Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 1 of 26 Page ID #:1

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Peter I. Ostroff, SBN 45718
postroff@sidley.com
Rollin A. Ransom, SBN 196126
rransom@sidley.com
Charlie J. Sarosy, SBN 302439
csarosy@sidley.com
SIDLEY AUSTIN LLP
555 West Fifth Street, Suite 4000
Los Angeles, California 90013
Telephone: +1 213 896-6000
Facsimile: +1 213 896-6600

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA
UMG RECORDINGS, INC.; CAPITOL
RECORDS, LLC; WARNER BROS.
RECORDS INC.; WARNER MUSIC
LATINA INC.; SONY MUSIC
ENTERTAINMENT; SONY MUSIC
ENTERTAINMENT US LATIN LLC;
ARISTA RECORDS LLC; ATLANTIC
RECORDING CORPORATION;
ELEKTRA ENTERTAINMENT
GROUP INC.; FUELED BY RAMEN,
LLC; KEMOSABE RECORDS LLC;
LAFACE RECORDS LLC;
NONESUCH RECORDS INC.; WEA
INTERNATIONAL INC.; ZOMBA
RECORDING LLC,
Plaintiffs,

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v.

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PMD TECHNOLOGIE UG d/b/a
YouTube-mp3; PHILIP MATESANZ;
and DOES 1-10,

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Defendants.

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) Case No.: 2:16-CV-07210
)
)
) COMPLAINT FOR:
)
) 1. DIRECT COPYRIGHT
)
INFRINGEMENT;
)
) 2. CONTRIBUTORY COPYRIGHT
INFRINGEMENT;
)
)
) 3. VICARIOUS COPYRIGHT
INFRINGEMENT;
)
)
) 4. INDUCEMENT OF
COPYRIGHT INFRINGEMENT;
)
AND
)
)
) 5. CIRCUMVENTION OF
TECHNOLOGICAL
)
MEASURES
)
)
)
) DEMAND FOR JURY TRIAL
)
)
)
)

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COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 2 of 26 Page ID #:2

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Plaintiffs UMG Recordings, Inc.; Capitol Records, LLC; Warner Bros. Records

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Inc.; Warner Music Latina Inc.; Sony Music Entertainment; Sony Music

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Entertainment US Latin LLC; Arista Records LLC; Atlantic Recording Corporation;

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Elektra Entertainment Group Inc.; Fueled by Ramen, LLC; Kemosabe Records LLC;

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LaFace Records LLC; Nonesuch Records Inc.; WEA International Inc.; and Zomba

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Recording LLC (collectively, “Plaintiffs”), by and through their attorneys, hereby

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allege as follows:
INTRODUCTION

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1.

Plaintiffs are record companies that, along with their affiliated labels,

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create, manufacture, and/or distribute the vast majority of all recorded music

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legitimately produced and sold in the United States. Defendants own and operate a

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website known as “YouTube-mp3” (“YTMP3”), which is located at the web address

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www.youtube-mp3.org. YTMP3 is designed to infringe and facilitate the

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infringement of Plaintiffs’ copyrighted sound recordings that are available on

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YouTube (www.youtube.com). YTMP3 rapidly and seamlessly removes the audio

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tracks contained in videos streamed from YouTube that YTMP3’s users access (these

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audio tracks consist largely of sound recordings owned by Plaintiffs), converts those

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audio tracks to an MP3 format, copies and stores them on YTMP3’s servers, and then

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distributes copies of the MP3 audio files from its servers to its users in the United

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States, enabling its users to download those MP3 files to their computers, tablets, or

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smart phones. All of this occurs without the authorization of Plaintiffs or of

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YouTube, which makes videos available to its users for viewing and listening online,

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but not for copying or downloading.

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2.

By its conduct, YTMP3 directly infringes Plaintiffs’ sound recordings. It

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also provides the site and facilities and means for its users to engage in copyright

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infringement, while profiting from the infringement. YTMP3 also materially

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contributes to the infringement by its users, of which it has knowledge.

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1
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 3 of 26 Page ID #:3

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3.

Capturing digital content streamed over the internet is known as “stream

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ripping.” Copyright infringement through stream ripping has become a major

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problem for Plaintiffs and for the recorded music industry as a whole. From 2013 to

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2015 alone, there has been a 50% increase in unauthorized stream ripping in the

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United States.

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4.

YTMP3’s conduct, and the conduct of its users that it enables and

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induces, infringes Plaintiffs’ copyrights and other rights. It also violates YouTube’s

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Terms of Service. In addition, on information and belief, YTMP3’s unauthorized

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conversion, copying, storage, and distribution of Plaintiffs’ copyrighted sound

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recordings is accomplished by YTMP3 unlawfully circumventing technological

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measures that YouTube has implemented to prevent the downloading or copying of

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content from the YouTube service. By engaging in and facilitating the unlawful

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infringement of Plaintiffs’ sound recordings, YTMP3 deprives Plaintiffs (and other

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copyright owners) of the benefits of their investment in these valuable works and

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interferes with and creates a substitute for legitimate streaming and download services

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that are authorized by Plaintiffs.

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5.

The scale of Defendants’ infringing activity is enormous. Plaintiffs are

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informed and believe, and on that basis allege, that the YTMP3 website is one of the

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most visited sites in the world, has tens of millions of users, and is responsible for

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upwards of 40% of all unlawful stream ripping of music from YouTube in the world.

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Defendants have boasted that YTMP3 is the “easiest online service for converting

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videos to mp3,” usable by virtually any internet-enabled device, including personal

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computers, tablets, and smart phones. Defendants also admit that “the whole

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conversion process will be performed by our infrastructure and you only have to

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download the audio file from our servers.”

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6.

Defendants’ unlawful conduct inflicts tremendous and irreparable

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damage on Plaintiffs’ businesses, and erodes authorized sales and distribution of

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sound recordings through traditional and online channels. Rampant copyright
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COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 4 of 26 Page ID #:4

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infringement of sound recordings over the internet, including the massive

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infringement engaged in and enabled by websites such as YTMP3, has resulted in

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significant harm to the music industry, including to artists who rely on recorded music

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for their livelihood. A recent survey found that 57 million persons in the United

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States are engaging in copyright infringement of sound recordings using unauthorized

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online services, including stream ripping services.

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7.

At the same time Defendants are depriving Plaintiffs and their recording

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artists of the fruits of their labor, Defendants are profiting from the operation of the

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YTMP3 website. Through the promise of illicit delivery of free music, Defendants

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have attracted millions of users to the YTMP3 website, which in turn generates

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advertising revenues for Defendants. For example, Plaintiffs are informed and

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believe, and on that basis allege, that Defendants – working with services such as

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Google’s “AdSense” program and Google’s “DoubleClick” service – profit from

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third-party advertising that targets users based on the users’ location (geo-targeting) or

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based on the users’ prior internet browsing history (interest-based targeting). Such

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targeted advertising maximizes the “click-through” rate of advertisements on the

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YTMP3 website (i.e., the number of visitors to the site who then “click” on an

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advertisement appearing on the site), thereby generating substantial revenues and

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profits to Defendants through their operation of the website.

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8.

Defendants’ provision of an easy-to-use service for copyright

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infringement has caused and is causing Plaintiffs significant and irreparable harm.

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Defendants’ business unlawfully profits from copyright infringement and free rides on

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the creative efforts and investments of others. Plaintiffs are entitled to preliminary

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and permanent injunctive relief to stop Defendants’ ongoing violation of Plaintiffs’

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rights, and to damages.
NATURE OF THE ACTION

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9.

This is an action for copyright infringement under the Copyright Act of

the United States, Title 17, United States Code §§ 101, et seq., and for violations of
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COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 5 of 26 Page ID #:5

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the provisions of the Copyright Act that prohibit persons from circumventing

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technological measures designed to protect copyrighted works.
JURISDICTION AND VENUE

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10.

This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331

and 1338(a).
11.

