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Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 1 of 17 Page ID #:181

1 Eleanor M. Lackman, Esq., No. 298594


elackman@cdas.com
2
COWAN, DEBAETS, ABRAHAMS,
3 & SHEPPARD LLP
9595 Wilshire Boulevard, Suite 900
4
Beverly Hills, CA 90212
5 Telephone: (310) 492-4392
Telefax: (310) 492-4394
6

7 Attorneys for Defendants


Kanye West and Getting Out Our Dreams, Inc.
8

9 UNITED STATES DISTRICT COURT


10 CENTRAL DISTRICT OF CALIFORNIA
11

12 RONALD OSLIN BOBB-SEMPLE, Case No.: 2:19-cv-1682 (FMO) (GJS)


13
Plaintiff,
14 DEFENDANTS KANYE WEST AND
15
vs. GETTING OUT OUR DREAMS,
INC.’s ANSWER TO PLAINTIFF’S
16 KANYE WEST, SCOTT RAMON COMPLAINT, AFFIRMATIVE
17 SEGURO MESCUDI p/k/a KID DEFENSES
CUDI (COLLECTIVELY p/k/a KIDS
18 SEE GHOSTS), TYRONE WILLIAM
19 GRIFFIN JR. p/k/a TY DOLLA
$IGN, ANDREW CLARKE p/k/a
20 ANDY C., JEFF BHASKER,
21 MICHAEL GEORGE DEAN p/k/a
MIKE DEAN, ANDREW DAWSON,
22 BRYAN MIGAL ATTMORE p/k/a
23 BOOGZDABEAST, GETTING OUT
OUR DREAMS, INC., DEF JAM
24 RECORDINGS, INC., AND
25 UNIVERSAL MUSIC GROUP, INC.,

26 Defendants.
27

28 1
DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 2 of 17 Page ID #:182

1
Pursuant to Rule 8(b) of the Federal Rules of Civil Procedure, Defendants Kanye

2 West and Getting Out Our Dreams, Inc. (collectively, “GOOD Defendants”), by their
3
undersigned attorneys Cowan, DeBaets, Abrahams & Sheppard LLP, for its Answer to
4

5 the Complaint filed by plaintiff Ronald Oslin Bobb-Semple (“Bobb-Semple”), states as

6 follows:
7
SUMMARY OF THE ACTION1
8

9 1. GOOD Defendants admit that this is an action under the Copyright Act, 17

10 U.S.C. § 106, but deny that Bobb-Semple is entitled to prevail and/or recover any relief
11
whatsoever on such claims, and deny the remaining allegations in Paragraph 1 of the
12

13 Complaint.

14 2. GOOD Defendants lack knowledge or information sufficient to form a


15
belief concerning the truth of the allegations contained in Paragraph 2 of the Complaint,
16

17 and on that basis deny the allegations of this Paragraph.


18 3. GOOD Defendants lack knowledge or information sufficient to form a
19
belief concerning the truth of the allegations contained in Paragraph 3 of the Complaint,
20

21 and on that basis deny the allegations of this Paragraph, except admit producing the
22 sound recording called “Freeee (Ghost Town Pt. 2)” (hereinafter “Freeee”).
23

24

25

26 1
The inclusion of headings contained in the Complaint is solely for purposes of
27 reference and should not be read as an admission as to any point raised therein.
28 2
DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 3 of 17 Page ID #:183

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4. GOOD Defendants lack knowledge or information sufficient to form a

2 belief concerning the truth of the allegations contained in Paragraph 4 of the Complaint,
3
and on that basis deny the allegations of this Paragraph, except admit that GOOD
4

5 Defendants did not obtain any permission to use any purported performance of Bobb-

6 Semple, nor provide him with any compensation, and state that GOOD Defendants were
7
not required to obtain any such permission, nor provide any such compensation.
8

9 5. GOOD Defendants state that no response is required to Paragraph 5 of the

10 Complaint insofar as it merely restates Bobb-Semple’s motivations for bringing the


11
action. To the extent any such response is required, GOOD Defendants deny the
12

13 allegations of this Paragraph.

