UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

CHAUNCEY MAHAN Petitioner, vs. ROC NATION, LLC, ROC-A-FELLA RECORDS, LLC, SHAWN CARTER p/k/a “JAY Z” Respondents. Case No. 14-cv-5075 (LGS)  JUDGE SCHOFIELD ECF CASE

PETITION FOR DECLARATORY JUDGMENT

COMES NOW the Petitioner, CHAUNCEY M. MAHAN, a citizen of the United States of America, by and through his counsel, James H. Freeman, Esq. of JH

 

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REEMAN

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3 Columbus Circle, Floor 15, New York, NY 10019; to seek a declaration of his ownership and authorship rights under the Copyright Act of 1976, 17 U.S.C. § 1 et seq., vis-à-vis the Respondents ROC NATION, LLC, a Delaware limited liability company registered to do business in the State of New York; ROC-A-FELLA, LLC, a Delaware limited liability company registered to do business in the State of New York; SHAWN C. CARTER p/k/a “JAY Z, a citizen of the State of New York; and alleges as follows:

 

 ii

IN

TRODUCTION

 

“Modern music owes a great debt to the behind-the-studio-glass magicians.”

 –

Alan Parsons,

 

A HISTORY OF RECORD PRODUCTION

 17 (1998).

“There’s definitely a big difference between a beatmaker and a producer because once you finish the beat, you have to produce the record.” – Dr. Dre,

Something from Nothing: Art of Rap

(2012)

 

Petitioner Chauncey Mahan (“Petitioner”) is a Grammy-award recognized producer and engineer of sound recordings. His work is embodied on albums released by the respondent Roc-A-Fella Records, including Jay Z – Vol. 3…

Life and Times of S. Carter 

 (1999); Jay Z – 

 The Dynasty: Roc La Familia:

(2000); and Beanie Sigel –

The Truth 

 (2000). Count I of the Petition respectfully seeks a declaratory judgment from the Honorable Court pursuant to 28 U.S.C. §§ 2201, 2202 declaring Petitioner to be a joint copyright owner and author of forty-five (45) published sound recordings, plus numerous unpublished copyrightable materials that are currently in possession of the Los Angeles police department. In the alternative, Petitioner seeks a declaration, upon good cause shown, that he is the sole owner of the subject sound recordings. Count II seeks a declaration that Roc-A-Fella’s underlying SR Copyrights identified in this Petition are invalid as a matter of statutory law and therefore have no legal effect. The registration forms are defective on their face,

inter alia 

, for claiming to be “employer-for-hire” where no employment relationship existed between the label and authors and no copyright assignment agreement was signed by Petitioner.