Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 1 of 15 Page ID #:1 1 2 3 4 5 6 7 8 9 10 11 12 DANIEL M. PETROCELLI (S.B. # 97802) dpetrocelli@omm.com DAVID MARROSO (S.B. # 211655) dmarroso@omm.com STEPHEN J. MCINTYRE (S.B. # 274481) smcintyre@omm.com O’MELVENY & MYERS LLP 1999 Avenue of the Stars Los Angeles, California 90067-6035 Telephone: (310) 553-6700 Facsimile: (310) 246-6779 KATRINA M. ROBSON (S.B. # 229835) krobson@omm.com O’MELVENY & MYERS LLP 1625 Eye Street, NW Washington, D.C. 20006-4001 Telephone: (202) 383-5300 Facsimile: (202) 383-5414 Attorneys for Plaintiff Global Music Rights, LLC 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 17 18 19 20 GLOBAL MUSIC RIGHTS, LLC, a Delaware limited liability company, Plaintiff, v. Case No. __________ COMPLAINT FOR COPYRIGHT INFRINGEMENT (17 U.S.C. § 101) ENTRAVISION COMMUNICATIONS JURY DEMAND CORPORATION., a Delaware corporation, 21 Defendant. 22 23 24 25 26 27 28 Plaintiff Global Music Rights, LLC (“Global Music Rights”), by and through its attorneys, states the following as its Complaint against Entravision Communications Corporation (“Entravision”): /// /// COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 2 of 15 Page ID #:2 1 2 PRELIMINARY STATEMENT 1. Musical compositions are intellectual property and, in the case of 3 “hit” compositions, highly valuable intellectual property. United States law grants 4 copyright owners certain exclusive rights to that property, including the right to 5 authorize others to perform publicly their music. See 17 U.S.C. § 106. 6 2. Terrestrial radio companies perform musical compositions to drive 7 listenership which, in turn, drives advertising and other forms of revenue. Before 8 performing publicly copyrighted compositions, however, terrestrial radio 9 companies must obtain authorization to do so. 10 3. When a terrestrial radio company performs a musical composition 11 without obtaining the necessary advanced permission, it acts in violation of federal 12 copyright laws. When that terrestrial radio company had been offered five 13 separate opportunities to license the public performances, declined all of the 14 opportunities, paid nothing for the performances, and still performed hundreds of 15 compositions 10,000 thousand times, then it acted willfully in violation of federal 16 copyright laws. 17 4. Defendant Entravision is a willful copyright infringer. By way of this 18 Complaint, plaintiff Global Music Rights seeks to hold Entravision accountable 19 for its willful infringements. 20 21 JURISDICTION AND VENUE 5. This is a suit for copyright infringement under the United States 22 Copyright Act of 1976, as amended, 17 U.S.C. § 101, et seq. (the “Copyright 23 Act”). This Court has jurisdiction pursuant to 28 U.S.C. § 1331 and 28 U.S.C. § 24 1338(a). 25 6. This Court has personal jurisdiction over Entravision because, among 26 other things, Entravision’s principal place of business is in the State of California 27 and in this judicial district, Entravision regularly conducts or has conducted 28 business in the State of California and in this judicial district, and Entravision has -2- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 3 of 15 Page ID #:3 1 caused injury to Global Music Rights within the State of California and in this 2 judicial district. 3 7. 4 Venue is proper in this judicial district pursuant to 28 U.S.C. § 1400(a), and 28 U.S.C. § 1391(b). 5 6 PARTIES 8. Performance Rights Organizations, or “PROs” as they are known in 7 the music industry, represent songwriters and publishers in licensing the public 8 performances of copyrighted music. For decades, there were only three PROs— 9 ASCAP, BMI, and SESAC—which collectively represented (and continue to 10 represent) more than tens of thousands of composers and 20 million compositions 11 that are available for public performance. 