14 JURISDICTION AND VENUE


15
6. GOOD Defendants state that the allegations contained in Paragraph 6 of
16

17 the Complaint contain conclusions of law as to which no responsive pleading is


18 necessary, but that to the extent any response is required, admit that Plaintiff purports
19
to bring this action under the Copyright Act, 17 U.S.C. § 101 et seq.
20

21 7. GOOD Defendants state that the allegations contained in Paragraph 7 of


22 the Complaint contain conclusions of law as to which no responsive pleading is
23
necessary, but that to the extent any response is required, admit that this Court has
24

25 subject matter jurisdiction over federal copyright claims pursuant to 28 U.S.C. §§ 1331
26 and 1338(a).
27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 4 of 17 Page ID #:184

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8. GOOD Defendants lack knowledge or information sufficient to form a

2 belief concerning the truth of the allegations contained in Paragraph 8 of the Complaint
3
as to any other defendant, except admit that GOOD Defendants are subject to personal
4

5 jurisdiction in California.

6 9. GOOD Defendants state that the allegations contained in Paragraph 9 of


7
the Complaint contain conclusions of law as to which no responsive pleading is
8

9 necessary, but to the extent any response is required, GOOD Defendants lack

10 knowledge or information sufficient to form a belief concerning the truth of the


11
allegations contained in Paragraph 9, and on that basis deny the allegations of this
12

13 Paragraph insofar as they relate to the residences or acts committed by any other

14 defendant, except GOOD Defendants deny that all of the events giving rise to Bobb-
15
Semple’s claims occurred in this district, and except admit that GOOD Defendants are
16

17 subject to personal jurisdiction in this district.


18 DEFENDANTS
19
10. GOOD Defendants admit the allegations contained in Paragraph 10 of the
20

21 Complaint.
22 11. GOOD Defendants lack knowledge or information sufficient to form a
23
belief concerning the truth of the allegations contained in Paragraph 11 of the
24

25 Complaint, and on that basis deny the allegations of this Paragraph, except admit that
26

27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 5 of 17 Page ID #:185

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defendant Scott Ramon Seguro Mescudi p/k/a Kid Cudi is a Grammy Award winning

2 performer.
3
12. GOOD Defendants admit the allegations contained in Paragraph 12 of the
4

5 Complaint.

6 13. GOOD Defendants lack knowledge or information sufficient to form a


7
belief concerning the truth of the allegations contained in Paragraph 13 of the
8

9 Complaint, and on that basis deny the allegations of this Paragraph, except admit that

10 defendant Tyrone William Griffin Jr. p/k/a Ty Dolla $ign is an internationally known
11
performing artist.
12

13 14. GOOD Defendants lack knowledge or information sufficient to form a

14 belief concerning the truth of the allegations contained in Paragraph 14 of the


15
Complaint, and on that basis deny the allegations of this Paragraph, except admit that
16

17 defendant Andrew Clarke p/k/a Andy C. is a music producer.


18 15. GOOD Defendants lack knowledge or information sufficient to form a
19
belief concerning the truth of the allegations contained in Paragraph 15 of the
20

21 Complaint, and on that basis deny the allegations of this Paragraph, except admit that
22 defendant Jeff Bhasker is a music producer.
23
16. GOOD Defendants lack knowledge or information sufficient to form a
24

25 belief concerning the truth of the allegations contained in Paragraph 16 of the


26

27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 6 of 17 Page ID #:186

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Complaint, and on that basis deny the allegations of this Paragraph, except admit that

2 defendant Andrew Dawson is a music producer.


