Jackson v. Warner Music Group Corp.
1:23-cv-10100
S.D.N.Y.Jun 11, 2024Background
- Plaintiff Jouan Jabez Jackson, proceeding pro se, alleged that various recording artists and entities—including Warner Music Group, Atlantic Records, Brandy Norwood, Rodney Jerkins, Charlie Puth, and others—willfully infringed his copyrighted song lyrics (the "Photofinish" collection and associated works).
- Jackson claimed the infringement occurred over 20 years, following a 1997 demo submission to Rodney Jerkins, and consisted of use of his lyrics or themes in popular songs and albums released by the defendants.
- In prior related actions brought in the early 2000s (Jackson I & II), Jackson sued for similar copyright infringement based on the same works and alleged facts; the courts dismissed those actions on the merits for failure to state a claim.
- In the present SDNY case, the court granted Jackson leave to amend after initially dismissing his complaint for failure to state a plausible claim.
- Jackson's operative Second Amended Complaint asserted only federal copyright infringement claims and sought $10 billion in damages, along with broad injunctive and declaratory relief.
- Plaintiff attached as evidence the copyright registration for his song lyrics collection, but did not produce evidence of a registered musical composition copyright.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preclusion (Res Judicata/Collateral Estoppel) | Claims are new or not previously decided; successive infringements justify relitigation | Prior cases resolved same claims or issues; claims barred | Dismissed on preclusion grounds for claims previously litigated or that could have been litigated |
| Ownership of Registered Copyright | Jackson owns lyrics registration and rights to compositions | Plaintiff lacks registration for musical compositions; only has lyrics | Only lyrics copyright registered; no musical composition copyright shown; no infringement of unregistered rights |
| Substantial Similarity/Copying | Defendants’ works show thematic or lyrical parallels to his registered lyrics, revealed by AI analysis | Any similarities involve unprotectable common words, phrases, or themes | No substantial similarity between protectable elements; only common and unprotectable themes/phrases present |
| Sufficiency of Pleading | Plaintiff’s complaint and exhibits provide detailed side-by-side comparisons and evidence | Complaint is speculative, conclusory, fails Rule 8 pleading standard | Complaint fails to state a claim; insufficient non-conclusory allegations of copying or substantial similarity |
Key Cases Cited
- Brown v. Felsen, 442 U.S. 127 (1979) (describes claim preclusion/res judicata, barring relitigation of claims that were or could be raised in prior actions with a judgment on the merits)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets pleading standard—complaint must state plausible claim to relief)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must have enough facts to state a plausible claim)
- Feist Publ’ns, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340 (1991) (copyright infringement requires ownership and actual copying of original elements)
- Spinelli v. Nat’l Football League, 903 F.3d 185 (2d Cir. 2018) (sets out elements for copyright infringement: valid copyright and infringement by defendant)