This Court has personal jurisdiction over Defendants, including pursuant

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to Federal Rule of Civil Procedure 4(k)(2), for at least the following reasons: (1)

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Plaintiffs’ claims arise under federal copyright law; (2) YTMP3 is dedicated

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exclusively to capturing, converting, and copying audio content that is maintained on

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a U.S.-based website, YouTube (www.youtube.com), which Defendants then

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distribute to users throughout the United States; (3) YTMP3 targets and attracts a

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substantial number of users in the United States (YTMP3 attracts more users from the

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United States than any other country); and (4) the effects of Defendants’ unlawful

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conduct are felt in the United States, including in this District, where several Plaintiffs

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are located and/or maintain substantial business operations.

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12.

U.S.C. § 1400(a).
THE PARTIES

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Plaintiffs

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13.

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Venue in this District is proper under 28 U.S.C. §§ 1391(b) and 28

Plaintiff UMG Recordings, Inc. is a Delaware corporation with its

principal place of business in Santa Monica, California.
14.

Plaintiff Capitol Records, LLC is a Delaware limited liability company

with its principal place of business in Santa Monica, California.
15.

Plaintiff Warner Bros. Records Inc. is a Delaware corporation with its

principal place of business in Burbank, California.
16.

Plaintiff Warner Music Latina Inc. is a Delaware corporation with its

principal place of business in Miami, Florida.

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4
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 6 of 26 Page ID #:6

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17.

Plaintiff Sony Music Entertainment is a Delaware partnership with its

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principal place of business in New York, New York, and has substantial business

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operations in this District.

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18.

Plaintiff Sony Music Entertainment US Latin LLC is a Delaware limited

liability company with its principal place of business in Coconut Grove, Florida.
19.

Plaintiff Arista Records LLC is a Delaware limited liability company

with its principal place of business in New York, New York.
20.

Plaintiff Atlantic Recording Corporation is a Delaware corporation with

its principal place of business in New York, New York.
21.

Plaintiff Elektra Entertainment Group Inc. is a Delaware corporation with

its principal place of business in New York, New York.
22.

Plaintiff Fueled by Ramen, LLC is a Delaware limited liability company

with its principal place of business in New York, New York.
23.

Plaintiff Kemosabe Records LLC is a Delaware limited liability company

with its principal place of business in New York, New York.
24.

Plaintiff LaFace Records LLC is a Delaware limited liability company

with its principal place of business in New York, New York.
25.

Plaintiff Nonesuch Records Inc. is a Delaware corporation with its

principal place of business in New York, New York.
26.

Plaintiff WEA International Inc. is a Delaware corporation with its

principal place of business in New York, New York.
27.

Plaintiff Zomba Recording LLC is a Delaware limited liability company

with its principal place of business in New York, New York.
28.

Plaintiffs UMG Recordings, Inc.; Capitol Records, LLC; Warner Bros.

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Records Inc.; Warner Music Latina Inc.; Sony Music Entertainment; Sony Music

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Entertainment US Latin LLC; Arista Records LLC; Atlantic Recording Corporation;

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Elektra Entertainment Group Inc.; Fueled by Ramen, LLC; Kemosabe Records LLC;

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5
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 7 of 26 Page ID #:7

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LaFace Records LLC; Nonesuch Records Inc.; WEA International Inc.; and Zomba

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Recording LLC are collectively referred to herein as “Plaintiffs.”

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29.

Plaintiffs, along with their affiliated labels, are the copyright owners or

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owners of exclusive rights with respect to the vast majority of copyrighted sound

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recordings sold in the United States. Under the Copyright Act, Plaintiffs have, inter

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alia, the exclusive rights to reproduce their copyrighted works, distribute copies or

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phonorecords of their copyrighted works and perform them by means of a digital

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audio transmission to the public. See 17 U.S.C. §§ 106(1), (3), (6). Plaintiffs are also

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the owners of sound recordings protected under state law.

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30.

In addition to manufacturing, distributing, licensing, and selling

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phonorecords in the form of CDs, vinyl records, and other tangible media, Plaintiffs

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distribute their sound recordings in the form of digital audio files delivered or

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performed over the internet through authorized services. Plaintiffs and the legitimate

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services with which they work provide a wide variety of lawful ways for consumers to

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enjoy recorded music that is distributed and performed over the internet, including

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digital download and/or streaming services like Apple Music, iTunes, Google Play,

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Amazon, Rhapsody, Spotify, and many others. Unlike Defendants’ unauthorized and

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unlawful service, these services generally operate lawfully and pay Plaintiffs for

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sound recordings that they distribute or perform.

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31.

Plaintiffs have invested and continue to invest significant money, time,

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effort, and creative talent to discover and develop recording artists, and to create,

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manufacture, advertise, promote, sell, and distribute sound recordings embodying

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their performances. Plaintiffs, their employees, their recording artists, and others in

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the music industry are compensated for their creative efforts and monetary

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investments largely from the sale and distribution of sound recordings to the public,

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including the authorized online sale, streaming, and distribution described above.

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6
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 8 of 26 Page ID #:8

1
2

Defendants
32.

Defendant PMD Technologie UG (“PMD”) is a German limited liability

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company organized and existing under the laws of Germany. PMD, which is wholly

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owned by Defendant Philip Matesanz (“Matesanz”), describes itself as the owner and

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operator of YTMP3.

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33.

On information and belief, Defendant Matesanz is a German citizen who

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lives in Germany. On information and belief, Matesanz personally directs and

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participates in, and personally receives a direct financial benefit from, the conduct

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alleged herein. Matesanz describes himself as the owner and sole employee of PMD,

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and thus is the ultimate owner and operator of YTMP3.
34.

Plaintiffs are informed and believe, and on that basis allege, that

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Defendants Does 1 through 10, along with Defendants PMD and Matesanz, own

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and/or operate YTMP3, or are otherwise responsible for and proximately caused and

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is causing the harm and damages alleged in this Complaint. Plaintiffs are unaware of

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the true names and capacities of the Defendants sued herein as Does 1 through 10, and

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for that reason, sue such Defendants by such fictitious names.

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35.

Defendants PMD, Matesanz, and Does 1-10 are collectively referred to as

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“Defendants.” Plaintiffs are informed and believe, and on that basis allege, that at all

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times relevant hereto, Defendants served as the agents of one another in infringing, or

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facilitating the infringement of, Plaintiffs’ copyrights.
THE YOUTUBE SERVICE

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36.

YouTube (www.youtube.com) is an online video service. It is also the

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largest on-demand music service in the world. Every day, people watch and listen to

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hundreds of millions of hours of videos that are available on YouTube and generate

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billions of “views” of those videos. Of those views, at least 30% are of music videos.

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37.

YouTube is a streaming service – the music videos on the site can be

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listened to and viewed by users while they are connected to the internet, but the

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transmission of those videos does not result in a permanent copy of the music video
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COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 9 of 26 Page ID #:9

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being made for offline access by the user. Music videos and the sound recordings

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that they contain cannot lawfully be downloaded, copied, saved, or distributed by

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YouTube users.

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38.

In its Terms of Service, YouTube strictly limits what users may do on the

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site, and with content that appears on YouTube. Among other things, YouTube’s

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Terms of Service impose the following prohibitions:

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a.

“You shall not copy, reproduce, distribute, transmit, broadcast,

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display, sell, license, or otherwise exploit any Content for any other

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purposes without the prior written consent of YouTube or the respective

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licensors of the Content.” (YouTube Terms of Service, ¶ 5(B));

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b.

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security-related features of the [YouTube] Service or features that

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prevent or restrict use or copying of any Content or enforce limitations on

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use of the Service or the Content therein.” (YouTube Terms of Service,

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¶ 5(C));

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c.

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Content without YouTube’s prior written authorization, unless YouTube

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makes available the means for such distribution through functionality

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offered by the [YouTube] Service (such as the Embeddable Player).”

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(YouTube Terms of Service, ¶ 4(A)); and

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d.

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means other than the video playback pages of the [YouTube] Service

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itself, the Embeddable Player, or other explicitly authorized means

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YouTube may designate.” (YouTube Terms of Service, ¶ 4(C))

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39.

