2
COMPLAINT NATURE OF THE ACTION
1.
This is an action for willful copyright infringement brought by plaintiffs Sean
Carey and Beau Golden (collectively “Plaintiffs”)
against Edward Christopher Sheeran p/k/a Ed Sheeran,
John “
Johnny
”
McDaid, Steve McCutcheon, p/k/a Steve Mac, and Amy Victoria Wadge
(collectively “Defendant Writers”);
Sony/ATV Songs, LLC, Rokstone Music Ltd., Universal Polygram International Publishing, Inc., Cookie Jar Music LLP, WB Music Corp., Kobalt Music Services America, Inc., and Bucks Music
Group Limited (collectively “Defendant Publishers/Administrators”);
Samuel Timothy McGraw p/k/a Tim McGraw, Audrey Faith Hill p/k/a Faith Hill, Sony Music Entertainment, and McGraw Music, LLC (all Defendants are at times
collectively referred to as “Defendants”)
for the blatant copying of Plaintiffs
’
song
“
When
I Found You” (“When I Found You,” or the “Song”)
in
the song “The Rest Of Our Life”
(
“The Rest Of Our Life” or the “Infringing Song”
or
the “Infringing Sound Recording”
) and for the subsequent exploitation and distribution of the Infringing Song and Infringing Sound Recording
in violation of Plaintiffs’ rights
. The Infringing Song/Sound Recording is the title track of the Number 1 country music album of the same name. The copying is, in many instances, verbatim, note-for-note copying of important and original elements of the Song, and is obvious to the ordinary observer. Furthermore, as discussed fully below, the copying was fully known by employees of Sony Music Entertainment to have occurred, but Sony Music Entertainment did not alert Plaintiffs or take any steps to prevent it. Indeed, as discussed below, it very well may have been an agent of Sony Music Entertainment who provided the other defendants herein with access to the Song.
Case 1:18-cv-00214 Document 1 Filed 01/10/18 Page 2 of 35
Mark Jaffe
