-day standup comedians,
`comedy has brought happiness to the faces of billions of people, and for nearly the
`last five decades, Robin Williams has been an integral part of that history.
`10. Spanning nearly forty years with unique insights expressed as an
`active comedian, philosopher, and entertainer in literally every format imaginable,
`the comedic works of Robin Williams have enriched global culture, our lives, the
`entertainment industry and provided insights into the absurdity, joy, pains, and
`irony of life. He pushed other comedians and entertainers to further hone their craft
`while continuing to trail blaze as a comedic talent until the end of his career.
`11. From his early beginnings at the Holy City Zoo in San Francisco and
`the Roxy in West Hollywood, California, to the television show Mork & Mindy
`and then through a plethora of movie acting roles, such as Genie in Disney’s
`Aladdin, and his iconic roles in Dead Poets Society and Good Will Hunting,
`Williams put his heart, soul and mind into every composition he wrote or role he
`played. His heart was never more evident and on display then when he spent years
`lending his comedic talent to the charitable organization Comic Relief USA, whose
`mission was to raise funds to those in need, particularly America’s homeless. He
`was joined on those Comic Relief USA television specials by Billy Crystal and
`Whoopi Goldberg among others. It is nowhere close to an exaggeration to say that
`Robin Williams was a national treasure.
`12. Williams’ on-stage presence and skill with comedic improvisation set
`the standard for the stand-up comedians. Not only was he skilled at communicating
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`through comedy, but he brought a personal honesty to his comedic routines,
`touching on subjects such as depression and addiction. In fact, Williams was so
`talented in free-form comedy that other comedians, who are now household names,
`impersonated him, which is the highest compliment a comedian can receive.
`13. Williams won six (6) Golden Globe Awards, including the Cecil B.
`DeMille Award, two (2) Primetime Emmy Awards, two (2) Screen Actors Guild
`Awards, an Academy Award, and most notably five (5) Grammy Awards for his
`comedy albums, including Best Comedy Album and Best Spoken Word Comedy
`Album.
`14. Yet, industry giants, such as the Defendant, took and exploited his
`works solely to make themselves money while knowing it had no license and had
`not paid, and would not be paying, royalties to Robin Williams and/or the
`beneficiaries of his Estate.
`15. 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.”
`16. One would think that entertainment giants like Pandora would honor
`the legacy of such an amazing talent, but instead it chose to illegally profit from
`the creative mind and literary/comedic works of Robin Williams.
`17.
`In fact, Defendant has made twenty-seven (27) of his works (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, “Reality … What
`a Concept”, and “A Night at the Met”. Plaintiff has duly complied with all required
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`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
`numbers) on or about January 25, 1980, and October 27, 1986 respectively.
`18. 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 sixteen (16) 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 Williams’s Works,
`gained listeners, subscribers and market share with full knowledge it did not have
`licenses and made no royalty payments for the Works, to increase its stock price
`helping them to reorganize the company with Sirius XM (although the two
`companies remain to this day completely separate corporations) for billions all
`while depriving the Robin Williams Estate and its beneficiaries from the legacy of
`Robin Williams.
`19. As of January 28, 2022, www.pandora.com advertised that Robin
`Williams had 223,000 monthly listeners. If each listener listened to only one (1)
`available work per month, that’s 2,676,000 broadcasts or/interactive streams per
`year at a minimum. Unfortunately, Williams has not received a fraction of a penny
`for any of these broadcasts or streams of the Works from Pandora.
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`20. 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
`license. This infringement continues on a daily basis as the Works are broadcast on
`Pandora radio and/or remain available for interactive streaming on Pandora
`Premium.
`21. 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 public performance licenses.
`22. Pandora only needed to contact one entity, Williams, to obtain the
`required licenses. Or Pandora could have chosen not to use Williams’s Works,
`particularly since it knew it did not have the required licenses. Instead, it chose to
`infringe.