“You agree not to circumvent, disable or otherwise interfere with

“You agree not to distribute in any medium any part of . . . the

“You agree not to access Content through any technology or

Plaintiffs are informed and believe, and on that basis allege as follows:

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YouTube has adopted and implemented technological measures to control access to

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content maintained on its site and to prevent or inhibit downloading, copying, or illicit

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distribution of that content. YouTube maintains two separate URLs for any given
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COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 10 of 26 Page ID #:10

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video file: one URL, which is visible to the user, is for the webpage where the video

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playback occurs, and one URL, which is not visible to the user, is for the video file

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itself. The second URL is generated using a complex (and periodically changing)

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algorithm – known as a “rolling cipher” – that is intended to inhibit direct access to

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the underlying YouTube video files, thereby preventing or inhibiting the

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downloading, copying, or distribution of the video files.
DEFENDANTS’ INFRINGING CONDUCT

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40.

YTMP3 was designed and exists for one principal reason: to profit from

the unauthorized reproduction and distribution of the popular copyrighted recorded

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music that appears on YouTube, a substantial portion of which is owned or controlled

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by Plaintiffs. YTMP3 accomplishes this goal by unlawfully removing the audio

12

tracks from videos that appear on the YouTube service, converting them to MP3 files,

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copying those files to its servers, and then distributing those audio files to YTMP3

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users in the United States in the form of downloadable MP3 audio files.

15

41.

Stream ripping has become a major threat to the music industry,

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functioning as an unlawful substitute for the purchase of recorded music and the

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purchase of subscriptions to authorized streaming services. Stream ripping replaces

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lawful, revenue-generating streaming and downloads of recordings over the internet

19

and sales of phonorecords in tangible media with the mass distribution of

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unauthorized copies, depriving copyright owners of compensation and enriching

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unlawful actors at copyright owners’ and artists’ expense.

22

42.

The scale of stream ripping, and the corresponding impact on music

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industry revenues, is enormous. Plaintiffs are informed and believe, and on that basis

24

allege, that tens, or even hundreds, of millions of tracks are illegally copied and

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distributed by stream ripping services each month. And YTMP3, as created and

26

operated by Defendants, is the chief offender, accounting for upwards of 40% of all

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unlawful stream ripping that takes place in the world.

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9
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 11 of 26 Page ID #:11

1

43.

The reason for Defendants’ success is straightforward: Defendants have

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created a service that, through a few simple mouse clicks on a computer, generates

3

infringing copies of Plaintiffs’ sound recordings and distributes those infringing

4

copies for free to any person who wants them. Indeed, the YTMP3 home page –

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depicted in the figure below – promotes the simplicity and efficiency of this infringing

6

service, touting that it is “the easiest online service for converting videos to mp3.”

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COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 12 of 26 Page ID #:12

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44.

YTMP3’s infringement of Plaintiffs’ copyrighted work begins with a

2

user who wants a copy of a song, at no cost. The user goes to YouTube

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(www.youtube.com) and searches for a video with the desired song, an example of

4

which is seen in the figure below.

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45.

The user then simply copies the webpage address (or “URL”) associated

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with the playback of that YouTube video (which appears at the top of the YouTube

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screen), goes to the interface on the YTMP3 home page, and pastes or enters the URL

23

into an input box. Once the URL is entered, the user clicks the “Convert Video”

24

button, as shown in the figure below.

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28
11
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 13 of 26 Page ID #:13

1

46.

YTMP3 then extracts the audio track from the YouTube video, converts

2

it to an MP3 audio file, and copies the file to its servers. Plaintiffs are informed and

3

believe, and on that basis allege, that, in order to access the YouTube video and

4

extract and copy the audio track, YTMP3 circumvents the technological measures that

5

YouTube has implemented to control access to content maintained on its site and to

6

prevent or inhibit illicit activities such as stream ripping. Among other things,

7

Plaintiffs are informed and believe, and on that basis allege, that YTMP3 employs a

8

means to circumvent the YouTube rolling cipher technology described above, and

9

other technological means that YouTube employs to protect content on its site.

10

47.

Having circumvented the protective technological measures implemented

11

by YouTube, and having extracted and made a copy of the audio file associated with

12

the relevant video, YTMP3 then presents the user with a “download” link. When the

13

user clicks that link, the YTMP3 service distributes the MP3 file audio directly from

14

Defendants’ servers to the user’s computer, as demonstrated in the figure and arrow

15

below.

16
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24
25
26
27
28

48.

Plaintiffs are informed and believe, and on that basis allege, that in

addition to distributing MP3 audio files to users, Defendants also make and store
copies of the files on their servers for further distribution to other users. Although the
12
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 14 of 26 Page ID #:14

1

YTMP3 webpage states that the service begins to extract the audio file associated with

2

a YouTube video only after a user has entered a YouTube video URL and clicked the

3

“Convert Video” button, and that the service “need[s] 3 to 4 minutes per video,” in

4

many instances – particularly in connection with very popular recordings – the service

5

will deliver an MP3 audio file to the user almost immediately. Plaintiffs are informed

6

and believe that such files are immediately available because Defendants copy and

7

store such files on their servers for expeditious distribution to later users.

8
9

49.

Defendants have no authorization or permission to copy, store, or

distribute Plaintiffs’ copyrighted sound recordings. By providing this all-in-one

10

infringement service, Defendants obtain a significant unfair advantage over competing

11

legitimate music services, which pay for the right to distribute Plaintiffs’ works, and

12

thus deprive Plaintiffs of the revenues to which they are entitled for exploitation of

13

their copyrighted works.

14

50.

Attached as Exhibit A is an initial list of a small sampling of the

15

numerous and rapidly growing number of sound recordings to which Plaintiffs and/or

16

their affiliated labels hold exclusive rights under copyright that have been and are

17

being infringed by Defendants. As set forth in Exhibit A, the copyright in each of

18

these sound recordings is registered in the United States Copyright Office or is the

19

subject of a completed application for registration of the recording. Plaintiffs intend

20

to amend the Complaint at an appropriate time to provide an expanded list of works

21

infringed by Defendants.

22

51.

By providing and operating their service, Defendants are both directly

23

infringing Plaintiffs’ copyrights and are inducing and materially contributing to the

24

infringement of Plaintiffs’ copyrights by others and derive financial benefit from that

25

infringement. Defendants have the right and ability to supervise and stop the

26

infringing activity – indeed, Defendant Matesanz has publicly admitted that he has

27

(and has exercised) the ability to observe the content of the YouTube videos that are

28

being “ripped” through YTMP3 – but they have taken no steps to stop the
13
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 15 of 26 Page ID #:15

1

infringement. Rather, Defendants designed and continue to operate their service to

2

optimize its usefulness for infringement.

3

52.

Defendants have also used one of Plaintiffs’ own recordings to induce,

4

entice, persuade, and cause users of the YTMP3 website to infringe Plaintiffs’

5

copyrights. In a blog posting announcing new functionality for the YTMP3 service

6

(specifically, an “extension” for a Google Chrome browser), the single example that

7

Defendants provided of a video that could be stream ripped through the YTPM3

8

website was the song “More” by the recording artist Usher, which is owned by

9

Plaintiff Sony Music Entertainment:

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12
13
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53.

are receiving a direct financial benefit from the copyright infringement occurring on
their service. Defendants have received millions of dollars in ill-gotten gains,
including by running revenue-generating advertisements on the site while committing
massive copyright infringement.
COUNT ONE

25
26
27
28

The motivation behind Defendants’ illegal conduct is clear: Defendants

(Direct Copyright Infringement)
54.

Plaintiffs repeat and reallege every allegation contained in paragraphs 1

through 53 as if fully set forth herein.
14
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 16 of 26 Page ID #:16

1

55.

Defendants, without authorization or consent from Plaintiffs, reproduce

2

and distribute into the United States unauthorized reproductions of Plaintiffs’

3

copyrighted sound recordings, including but not limited to those copyrighted sound

4

recordings listed in Exhibit A hereto. Such reproduction and distribution constitutes

5

infringement of Plaintiffs’ registered copyrights and the exclusive rights under

6

copyright in violation of 17 U.S.C. §§ 106(1) and (3).

7
8
9
10
11

56.

The infringement of Plaintiffs’ rights in each of their copyrighted sound

recordings constitutes a separate and distinct act of infringement.
57.

Defendants’ acts of infringement are willful, intentional, and purposeful,

in disregard of and indifferent to the rights of Plaintiffs.
58.

