throbber
In the
`United States Court of Appeals
`For the Seventh Circuit
`
`
`No. 11-1708
`
`VINCENT PETERS,
`professionally known as VINCE P,
`
`KANYE WEST, et al.,
`
`Plaintiff-Appellant,
`
`v.
`
`Defendants-Appellees.
`
`
`
`
`
`Appeal from the United States District Court
`for the Northern District of Illinois, Eastern Division.
`No. 10 C 3951—Virginia M. Kendall, Judge.
`
`
`ARGUED MARCH 26, 2012—DECIDED AUGUST 20, 2012
`
`Before EASTERBROOK, Chief Judge, and BAUER and WOOD,
`Circuit Judges.
`WOOD, Circuit Judge. In 2006, Vincent Peters, whose
`stage name is Vince P, wrote, recorded, and distributed
`a song entitled Stronger. The song’s title comes from a
`key line in its “hook” (refrain or chorus). The line in turn
`draws from an aphorism coined by Friedrich Nietzsche:
`“what does not kill me, makes me stronger.”
`
`

`
`2
`
`No. 11-1708
`
`Vince P believes that he had an opportunity to “make
`it” in the hip-hop recording industry—he needed only to
`find an executive producer. His search led him to John
`Monopoly, a business manager and close friend of
`Kanye West, one of hip-hop’s superstars. Vince P sent
`Monopoly a disc containing a recording of Stronger, and
`even secured a meeting with Monopoly, during which
`Vince P played his recording of Stronger for Monopoly.
`Monopoly was apparently impressed and agreed to be
`Vince P’s producer, so long as Vince P was funded by a
`record label. That funding never materialized, unfortu-
`nately, and so the proposed collaboration foundered.
`Shortly thereafter, Kanye West released a song entitled
`Stronger. West’s song also features a hook that repeats
`the Nietzschean maxim. Worse, according to Vince P,
`West’s song contains several other suspicious similarities
`to his song. Vince P tried to contact West, but he was
`turned away by West’s representatives. In response,
`Vince P registered his copyright in his version of
`Stronger with the U.S. Copyright Office and filed suit
`against West. The district court dismissed the com-
`plaint for failure to state a claim upon which relief can
`be granted. We agree with the district court that the
`two songs are not similar enough
`to support a
`finding that copyright infringement has occurred, and
`we thus affirm.
`
`I
`Vince P describes himself in the complaint as an
`up-and-coming hip-hop artist and songwriter. In 2006,
`
`

`
`No. 11-1708
`
`3
`
`as he was beginning his career in music, he wrote and
`recorded a song entitled Stronger, which is about the
`competitive—indeed cutthroat—nature of the hip-hop
`and rap world. For clarity, we refer to this as Stronger
`(VP). Vince P’s music apparently captured the attention
`of someone at Interscope Records; that person told
`him that the company would devote “substantial re-
`sources” to producing Vince P’s inaugural album, but
`only if he could procure the services of a good executive
`producer.
`His search led him to John Monopoly, a well-known
`producer and—importantly for our purposes—a close
`friend and business manager to Kanye West. Vince P
`sent several of his songs to Monopoly, who liked what
`he heard enough to schedule a meeting. On November 12,
`2006, Vince P and Monopoly met at the latter’s home
`in Chicago, where Vince P played several of his re-
`cordings, including Stronger (VP). At the conclusion of
`their meeting, Vince P left a CD of some of his songs—
`including Stronger (VP)—with Monopoly. Eventually,
`Monopoly agreed to be Vince P’s executive producer,
`so long as Interscope Records was willing to fund the
`recording project. That funding, however, fell through,
`and so the project stalled.
`In July 2007, less than a year after the November 2006
`meeting between Vince P and Monopoly, West released
`his own single titled Stronger. (We call this Stronger (KW).)
`It was a huge hit. The song earned the #1 spot in
`several Billboard charts, the single sold over three
`million copies, and it eventually earned West a Grammy
`
`

