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Reggaeton Showdown
Highest Court D. Puerto Rico
Year Ended 2009
Plaintiffs Eliel
Music Publisher(s)
Record Label(s)
Defendants Daddy Yankee
El Cartel Records
Luny Tunes
Music Publisher(s)
Other No Other parties on file
Short Description Three of the biggest names in "reggaeton" music production and performance are represented in this suit, between the genre's godfather, Daddy Yankee, and producers Eliel and Luny Tunes. Eliel originally brought suit against Yankee, alleging that he was a co-author of certain Yankee songs for which he was not given proper credit. He filed a declaratory judgment action, requesting accounting. Yankee originally tried dismissing the complaint because Eliel failed to follow registration formalities, but the court held, as Plaintiff asserted, that registration is only a prerequisite for an infringement action, not declaratory judgment. The district court then denied Plaintiff's summary judgment. Though evidence supported Eliel's contentions, there were issues left to be litigated. Joint authorship requires both (1) that the two parties' contributions are independently copyrightable, and (2) that the parties intended to join their work into a final product. In this case, not enough was known about the circumstances of the song's production to rule summarily. In a later opinion, after Eliel added Luny Tunes as co-Defendant, the court dismissed Luny Tunes' counterclaims against Eliel, since they were based on earlier songs outside the limitations period and were not part of the same transaction as the songs Plaintiff sued on; the counterclaims were time-barred and, since they were not compulsory, were not tolled by the filing of Plaintiff's suit. - LSW

Legal Issues
Copyrights Ownership Accounting
    Declaratory Judgment
    Joint Authorship, Works-for-Hire & Derivative Creations
    Registration & Formalities
General Affirmative Defenses Statutes of Limitation


Opinions Sebastian Music Group, Inc. v. Ayala-Rodriguez
2009 Copr.L.Dec. P 29,847 / 2009 WL 4727791
D. Puerto Rico , December 02, 2009 ( Civil No. 07-1436(JP) )


Sebastian Music Group, Inc. v. Ayala-Rodriguez
594 F.Supp.2d 176
D. Puerto Rico , November 24, 2008 ( Civil No. 07-1436(JP) )


Sebastian Music Group, Inc. v. Ayala-Rodriguez
2008 WL 919683
D. Puerto Rico , April 03, 2008 ( Civil No. 07-1436(JP) )


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Related Searches Parties
Daddy Yankee ( Defendant )
El Cartel Records ( Defendant )
Eliel ( Plaintiff )
Luny Tunes ( Defendant )
Music Publisher(s) ( Plaintiff )
Music Publisher(s) ( Defendant )
Record Label(s) ( Plaintiff )

Legal Issues
Copyrights / Ownership / Accounting
Copyrights / Ownership / Declaratory Judgment
Copyrights / Ownership / Joint Authorship, Works-for-Hire & Derivative Creations
Copyrights / Ownership / Registration & Formalities
General / Affirmative Defenses / Statutes of Limitation

Courts
D. Puerto Rico (highest court)


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