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v.
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Defendants.
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COMPLAINT
Plaintiffs UMG Recordings, Inc.; Capitol Records, LLC; Warner Bros. Records
Inc.; Warner Music Latina Inc.; Sony Music Entertainment; Sony Music
Elektra Entertainment Group Inc.; Fueled by Ramen, LLC; Kemosabe Records LLC;
LaFace Records LLC; Nonesuch Records Inc.; WEA International Inc.; and Zomba
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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tracks contained in videos streamed from YouTube that YTMP3s 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 YTMP3s 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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YouTube, which makes videos available to its users for viewing and listening online,
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2.
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also provides the site and facilities and means for its users to engage in copyright
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1
COMPLAINT
3.
problem for Plaintiffs and for the recorded music industry as a whole. From 2013 to
2015 alone, there has been a 50% increase in unauthorized stream ripping in the
United States.
4.
YTMP3s conduct, and the conduct of its users that it enables and
induces, infringes Plaintiffs copyrights and other rights. It also violates YouTubes
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content from the YouTube service. By engaging in and facilitating the unlawful
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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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5.
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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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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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6.
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significant harm to the music industry, including to artists who rely on recorded music
for their livelihood. A recent survey found that 57 million persons in the United
7.
At the same time Defendants are depriving Plaintiffs and their recording
artists of the fruits of their labor, Defendants are profiting from the operation of the
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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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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YTMP3 website (i.e., the number of visitors to the site who then click on an
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8.
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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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9.
the United States, Title 17, United States Code 101, et seq., and for violations of
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COMPLAINT
the provisions of the Copyright Act that prohibit persons from circumventing
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10.
and 1338(a).
11.
to Federal Rule of Civil Procedure 4(k)(2), for at least the following reasons: (1)
Plaintiffs claims arise under federal copyright law; (2) YTMP3 is dedicated
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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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12.
U.S.C. 1400(a).
THE PARTIES
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Plaintiffs
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13.
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4
COMPLAINT
17.
principal place of business in New York, New York, and has substantial business
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18.
liability company with its principal place of business in Coconut Grove, Florida.
19.
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Records Inc.; Warner Music Latina Inc.; Sony Music Entertainment; Sony Music
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Elektra Entertainment Group Inc.; Fueled by Ramen, LLC; Kemosabe Records LLC;
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5
COMPLAINT
LaFace Records LLC; Nonesuch Records Inc.; WEA International Inc.; and Zomba
29.
Plaintiffs, along with their affiliated labels, are the copyright owners or
owners of exclusive rights with respect to the vast majority of copyrighted sound
recordings sold in the United States. Under the Copyright Act, Plaintiffs have, inter
alia, the exclusive rights to reproduce their copyrighted works, distribute copies or
audio transmission to the public. See 17 U.S.C. 106(1), (3), (6). Plaintiffs are also
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30.
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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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31.
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effort, and creative talent to discover and develop recording artists, and to create,
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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
1
2
Defendants
32.
company organized and existing under the laws of Germany. PMD, which is wholly
owned by Defendant Philip Matesanz (Matesanz), describes itself as the owner and
operator of YTMP3.
33.
participates in, and personally receives a direct financial benefit from, the conduct
alleged herein. Matesanz describes himself as the owner and sole employee of PMD,
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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
13
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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35.
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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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36.
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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.
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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
being made for offline access by the user. Music videos and the sound recordings
YouTube users.
38.
In its Terms of Service, YouTube strictly limits what users may do on the
site, and with content that appears on YouTube. Among other things, YouTubes
a.
display, sell, license, or otherwise exploit any Content for any other
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b.
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5(C));
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c.
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d.
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means other than the video playback pages of the [YouTube] Service
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39.
Plaintiffs are informed and believe, and on that basis allege as follows:
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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
video file: one URL, which is visible to the user, is for the webpage where the video
playback occurs, and one URL, which is not visible to the user, is for the video file
itself. The second URL is generated using a complex (and periodically changing)
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40.
YTMP3 was designed and exists for one principal reason: to profit from
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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.
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functioning as an unlawful substitute for the purchase of recorded music and the
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industry revenues, is enormous. Plaintiffs are informed and believe, and on that basis
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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
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operated by Defendants, is the chief offender, accounting for upwards of 40% of all
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COMPLAINT
43.
created a service that, through a few simple mouse clicks on a computer, generates
copies for free to any person who wants them. Indeed, the YTMP3 home page
depicted in the figure below promotes the simplicity and efficiency of this infringing
service, touting that it is the easiest online service for converting videos to mp3.