12 9. Founded in 2013, Global Music Rights is the fourth PRO overall— 13 and the first new PRO in the United States in more than 70 years. Global Music 14 Rights represents an elite roster of roughly 80 premium songwriters and associated 15 publishers, including Bruce Springsteen, Bruno Mars, Drake, Pharrell Williams, 16 John Lennon, and The Eagles, in licensing the public performances of their 17 copyrighted music (the “Global Music Rights Compositions”). These songwriters 18 and publishers have granted Global Music Rights the right to license to others the 19 Global Music Rights Compositions. Global Music Rights has the right to license 20 their works, collect applicable license fees for performances of those works, remit 21 payments, and enforce the intellectual property rights in court if necessary. 22 10. Global Music Rights is a Delaware limited liability company with its 23 principal place of business at 1100 Glendon Avenue, Suite 2000, Los Angeles, 24 California 90024. 25 26 27 28 11. Entravision is a Delaware corporation with its principal place of business at 2425 Olympic Boulevard, Santa Monica, California 90404. 12. Entravision is a sophisticated media company that operates scores of radio stations across the United States and reports annual revenues of nearly $300 -3- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 4 of 15 Page ID #:4 1 million. During the relevant period in this case, Entravision owned radio stations 2 including but not limited to: KDLD-FM, KLYY-FM, KSSE-FM, KFRQ-FM, 3 KOFX-FM, KXKL-FM, KIMN-FM, and KVLY-FM. 4 13. Some of Entravision’s radio stations perform Global Music Rights 5 Compositions and, since at least 2017, these Entravision stations have performed 6 Global Music Rights Compositions without obtaining a license in violation of 7 copyright laws. 8 THE COPYRIGHTED WORKS 9 14. Beginning as late as January 1, 2017 (and possibly earlier) and 10 continuing through the present, radio stations owned by Entravision have publicly 11 performed Global Music Rights Compositions without obtaining a license and 12 without paying for their performances. Exhibit A identifies the Global Music 13 Rights Compositions that are currently the subject of this lawsuit. Radio stations 14 owned by Entravision performed publicly these Global Music Rights 15 Compositions more than 10,000 times.1 16 15. Each of the Global Music Rights Compositions listed on Exhibit A 17 was registered with the United States Copyright Office and complied in all 18 respects with the requirements of the Copyright Act. Certificates of Registration 19 have been granted for each of those works. 20 16. The owners of each work listed on Exhibit A each possess public 21 performance rights in the Global Music Rights Compositions. Those owners have 22 granted to Global Music Rights the exclusive third-party right to license to others 23 the right to perform publicly the Global Music Rights Compositions. 24 17. For each infringement listed on Exhibit A, Entravision and/or radio 25 stations owned by Entravision did not have a valid license, authorization, 26 permission, or consent to perform publicly the Global Music Rights Compositions. 27 28 1 Global Music Rights reserves the right to amend its complaint based on further investigation and/or information learned in discovery. -4- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 5 of 15 Page ID #:5 1 18. Also, radio stations owned by Entravision may have performed 2 publicly without authorization and, therefore, intentionally infringed other Global 3 Music Rights Compositions that are not identified on Exhibit A and for which they 4 may be liable under the Copyright Act. 5 19. Entravision’s infringement of each Global Music Rights Composition 6 is governed by the same legal rules and involves similar facts and, thus, litigating 7 them together promotes the administration of justice and avoids a multiplicity of 8 separate, similar actions against Entravision. 9 10 ENTRAVISION’S INTENTIONAL INFRINGEMENT 20. Entravision-owned radio stations have infringed the Global Music 11 Rights Compositions thousands of times. Entravision had the legal obligation to 12 ensure that its radio stations obtained authorization to perform the Global Music 13 Rights Compositions before the stations publicly performed the Global Music 14 Rights Compositions. Entravision did not obtain the necessary authorization, 15 making the calculated decision instead to infringe freely and hope Global Music 16 Rights would either not find out or not enforce its rights. 