3
17. GOOD Defendants lack knowledge or information sufficient to form a
4

5 belief concerning the truth of the allegations contained in Paragraph 17 of the

6 Complaint, and on that basis deny the allegations of this Paragraph, except admit that
7
defendant Michael George Dean p/k/a Mike Dean is a music producer.
8

9 18. GOOD Defendants lack knowledge or information sufficient to form a

10 belief concerning the truth of the allegations contained in Paragraph 18 of the


11
Complaint, and on that basis deny the allegations of this Paragraph, except admit that
12

13 defendant Bryan Migal Attmore p/k/a BoogzDaBeast is a music producer.

14 19. GOOD Defendants deny the allegations contained in Paragraph 19 of the


15
Complaint, except admit that Getting Out Our Dreams, Inc. is a California corporation.
16

17 20. GOOD Defendants lack knowledge or information sufficient to form a


18 belief concerning the truth of the allegations contained in Paragraph 20 of the
19
Complaint, and on that basis deny the allegations of this Paragraph.
20

21 21. GOOD Defendants lack knowledge or information sufficient to form a


22 belief concerning the truth of the allegations contained in Paragraph 21 of the
23
Complaint, and on that basis deny the allegations of this Paragraph, except admit that
24

25 defendant Universal Music Group is a Delaware Corporation.


26 THE COPYRIGHTED WORK AT ISSUE
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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 7 of 17 Page ID #:187

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22. GOOD Defendants lack knowledge or information sufficient to form a

2 belief concerning the truth of the allegations contained in Paragraph 22 of the


3
Complaint, and on that basis deny the allegations of this Paragraph.
4

5 23. GOOD Defendants lack knowledge or information sufficient to form a

6 belief concerning the truth of the allegations contained in Paragraph 23 of the


7
Complaint, and on that basis deny the allegations of this Paragraph.
8

9 24. GOOD Defendants lack knowledge or information sufficient to form a

10 belief concerning the truth of the allegations contained in Paragraph 24 of the


11
Complaint, and on that basis deny the allegations of this Paragraph.
12

13 INFRINGEMENT BY DEFENDANTS

14 25. GOOD Defendants lack knowledge or information sufficient to form a


15
belief concerning the truth of the allegations contained in Paragraph 25, and on that
16

17 basis deny the allegations of this Paragraph insofar as they relate to any other defendant,
18 except GOOD Defendants admit that they did not acquire a license from Bobb-Semple,
19
and state that no such license was required to be obtained by GOOD Defendants.
20

21 26. GOOD Defendants deny the allegations contained in Paragraph 26 of the


22 Complaint.
23
27. GOOD Defendants deny the allegations contained in Paragraph 27 of the
24

25 Complaint.
26

27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 8 of 17 Page ID #:188

1
28. GOOD Defendants deny the allegations contained in Paragraph 28 of the

2 Complaint as it pertains to GOOD Defendants.


3
29. GOOD Defendants neither admit nor deny the allegations contained in
4

5 Paragraph 29 of the Complaint, and respectfully refer the Court to any recordings that

6 will be admitted into evidence in this case, which speak for themselves.
7
30. GOOD Defendants lack knowledge or information sufficient to form a
8

9 belief concerning the truth of the allegations contained in Paragraph 30, and respectfully

10 refer the Court to any recordings that will be admitted into evidence in this case, which
11
speak for themselves.
12

13 31. GOOD Defendants deny the allegations contained in Paragraph 31 of the

14 Complaint.
15
32. GOOD Defendants lack knowledge or information sufficient to form a
16

17 belief concerning the truth of the allegations contained in Paragraph 32, and on that
18 basis deny the allegations of this Paragraph.
19
33. GOOD Defendants lack knowledge or information sufficient to form a
20

21 belief concerning the truth of the allegations contained in Paragraph 33, and on that
22 basis deny the allegations of this Paragraph, and respectfully refer the Court to the
23
credits accompanying Freeee, which speak for themselves.
24

25 34. GOOD Defendants deny the allegations contained in Paragraph 34 of the


26 Complaint.
27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 9 of 17 Page ID #:189

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35. GOOD Defendants admit the allegations contained in Paragraph 35 of the

2 Complaint.
3
36. GOOD Defendants lack knowledge or information sufficient to form a
4

5 belief concerning the truth of the allegations contained in Paragraph 36.

