Case 2:22-cv-00817-DSF-MAA 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
`
`BRAVE LION, INC.,
` Case Number: 22-cv-00817
`on behalf of Andrew Clay Silverstein,
`
`
`a/k/a Andrew Dice Clay
`COMPLAINT FOR COPYRIGHT
`
`INFRINGEMENT
`
`Plaintiff,
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`
`vs.
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`PANDORA MEDIA, LLC,
`DEMAND FOR JURY TRIAL
`
` Defendant.
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`Plaintiff BRAVE LION, INC., on behalf of Andrew Clay Silverstein a/k/a
`
`Andrew Dice Clay, 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. BRAVE LION, INC., on behalf of Andrew Clay
`Silverstein, is a copyright owner of properly registered literary works (the “Works”
`or “Clay’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.
`This court has general personal jurisdiction over Plaintiff because
`Plaintiff has its principal place of business 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.
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`PARTIES
`7.
`Plaintiff, BRAVE LION, INC., on behalf of Andrew Clay Silverstein
`a/k/a Andrew Dice Clay (hereinafter collectively “Clay” or “Andrew Dice Clay”),
`is a stand-up comedian, actor, musician and producer who resides in Los Angeles,
`California. BRAVE LION, INC., has its principal place of business at 11766
`Wilshire Blvd., Suite 500, Los Angeles, California 90025.
`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 (Clay’s
`compositions, as noted, are referred to herein as “the Works” or “Clay’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 Clay’s Works but admitted that it did not do so in Security and Exchange
`Commission (SEC) filings, and admitted that it would very likely face copyright
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`infringement liability as a 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.
`One of the greatest freedoms in the world is the ability to speak freely
`about any subject or topic. This is why comedians hold such a significant role in
`society. Many times comedian’s express feelings or frustrations that their audiences
`may want to express themselves but lack the nerve to voice them out loud. Instead,
`they immerse themselves in comedy routines which have been curated with great
`care and attention to detail to make their fans feel like their voice and opinions are
`being heard. In reality, most of us are just living vicariously through the comedians
`we have come to love and appreciate.
`10. Enter stage left: The Diceman, (a/k/a Andrew Dice Clay) one of
`America’s most controversial and outrageous comics. With forty-four (44) years as
`an active comedian, Mr. Clay’s comedic career can be described by the parental
`advisory on his certified gold debut album Dice, “Warning: This album is
`offensive.”
`11. Mr. Clay is a stand-up comedian, actor, musician, television and film
`producer. While some may consider his comedic routines offensive, his brash and
`blatantly honest persona on stage has won over the hearts of millions of loyal fans
`who appreciate his character, observational and improvisational comedy as well as
`his political satire.
`12. Mr. Clay has forever left his mark on the entertainment world, and
`especially in the world of comedy. Mr. Clay was the first comedian to sell out
`Madison Square Garden two nights in a row, as well as numerous sporting arenas
`across the country, and in true Diceman-fashion, is the only performer ever
`“Banned For Life from MTV.”
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`13. Mr. Clay’s brutally honest, unapologetic, and uncensored approach to
`comedy is truly what makes him unique and remarkable amongst other comedians.
`However, his versatility as an artist far exceeds the comedy stage. As an actor, Mr.
`Clay has been actively involved in Hollywood, appearing in feature-length films
`such as Wacko, Making the Grade, Pretty in Pink, Casual Sex?, and most recently
`A Star Is Born starring alongside Bradley Cooper, Lady Gaga, Dave Chappelle and
`Sam Elliot. If that wasn’t enough, Mr. Clay found his way to the small screen in
`television favorites such as M*A*S*H, Diff’rent Strokes, Crime Story, Entourage,
`numerous HBO comedy specials, and Saturday Night Live.
`14.
`In 1989, Mr. Clay was named Comedy Act of the Year by
`Performance magazine, and his popular comedy album, The Day the Laughter
`Died, peaked at No. 39 on the Billboard 200.
`15. No matter the venue or entertainment medium, The Diceman
`continues to captivate audiences with his superb ability to make people laugh about
`the realest and most uncomfortable topics, and that’s what makes Mr. Clay a
`comedic legend in his own right.
`16. 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.”