`
`4
`
`No. 11-1708
`
`for Best Rap Solo Performance. Vince P, however, was
`not among its fans. He noticed what he thought were
`several infringing similarities between his 2006 song
`and West’s more recent release. Vince P also saw that
`Monopoly was listed as a manager on the notes to
`West’s album GRADUATION, on which Stronger (KW)
`appears. Vince P attempted to contact West, but he
`was
`rebuffed by West’s
`representatives, and so
`he
`turned
`to
`the
`federal courts. After
`formally
`registering his copyright in Stronger (VP) with the U.S.
`Copyright Office, see 17 U.S.C. § 411(a), Reed-Elsevier
`v. Muchnick, 130 S. Ct. 1237, 1241 (2010) (copyright reg-
`istration, while not jurisdictional, is a substantive re-
`quirement of infringement litigation), Vince P sued West
`in the U.S. District Court for the Northern District of
`Illinois. That court dismissed Vince P’s complaint under
`Federal Rule of Civil Procedure 12(b)(6), and he
`now appeals.
`
`II
`We review the district court’s order granting West’s
`motion to dismiss de novo. Justice v. Town of Cicero, 577
`F.3d 768, 771 (7th Cir. 2009). We “construe the complaint
`in the light most favorable to the plaintiff,” and we there-
`fore draw all plausible inferences in Vince P’s favor.
`Tamayo v. Blagojevich, 526 F.3d 1074, 1081 (7th Cir. 2008).
`As a practical matter for the present case, this means
`that we assume as true all of Vince P’s allegations re-
`garding Monopoly’s early access to Vince P’s song and
`his claims about the close relationship between Monopoly
`
`

`
`No. 11-1708
`
`5
`
`and Kanye West. We review de novo the district court’s
`determinations regarding the similarity between the
`two songs as well as its ultimate conclusion of nonin-
`fringement. Intervest Constr. Inc. v. Canterbury Estate
`Homes, Inc., 554 F.3d 914, 919-20 (11th Cir. 2008).
`Vince P’s complaint contains only one claim: his allega-
`tion that Stronger (KW) infringes his valid copyright in
`Stronger (VP). Proving
`infringement of a copyright
`owner’s exclusive right under 17 U.S.C. § 106(1) (the
`reproduction right) requires proof of “(1) ownership of a
`valid copyright, and (2) copying of constituent elements
`of the work that are original.” Feist Publ’ns, Inc. v. Rural
`Tel. Serv. Co., 499 U.S. 340, 361 (1991); JCW Invs., Inc. v.
`Novelty, Inc., 482 F.3d 910, 914 (7th Cir. 2007).
`
`A
`Copyright “registration made before or within five
`years after the first publication of the work shall con-
`stitute prima facie evidence of the validity of the copy-
`right.” 17 U.S.C. § 410(c). Vince P applied for copyright
`registration in Stronger (VP) on March 28, 2010, which
`is well within the statutory five-year window be-
`ginning in 2006. West appropriately does not challenge
`Vince P’s copyright registration, nor does he otherwise
`question the validity of Vince P’s copyright ownership
`in Stronger (VP). Vince P has thus made a prima facie
`showing of his ownership in the whole of the lyrics to
`his song.
`Nevertheless, whether the parts of that song that West
`allegedly copied are, on their own, entitled to copyright
`
`

`
`6
`
`No. 11-1708
`
`protection is a separate question. If the copied parts are
`not, on their own, protectable expression, then there can
`be no claim for infringement of the reproduction right.
`See Peter F. Gaito Architecture, LLC v. Simone Dev. Corp.,
`602 F.3d 57, 61 (2d Cir. 2010).
`
`B
`Satisfied that Vince P has shown valid copyright owner-
`ship, we turn our attention to the question of copying.
`The standard for copying is surprisingly muddled.
`Where direct evidence, such as an admission of copying,
`is not available (as is typically the case, see JCW, 482 F.3d
`at 915), a plaintiff may prove copying by showing that
`the defendant had the opportunity to copy the original
`(often called “access”) and that the two works are “sub-
`stantially similar,” thus permitting an inference that the
`defendant actually did copy the original. The various
`efforts to define these two key concepts, however, have
`unfortunately had the unintended effect of obscuring
`rather than clarifying the issues. This court has said
`that substantial similarity can be shown by evidence of
`“actual copying” and “improper appropriation.” Incredible
`Techs., Inc. v. Virtual Techs., Inc., 400 F.3d 1007, 1011
`(7th Cir. 2005). Thus, we permit copying to be proven by
`evidence of access, actual copying, and improper appro-
`priation. Vince P argues that we should adopt a hybrid
`of our own approach and the one that he argues prevails
`in the Second Circuit. That court, he contends, permits
`actual copying to be proven by “access” and “probative
`similarity” (which is distinct from substantial similarity).
`
`