17 21. Entravision is aware and knows that the public performance of 18 copyrighted musical compositions on its radio stations without a valid license 19 would constitute copyright infringement. According to its website, “Entravision 20 Communications Corporation is a leading global media company” with an 21 “expansive portfolio . . . comprised of television, radio, and digital properties and 22 data analytics services.” See http://www.entravision.com/ 23 investor-info/ (last accessed on October 2, 2019). Entravision “owns and operates 24 49 . . . radio stations featuring nationally recognized talent.” Id. As a media 25 company of this size, Entravision is well-versed in matters of licensing and 26 copyright infringement and understands fully its obligation to obtain a 27 performance rights license before performing copyrighted works on its radio 28 stations. -5- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 6 of 15 Page ID #:6 1 22. Entravision is aware and knows that the public performance of the 2 Global Music Rights Compositions required prior authorization and that publicly 3 performing the Global Music Rights Compositions without prior authorization 4 would constitute copyright infringement. Global Music Rights’s entrance into the 5 PRO market in 2013 was headline news in the music industry and was noted in 6 multiple national publications. See, e.g., Ben Sisario, Irving Azoff to Start New 7 Entertainment Business, NEW YORK TIMES, Sept. 4, 2013.2 In the years 8 following Global Music Rights’s founding, prominent music industry publications 9 have regularly published articles tracking the movement of artists from other 10 PROs to Global Music Rights. See, e.g., Ed Christman, Pharrell to Leave ASCAP 11 for Irving and Grimmet’s Global Music Rights, BILLBOARD MAGAZINE, Jul. 12 25, 2014;3 Ed Christman, Prince Estate Taps Azoff’s Global Music Rights to 13 Oversee Artist’s Entire Catalog, BILLBOARD MAGAZINE, Jan. 11, 2017.4 14 Another PRO, BMI, posted a notice on its website notifying licensees that a 15 number of songwriters previously affiliated with BMI had joined Global Music 16 Rights and that a license from BMI would no longer permit the public 17 performance of those songwriters’ compositions. 18 23. Entravision made a willful, calculated, and strategic decision not to 19 obtain prior authorization to perform publicly the Global Music Rights 20 Compositions and hope that Global Music Rights would not find out or would 21 choose not to enforce its rights. On multiple occasions between January 2017 and 22 March 2019, Global Music Rights offered Entravision the opportunity to license 23 24 25 26 27 28 2 Available at https://www.nytimes.com/2013/09/05/business/media/irving-azoffstarts-new-entertainment-business.html (last accessed October 2, 2019). 3 Available at https://www.billboard.com/articles/business/6188942 /pharrell-to-leave-ascap-for-irving-and-grimmets-global-music-rights (last accessed October 2, 2019). 4 Available at https://www.billboard.com/articles/business/7654288/prince-globalmusic-rights-gmr-performance-licensing-deal (last accessed October 2, 2019). -6- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 7 of 15 Page ID #:7 1 Global Music Rights Compositions for public performance and warned 2 Entravision that its stations were not authorized to perform publicly the Global 3 Music Rights Compositions unless Entravision secured and paid for a license: 4 a. The first written proposal from Global Music Rights to Entravision was 5 in January 2017. It stated: “Global Music Rights has agreed to offer a 9- 6 month . . . license to [Entravision] . . . If you choose to enter into this . . . 