6 37. GOOD Defendants deny the allegations contained in Paragraph 37 of the


7
Complaint as they pertain to GOOD Defendants.
8

9 38. GOOD Defendants admit the allegations contained in Paragraph 38 of the

10 Complaint.
11
39. GOOD Defendants admit the allegations contained in Paragraph 39 of the
12

13 Complaint.

14 40. GOOD Defendants admit the allegations contained in Paragraph 40 of the


15
Complaint.
16

17 41. GOOD Defendants state that the allegations contained in Paragraph 41 of


18 the Complaint contain conclusions of law as to which no responsive pleading is
19
necessary, but that to the extent any response is required, GOOD Defendants otherwise
20

21 deny the allegations contained in Paragraph 41 of the Complaint.


22 42. GOOD Defendants state that the allegations contained in Paragraph 42 of
23
the Complaint contain conclusions of law as to which no responsive pleading is
24

25 necessary, but that to the extent any response is required, GOOD Defendants otherwise
26 deny the allegations contained in Paragraph 42 of the Complaint.
27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 10 of 17 Page ID #:190

1
43. GOOD Defendants deny the allegations contained in Paragraph 43 of the

2 Complaint.
3
44. GOOD Defendants deny the allegations contained in Paragraph 44 of the
4

5 Complaint.

6 45. GOOD Defendants deny the allegations contained in Paragraph 45 of the


7
Complaint.
8

9 46. GOOD Defendants state that the allegations contained in Paragraph 46 of

10 the Complaint contain conclusions of law as to which no responsive pleading is


11
necessary, but that to the extent any response is required, GOOD Defendants deny the
12

13 allegations of this Paragraph.

14 47. GOOD Defendants state that the allegations contained in Paragraph 47 of


15
the Complaint contain conclusions of law as to which no responsive pleading is
16

17 necessary, but that to the extent any response is required, GOOD Defendants deny the
18 allegations of this Paragraph.
19
48. GOOD Defendants deny the allegations contained in Paragraph 48 of the
20

21 Complaint as they pertain to GOOD Defendants.


22 49. GOOD Defendants admit that they did not acquire a license from Bobb-
23
Semple as referenced in Paragraph 49 of the Complaint, and state that no such license
24

25 was required to be obtained by GOOD Defendants.


26

27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 11 of 17 Page ID #:191

1
50. GOOD Defendants lack knowledge or information sufficient to form a

2 belief concerning the truth of the allegations contained in Paragraph 50 of the


3
Complaint, and on that basis deny the allegations of this Paragraph.
4

5 51. GOOD Defendants state that the allegations contained in Paragraph 51 of

6 the Complaint contain conclusions of law as to which no responsive pleading is


7
necessary, but to the extent any response is required, GOOD Defendants deny the
8

9 allegations of this Paragraph.

10 52. GOOD Defendants deny the allegations contained in Paragraph 52 of the


11
Complaint as they pertain to GOOD Defendants.
12

13 53. GOOD Defendants state that the allegations contained in Paragraph 53 of

14 the Complaint contain conclusions of law as to which no responsive pleading is


15
necessary, but to the extent any response is required, GOOD Defendants deny the
16

17 allegations of this Paragraph, except admit that the defendants named herein had certain
18 roles in connection with the creation, distribution and exploitation of Freeee.
19
54. GOOD Defendants deny all the allegations contained in Paragraph 54 of
20

21 the Complaint as they pertain to Good Defendants. GOOD Defendants lack knowledge
22 or information sufficient to form a belief concerning the truth of the allegations
23
contained in this Paragraph, and on that basis deny the allegations contained therein.
24

25 55. GOOD Defendants deny the allegations contained in Paragraph 55 of the


26 Complaint as they pertain to GOOD Defendants.
27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 12 of 17 Page ID #:192