`
`No. 11-1708
`
`7
`
`Appellant’s Br. at 26 (citing Laureyssens v. Idea Group, Inc.,
`964 F.2d 131, 140 (2d Cir. 1992)). Putting these tests to-
`gether, he seems to want us to require proof of access,
`improper appropriation, and actual copying by means
`of showing probative similarity and access (again).
`Other circuits have also had trouble expressing the
`test with any clarity. The First Circuit, for example,
`finds copying where the plaintiff has shown substantial
`similarity, access, and probative similarity. T-Peg, Inc. v.
`Vermont Timber Works, Inc., 459 F.3d 97, 111-12 (1st Cir.
`2006). The formulation found in the Second Circuit re-
`quires proof of improper appropriation and actual
`copying; the latter is shown by proving access and proba-
`tive similarity. Jorgensen v. Epic/Sony Records, 351 F.3d 46,
`51 (2d Cir. 2003); Laureyssens, 964 F.2d at 140. The
`Eleventh Circuit
`takes still a different approach,
`requiring either “striking similarity” or access and merely
`probative similarity. Peter Letterese & Assocs. v. World
`Institute of Scientology Enterprises, 533 F.3d 1287, 1300-01
`(11th Cir. 2008); see also La Resolana Architects, PA v.
`Reno, Inc., 555 F.3d 1171, 1178-79 (10th Cir. 2009) (applying
`same test). See also Universal Furniture Int’l, Inc. v.
`Collezione Europa USA, Inc., 618 F.3d 417, 435 (4th Cir. 2010)
`(access, intrinsic similarity, and extrinsic similarity); Frye
`v. YMCA Camp Kitaki, 617 F.3d 1005, 1008 (8th Cir. 2010)
`(same); Armour v. Knowles, 512 F.3d 147, 152 (5th Cir.
`2007) (factual copying and substantial similarity, where
`factual copying is shown either by striking similarity, or
`access and probative similarity); Bridgeport Music, Inc. v.
`UMG Recordings, Inc., 585 F.3d 267, 274 (6th Cir. 2009)
`(access and substantial similarity, or “a high degree of
`
`

`
`8
`
`No. 11-1708
`
`similarity”); Kay Berry, Inc. v. Taylor Gifts, Inc., 421 F.3d 199,
`207-08 (3d Cir. 2005) (access, copying, and improper
`appropriation).
`Despite all of this confusing nomenclature, this strikes
`us as a “pseudo-conflict”: despite the conflicting and
`confusing verbiage, the outcomes do not appear to
`differ. Jendusa-Nicolai v. Larsen, 677 F.3d 320, 322-23
`(7th Cir. 2012); see also Nightingale Home Healthcare, Inc. v.
`Anodyne Therapy, LLC, 626 F.3d 958, 960-62 (7th Cir. 2010)
`(describing a pseudo-conflict in trademark law). Funda-
`mentally, proving the basic tort of infringement simply
`requires the plaintiff to show that the defendant had an
`actual opportunity to copy the original (this is because
`independent creation is a defense to copyright infringe-
`ment), and that the two works share enough unique
`features to give rise to a breach of the duty not
`to copy another’s work. Our analysis will follow this
`structure.
`
`i
`We begin with the question of opportunity. We
`already know (for purposes of this Rule 12(b)(6) inquiry)
`that Monopoly had access to Vince P’s song and that
`Monopoly has a close relationship with West. These
`allegations are more
`than enough
`to support an
`inference that West had an opportunity to copy Stronger
`(VP). Not only did Monopoly actually hear Vince P’s
`song: he also twice received copies of it, once before
`their November 2006 meeting and again on a CD during
`that meeting. Furthermore, Monopoly is credited with
`
`

`
`No. 11-1708
`
`9
`
`acting as West’s manager on the GRADUATION album.
`This evidence of close collaboration between West and
`Monopoly suggests that Monopoly may have passed
`Vince P’s song on to West during the production of the
`album, and that West could have used that song in
`crafting his own hit single. Viewed together, these al-
`legations, taken as true, suggest that Monopoly and
`West had ample access to Stronger (VP), and that this
`access gave West an opportunity to copy the song.
`
`ii
`But even assuming that West had the opportunity to
`copy the lyrics to Stronger (VP), the question remains
`whether the complaint plausibly alleges that he actually
`did so. Before we can answer this question, we must
`confront the differences among the circuits about the
`relation between proof of access and evidence of similar-
`ity. Some circuits follow an “inverse ratio” rule, under
`which the strength of proof of similarity varies inversely
`with the proof of access (i.e., strong proof of access allows
`for only weak proof of similarity, and vice versa). Three
`Boys Music Corp. v. Bolton, 212 F.3d 477, 485 (9th Cir. 2000);
`see also Benay v. Warner Bros. Entm’t, Inc., 607 F.3d 620
`(9th Cir. 2010); Stromback v. New Line Cinema, 384 F.3d
`283, 293 (6th Cir. 2004); Amini Innovation Corp. v. Anthony
`California, Inc., 439 F.3d 1365, 1368-69 (Fed. Cir. 2006)
`(applying Ninth Circuit
`law). Other courts have
`rejected the inverse-ratio rule. After following that rule
`for several decades,
`the Second Circuit expressly
`rejected it in 1961, concluding that the rule “confuses
`
`