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COMPLAINT
44.
user who wants a copy of a song, at no cost. The user goes to YouTube
(www.youtube.com) and searches for a video with the desired song, an example of
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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
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into an input box. Once the URL is entered, the user clicks the Convert Video
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COMPLAINT
46.
YTMP3 then extracts the audio track from the YouTube video, converts
it to an MP3 audio file, and copies the file to its servers. Plaintiffs are informed and
believe, and on that basis allege, that, in order to access the YouTube video and
extract and copy the audio track, YTMP3 circumvents the technological measures that
YouTube has implemented to control access to content maintained on its site and to
prevent or inhibit illicit activities such as stream ripping. Among other things,
Plaintiffs are informed and believe, and on that basis allege, that YTMP3 employs a
means to circumvent the YouTube rolling cipher technology described above, and
other technological means that YouTube employs to protect content on its site.
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47.
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by YouTube, and having extracted and made a copy of the audio file associated with
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the relevant video, YTMP3 then presents the user with a download link. When the
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user clicks that link, the YTMP3 service distributes the MP3 file audio directly from
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Defendants servers to the users computer, as demonstrated in the figure and arrow
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below.
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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
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COMPLAINT
YTMP3 webpage states that the service begins to extract the audio file associated with
a YouTube video only after a user has entered a YouTube video URL and clicked the
Convert Video button, and that the service need[s] 3 to 4 minutes per video, in
many instances particularly in connection with very popular recordings the service
will deliver an MP3 audio file to the user almost immediately. Plaintiffs are informed
and believe that such files are immediately available because Defendants copy and
store such files on their servers for expeditious distribution to later users.
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49.
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legitimate music services, which pay for the right to distribute Plaintiffs works, and
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thus deprive Plaintiffs of the revenues to which they are entitled for exploitation of
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50.
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numerous and rapidly growing number of sound recordings to which Plaintiffs and/or
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their affiliated labels hold exclusive rights under copyright that have been and are
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these sound recordings is registered in the United States Copyright Office or is the
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infringed by Defendants.
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infringing Plaintiffs copyrights and are inducing and materially contributing to the
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infringement of Plaintiffs copyrights by others and derive financial benefit from that
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infringement. Defendants have the right and ability to supervise and stop the
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infringing activity indeed, Defendant Matesanz has publicly admitted that he has
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(and has exercised) the ability to observe the content of the YouTube videos that are
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being ripped through YTMP3 but they have taken no steps to stop the
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COMPLAINT
52.
entice, persuade, and cause users of the YTMP3 website to infringe Plaintiffs
copyrights. In a blog posting announcing new functionality for the YTMP3 service
(specifically, an extension for a Google Chrome browser), the single example that
Defendants provided of a video that could be stream ripped through the YTPM3
website was the song More by the recording artist Usher, which is owned by
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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
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55.
copyrighted sound recordings, including but not limited to those copyrighted sound
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56.
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Plaintiffs copyrights and exclusive rights under copyright, Plaintiffs are entitled to
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$150,000 with respect to each work infringed, or such other amounts as may be proper
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U.S.C. 504(b), Plaintiffs are entitled to their actual damages, including Defendants
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59.
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continue to cause Plaintiffs great and irreparable injury that cannot be fully
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COMPLAINT
COUNT TWO
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61.
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infringing acts of users of the YTMP3 website. Defendants have actual and
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64.
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Plaintiffs copyrights and exclusive rights under copyright, Plaintiffs are entitled to
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$150,000 with respect to each work infringed, or such other amounts as may be proper
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U.S.C. 504(b), Plaintiffs are entitled to their actual damages, including Defendants
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67.
continue to cause Plaintiffs great and irreparable injury that cannot fully be
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COMPLAINT
COUNT THREE
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69.
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71.
Defendants are vicariously liable for the infringing acts of users of the
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YTMP3 website. Defendants have the right and ability to supervise and control the
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infringing activities that occur through the use of YTMP3, and at all relevant times
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have derived a direct financial benefit from the infringement of Plaintiffs copyrights.
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copyrighted sound recordings, including but not limited to those sound recordings
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72.
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Plaintiffs copyrights and exclusive rights under copyright, Plaintiffs are entitled to
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$150,000 with respect to each work infringed, or such other amounts as may be proper
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17
COMPLAINT
U.S.C. 504(b), Plaintiffs are entitled to their actual damages, including Defendants
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75.
continue to cause Plaintiffs great and irreparable injury that cannot fully be
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COUNT FOUR
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77.