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56. GOOD Defendants deny the allegations contained in Paragraph 56 of the

2 Complaint as they pertain to GOOD Defendants, except state that Freeee continues to
3
be exploited in the marketplace in connection with the Kids See Ghosts album.
4

5 COUNT I
COPYRIGHT INFRINGEMENT
6

7 57. GOOD Defendants incorporate their responses to the allegations in

8 Paragraphs 1-56, as if fully set forth herein.


9
58. GOOD Defendants lack knowledge or information sufficient to form a
10

11 belief concerning the truth of the allegations contained in Paragraph 58 of the

12 Complaint, and on that basis deny the allegations of this Paragraph.


13
59. GOOD Defendants lack knowledge or information sufficient to form a
14

15 belief concerning the truth of the allegations contained in Paragraph 59 of the

16 Complaint, and on that basis deny the allegations of this Paragraph.


17
60. GOOD Defendants deny all the allegations contained in Paragraph 60 of
18

19 the Complaint as they pertain to Good Defendants. GOOD Defendants lack knowledge
20 or information sufficient to form a belief concerning the truth of the allegations
21
contained in this Paragraph, and on that basis deny the allegations contained therein.
22

23 61. GOOD Defendants the allegations contained in Paragraph 61 of the


24 Complaint contain conclusions of law as to which no responsive pleading is necessary,
25
but that to the extent any response is required, GOOD Defendants otherwise deny the
26

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 13 of 17 Page ID #:193

1
allegations contained in Paragraph 61 of the Complaint as they pertain to GOOD

2 Defendants.
3
62. GOOD Defendants deny the allegations contained in Paragraph 62 of the
4

5 Complaint as they pertain to GOOD Defendants, except admit that GOOD Defendants

6 did not seek permission from Bobb-Semple, and state that no such permission was
7
necessary to be sought by GOOD Defendants.
8

9 63. GOOD Defendants deny the allegations contained in Paragraph 63 of the

10 Complaint as they pertain to GOOD Defendants.


11
64. GOOD Defendants deny the allegations contained in Paragraph 64 of the
12

13 Complaint, including each of its subparagraphs (a) - (d), as they pertain to GOOD

14 Defendants.
15
65. GOOD Defendants deny the allegations contained in Paragraph 65 of the
16

17 Complaint as they pertain to GOOD Defendants, except admit that Freeee continues to
18 be distributed by the defendants.
19
66. GOOD Defendants deny the allegations contained in Paragraph 66 of the
20

21 Complaint as they pertain to GOOD Defendants.


22 67. GOOD Defendants deny the allegations contained in Paragraph 67 of the
23
Complaint.
24

25 68. GOOD Defendants deny the allegations contained in Paragraph 68 of the


26 Complaint.
27

28 13
DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 14 of 17 Page ID #:194

1
69. GOOD Defendants deny the allegations contained in Paragraph 69 of the

2 Complaint.
3
70. GOOD Defendants deny the allegations contained in Paragraph 70 of the
4

5 Complaint.

6 71. GOOD Defendants deny the allegations contained in Paragraph 71 of the


7
Complaint.
8

9 Bobb-Semple’s Prayer for Relief does not necessitate responsive pleading, but

10 GOOD Defendants deny that Bobb-Semple is entitled to any of the relief sought therein.
11
GOOD DEFENDANTS’ AFFIRMATIVE DEFENSES
12

13 GOOD Defendants make the following allegations as affirmative defenses

14 against the claims asserted against them without admitting that they bear the burden of
15
persuasion or presentation of evidence on each or any of these matters, and without
16

17 waiving the right to assert and rely upon other defenses that become available or appear
18 during the course of this Action.
19
FIRST AFFIRMATIVE DEFENSE
20 (Failure to State a Claim)
21
1. Bobb-Semple fails to state a claim upon which relief can be granted.
22

