Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Standard view
Full view
of .
Look up keyword
Like this
0 of .
Results for:
No results containing your search query
P. 1
Complaint for Declaratory Relief 2013.08.15 (1)

Complaint for Declaratory Relief 2013.08.15 (1)

Ratings: (0)|Views: 1,884|Likes:
Published by scprweb

More info:

Published by: scprweb on Aug 16, 2013
Copyright:Attribution Non-commercial


Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less





"Blurred Lines copies "their compositions n the case ofthe MarvinGaye-
 related defendants (the "Gaye defendants) its a son called "Got o Give
For e owner ofFunkadelics sons Brideport Music nc ("Brideport) its a
son called "Sexy Ways. But there are no similarities between plaintiffs
composition and those the claimants allee they own other than comonplace
 musical elements laintiffs created a hit and did it without copyin anyone elses
2he basis of the Gaye defendants claims is that "BluedLines and
"Got o Give t Up "feel or "sound the same Bein reminscent of a "sound is
 not copyriht ininement he intent in producin "Blurred Lines was to evoke
an era. n reality the Gaye defendnts are claimin ownershipof an entire enre as
opposed to a specic work and Brideport is claimin the same work
3 he realty is that thesons themselves are stkly different Since that
is the salient factor in a claim for copyriht ininement in the face of the treats of 
defendants to comence lawsuits plaintiffs must seek declatory relief om is
ourt that conrms plaintiffs' unfetered riht to exploit "Blurred Linesee of 
defendants' claims
JSDCTON  VEE
4his action is brouht and this ourt has subject materjurisdiction  pursuant to 28 US. Sections 133 338 and 2201 his ourt has federalquestion jurisdiction in this matter in that plaintiffs seek a declaation of rihts under the opyriht Act of 1976 17 US. § 101
et seq
5 Venue lies within ths our pursuant to 28 US. Sections1391(b)(2)(3) (c) (d) nd 1400(a) in that defendants Franke istianGaye andMarvin Gaye
are domiciled and reside for venue purposes and e subject to personal jurisdiction in this district that on information and belief defendant NonaMarvisa Gaye is a parttime resident of this district and that sheand defendant Brideport Music Inc ("Brideport) reularly and systematically conduct business
KN OESPTERNOUNER
in this district and, therefore, ae subject to personal jurisdiction in this district
H PS
Plaintiffs are e composers of e multinational hit son "Blurred
Lines, whichwas released in or about March
"Blurred Lines has ered
 more th
140 miion
 views on Youubecom
7.On information and belief, Brideport is and at all times material herein
 has been a corporation oranized and existin under e laws of the State of 
Michin and is in the business of acquirin and exploitin copyriht interests in
 musicalcompositions, and in the business of ollin for oppornities to threaten to
sueand to sue musicians, performers, producers and others in the musicindustry for
ininementof its copyrihts Brideport reularly and systematicaly does
 business in the state of alifoa by, amon other thins, neotiatin and rantin
icenses to use the sons in which it has a copyriht interest to licensees in
alifoia and resortin to the alifoia courts Brideport has claimed an
ownership interest in the copyriht to the composition "Sexy Ways written by
Geore linton d Grace ook
8 On information and belief, defend Frankie hristian Gaye is and at
al times material herein has been an individual residin in Los Aneles ounty,
9On information and belief, defendant Marvin Gaye III is and at all
 times materia herein has been n individual residin in Los neles ounty,
Oninfo rmationa nd beief, defe ndan t ona M a rvisa Gayeis a ndatal
 times materia herein has been an individual residinin Los Aneles ounty
alifoa nd the State of hodesld, who reulary conducts business as an
entertainer in the ounty of Los Anees, alifoia Defendants Frankie ristian
Gaye, Marvin Gaye II d Mona Mvisa Gaye are referred to collectively
 hereinaer as "the Gayes

You're Reading a Free Preview

/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->