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79.
Defendants are liable under the Copyright Act for inducing the infringing
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acts of the users of YTMP3. Defendants operate the YTMP3 website with the
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Defendants have failed to take any meaningful action to prevent the widespread and
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rapidly growing infringement by their users and in fact have taken affirmative steps to
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80.
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cause users of the YTMP3 website to infringe Plaintiffs copyrights in their sound
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recordings, including but not limited to those sound recordings listed in Exhibit A
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users the ease with which their service copies audio files: We will start to convert
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COMPLAINT
the audiotrack of your videofile to mp3 as soon as you have submitted it and you will
be able to download it. Different from other services the whole conversion process
will be performed by our infrastructure and you only have to download the audio file
81.
intentionally take steps that are substantially certain to result in direct infringement of
Plaintiffs sound recordings, including but not limited to those sound recordings listed
82.
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83.
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Plaintiffs copyrights and exclusive rights under copyright, Plaintiffs are entitled to
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$150,000 with respect to each work infringed, or such other amounts as may be proper
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U.S.C. 504(b), Plaintiffs are entitled to their actual damages, including Defendants
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86.
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continue to cause Plaintiffs great and irreparable injury that cannot fully be
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COUNT FIVE
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7
88.
measures that YouTube has implemented to effectively control access to and prevent
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90.
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protects the rights of Plaintiffs under the Copyright Act in sound recordings including
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1201(b)(1)(A).
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91.
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YTMP3, which has only a limited commercially significant purpose or use other than
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YouTube, that effectively protects the rights of Plaintiffs under the Copyright Act in
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sound recordings including but not limited to those listed in Exhibit A hereto, in
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92.
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YTMP3, which is marketed by Defendants, and with Defendants knowledge, for use
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YouTube, that effectively protects the rights of Plaintiffs under the Copyright Act in
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COMPLAINT
sound recordings including but not limited to those listed in Exhibit A hereto, in
93.
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94.
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96.
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continue to cause Plaintiffs great and irreparable injury that cannot fully be
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(a)
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works, including:
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COMPLAINT
i.
Defendants and their officers, agents, servants, employees, attorneys, and others in
active concert or participation with each or any of them, (a) cease infringing, or
in the infringement of, any of Plaintiffs copyrights protected by the Copyright Act,
controls access to Plaintiffs copyrighted works; and (c) surrender, and cease to use,
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controlled by Defendants;
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ii.
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Copyright Act (17 U.S.C. 502, 1203), 28 U.S.C. 1651(a), and this Courts
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Order, including any Web hosts, domain-name registrars, domain name registries, and
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proxy or reverse proxy services, and their administrators, from facilitating access to
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any or all domain names, URLs and websites (including, without limitation,
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(a) disable access to www.youtube-mp3.org and any related domain names specified
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by Plaintiffs through a registry hold or otherwise, and to make them inactive and non-
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by Plaintiffs to re-register the domain names in Plaintiffs names and under Plaintiffs
27
ownership;
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22
COMPLAINT
(C)
to YTMP3 and any other domain names, URLs, or websites through which
software with notice of the Order from distributing any applications, toolbars, or
similar software applications that interoperate with any domain names, URLs, or
limitation www.youtube-mp3.org;
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(c)
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$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
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(d)
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amount of $2,500 with respect to each act of circumvention or, in the alternative, at
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(e)
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COMPLAINT
(g)
for such other relief as the Court may deem just and proper.
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24
COMPLAINT
Pursuant to Local Rule 38-1 and Rule 38(b) of the Federal Rules of Civil
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COMPLAINT
Exhibit A
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
1.
2.
3.
4.
5.
6.
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.
12.
13.
Isyss
Jennifer Hudson
Outkast
Paula DeAnda
Santana feat.
Michelle Branch
Sarah McLachlan
Brett Eldredge
399-074
751-747
Hunter Hayes
I Want Crazy
748-751
James Blunt
You're Beautiful
393-742
Jennifer Love
Hewitt
Lupe Fiasco
227-488
Paris, Tokyo
639-320
Space Jam
230-149
Simple Plan
639-323
Skrillex
Recess
743-328
Sugar Ray
303-749
The Rembrandts
Trans-Siberian
Orchestra
Collective Soul
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
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
Locked Out Of
Heaven
When I Was Your
Man
Marvin Gaye
One Call Away
30.
Atlantic Recording
Corporation
We Don't Talk
Anymore
31.
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Atlantic Recording
Corporation
Christina Perri
Human
DLOW
Do It Like Me
GDFR
Good Feeling
754-532
Galantis
No Money
Galantis
Galantis
Runaway (U & I)
773-121
Kevin Gates
La Familia
Melanie Martinez
Alphabet Boy
Melanie Martinez
Carousel
Melanie Martinez
Pity Party
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
756-206
App. No. 12830804621
App. No. 13197808686
Exhibit A
Page 27
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
Hero
Wiz Khalifa
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
Darius Rucker
51.
52.
Katy Perry
Keith Urban
53.
54.
Norah Jones
Darius Rucker
55.
Eric Church
56.
57.
58.
59.
Katy Perry
Lady Antebellum
The Decemberists
Lady Antebellum
60.
61.
Lady Antebellum
Alana Davis
History in the
Making
Hot N Cold
Only You Can Love
Me This Way
Chasing Pirates
Dont Think I Dont
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.
Exhibit A
Page 28
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
278-241
Bruno Mars
Grenade
671-062
Bruno Mars
671-062
Bruno Mars
671-062
Bruno Mars
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
Stressed Out
Die Young
Get Up
772-681
715-271
388-894
78.
79.
400-094
395-929
80.
81.
82.
83.
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
343-668
297-686
225-933
233-296
619-959
619-959
198-743
Exhibit A
Page 29
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
84.
Toni Braxton
287-194
85.
86.
Usher
Usher
87.
88.
89.
90.
91.
Marion Barfs
Slow Dance
Say Something
303-613
300-332
736-234
92.
93.
94.
95.
96.
97.
98.
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.
Usher
Usher feat. Young
Jeezy
Clint Mansell
Bill Frisell
A Great Big World
& Christina Aguilera
A$AP Rocky
A$AP Rocky
Becky G
Beyonc
Beyonc
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
105.
106.
107.
108.
Chris Brown
Chris Brown, feat.
Usher and Rick
Ross
Ciara
Daft Punk
Ella Henderson
Elle King
Elle King
Fifth Harmony
Fifth Harmony
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
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
112.
113.
114.
115.
116.
117.
118.
119.
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.
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
135.
136.
137.
138.
139.
140.
P!nk
Pitbull
Pitbull
Pitbull
Rachel Platten
Shakira
Sia
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
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
The
Neighbourhood
The
Neighbourhood
Walk The Moon
Beyonc
Chris Brown
Christina Aguilera
Five For Fighting
Justin Timberlake
Martika
Afraid
729-095
Sweater Weather
729-095
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
157.
158.
159.
160.
161.
Beyonc
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
162.
163.
164.
165.
Limi-T21
681-904
740-358
Exhibit A
Page 32
Plaintiff
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
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
Gavin Rossdale
189.
190.
191.
192.
193.
194.
Hinder
India. Arie
Jennifer Lopez
Juanes
Kacey Musgraves
Lady Gaga
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
195.
196.
197.
198.
199.
200.
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
Lady Gaga
Mary J. Blige
Ne-Yo
Nelly
Neon Trees
Neon Trees
671-815
636-307
612-632
662-586
647-020
748-665
210.
211.
212.
213.
214.
215.
216.
217.
218.
219.
220.
221.
222.
619-905
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
712-989
709-927
770-658
764-950
764-632
745-075
757-030
768-591
760-985
768-222
Exhibit A
Page 34
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
Twist My Fingaz
Diamonds
770-185
755-956
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
Mike Posner
Neon Trees
244.
245.
246.
247.
Shawn Mendes
Timeflies
Shawn Mendes
Chino & Nacho
feat. Farruko
248.
249.
250.
251.
252.
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
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
Kacey Musgraves
Kem
769-034
759-369
Ne-Yo
Ariana Grande
Florida Georgia
Line
James Bay
Mat Kearney
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
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
Plaintiff
Artist
Song Title
SR No. (or
App. No.
where
indicated)
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
Casa De Leones
Mana
Disturbed
A Tribe Called
Quest
Aaliyah
Aaron Carter
Backstreet Boys
Backstreet Boys
Britney Spears
299.
300.
301.
302.
303.
304.
Justin Timberlake
NSYNC
Paradise Lost
R. Kelly
R. Kelly
Usher feat. Shyne,
Kanye West, &
Twista
12
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