23 SECOND AFFIRMATIVE DEFENSE


(Lack of Standing)
24

25 2. The Complaint, and each cause of action alleged therein, is barred because
26 Bobb-Semple lacks standing to assert the purported claims set forth therein.
27

28 14
DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 15 of 17 Page ID #:195

1
THIRD AFFIRMATIVE DEFENSE
(Fair Use)
2

3 3. The Complaint, and each cause of action alleged therein, is barred because

4 GOOD Defendants’ use of the subject material constitutes fair use.


5
FOURTH AFFIRMATIVE DEFENSE
6 (First Amendment)
7
4. The Complaint, and each cause of action alleged therein, is barred by the
8

9 First Amendment to the United States Constitution.

10 FIFTH AFFIRMATIVE DEFENSE


11 (Misuse of Copyright)

12 5. As to any and all claims for relief based upon GOOD Defendants’ alleged
13
infringement of alleged copyrights owned by Bobb-Semple, Bobb-Semple’s actions
14

15 constitute misuse of copyright.

16 SIXTH AFFIRMATIVE DEFENSE


17 (Laches)
18 6. The Complaint is barred, in whole or in part, by the doctrine of laches,
19
waiver, estoppel, or acquiescence.
20

21 SEVENTH AFFIRMATIVE DEFENSE


(Innocent Infringement)
22

23 7. To the extent any copyright has been infringed, which GOOD Defendants
24 do not concede, GOOD Defendants’ actions were innocent and non-willful, and Bobb-
25
Semple fails to identify any facts supporting its allegations of willfulness.
26

27 PRAYER FOR RELIEF


28 15
DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 16 of 17 Page ID #:196

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WHEREFORE, GOOD Defendants respectfully request that they be awarded

2 judgment as follows:
3
1. Denying all relief sought by Bobb-Semple in the Complaint;
4

5 2. Dismissing the Complaint in its entirety with prejudice;

6 3. Declaring that GOOD Defendants have not infringed any copyright of


7
Bobb-Semple’s;
8

9 4. Finding that Bobb-Semple is not entitled to damages;

10 5. Awarding GOOD Defendants their reasonable attorney’s fees, costs,


11
expenses, and interest; and
12

13 6. Awarding GOOD Defendants such other and further relief as the Court

14 deems just and proper.


15
Respectfully submitted,
16

17 Dated: Beverly Hills, CA COWAN, DEBAETS, ABRAHAMS & SHEPPARD


June 3, 2019 LLP
18

19
By: /s/ Eleanor M. Lackman
20 Eleanor M. Lackman, Esq., No. 298594
21 9595 Wilshire Boulevard, Suite 900
Beverly Hills, CA 90212
22 Tel.: (310) 492-4392
23 Fax: (310) 492-4394
elackman@cdas.com
24

25 Attorneys for Defendants Kanye West and


Getting Out Our Dreams, Inc.
26

27

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES
Case 2:19-cv-01682-FMO-GJS Document 45 Filed 06/03/19 Page 17 of 17 Page ID #:197

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DEMAND FOR JURY TRIAL

2 GOOD Defendants hereby demand trial by jury on all claims and defenses
3
properly triable to a jury in this action.
4

5 Respectfully submitted,

6 Dated: Beverly Hills, CA COWAN, DEBAETS, ABRAHAMS & SHEPPARD


7 June 3, 2019 LLP

9 By: /s/ Eleanor M. Lackman


Eleanor M. Lackman, Esq., No. 298594
10 9595 Wilshire Boulevard, Suite 900
11 Beverly Hills, CA 90212
Tel.: (310) 492-4392
12 Fax: (310) 492-4394
13 elackman@cdas.com

14 Attorneys for Defendants Kanye West and


15 Getting Out Our Dreams, Inc.

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DEFENDANTS KANYE WEST AND GETTING OUT OUR DREAMS, INC.’S ANSWER TO
PLAINTIFF’S COMPLAINT, AFFIRMATIVE DEFENSES