`
`10
`
`No. 11-1708
`
`more than it clarifies.” Arc Music Corp. v. Lee, 296 F.2d
`186 (2d Cir. 1961).
`This court’s rule has not been so explicit, although
`we have occasionally endorsed something that comes
`close to this inverse approach. In Selle v. Gibb, 741 F.2d
`896, 903 n.4 (7th Cir. 1984), we held that “degree of sim-
`ilarity required to establish an inference of access
`[should be] in an inverse ratio to the quantum of direct
`evidence adduced to establish access.” More recently, we
`noted that “similarity that is so close as to be highly
`unlikely to have been an accident of independent
`creation is evidence of access.” Ty, Inc. v. GMA Accessories,
`Inc., 132 F.3d 1167, 1170 (7th Cir. 1997) (emphasis in
`original); but see id. (noting that such similarity cannot
`be evidence of access when both are copies of something
`in the public domain). See also Alex Kozinski, How I
`Narrowly Escaped Insanity, 48 UCLA L. REV. 1293, 1302
`(2001) (describing personal experience of very close
`similarity between a popular movie and a novel he
`was writing, but then noting that the movie producers
`could not have seen his uncompleted manuscript). Thus,
`in both Selle and GMA Accessories, we noted that evidence
`that two works are very similar can suggest that the
`alleged infringer had access to the original.
`Notably, however, we have never endorsed the other
`side of the inverse relation: the idea that a “high degree
`of access” justifies a “lower standard of proof” for sim-
`ilarity. Three Boys Music, 212 F.3d at 485. As we ex-
`plained above, evidence of access is required because
`independent creation is a defense to copyright infringe-
`
`

`
`No. 11-1708
`
`11
`
`ment, and so a plaintiff must show that the defendant
`had an opportunity to copy her original work. This issue
`is independent of the question whether an alleged
`infringer breached his duty not to copy another’s work.
`See GMA Accessories, 132 F.3d at 1170. Once a plaintiff
`establishes that a defendant could have copied her
`work, she must separately prove—regardless of how
`the opportunity was—that
`good or restricted
`the
`allegedly infringing work is indeed a copy of her origi-
`nal. In this case, Vince P has adequately pleaded
`that West had an opportunity to copy his song, but that
`does not help him prove similarity. Vince P must show
`that West actually copied his song by pointing to sim-
`ilarities between the two works. We are not persuaded
`that the similarities alleged by Vince P rise to the level
`of copyright infringement.
`For the benefit of readers interested in coming to
`their own conclusions about these two songs, we have
`included the full lyrics to each one in the Appendix to
`this opinion. For present purposes, however, we give
`the two “hooks,” which provide the backdrop to the
`discussion that follows:
`
`Stronger (VP) [Hook]
`What don’t kill me make me stronger
`The more I blow up the more you wronger
`You copied my CD you can feel my hunger
`The wait is over couldn’t wait no longer
`
`

`
`12
`
`No. 11-1708
`
`Stronger (KW) [Hook]
`N-N-N-now th-th-that don’t kill me
`Can only make me stronger
`I need you to hurry up now
`Cause I can’t wait much longer
`I know I got to be right now
`Cause I can’t get much wronger
`Man I’ve been waitin’ all night now
`That’s how long I’ve been on ya.
`Three features in particular of Stronger (KW) form
`the basis of Vince P’s argument that West’s song
`infringes his. First, he notes that the hooks of both songs
`derive from the same common maxim and that they
`implement similar rhyme schemes (stronger, wronger,
`etc.). Second, he points to the songs’ shared title, which
`again derives from Nietzsche. Finally, he notes that both
`songs contain “incongruous” references to the British
`model Kate Moss, who is not usually featured in rap
`or hip-hop lyrics.
`Nietzsche’s phrase “what does not kill me, makes me
`stronger” comes from TWILIGHT OF THE IDOLS (1888).
`Although the fact that both songs quote from a 19th
`century German philosopher might, at first blush, seem
`to be an unusual coincidence, West correctly notes that
`the aphorism has been repeatedly invoked in song lyrics
`over the past century. Notably, an even more recent
`popular song—one that held the top spot
`in the
`Billboard Hot 100 chart at about the same time as oral
`argument in this case—also shares this key feature
`with both West’s and Vince P’s songs. See Gary Trust,
`
`

