Capitol Records, Inc. v. MP3Tunes, LLC, 28 F. Supp. 3d 190

This memorandum addresses competing jury instructions about statutory damages where two owners hold copyrights in the musical composition and the sound recording of the infringed work.
The court had previously ruled that plaintiffs sharing both copyrights may receive a single award of statutory damages for the infringed work.
Statutory damages are calculated by treating separate copyrights as not distinct works unless they can live their own copyright life.
The decision cites Spooner v. EEN, Inc. and other authorities to treat the sound recording and composition as one work where the infringement targeted the sound recording.
The court rejects Teevee Toons, Inc. v. MP3.com, Inc. as controlling, criticizing its approach to multiple awards when ownership is separate.
Conclusion: where two owners hold copyrights in the composition and sound recording of the same song, they share a single statutory damages award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether two copyrights in one song yield one statutory damages award	Plaintiff argues for one award for the work.	Defendant argues possible multiple awards if ownership is separate.	One award per work; single damages for both rights.
Whether composition and sound recording copyrights are a single work for damages	Plaintiff asserts the two rights are part of one work.	Defendant contends separate exploitation could justify separate awards.	They are subsumed in one work for statutory damages.

Bryant v. Media Right Prods., Inc., 603 F.3d 135 (2d Cir. 2010) (one award of damages for any work infringed)
Robert Stigwood Grp. Ltd. v. O’Reilly, 530 F.2d 1096 (2d Cir. 1976) (overlapping copyrights in libretto, score, and performance)
Teevee Toons, Inc. v. MP3.com, Inc., 134 F. Supp. 2d 546 (S.D.N.Y. 2001) (controversial rule on separate awards based on ownership)
Spooner v. EEN, Inc., 2010 WL 1930239 (D. Me. 2010) (one work when infringement targeted sound recordings; no separate musical-life)