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Prunté v. Universal Music Group, Inc.
United States District Court for the District of Columbia
699 F. Supp. 2d 15 (2010)
Facts
Hip-hop songwriter Robert Prunté (plaintiff) took part in a service designed to promote success in the music industry. Prunté sent 38 of his songs to the provider of the service, Inside Sessions, a division of Universal Music Group, Inc. (Universal), for expert feedback. A few years later, Prunté brought copyright-infringement claims against approximately 45 individuals and corporate entities (defendants) in the United States District Court for the District of Columbia. Prunté alleged that the defendants conspired to copy protectible elements of his copyrighted songs. Prunté also alleged that the defendant production companies conspired to provide more of his songs to popular rap artists in the future. Prunté’s song-by-song allegations followed a pattern in which phrases, themes, and titles were identified as occurring in both his work and the allegedly infringing songs. However, the phrases in question tended to be stock phrases such as “that’s what’s up,” and the themes were generally limited to sex and drugs. The defendants who appeared in court moved for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Friedman, J.)
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