`
`No. 11-1708
`
`13
`
`Kelly Clarkson Returns to Hot 100 Peak, The Wanted Hit
`Top 10, BILLBOARD, available at http://www.billboard.com/
`#/news/kelly-clarkson-returns-to-hot-100-peak-the-10063
`16152.story (last visited July 13, 2012) (discussing Stronger
`(What Doesn’t Kill You), performed by Kelly Clarkson).
`The ubiquity of this common saying, together with its
`repeated use in other songs, suggests that West’s title
`and lyric do not infringe on Vince P’s song. Acuff-Rose
`Music, Inc. v. Jostens, Inc., 155 F.3d 140, 144 (2d Cir. 1998);
`Selle, 741 F.2d at 901.
`Next, Vince P claims that West’s song infringes on the
`rhyme pattern he uses in the hook. But this argument
`misapprehends the nature of Vince P’s rights. Copyright
`protects actual expression, not methods of expression. 17
`U.S.C. § 102(b); Baker v. Selden, 101 U.S. 99, 104 (1879). Just
`as a photographer cannot claim copyright in the use of
`a particular aperture and exposure setting on a given
`lens, no poet can claim copyright protection in the
`form of a sonnet or a limerick. Similarly, Vince P cannot
`claim copyright over a tercet. See Steele v. Turner Broad.
`Sys. Inc., 646 F. Supp. 2d 185, 192 (D. Mass. 2009) (“A
`common rhyme scheme or structure does not qualify as
`original expression protectable under federal copyright
`law.”). (We note for the sake of precision that, although
`Vince P seems to be claiming protection over a “triple
`rhyme,” a closer examination of his lyrics reveals that he
`actually uses a soft quadruple monorhyme (stronger,
`wronger, hunger, longer). West, by contrast, uses two soft
`four-line schemes (stronger and longer, and wronger and
`“on ya.”).) Nor are we persuaded that the particular
`rhymes of stronger, longer, and wronger qualify for
`
`

`
`14
`
`No. 11-1708
`
`copyright protection. See Prunte v. Universal Music Grp.,
`699 F. Supp. 2d. 15, 29 (D.D.C. 2010) (no protection for
`rhyming “-ill” sound).
`We turn then to the songs’ references to Kate Moss,
`a well-known supermodel. In Vince P’s song, the line is
`“Trying to get a model chick like Kate Moss”; in West’s
`it is “You could be my black Kate Moss tonight.” Vince P
`argues that his lyrical reference to Kate Moss “as a
`paragon of female beauty” is so unique as to “undermine[]
`the possibility of coincidental similarity.” We cannot go
`that far. In the first place, the lines are entirely different.
`In the second, analogizing to models as a shorthand
`for beauty is, for better or for worse, commonplace in
`our society. The particular selection of Kate Moss, who
`is very famous in her own right, adds little to the
`creative choice. And finally, the name alone cannot con-
`stitute protectable expression. Feist, 499 U.S. at 347;
`Schroeder v. William Morrow & Co., 566 F.2d 3, 5 (7th
`Cir. 1977).
`Even viewing all of these elements in combination, we
`conclude that Vince P has not plausibly alleged that
`Stronger (KW) infringes on Stronger (VP). Vince P’s theory
`is that the combination of the songs’ similar hooks, their
`shared title, and their references to Kate Moss would
`permit a finding of infringement. But, as we have dis-
`cussed, in the end we see only two songs that rhyme
`similar words, draw from a commonplace maxim, and
`analogize feminine beauty to a specific successful model.
`These songs are separated by much more than “small
`cosmetic differences,” JCW, 482 F.3d at 916; rather, they
`
`

`
`No. 11-1708
`
`15
`
`share only small cosmetic similarities. This means that
`Vince P’s claim for copyright infringement fails as
`a matter of law. The judgment of the district court
`is AFFIRMED.
`
`