`23. Williams, via his company Little Andrew Enterprises, Inc., (“LAE
`Inc.,”) entered into a recording agreement with Casablanca Record and Filmworks,
`Inc. (“Casablanca”), dated March 13, 1979 (the “Williams Casablanca
`Agreement”). Under the terms of the Williams Casablanca Agreement, Williams
`was obligated to provide his exclusive performance services to Casablanca, and
`Casablanca acquired exclusive ownership rights in the sound recordings of
`Williams’ comedic performances in perpetuity.
`24.
` Williams, however, retained all of his exclusive rights in the Works.
`25. Additionally, Robin Williams, via his company LAE, Inc., entered
`into a recording agreement with CBS Records, a division of CBS, Inc., (“CBS”),
`and dated August 5, 1979 (the Williams CBS Agreement”). Under the terms of the
`Williams CBS Agreement, Williams was obligated to provide his exclusive
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`comedic performance services to CBS, for a performance at the Metropolitan Opera
`House at Lincoln Centre in New York, and CBS acquired exclusive ownership
`rights in the sound recordings of Williams’ performances in perpetuity. Williams
`likewise retained all exclusive rights in these Works.
`26. Pandora’s failure to obtain the necessary licenses for the Works, or
`pay royalties, but to nonetheless infringe by exploiting 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 ever 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
`was only removed, not so coincidentally, after Pandora’s transaction with Sirius
`XM Radio.
`27. Pandora nonetheless did not even take the simplest of steps to ask
`Williams or his representatives for licenses 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 Williams beginning in April 2021, to engage Pandora in
`good faith negotiations, to no avail.
`28. While Pandora’s counsel wrote on September 14, 2021 to advise that
`counsel would respond with Pandora’s position about unlicensed spoken word
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`content appearing on Pandora’s platform, no substantive response from Pandora or
`its counsel has been sent or received.
`CAUSE OF ACTION
`(Copyright Infringement – 17 U.S.C. § 501)
`29. Plaintiff repeats and re-alleges the foregoing paragraphs as if fully set
`forth herein.
`30. 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.
`31. Defendant has directly, vicariously, and/or contributorily infringed
`and/or induced infringement of Plaintiff’s copyright in violation of 17 U.S.C. § 501.
`32. Defendant has publicly performed, broadcasted, and provided its
`listeners/users of the Works, as discussed hereinabove.
`33. 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.
`34. Defendant’s infringement has been and continues to be, willful,
`intentional, purposeful, and with complete disregard to Plaintiff’s rights.
`35. As a direct and proximate result of Defendant’s infringement, Plaintiff
`has been irreparably harmed.
`36. 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.
`37. Plaintiff has received no royalties or payments for the Works
`embodied in the sound recording of the underlying literary compositions.
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`38. Defendant has continued to market, exploit, reproduce, distribute, and
`publicly perform the Works through this day, which violates Plaintiff’s copyrights
`and are at issue in this lawsuit.
`39. 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.
`40. The infringement is continuing as the Works continue to be exploited,
`performed, broadcast, and streamed across Defendant’s applicable platforms,
`and/or their agents.
`41. 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.
`42.
`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 $4,050,000 ($150,000 times 27 registered Works).
`43. 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.
`44. 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.
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`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.
`
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`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff prays for judgment and relief, as follows:
`45. For Judgment in favor of Plaintiff and against Defendant.
`46. For a declaration and finding that Defendant has willfully infringed
`Plaintiff’s copyrighted work in violation of the Copyright Act;
`47. 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;
`48. 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);
`49. 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);
`50. For costs of suit herein, including an award of attorneys’ fees pursuant
`to 17 U.S.C. § 505;
`51. For pre-judgment and post-judgment interest;
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`52. 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;
`53. 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.
`
`
`PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 38(b), AND
`OTHERWISE, PLAINTIFF DEMANDS A JURY TRIAL ON ALL ISSUES
`RAISED IN THIS COMPLAINT.
`
`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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