As a direct and proximate result of Defendants’ infringement of

12

Plaintiffs’ copyrights and exclusive rights under copyright, Plaintiffs are entitled to

13

the maximum statutory damages, pursuant to 17 U.S.C. § 504(c), in the amount of

14

$150,000 with respect to each work infringed, or such other amounts as may be proper

15

under 17 U.S.C. § 504(c). In the alternative, at Plaintiffs’ election pursuant to 17

16

U.S.C. § 504(b), Plaintiffs are entitled to their actual damages, including Defendants’

17

profits from infringement, in amounts to be proven at trial.

18
19
20

59.

Plaintiffs are entitled to their costs, including reasonable attorneys’ fees,

pursuant to 17 U.S.C. § 505.
60.

Defendants’ conduct is causing, and, unless enjoined by this Court, will

21

continue to cause Plaintiffs great and irreparable injury that cannot be fully

22

compensated or measured in money. Plaintiffs have no adequate remedy at law.

23

Pursuant to 17 U.S.C. § 502, Plaintiffs are entitled to a preliminary injunction and a

24

permanent injunction prohibiting infringement of Plaintiffs’ copyrights and exclusive

25

rights under copyright.

26
27
28
15
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 17 of 26 Page ID #:17

1

COUNT TWO

2

(Contributory Copyright Infringement)

3
4
5

61.

Plaintiffs repeat and reallege every allegation contained in paragraphs 1

through 60 as if fully set forth herein.
62.

As detailed above, users of the YTMP3 website are engaged in repeated

6

and pervasive infringement of Plaintiffs’ exclusive rights to reproduce and distribute

7

their copyrighted recordings.

8
9

63.

Defendants are liable as contributory copyright infringers for the

infringing acts of users of the YTMP3 website. Defendants have actual and

10

constructive knowledge of the infringing activity of YTMP3’s users. Defendants

11

knowingly cause and otherwise materially contribute to these unauthorized

12

reproductions and distributions of Plaintiffs’ copyrighted sound recordings, including

13

but not limited to those sound recordings listed in Exhibit A hereto.

14
15
16
17
18

64.

The infringement of Plaintiffs’ rights in each of their copyrighted sound

recordings constitutes a separate and distinct act of infringement.
65.

Defendants’ acts of infringement are willful, intentional, and purposeful,

in disregard of and indifferent to the rights of Plaintiffs.
66.

As a direct and proximate result of Defendants’ infringement of

19

Plaintiffs’ copyrights and exclusive rights under copyright, Plaintiffs are entitled to

20

the maximum statutory damages, pursuant to 17 U.S.C. § 504(c), in the amount of

21

$150,000 with respect to each work infringed, or such other amounts as may be proper

22

under 17 U.S.C. § 504(c). In the alternative, at Plaintiffs’ election pursuant to 17

23

U.S.C. § 504(b), Plaintiffs are entitled to their actual damages, including Defendants’

24

profits from infringement, in amounts to be proven at trial.

25
26
27
28

67.

Plaintiffs are entitled to their costs, including reasonable attorneys’ fees,

pursuant to 17 U.S.C. § 505.
68.

Defendants’ conduct is causing, and, unless enjoined by this Court, will

continue to cause Plaintiffs great and irreparable injury that cannot fully be
16
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 18 of 26 Page ID #:18

1

compensated or measured in money. Plaintiffs have no adequate remedy at law.

2

Pursuant to 17 U.S.C. § 502, Plaintiffs are entitled to a preliminary injunction and a

3

permanent injunction prohibiting infringement of Plaintiffs’ copyrights and exclusive

4

rights under copyright.

5

COUNT THREE

6

(Vicarious Copyright Infringement)

7
8
9

69.

Plaintiffs repeat and reallege every allegation contained in paragraphs 1

through 68 as if fully set forth herein.
70.

As detailed above, users of the YTMP3 website are engaged in repeated

10

and pervasive infringement of Plaintiffs’ exclusive rights to reproduce and distribute

11

their copyrighted recordings.

12

71.

Defendants are vicariously liable for the infringing acts of users of the

13

YTMP3 website. Defendants have the right and ability to supervise and control the

14

infringing activities that occur through the use of YTMP3, and at all relevant times

15

have derived a direct financial benefit from the infringement of Plaintiffs’ copyrights.

16

Defendants are therefore vicariously liable for the infringement of Plaintiffs’

17

copyrighted sound recordings, including but not limited to those sound recordings

18

listed in Exhibit A hereto.

19
20
21
22
23

72.

The infringement of Plaintiffs’ rights in each of their copyrighted sound

recordings constitutes a separate and distinct act of infringement.
73.

Defendants’ acts of infringement are willful, intentional, and purposeful,

in disregard of and indifferent to the rights of Plaintiffs.
74.

As a direct and proximate result of Defendants’ infringement of

24

Plaintiffs’ copyrights and exclusive rights under copyright, Plaintiffs are entitled to

25

the maximum statutory damages, pursuant to 17 U.S.C. § 504(c), in the amount of

26

$150,000 with respect to each work infringed, or such other amounts as may be proper

27

under 17 U.S.C. § 504(c). In the alternative, at Plaintiffs’ election pursuant to 17

28
17
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 19 of 26 Page ID #:19

1

U.S.C. § 504(b), Plaintiffs are entitled to their actual damages, including Defendants’

2

profits from infringement, in amounts to be proven at trial.

3
4
5

75.

Plaintiffs are entitled to their costs, including reasonable attorneys’ fees,

pursuant to 17 U.S.C. § 505.
76.

Defendants’ conduct is causing, and, unless enjoined by this Court, will

6

continue to cause Plaintiffs great and irreparable injury that cannot fully be

7

compensated or measured in money. Plaintiffs have no adequate remedy at law.

8

Pursuant to 17 U.S.C. § 502, Plaintiffs are entitled to a preliminary injunction and a

9

permanent injunction prohibiting infringement of Plaintiffs’ copyrights and exclusive

10

rights under copyright.

11

COUNT FOUR

12

(Inducement of Copyright Infringement)

13
14
15

77.

Plaintiffs repeat and reallege every allegation contained in paragraphs 1

through 76 as if fully set forth herein.
78.

As detailed above, users of the YTMP3 website are engaged in repeated

16

and pervasive infringement of Plaintiffs’ exclusive rights to reproduce and distribute

17

their copyrighted recordings.

18

79.

Defendants are liable under the Copyright Act for inducing the infringing

19

acts of the users of YTMP3. Defendants operate the YTMP3 website with the

20

objective of promoting its use to infringe Plaintiffs’ copyrights. In addition,

21

Defendants have failed to take any meaningful action to prevent the widespread and

22

rapidly growing infringement by their users and in fact have taken affirmative steps to

23

encourage, promote, and assist infringement by their users.

24

80.

Defendants knowingly and intentionally induce, entice, persuade, and

25

cause users of the YTMP3 website to infringe Plaintiffs’ copyrights in their sound

26

recordings, including but not limited to those sound recordings listed in Exhibit A

27

hereto, in violation of Plaintiffs’ copyrights. Indeed, Defendants expressly promote to

28

users the ease with which their service copies audio files: “We will start to convert
18
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 20 of 26 Page ID #:20

1

the audiotrack of your videofile to mp3 as soon as you have submitted it and you will

2

be able to download it. Different from other services the whole conversion process

3

will be performed by our infrastructure and you only have to download the audio file

4

from our servers.”

5

81.

Through these activities, among others, Defendants knowingly and

6

intentionally take steps that are substantially certain to result in direct infringement of

7

Plaintiffs’ sound recordings, including but not limited to those sound recordings listed

8

in Exhibit A hereto, in violation of Plaintiffs’ copyrights.

9

82.

Despite their knowledge that infringing material is made available to

10

users by means of YTMP3, Defendants have failed to take reasonable steps to

11

minimize the infringing capabilities of the website.

12
13
14
15
16

83.

The infringement of Plaintiffs’ rights in each of their copyrighted sound

recordings constitutes a separate and distinct act of infringement.
84.

Defendants’ acts of infringement are willful, intentional, and purposeful,

in disregard of and indifferent to the rights of Plaintiffs.
85.

As a direct and proximate result of Defendants’ infringement of

17

Plaintiffs’ copyrights and exclusive rights under copyright, Plaintiffs are entitled to

18

the maximum statutory damages, pursuant to 17 U.S.C. § 504(c), in the amount of

19

$150,000 with respect to each work infringed, or such other amounts as may be proper

20

under 17 U.S.C. § 504(c). In the alternative, at Plaintiffs’ election pursuant to 17

21

U.S.C. § 504(b), Plaintiffs are entitled to their actual damages, including Defendants’

22

profits from infringement, in amounts to be proven at trial.

23
24
25

86.

Plaintiffs are entitled to their costs, including reasonable attorneys’ fees,

pursuant to 17 U.S.C. § 505.
87.

Defendants’ conduct is causing, and, unless enjoined by this Court, will

26

continue to cause Plaintiffs great and irreparable injury that cannot fully be

27

compensated or measured in money. Plaintiffs have no adequate remedy at law.

28

Pursuant to 17 U.S.C. § 502, Plaintiffs are entitled to a preliminary injunction and a
19
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 21 of 26 Page ID #:21

1

permanent injunction prohibiting infringement of Plaintiffs’ copyrights and exclusive

2

rights under copyright.

3

COUNT FIVE

4

(Circumvention of Technological Measures)

5
6
7

88.

Plaintiffs repeat and reallege every allegation contained in paragraphs 1

through 87 as if fully set forth herein.
89.

On information and belief, the YTMP3 service circumvents technological

8

measures that YouTube has implemented to effectively control access to and prevent

9

copying of works protected under the Copyright Act, in violation of 17 U.S.C.

10

§ 1201(a). More specifically, Defendants’ service descrambles a scrambled work,

11

decrypts an encrypted work, or otherwise avoids, bypasses, removes, deactivates, or

12

impairs a technological measure without the authority of Plaintiffs or YouTube.

13

90.

Defendants own, operate, provide, and offer to the public a service,

14

YTMP3, which is primarily designed for the purpose of circumventing protection

15

afforded by a technological measure, implemented by YouTube, that effectively

16

protects the rights of Plaintiffs under the Copyright Act in sound recordings including

17

but not limited to those listed in Exhibit A hereto, in violation of 17 U.S.C.

18

§ 1201(b)(1)(A).

19

91.

Defendants own, operate, provide, and offer to the public a service,

20

YTMP3, which has only a limited commercially significant purpose or use other than

21

to circumvent protection afforded by a technological measure, implemented by

22

YouTube, that effectively protects the rights of Plaintiffs under the Copyright Act in

23

sound recordings including but not limited to those listed in Exhibit A hereto, in

24

violation of 17 U.S.C. § 1201(b)(1)(B).

25

92.

Defendants own, operate, provide, and offer to the public a service,

26

YTMP3, which is marketed by Defendants, and with Defendants’ knowledge, for use

27

in circumventing protection afforded by a technological measure, implemented by

28

YouTube, that effectively protects the rights of Plaintiffs under the Copyright Act in
20
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 22 of 26 Page ID #:22

1

sound recordings including but not limited to those listed in Exhibit A hereto, in

2

violation of 17 U.S.C. § 1201(b)(1)(C).

3

93.

Plaintiffs have been injured by Defendants’ violations of 17 U.S.C.

4

§ 1201, including because Defendants’ violations have permitted or facilitated the

5

infringement of Plaintiffs’ copyrighted works as described more fully herein.

6
7
8
9

94.

Defendants’ conduct as described herein was and is willful, intentional,

and purposeful, in disregard of and indifferent to the rights of Plaintiffs.
95.

As a direct and proximate result of Defendants’ violations of 17 U.S.C.

§ 1201, Plaintiffs are entitled to the maximum statutory damages, pursuant to 17

10

U.S.C. § 1203(c)(3)(A), in the amount of $2,500 with respect to each act of

11

circumvention. In the alternative, at Plaintiffs’ election pursuant to 17 U.S.C.

12

§ 1203(c)(2), Plaintiffs are entitled to their actual damages, including Defendants’

13

profits from circumvention, in amounts to be proven at trial.

14
15
16

96.

Plaintiffs are entitled to their costs, including reasonable attorneys’ fees,

pursuant to 17 U.S.C. §§ 505 and 1203(b)(4), (5).
97.

Defendants’ conduct is causing, and, unless enjoined by this Court, will

17

continue to cause Plaintiffs great and irreparable injury that cannot fully be

18

compensated or measured in money. Plaintiffs have no adequate remedy at law.

19

Pursuant to 17 U.S.C. § 1203(b)(1), Plaintiffs are entitled to a preliminary injunction

20

and a permanent injunction prohibiting Defendants ongoing violation of the anti-

21

circumvention provisions of 17 U.S.C. § 1201.

22

WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:

23

(a)

24
25

for a declaration that Defendants, both directly and secondarily, willfully

infringe Plaintiffs’ copyrights;
(b)

for such equitable relief under Titles 17 and 28 as is necessary to prevent

26

or restrain infringement of Plaintiffs’ copyrights and circumvention of YouTube’s

27

technological measures that effectively control access to Plaintiffs’ copyrighted

28

works, including:
21
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 23 of 26 Page ID #:23

i.

1

a preliminary injunction and a permanent injunction requiring that

2

Defendants and their officers, agents, servants, employees, attorneys, and others in

3

active concert or participation with each or any of them, (a) cease infringing, or

4

causing, enabling, facilitating, encouraging, promoting and inducing or participating

5

in the infringement of, any of Plaintiffs’ copyrights protected by the Copyright Act,

6

whether now in existence or hereafter created; (b) cease circumventing, or causing,

7

enabling, facilitating, encouraging, promoting, and inducing or participating in the

8

circumvention of, any technological measure maintained by YouTube that effectively

9

controls access to Plaintiffs’ copyrighted works; and (c) surrender, and cease to use,

10

the domain name of www.youtube-mp3.org, and any variant thereof owned or

11

controlled by Defendants;

12

ii.

entry of an Order, pursuant to Sections 502 and 1203 of the

13

Copyright Act (17 U.S.C. §§ 502, 1203), 28 U.S.C. § 1651(a), and this Court’s

14

inherent equitable powers,
(A)

15

enjoining Defendants and all third parties with notice of the

16

Order, including any Web hosts, domain-name registrars, domain name registries, and

17

proxy or reverse proxy services, and their administrators, from facilitating access to

18

any or all domain names, URLs and websites (including, without limitation,

19

www.youtube-mp3.org) through which Defendants infringe Plaintiffs’ copyrights;
(B)

20

requiring domain name registries and/or registrars holding or

21

listing Defendants’ domain names and websites (including, without limitation,

22

www.youtube-mp3.org) through which Defendants infringe Plaintiffs’ copyrights to:

23

(a) disable access to www.youtube-mp3.org and any related domain names specified

24

by Plaintiffs through a registry hold or otherwise, and to make them inactive and non-

25

transferable, and (b) transfer Defendants’ domain names to a registrar to be appointed

26

by Plaintiffs to re-register the domain names in Plaintiffs’ names and under Plaintiffs’

27

ownership;

28
22
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 24 of 26 Page ID #:24

(C)

1

enjoining all third parties with notice of the Order from

2

maintaining, operating, or providing advertising, financial, technical, or other support

3

to YTMP3 and any other domain names, URLs, or websites through which

4

Defendants infringe Plaintiffs’ copyrights, including without limitation www.youtube-

5

mp3.org; and enjoining all third-party distributors of applications, toolbars or similar

6

software with notice of the Order from distributing any applications, toolbars, or

7

similar software applications that interoperate with any domain names, URLs, or

8

websites through which Defendants infringe Plaintiffs’ copyrights, including without

9

limitation www.youtube-mp3.org;

10

(c)

for statutory damages pursuant to 17 U.S.C. § 504(c), in the amount of

11

$150,000 per infringed work, arising from Defendants’ violations of Plaintiffs’ rights

12

under the Copyright Act or, in the alternative, at Plaintiffs’ election pursuant to 17

13

U.S.C. § 504(b), Plaintiffs’ actual damages, including Defendants’ profits from

14

infringement, in amounts to be proven at trial;

15

(d)

for statutory damages pursuant to 17 U.S.C. § 1203(c)(3)(A), in the

16

amount of $2,500 with respect to each act of circumvention or, in the alternative, at

17

Plaintiffs’ election pursuant to 17 U.S.C. § 1203(c)(2), Plaintiffs’ actual damages,

18

including Defendants’ profits from circumvention, in amounts to be proven at trial.

19
20
21

(e)

for Plaintiffs’ costs, including reasonable attorneys’ fees, pursuant to 17

U.S.C. §§ 505 and 1203(b)(4), (5) and otherwise;
(f)

for prejudgment and post-judgment interest; and

22
23
24
25
26
27
28
23
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 25 of 26 Page ID #:25

1

(g)

for such other relief as the Court may deem just and proper.

2
3
4
5
6
7
8

Dated: September 26, 2016

SIDLEY AUSTIN LLP
By: /s/ Rollin A. Ransom
Peter I. Ostroff
Rollin A. Ransom
Charlie J. Sarosy
Attorneys for Plaintiffs

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
24
COMPLAINT

 Case 2:16-cv-07210 Document 1 Filed 09/26/16 Page 26 of 26 Page ID #:26

1

DEMAND FOR JURY TRIAL

2

Pursuant to Local Rule 38-1 and Rule 38(b) of the Federal Rules of Civil

3
4
5

Procedure, Plaintiffs hereby demand a trial by jury.
Dated: September 26, 2016

SIDLEY AUSTIN LLP

6
7
8
9

By: /s/ Rollin A. Ransom
Peter I. Ostroff
Rollin A. Ransom
Charlie J. Sarosy
Attorneys for Plaintiffs

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
25
COMPLAINT

 Case 2:16-cv-O721O Document 1-1 Filed 09/26/16 Page 1 of 13 Page ID #:27

Exhibit A

Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 2 of 13 Page ID #:28

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

1.
2.
3.
4.
5.
6.

Arista Records LLC
Arista Records LLC
Arista Records LLC
Arista Records LLC
Arista Records LLC
Arista Records LLC

Anthony Hamilton
Avril Lavigne
Baby Bash
Babyface
Babyface
Diamond Rio

625-444
319-397
627-153
395-581
298-052
192-192

7.
8.
9.
10.
11.

Arista Records LLC
Arista Records LLC
Arista Records LLC
Arista Records LLC
Arista Records LLC

12.
13.

Arista Records LLC
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation

Isyss
Jennifer Hudson
Outkast
Paula DeAnda
Santana feat.
Michelle Branch
Sarah McLachlan
Brett Eldredge

The Point of it All
Complicated
Cyclone
Grown & Sexy
There She Goes
Love a Little
Stronger
Day & Night
Spotlight
Rosa Parks
Doing Too Much
The Game of Love
Wintersong
Bring You Back

399-074
751-747

Hunter Hayes

I Want Crazy

748-751

James Blunt

You're Beautiful

393-742

Jennifer Love
Hewitt
Lupe Fiasco

Cool With You

227-488

Paris, Tokyo

639-320

Quad City DJs

Space Jam

230-149

Simple Plan

Your Love Is A Lie

639-323

Skrillex

Recess

743-328

Sugar Ray

When It's Over

303-749

The Rembrandts

Show Me Your Love 121-483

Trans-Siberian
Orchestra
Collective Soul

This Is Who You Are 284-961

14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.

December

306-563
618-088
264-091
393-631
325-816

207-109

Exhibit A
Page 26

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 3 of 13 Page ID #:29

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation

Bruno Mars

It Will Rain

705-798

Bruno Mars

756-206

Charlie Puth feat.
Meghan Trainor
Charlie Puth

Locked Out Of
Heaven
When I Was Your
Man
Marvin Gaye
One Call Away

30.

Atlantic Recording
Corporation

Charlie Puth feat.
Selena Gomez

We Don't Talk
Anymore

App. No. 13197808686

31.

Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation

Christina Perri

Human

DLOW

Do It Like Me

Flo Rida feat. Sage
The Gemini &
Lookas
Flo Rida

GDFR

App. No. 11832807177
App No. 13868145511
768-651

Good Feeling

754-532

Galantis

No Money

Galantis

Peanut Butter Jelly

App No. 13872657591
773-121

Galantis

Runaway (U & I)

773-121

Kevin Gates

La Familia

Melanie Martinez

Alphabet Boy

Melanie Martinez

Carousel

Melanie Martinez

Pity Party

App. No. 13217748591
App. No. 12923640761
App. No. 12923640761
App. No. 12923640761

25.
26.
27.
28.
29.

32.
33.

34.
35.
36.
37.
38.
39.
40.
41.

Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation

Bruno Mars

2

756-206
App. No. 12830804621
App. No. 13197808686

Exhibit A
Page 27

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 4 of 13 Page ID #:30

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

42.

Atlantic Recording
Corporation

Post To Be

43.

Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation

Omarion feat. Chris
Brown & Jhene
Aiko
Skillet

Hero

Wiz Khalifa

Black and Yellow

App. No. 13875879278;14021282474
657-156; 657152
703-969

Wiz Khalifa feat.
Charlie Puth
Wiz Khalifa

See You Again

768-651

We Dem Boyz

Brandy

Afrodisiac

Kevin Gates

2 Phones

Kevin Gates

Really Really

50.

Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Capitol Records, LLC

App. No. 11832807574;
App. No. 11748505302
370-673

Darius Rucker

51.
52.

Capitol Records, LLC
Capitol Records, LLC

Katy Perry
Keith Urban

53.
54.

Capitol Records, LLC
Capitol Records, LLC

Norah Jones
Darius Rucker

55.

Capitol Records, LLC

Eric Church

56.
57.
58.
59.

Capitol Records, LLC
Capitol Records, LLC
Capitol Records, LLC
Capitol Records, LLC.

Katy Perry
Lady Antebellum
The Decemberists
Lady Antebellum

60.
61.

Capitol Records, LLC.
Elektra Entertainment
Group Inc.

Lady Antebellum
Alana Davis

History in the
Making
Hot N Cold
Only You Can Love
Me This Way
Chasing Pirates
Don’t Think I Don’t
Think About It
Love Your Love The
Most
Teenage Dream
American Honey
January Hymn
Lookin' For A Good
Time
Need You Now
32 Flavors

44.
45.
46.

47.
48.
49.

3

App. No. 13217748591
App. No. 13217748591
651-366
638-214
656-713
636-557
651-367
656-709
662-267
644-544
671-440
656-386
644-543
245-201

Exhibit A
Page 28

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 5 of 13 Page ID #:31

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.

Bjork

Joga

245-199

Bryan White

So Much for
Pretending
Are You Gonna Be
My Girl?
Get Ur Freak On

227-463

252-365

Nada Surf
Natalie Merchant

Life Is Sweet

255-044

The Format

On Your Porch

343-055

Third Eye Blind

Never Let You Go

278-241

Bruno Mars

Grenade

671-062

Bruno Mars

671-062

Bruno Mars

Just the Way You
Are
Runaway Baby

671-062

Bruno Mars

The Lazy Song

671-062

75.
76.
77.

Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Elektra Entertainment
Group Inc.
Fueled By Ramen, LLC
Kemosabe Records LLC
LaFace Records LLC

God Moving Over
The Face of the
Waters
Popular

Stressed Out
Die Young
Get Up

772-681
715-271
388-894

78.
79.

LaFace Records LLC
LaFace Records LLC

Twenty One Pilots
Ke$ha
Ciara feat.
Chamillionaire
Donell Jones
Kelis

400-094
395-929

80.
81.
82.
83.

LaFace Records LLC
LaFace Records LLC
LaFace Records LLC
LaFace Records LLC

Outkast
P!nk
P!nk
TLC

My Apology
What's That Right
There
Jazzy Belle
So What
Sober
Creep

62.
63.
64.
65.
66.

67.
68.
69.
70.
71.
72.
73.
74.

Jet
Missy Elliott
Moby

4

343-668
297-686

225-933

233-296
619-959
619-959
198-743
Exhibit A
Page 29

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 6 of 13 Page ID #:32

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

84.

LaFace Records LLC

Toni Braxton

287-194

85.
86.

LaFace Records LLC
LaFace Records LLC

Usher
Usher

87.
88.

LaFace Records LLC
LaFace Records LLC

89.
90.
91.

Nonesuch Records Inc.
Nonesuch Records Inc.
Sony Music Entertainment

Marion Barfs
Slow Dance
Say Something

303-613
300-332
736-234

92.
93.
94.
95.
96.
97.
98.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

Everyday
F**kin' Problems
Shower
XO
Partition
River Bank
Pretty Girls

768-267
716-229
760-239
747-291
747-291
743-012
758-502

99.
100.
101.
102.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

Usher
Usher feat. Young
Jeezy
Clint Mansell
Bill Frisell
A Great Big World
& Christina Aguilera
A$AP Rocky
A$AP Rocky
Becky G
Beyoncé
Beyoncé
Brad Paisley
Britney Spears &
Iggy Azalea
Calvin Harris
Calvin Harris
Cam
Carrie Underwood

He Wasn't Man
Enough
Moving Mountains
One Day You'll Be
Mine
Think of You
Love In This Club

Pray To God
Summer
Burning House
Something In the
Water
Loyal
New Flame

763-016
763-015
761-101
752-448

103. Sony Music Entertainment
104. Sony Music Entertainment

105.
106.
107.
108.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

109. Sony Music Entertainment
110. Sony Music Entertainment
111. Sony Music Entertainment

Chris Brown
Chris Brown, feat.
Usher and Rick
Ross
Ciara
Daft Punk
Ella Henderson
Elle King
Elle King
Fifth Harmony
Fifth Harmony

5

Body Party
Get Lucky
Ghost
America's
Sweetheart
Ex's & Oh's
Sledgehammer
Worth It

620-940
257-730
200-154
620-940

760-918
760-917

724-526
725-802
766-237
766-256
766-187
768-357
768-360
Exhibit A
Page 30

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 7 of 13 Page ID #:33

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

112.
113.
114.
115.
116.
117.
118.
119.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

Make A Move
Take Me To Church
Beachin'
All of Me
Catch My Breath
Heartbeat Song
American Kids
Show Me

734-390
763-599
737-050
732-356
714-019
765-819
744-302
742-549

120.
121.
122.
123.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

Rude
All About That Bass
Lips Are Movin
Like I'm Gonna Lose
You
Adorn
Smile
We Can't Stop
Platinum
Smokin' and
Drinkin'
Somethin' Bad

763-612
758-102
766-271
766-270

124.
125.
126.
127.
128.

Gavin DeGraw
Hozier
Jake Owen
John Legend
Kelly Clarkson
Kelly Clarkson
Kenny Chesney
Kid Ink, feat. Chris
Brown
Magic!
Meghan Trainor
Meghan Trainor
Meghan Trainor,
feat. John Legend
Miguel
Mikky Ekko
Miley Cyrus
Miranda Lambert
Miranda Lambert

Classic
Troublemaker
Best Song Ever
Story of My Life
Just Give Me A
Reason
Try
Feel This Moment
Timber
Time of Our Lives
Fight Song
Can't Remember To
Forget You
Chandelier

754-326
727-210
737-314
740-364
709-056

129. Sony Music Entertainment
130.
131.
132.
133.
134.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

Miranda Lambert &
Carrie Underwood
MKTO
Olly Murs
One Direction
One Direction
P!nk

135.
136.
137.
138.
139.
140.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

P!nk
Pitbull
Pitbull
Pitbull
Rachel Platten
Shakira

141. Sony Music Entertainment

Sia

6

709-268
769-228
726-503
753-655
753-655
753-655

709-056
714-643
737-322
763-598
758-820
756-301
756-331

Exhibit A
Page 31

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 8 of 13 Page ID #:34

Plaintiff

142. Sony Music Entertainment
143. Sony Music Entertainment
144.
145.
146.
147.
148.
149.
150.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment

151. Sony Music Entertainment

Artist

Song Title

SR No. (or
App. No.
where
indicated)

The
Neighbourhood
The
Neighbourhood
Walk The Moon
Beyoncé
Chris Brown
Christina Aguilera
Five For Fighting
Justin Timberlake
Martika

Afraid

729-095

Sweater Weather

729-095

Shut Up and Dance
***Flawless
Turn Up the Music
Ain't No Other Man
100 Years
Mirrors
Love... Thy Will Be
Done
International Love

764-108
747-291
711-816
719-409
698-020
736-613
135-270

Rain Over Me

681-904

No Ordinary Love
Beautiful Girls
Best Love Song

183-731
730-825
706-396
714-751
747-291
714-855
735-241
727-192
711-049

156. Sony Music Entertainment

Pitbull feat. Chris
Brown
Pitbull feat. Marc
Anthony
Sade
Sean Kingston
T-Pain feat. Chris
Brown
Alicia Keys

157.
158.
159.
160.
161.

Beyoncé
Justin Timberlake
Miley Cyrus
Sara Bareilles
Chayanne

Girl On Fire
(Inferno Version)
Drunk In Love
Suit & Tie
Wrecking Ball
Brave
Salome

Ednita Nazario

Sin Querer

727-222

Grupo Niche

Una Aventura

727-175

Juan Gabriel

Abrazame Muy
Fuerte
Solo Busco Amor

714-818

152. Sony Music Entertainment
153. Sony Music Entertainment
154. Sony Music Entertainment
155. Sony Music Entertainment

162.
163.
164.
165.

Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
Sony Music Entertainment
US Latin LLC
Sony Music Entertainment
US Latin LLC
Sony Music Entertainment
US Latin LLC
Sony Music Entertainment
US Latin LLC
Sony Music Entertainment
US Latin LLC

Limi-T21

7

681-904

740-358

Exhibit A
Page 32

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 9 of 13 Page ID #:35

Plaintiff

166. Sony Music Entertainment
US Latin LLC
167. Sony Music Entertainment
US Latin LLC
168. Sony Music Entertainment
US Latin LLC
169. UMG Recordings, Inc.
170. UMG Recordings, Inc.
171. UMG Recordings, Inc.
172. UMG Recordings, Inc.
173. UMG Recordings, Inc.
174. UMG Recordings, Inc.
175. UMG Recordings, Inc.
176. UMG Recordings, Inc.
177. UMG Recordings, Inc.
178.
179.
180.
181.
182.
183.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

Artist

Song Title

SR No. (or
App. No.
where
indicated)

Los Buitres De
Culiacan Sinaloa
Marc Anthony

Borracho De Amor

728-337

Cambio De Piel

727-217

Marc Anthony

Vivir Mi Vida

727-217

Sam Hunt
Owl City
Weezer
James Bay
10 Years
3 Doors Down
AFI
American Authors
Babyface

Take your Time
My Everything
Back To The Shack
Hold Back The River
Shoot It Out
It's Not My Time
Medicate
Believer
I Hope That You're
Okay
Pioneer
Let Me Down Easy
Because We Can
I'm a Star
I Do
Dutty Love

763-130
769-042
762-642
766-215
658-821
610-760
703-778
720-637
746-037

I Don't Care
It'z Just What We
Do
Thinkin Bout You
Every Storm (Runs
Out Of Rain)
Love Remains The
Same
Without You
Cocoa Butter
(What Is) Love?
La Luz
Merry Go 'Round
Applause

620-007
708-128

186. UMG Recordings, Inc.
187. UMG Recordings, Inc.

The Band Perry
Billy Currington
Bon Jovi
Chrisette Michele
Colbie Caillat
Don Omar feat.
Natti Natasha
Fall Out Boy
Florida Georgia
Line
Frank Ocean
Gary Allan

188. UMG Recordings, Inc.

Gavin Rossdale

189.
190.
191.
192.
193.
194.

Hinder
India. Arie
Jennifer Lopez
Juanes
Kacey Musgraves
Lady Gaga

184. UMG Recordings, Inc.
185. UMG Recordings, Inc.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

8

718-182
664-523
716-425
670-162
674-233
696-141

699-626
711-926
613-599
619-215
721-176
676-979
736-863
711-865
729-225
Exhibit A
Page 33

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 10 of 13 Page ID #:36

195.
196.
197.
198.
199.
200.

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

Lady Gaga
Mary J. Blige
Ne-Yo
Nelly
Neon Trees
Neon Trees

Born This Way
The One
Closer
Just a Dream
Animal
Sleeping With A
Friend
Single

671-815
636-307
612-632
662-586
647-020
748-665

201. UMG Recordings, Inc.
202. UMG Recordings, Inc.
203. UMG Recordings, Inc.
204. UMG Recordings, Inc.
205. UMG Recordings, Inc.
206.
207.
208.
209.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

210.
211.
212.
213.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

214.
215.
216.
217.
218.
219.
220.
221.
222.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

223. UMG Recordings, Inc.

New Kids On The
Block
Nikki Yanofsky
Nirvana
Owl City
Rick Ross feat.
Drake
Rise Against
Saliva
Shiny Toy Guns
Skylar Grey feat.
Eminem
Sugarland
The Bravery
The Dream
Toni Braxton &
Babyface
will.i.am
Zedd
2 Chainz
Alessia Cara
August Alsina
Jeremih
Jeremih
Lil Durk
Logic
Ludacris

9

619-905

Take The "A" Train 650-850
You Know You're
320-325
Right
Fireflies
628-227
Aston Martin Music 656-701
Audience Of One
Family Reunion
Ghost Town
C'mon Let Me Ride

617-587
622-778
619-193
715-320

Already Gone
Slow Poison
Sweat It Out
Roller Coaster

614-064
636-199
628-545
746-038

Scream & Shout
Clarity
Watch Out
Here
Hip Hop
Don't Tell 'Em
Planez
500 Homicides
Under Pressure
(Deluxe)
Call Ya Bluff
(Explicit)

712-989
709-927
770-658
764-950
764-632
745-075
757-030
768-591
760-985
768-222

Exhibit A
Page 34

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 11 of 13 Page ID #:37

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

Twist My Fingaz
Diamonds

770-185
755-956

226. UMG Recordings, Inc.
227. UMG Recordings, Inc.

YG
Common feat. Big
Sean
Jhene Aiko
Calibre 50

758-150
753-505

228.
229.
230.
231.
232.
233.
234.

Gwen Stefani
K Camp
Maroon 5
Rise Against
Selena Gomez
Yelawolf
Zedd

Lyin King
Contigo (Walmart
Deluxe Edition)
Baby Don't Lie
Comfortable
Animals
The Black Market
Good For You
Till It's Gone
I Want You To
Know
Papercut

224. UMG Recordings, Inc.
225. UMG Recordings, Inc.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

235. UMG Recordings, Inc.
236.
237.
238.
239.
240.
241.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

Zedd feat. Troye
Sivan
BORNS
Maroon 5
American Authors
Brandon Flowers
Fall Out Boy
Gaslight Anthem

242. UMG Recordings, Inc.
243. UMG Recordings, Inc.

Mike Posner
Neon Trees

244.
245.
246.
247.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

Shawn Mendes
Timeflies
Shawn Mendes
Chino & Nacho
feat. Farruko

248.
249.
250.
251.
252.

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

David Nail
Kip Moore
Chris Stapleton
Easton Corbin
Kacey Musgraves
10

Electric Love
unkiss me
Go Big Or Go Home
Can't Deny My Love
Uma Thurman
Get Hurt (Best Buy
Deluxe)
I Took A Pill In Ibiza
Songs I Can't Listen
To
Stitches
NSFW
Life Of The Party
Me Voy
Enamorando
(Remix)
Night's On Fire
I'm To Blame
Traveller
About To Get Real
Dime Store Cowgirl

752-187
767-416
763-862
753-236
768-302
750-133
759-731
768-812
753-780
763-864
765-493
768-372
766-286
755-607
768-540
764-637
769-732
759-530
769-727
762-486

770-024
757-652
768-426
770-356
769-033
Exhibit A
Page 35

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 12 of 13 Page ID #:38

Plaintiff

Artist

Song Title

SR No. (or
App. No.
where
indicated)

253. UMG Recordings, Inc.
254. UMG Recordings, Inc.

Kacey Musgraves
Kem

769-034
759-369

255. UMG Recordings, Inc.

Ne-Yo

256. UMG Recordings, Inc.

Ariana Grande

257. UMG Recordings, Inc.
258. UMG Recordings, Inc.
259. UMG Recordings, Inc.

Florida Georgia
Line
James Bay
Mat Kearney

260. UMG Recordings, Inc.
261. UMG Recordings, Inc.

Sage The Gemini
Diana Krall

262.
263.
264.
265.
266.

Brandon Flowers
Carly Rae Jepsen
Cold War Kids
Far East Movement
Neon Trees

Pageant Material
Promise To Love
(Target Deluxe)
Non-Fiction (Target
Deluxe)
My Everything
(Target Deluxe)
Anything Goes
(Target Deluxe)
Let It Go EP
Just Kids (Target
Version)
Good Thing
Don't Dream It's
Over
Swallow It
Call Me Maybe
Louder Than Ever
Like A G6
Sleeping With A
Friend
No Broken Hearts

UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.
UMG Recordings, Inc.

267. Warner Bros. Records Inc.
268.
269.
270.
271.
272.
273.

Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.

274. Warner Bros. Records Inc.
275.
276.
277.
278.

Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.

Bebe Rexha feat.
Nicki Minaj
Jason Derulo
Jason Derulo
Jason Derulo
Steve Jablonsky
Faith Hill
Frankie Ballard
Gucci Mane &
Waka Flocka Flame
Idina Menzel
Jason Derulo
Linkin Park
Mike Jones

11

Get Ugly
If It Ain't Love
Want To Want Me
Arrival To Earth
Cry
Tell Me You Get
Lonely
Ferrari Boyz
Defying Gravity
Whatcha Say
New Divide
Back Then

766-424
757-296
760-515
750-586
765-627
765-498
766-058
661-083
696-123
695-851
658-290
737-412
App. No. 13978251246
774-211
775-353
774-211
630-797
321-377
694-426
693-090
611-146
685-175
656-468
614-461

Exhibit A
Page 36

 Case 2:16-cv-07210 Document 1-1 Filed 09/26/16 Page 13 of 13 Page ID #:39

Plaintiff

279. Warner Bros. Records Inc.
280.
281.
282.
283.
284.
285.
286.
287.
288.
289.

Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Bros. Records Inc.
Warner Music Latina Inc.
Warner Music Latina Inc.
Warner Music Latina Inc.
Warner Music Latina Inc.

Artist

Song Title

SR No. (or
App. No.
where
indicated)

Red Hot Chili
Peppers
Tegan and Sara
The Goo Goo Dolls
Wiz Khalifa
Fleetwood Mac
Neil Young
Madonna
Alex Ubago
Alexander Acha
Benny Ibarra
Caballo Dorado

The Adventures of
Rain Dance Maggie
Closer
Better Days
Say Yeah
Little Lies
Four Strong Winds
Like A Virgin
Dame Tu Aire
Te Amo
Cielo
No Rompas Mi
Corazon
No Te Veo
Si No Te Hubieras
Ido
The Sound Of
Silence
Get A Hold

693-084

290. Warner Music Latina Inc.
291. Warner Music Latina Inc.

Casa De Leones
Mana

292. WEA International Inc.

Disturbed

293. Zomba Recording LLC
294. Zomba Recording LLC

A Tribe Called
Quest
Aaliyah

295. Zomba Recording LLC
296. Zomba Recording LLC
297. Zomba Recording LLC

Aaron Carter
Backstreet Boys
Backstreet Boys

298. Zomba Recording LLC

Britney Spears

299.
300.
301.
302.
303.
304.

Justin Timberlake
NSYNC
Paradise Lost
R. Kelly
R. Kelly
Usher feat. Shyne,
Kanye West, &
Twista

Zomba Recording LLC
Zomba Recording LLC
Zomba Recording LLC
Zomba Recording LLC
Zomba Recording LLC
Zomba Recording LLC

12

Age Ain't Nothing
But A Number
I Want Candy
All I Have To Give
Quit Playing Games
(With My Heart)
Baby, One More
Time
Cry Me A River
Pop
One Second
I Believe I Can Fly
Bump N' Grind
Confessions Part II:
Remix

719-499
610-395
644-167
080-985
004-340
059-442
643-984
654-572
326-700
394-990
611-678
654-577
775-134
218-032
293-843
307-037
260-873
250-678
300-848
356-704
302-433
250-659
231-941
288-094
359-122

Exhibit A
Page 37