7 license, stations owned by Entravision Communications Corp . . . may 8 publicly perform Global Music Rights’s repertory . . . .” Entravision did 9 not respond, did not submit a signed license, and did not pay Global 10 11 Music Rights any money. b. In March 2017, Global Music Rights sent Entravision another 12 communication, stating: “We write to follow up on our attempts to 13 contact you concerning your radio station group and Global Music 14 Rights compositions. Global Music Rights offered [a] . . . license to 15 radio station groups seeking to use Global Music Rights compositions . . 16 . To date, we have not received a signed agreement or payment from 17 you. Accordingly, you are not authorized to perform Global Music 18 Rights compositions.” Entravision did not respond, did not submit a 19 signed license, and did not pay Global Music Rights any money. 20 c. In August 2017, Global Music Rights sent Entravision another 21 communication, stating: “Global Music Rights is . . . offering [a] 6- 22 month license . . . If you choose to enter into this . . . license, stations 23 owned by Entravision Communications Corp may publicly perform 24 Global Music Rights’s repertory.” Entravision did not respond, did not 25 submit a signed license, and did not pay Global Music Rights any 26 money. 27 28 d. In February 2018, Global Music Rights sent Entravision another communication, stating: “Global Music Rights is . . . offering [a] 6-7- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 8 of 15 Page ID #:8 1 month license . . . If you choose to enter into this . . . license, stations 2 owned by Entravision Communications Corp may publicly perform 3 Global Music Rights’s repertory.” Entravision did not respond, did not 4 submit a signed license, and did not pay Global Music Rights any 5 money. 6 e. In August 2018, Global Music Rights sent Entravision another 7 communication, stating: “Global Music Rights is . . . offering [a] 6- 8 month license . . . If you choose to enter into this . . . license, stations 9 owned by Entravision Communications Corp may publicly perform 10 Global Music Rights’s repertory.” Entravision did not respond, did not 11 submit a signed license, and did not pay Global Music Rights any 12 money. 13 f. In March 2019, Global Music Rights sent Entravision another 14 communication, stating: “Global Music Rights is . . . offering [a] 6- 15 month license . . . If you choose to enter into this . . . license, stations 16 owned by Entravision Communications Corp may publicly perform 17 Global Music Rights’s repertory.” Entravision did not respond, did not 18 submit a signed license, and did not pay Global Music Rights any 19 money. 20 24. Entravision did not respond to any of the communications and did not 21 obtain authorization to perform the Global Music Rights Compositions. 22 Nevertheless, stations owned by Entravision performed publicly more than 130 23 Global Music Rights Compositions, over 10,000 times, at a minimum. 24 25. The stations that performed the Global Music Rights Compositions 25 without authorization profited handsomely from the use of the intellectual 26 property. In each of 2017 and 2018 Entravision reported net revenues in excess of 27 $60 million for its radio stations. 28 -8- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 9 of 15 Page ID #:9 1 CLAIM FOR RELIEF 2 COUNT I 3 (Direct Copyright Infringement – Public Performance) 4 5 6 7 8 9 10 26. Global Music Rights incorporates herein by this reference each and every allegation contained in paragraphs 1 through 25 above. 27. The copyrights to the Global Music Rights Compositions have been registered with the United States Copyright Office. 28. Global Music Rights has the exclusive third-party right to authorize others to publicly perform the Global Music Rights Compositions. 29. Entravision has infringed the copyright interests in the Global Music 11 Rights Compositions by performing the Global Music Rights Compositions on its 12 radio stations without authorization, in violation of the Copyright Act, 17 U.S.C. 13 §§ 106 and 501. 14 30. Entravision’s acts of infringement are willful, intentional, purposeful, 15 and in disregard of and indifferent to the rights of Global Music Rights and those 16 of the songwriters it represents. 