`
`16
`
`No. 11-1708
`
`APPENDIX
`
`Stronger
`Vince P
`
`Chorus (2x)
`What don’t kill me make me stronger
`The more I blow up the more you wronger
`You copped my CD you can feel my hunger
`The wait is over couldn’t wait no longer
`
`Verse 1:
`I came from the bottom of the bottom
`To make it to the bottom
`Snuck in the back door now I got
`A&R’s back then should have signed
`Said I wasn’t gangsta said I couldn’t rhyme
`Vince P why don’t you stick to making beats
`You know what how bout I rap on my beats
`Make my own tracks stack my own stacks
`I’m hot you a loser and that’s a fact
`I’m bout to take you back when emcees was real
`Didn’t care where you from or if you had a deal
`Fist fights no guns no body packing steel
`Family reunions food on the grill
`This ain’t my barbeque but can I get a plate
`I’m still real hungry and I just ate
`This ain’t my barbeque but can I get a plate
`I’m still real hungry and I just ate
`
`

`
`No. 11-1708
`
`17
`
`Chorus (2x) [as before]
`
`Verse 2:
`I ain’t from Europe but I wear Lacoste
`And every day I hustle like Rick Ross
`Trying to get a model chick like Kate Moss
`Then trade her to another team like Randy Moss
`I’m the chosen one cause I got the force
`And I’m the unsigned hype but I’m not in the source
`All these dudes in Chicago tried to diss me
`Cause on the low they girls they kiss me
`And when I’m on the road you know they miss me
`Check out my MySpace check the Bentley
`I’m moving on up like George and Weezy
`And money on my mind like Little Weezy
`I’m the brand new kick pusher music distributor
`And make crazy rhymes like I’m related to Luda
`You can find me at the Croc Lounge
`Or at the Funky Buddha
`Catch a plane from O’Hare straight to Burmuda
`Check my lex diamonds call me Lex Luther
`Don’t like guns but my beats are ruggas
`Can’t you feel how these horns going right
` through you
`Can’t you feel how these horns going right
` through you
`I’m Vince P and I’m going to the top
`And I won’t stop till I get to the top
`
`

`
`18
`
`No. 11-1708
`
`You know my rhymes is hot and you know
` my beats is hot
`You know Vince P is going going to the top
`
`Chorus (2x) [as before]
`
`

`
`No. 11-1708
`
`19
`
`Stronger
`
`Kanye West
`
`Chorus:
`N-N-N-now th-th-that don’t kill me
`Can only make me stronger
`I need you to hurry up now
`Cause I can’t wait much longer
`I know I got to be right now
`Cause I can’t get much wronger
`Man, I’ve been waitin’ all night now
`That’s how long I’ve been on ya
`
`Verse 1:
`I need you right now
`I need you right now
`Let’s get lost tonight
`You could be my black Kate Moss tonight
`Play secretary I’m the boss tonight
`And you don’t give a f*** what they all say right?
`Awesome, the Christian in Christian Dior
`Damn they don’t make ‘em like this anymore
`I ask, cause I’m not sure
`Do anybody make real sh*t anymore?
`Bow in the presence of greatness
`Cause right now thou has forsaken us
`You should be honored by my lateness
`That I would even show up to this fake sh*t
`So go ahead go nuts go ape sh*t
`Especially in my Pastelle or my Bape sh*t
`
`

`
`20
`
`No. 11-1708
`
`Act like you can’t tell who make this
`New gospel homey take six, and take this, haters
`
`Chorus [as before]
`
`Verse 2:
`I need you right now
`I need you right now
`me likey
`I don’t know if you got a man or not,
`If you made plans or not
`If God put me in your plans or not
`I’m trippin’ this drink got me sayin’ a lot
`But I know that God put you in front of me
`So how the h*ll could you front on me
`There’s a thousand you’s there’s only one of me
`I’m trippin’, I’m caught up in the moment right?
`This is Louis Vuitton Don night
`So we gon’ do everything that Kan like
`Heard they’d do anything for a Klondike
`Well I’d do anything for a blonde d*ke
`And she’ll do anything for the limelight
`And we’ll do anything when the time’s right
`ugh, baby you’re makin’ it (harder, better,
` faster, stronger)
`
`Chorus [as before]
`
`Verse 3:
`I need you right now
`I need you right now
`
`

`
`No. 11-1708
`
`21
`
`You know how long I’ve been on ya?
`Since Prince was on Apollonia
`Since O.J. had Isotoners
`Don’t act like I never told ya (x6)
`Baby you’re making it (harder, better,
` faster, stronger)
`
`Chorus [as before]
`
`8-20-12

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket