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Laws v. Sony Music Entertainment
United States Court of Appeals for the Central District of California
294 F. Supp. 2d 1160 (2003)
Debra Laws (plaintiff) recorded a song called Very Special in 1981. The song was recorded in accordance with Laws’s recording agreement with Spirit Productions (Spirit). Spirit, in turn, had contracted with Elektra Records (Elektra) to produce master recordings of Laws’s songs. As a part of the contract between Spirit and Elektra, Elektra held the copyright in productions of Laws’s songs and the ability to license those productions. Warner Communications (Warner), Elektra’s parent company, licensed Very Special in 2002 to Sony Music Entertainment (Sony) (defendant), for sampling in Jennifer Lopez’s song All I Have. The recording for All I Have included a credit to Debra Laws, as required in the license agreement. After All I Have became successful, Laws sued Sony claiming misappropriation of her name and voice for commercial purposes under California law. The district court found that Laws’s claims were preempted by federal copyright law under the Copyright Act. Laws appealed the decision.
Rule of Law
Holding and Reasoning (Baird, J.)
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