17 31. As a direct and proximate result of Entravision’s willful and 18 infringing uses of the Global Music Rights Compositions, Global Music Rights is 19 entitled to maximum statutory damages of $150,000 for each copyright infringed, 20 or actual damages and Entravision’s profits in amounts to be proven at trial, and/or 21 such other amount as may be proper under 17 U.S.C. § 504(c). 22 23 24 32. Global Music Rights is further entitled to recover its attorneys’ fees and costs pursuant to 17 U.S.C. § 505. 33. As a result of Entravision’s acts and conduct, Global Music Rights 25 has sustained and will continue to sustain substantial, immediate, and irreparable 26 injury, for which there is no adequate remedy at law. Global Music Rights is 27 informed and believes, and on that basis avers, that unless enjoined by this Court, 28 Entravision will continue to infringe Global Music Rights’s rights in the Global -9- COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 10 of 15 Page ID #:10 1 Music Rights Compositions. Global Music Rights is entitled to permanent 2 injunctive relief to restrain and enjoin Entravision’s continuing infringing conduct. 3 JURY DEMAND 4 34. Plaintiff demands trial by jury on all issues so triable. 5 6 7 8 9 10 PRAYER FOR RELIEF WHEREFORE, Global Music Rights requests that the Court enter judgment in its favor and against Entravision as follows: a) That Entravision has violated Section 501 of the Copyright Act (17 U.S.C. § 501); b) Require Entravision to pay maximum statutory damages in an amount 11 not less than $150,000 per Global Music Rights Composition as 12 permitted in 17 U.S.C. § 504(c), or pursuant to 17 U.S.C. § 504(b), 13 Global Music Rights’s actual damages plus Entravision’s profits from 14 infringement, in an amount to be proven at trial, and such further 15 damages as permitted by applicable law; 16 c) That Entravision, its agents, servants, employees, and all persons 17 acting under its permission and authority, be preliminarily and 18 permanently enjoined and restrained from infringing, in any manner, 19 the Global Music Rights Compositions, pursuant to 17 U.S.C. § 502; 20 21 22 d) That Entravision be ordered to pay costs, including reasonable attorneys’ fees, pursuant to 17 U.S.C. § 505; and e) Such other and further relief as the Court may deem just and proper. 23 24 25 26 27 28 - 10 - COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 11 of 15 Page ID #:11 1 2 3 Dated: October 3, 2019 Respectfully submitted, 4 5 By: /s/ Daniel M. Petrocelli______ 6 Daniel M. Petrocelli dpetrocelli@omm.com David Marroso dmarroso@omm.com Stephen J. McIntrye smcintyre@omm.com O’MELVENY & MYERS LLP 1999 Avenue of the Stars Los Angeles, California 90067 Telephone: (310) 553-6700 7 8 9 10 11 12 13 Katrina M. Robson (pro hac vice) krobson@omm.com O’MELVENY & MYERS LLP 1625 Eye Street, NW Washington, D.C. 20006-4001 Telephone: (202) 383-5300 14 15 16 17 18 19 Attorneys for Global Music Rights, LLC 20 21 22 23 24 25 26 27 28 - 11 - COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 12 of 15 Page ID #:12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT A GLOBAL MUSIC RIGHTS COMPOSITIONS INFRINGED BY ENTRAVISION No. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. Composition Title U.S. Copyright Registration Number CATCH MY FALL AGAINST THE WIND BEAUTIFUL LOSER FEEL LIKE A NUMBER FIRE DOWN BELOW FIRE LAKE HER STRUT HOLLYWOOD NIGHTS KATMANDU MAINSTREET NIGHT MOVES ROCK AND ROLL NEVER FORGETS STILL THE SAME SUNSPOT BABY TRAVELIN' MAN TURN THE PAGE (LIVE BULLET) WE'VE GOT TONITE YOU'LL ACCOMP'NY ME ROLL ME AWAY BORN TO RUN BLINDED BY THE LIGHT BORN IN THE U.S.A. BRILLIANT DISGUISE COVER ME DANCING IN THE DARK FIRE GLORY DAYS HUNGRY HEART I'M ON FIRE MY HOMETOWN PINK CADILLAC ROSALITA (COME OUT...) TENTH AVENUE FREEZE-OUT THE RIVER THUNDER ROAD TUNNEL OF LOVE SPIRIT IN THE NIGHT LIGHT OF DAY HUNGER STRIKE - 12 - PA0000214888 PA0000074189 EU0000565028 PA0000131458 PA0000135530 PA0000058403 PA0000074937 PA0000131455 EU0000565029 PA0000135529 PA0000135531 PA0000135532 PA0000044251 EU0000725043 EU0000565030 EU0000386404 PA0000131459 PAu000123327 PA0000170542 EU616322 EU0000376180 PAu000634797 PAu001023407 PAu000372038 PAu000610205 PA0000002445 PAu000634801 PAu000149052 PAu000634793 PAu000634798 PAu000497022 EU467944 EU616319 PAu000149051 EU616320 PAu001023402 EU376181 PA0001245565 PA0000563394 COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 13 of 15 Page ID #:13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 No. Composition Title 40. 