Cope Et Al v. Warner Records, Inc. Et Al
Cope Et Al v. Warner Records, Inc. Et Al
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28 COMPLAINT FOR COPYRIGHT INFRINGEMENT
Case 2:22-cv-01384 Document 1 Filed 03/01/22 Page 2 of 5 Page ID #:2
3 BEDWARD, for their complaint against WARNER RECORDS, INC., DUA LIPA,
6 PARTIES
8 State of Florida.
12 of Florida.
14 of Florida.
16 Florida.
18 organized and existing pursuant to the laws of the State of Delaware with its principal
26 several remixes and as videos. Various formats of the performance reached as high as
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28 COMPLAINT FOR COPYRIGHT INFRINGEMENT
Case 2:22-cv-01384 Document 1 Filed 03/01/22 Page 3 of 5 Page ID #:3
1 Number 3 on the United States Billboard 200 Chart and Number 2 on Billboard’s Hot
2 100.
4 KANTE are, upon information and belief, all individual residents of Venice, California.
6 10. The true names and capacities of the Defendants sued as DOES 1 through
7 10, whether individual, corporate, associate or otherwise, are unknown to Plaintiffs who
8 therefore sue such Defendants by fictitious names. Plaintiffs are informed and believe
9 and thereupon allege that each of the Defendants designated as a fictitiously named
10 Defendant is in some manner responsible for the wrongful acts complained of herein. If
11 and when Plaintiffs ascertain the true names and capacities of DOES 1 through 10,
12 Plaintiffs will amend this Complaint to state their true names and capacities.
13 11. Plaintiffs are informed and believe and thereupon alleges that at all relevant
14 times each of the Defendants was the agent and employee of each other Defendant and
15 acted within the course and scope of their respective agency and/or employment in the
18 12. The subject matter jurisdiction of this Court is invoked pursuant to 28 USC
21 WARNER RECORDS has its principal place of business in this District and the other
23 FACTS
24 14. Plaintiffs are members of the band Artikal Sound System. Artikal Sound
25 System has been performing and touring together since 2010 and their album upon which
26 the song “Live Your Life” appears charted on the Billboard charts at number 2 in the
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28 COMPLAINT FOR COPYRIGHT INFRINGEMENT
Case 2:22-cv-01384 Document 1 Filed 03/01/22 Page 4 of 5 Page ID #:4
1 reggae section in 2017. They are the authors and copyright owners of the composition of
2 the song entitled “Live Your Life.” Attached hereto as Exhibit A is a true and correct
3 copy of the Certificate from the U.S. Copyright Office for “Live Your Life,” Registration
4 Number PA 2-314-836.
5 15. “Live Your Life” is an original work which was written in 2017. Plaintiffs
6 spent their time and talent creating and recording “Live Your Life.” and are entitled to
8 16. “Live Your Life” was commercially released on CD Baby in 2017 and
10 Amazon and Sound Cloud. The recording was and continues to be commercially
11 available.
12 17. In 2020, on information and belief, Defendants listened to and copied “Live
13 Your Life” before and during the time when they were writing “Levitating.”
14 18. “Levitating” is substantially similar to “Live Your Life.” Given the degree
15 of similarity, it is highly unlikely that “Levitating” was created independently from “Live
16 Your Life.”
26 damages.
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28 COMPLAINT FOR COPYRIGHT INFRINGEMENT
Case 2:22-cv-01384 Document 1 Filed 03/01/22 Page 5 of 5 Page ID #:5
6 4. For such other relief as the Court may deem just and proper.
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DEMAND FOR JURY TRIAL
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Plaintiffs CHRISTOPHER EDWARD COPE, CHRISTOPHER EDWARD
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MONTAGUE, FABIAN ANDRES ACUNA, ADAM SPENCER KAMPF and DENTON
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BEDWARD hereby demand a jury trial on all issues herein triable by a jury.
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Dated: March 1, 2022
20 LAW OFFICES OF ROBERT S. BESSER
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By: s/ Robert S. Besser
22 ROBERT S. BESSER
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28 COMPLAINT FOR COPYRIGHT INFRINGEMENT