`17. One would think that entertainment giants like Pandora would honor
`the legacy of such an amazing talent, and instead it has chosen to illegally profit
`from the creative mind and literary/comedic works of Mr. Clay.
`18.
`In fact, Defendant has made fifty-seven (57) 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
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`Exhibit A). In addition to no license, it also made no royalty payments for the
`Works. The Works are contained on the albums, “Dice”, “Dice Rules”, “Politically
`Incorrect (Various Artists)”, and “The Day The Laughter Died”. 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 numbers) on or about August 18, 1990.
`19. 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 all fifty-seven (57)
`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 of the Works and
`no royalty payments for the reproduction of the Works. The end result is Pandora
`took Clay’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 it to reorganize the company with Sirius XM
`(although the two companies remain to this day completely separate corporations)
`for billions all while depriving Clay of his royalties and the benefits of his ongoing
`legacy.
`20. As of February 1, 2022, www.pandora.com advertised that Andrew
`Dice Clay had 8,200 monthly listeners. If each listener listened to only one (1)
`available work per month, that’s 98,400 broadcasts or/interactive streams per year
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`at a minimum. Unfortunately, Clay has not received a fraction of a penny for any
`of these broadcasts or streams of the Works from Pandora.
`21. 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.
`22. 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.
`23. Pandora only needed to contact one entity, Clay, to obtain the required
`licenses. Or Pandora could have chosen not to use Clay’s Works, particularly since
`it knew it did not have the required licenses. Instead, Pandora chose to infringe.
`24. Clay, through his company, Fleebin Dabble Productions, Inc., entered
`into a recording agreement with Def American Recordings, Inc., (“Def American”)
`on May 19, 1988 (the “Clay Def American Agreement”). Under the terms of the
`Clay Def American Agreement, Mr. Clay was obligated to provide his exclusive
`performance services to Def American, and Def American acquired exclusive
`ownership rights in the sound recordings of Mr. Clay’s comedic performances in
`perpetuity.
`25. Mr. Clay retained his exclusive rights in the Works.
`26. Pandora’s failure to obtain the necessary licenses for the Works, or
`pay any royalties for the Works, but to nonetheless infringe by exploiting the Works,
`has been willful. In Pandora’s own SEC 10K public filing with the SEC from 2011
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`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 Clay
`or his representatives for the any of the proper 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 Clay 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
`content appearing on Pandora’s platform, no substantive response from Pandora or
`its counsel has been sent or received.
`29. As the Diceman might say, Pandora and Dice went up the hill, but
`Pandora came down with all the money.
`CAUSE OF ACTION
`(Copyright Infringement – 17 U.S.C. § 501)
`30. Plaintiff repeats and re-alleges the foregoing paragraphs as if fully set
`forth herein.
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`31. 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.
`32. Defendant has directly, vicariously, and/or contributorily infringed
`and/or induced infringement of Plaintiff’s copyright in violation of 17 U.S.C. § 501.
`33. Defendant has publicly performed, broadcasted, and provided its
`listeners/users of the Works, as discussed hereinabove.
`34. 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.
`35. Defendant’s infringement has been and continues to be, willful,
`intentional, purposeful, and with complete disregard to Plaintiff’s rights.
`36. As a direct and proximate result of Defendant’s infringement, Plaintiff
`has been irreparably harmed.
`37. 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.
`38. Plaintiff has received no royalties or payments for the Works
`embodied in the sound recording of the underlying literary compositions.
`39. 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.
`40. 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.
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`41. The infringement is continuing as the Works continue to be exploited,
`performed, broadcast, and streamed across Defendant’s applicable platforms,
`and/or their agents.
`42. 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.
`43.
`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 $8,550,000 ($150,000 times 57 registered Works).
`44. 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.
`45. 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.
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`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff prays for judgment and relief, as follows:
`46. For Judgment in favor of Plaintiff and against Defendant.
`47. For a declaration and finding that Defendant has willfully infringed
`Plaintiff’s copyrighted work in violation of the Copyright Act;
`48. 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;
`49. 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);
`50. 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);
`51. For costs of suit herein, including an award of attorneys’ fees pursuant
`to 17 U.S.C. § 505;
`52. For pre-judgment and post-judgment interest;
`53. 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,
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`contributorily infringes, or vicariously infringes Plaintiff’s rights in the work
`protected by the Copyright Act;
`54. 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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`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`