41. SAY HELLO 2 HEAVEN DYSTOPIA 42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53. 54. 55. 56. 57. 58. 59. 60. 61. 62. 63. 64. 65. 66. 67. 68. 69. 70. 71. 72. 73. 74. 75. 76. 77. 78. 79. 80. 81. 82. RIDE THE LIGHTNING DESPERADO LAST RESORT LYIN' EYES ONE OF THESE NIGHTS TEQUILA SUNRISE THE LONG RUN BOYS OF SUMMER BETTER MAN JEREMY YELLOW LEDBETTER CAN'T DENY ME MIND YOUR MANNERS SIRENS ALIVE BLACK EVEN FLOW AM I SAVAGE? ATLAS, RISE! BATTERY HARDWIRED HARVESTER OF SORROW HIT THE LIGHTS HOLIER THAN THOU MOTH INTO FLAME NO LEAF CLOVER NOTHING ELSE MATTERS NOW THAT WE'RE DEAD ONE SAD BUT TRUE SEEK & DESTROY SPIT OUT THE BONE WHEREVER I MAY ROAM WHIPLASH JUMP IN THE FIRE DISPOSABLE HEROES ENTER SANDMAN ESCAPE FUEL HERO OF THE DAY KING NOTHING U.S. Copyright Registration Number PA0000563402 PA0002065923 PA0000260105 EU399849 PA0000045157 PA0000016335 PA0000016327 EP326574 PA0000046173 PA0000239432 PA0000663649 PA0000563408 PA0000756318 PA0002114397 PA0001860408 PA0001865642 PA0000563413 PA0000563412 PA0000544552 PA0002072154 PA0002071962 PA0000290088 PA0002042603 PA0000384985 PA0000309504 PA0000537294 PA0002071965 PA0000996438 PA0000537299 PA0002071964 PA0000384983 PA0000537293 PA0000309512 PA0002072339 PA0000537296 PA0000309509 PA0000309507 PA0000290084 PA0000537292 PA0000260103 PA0000879637 PA0001589182 PA0000803511 - 13 - COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 14 of 15 Page ID #:14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 No. 83. 84. 85. 86. 87. 88. 89. 90. 91. 92. 93. 94. 95. 96. 97. 98. 99. 100. 101. 102. 103. 104. 105. 106. 107. 108. 109. 110. 111. 112. 113. 114. 115. 116. 117. 118. 119. 120. 121. 122. 123. 124. 125. 126. Composition Title U.S. Copyright Registration Number OF WOLF AND MAN THE MEMORY REMAINS THE THING THAT SHOULD NOT BE THE UNFORGIVEN THROUGH THE NEVER TRAPPED UNDER ICE WELCOME HOME (SANITARIUM) BREAK IT UP FEELS LIKE THE FIRST TIME I DON'T WANT TO LIVE W/O YOU I WANT TO KNOW WHAT LOVE IS URGENT FACE THE FACE LET MY LOVE OPEN THE DOOR SLIT SKIRTS ANOTHER TRICKY DAY ATHENA EMINENCE FRONT SLIP KID SQUEEZE BOX WHO ARE YOU YOU BETTER YOU BET YOU REALLY GOT A HOLD ON ME WHO'S LOVING YOU LAUGHING BOY MY GUY THE ONE WHO REALLY LOVES YOU TWO LOVERS MICKEY'S MONKEY BABY THATS BACKATCHA BEING WITH YOU THE AGONY AND THE ECSTASY I'VE BEEN GOOD TO YOU MORE LOVE AUTOMATICALLY SUNSHINE FLOY JOY GET READY I WANT A LOVE I CAN SEE YOU'LL LOSE A PRECIOUS LOVE I DON’T BLAME YOU AT ALL ABRACADABRA FLY LIKE AN EAGLE LIVING IN THE USA ROCK'N ME PA0000537300 PA0000879638 PA0000290086 PA0000537295 PA0000537298 PA0000260102 PA0000290085 PA0000111560 PAu000161350 PA0000349891 PA0000233586 PA0000111563 PA0000271507 PAu000195123 PA0000148642 PAu000276742 PA0000152025 PA0000152030 EU0000626826 EU0000626830 PA0000038596 PAu000276746 EU0000746652 EU0000638752 EP0000172741 EU0000818026 EU0000706593 EU0000744333 EU0000781471 EP0000335871 PA0000112943 EP0000335869 EU0000699498 EP0000231124 EP0000298785 EP0000294057 EP0000212745 PA0000371365 EP0000198595 EP0000291287 PA0000142113 EU0000671181 EU0000076235 EP361643 - 14 - COMPLAINT FOR COPYRIGHT INFRINGEMENT Case 2:19-cv-08535 Document 1 Filed 10/03/19 Page 15 of 15 Page ID #:15 1 2 3 4 No. 127. 128. 129. 130. Composition Title TAKE THE MONEY AND RUN SPACE INTRO. HOT IN THE CITY WHITE WEDDING U.S. Copyright Registration Number EU0000671184 EU0000679837 PA0000159639 PA0000159638 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 15 - COMPLAINT FOR COPYRIGHT INFRINGEMENT