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Lil' Wayne's Sampling Karma
Highest Court E.D. Louisiana
Year Ended 2009
Plaintiffs Music Publisher(s)
Defendants Lil' Wayne
Other Henry Ate
Swanepoel, Karma Ann
Short Description Plaintiff is the publisher for Karma Ann Swanepoel, songwriter for the South African band, Henry Ate, who sued Lil' Wayne for sampling the band on a track released for free on the internet. Lil's song was intended to to "create buzz" in anticipation of Lil's upcoming album, "Tha Carter III." After the album was released (which did not contain the infringing song), Plaintiff sued and sought discovery documents relating to the album's gross revenue, under a theory of "indirect profits," seeing as the song was accessed by over 16 million people online. According to the court, the case was in its "infancy," and Plaintiff had shown a sufficient nexus between the pre-album song and the later-released album such that the document requests were reasonable. Defendant had presumably benefitted from the infringing song through album sales, and the court granted Plaintiff's motion to compel. - LSW

Legal Issues
Civil Procedure Evidence Discovery
Copyrights Infringement Sampling & Distribution/Dissemination
General Equitable Actions Unjust Enrichment


Opinions Urband & Lazar Music Pub., Inc. v. Carter
2009 WL 799759
E.D. Louisiana , March 23, 2009 ( No. 08-3566 )


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Related Searches Parties
Henry Ate ( Other )
Lil' Wayne ( Defendant )
Music Publisher(s) ( Plaintiff )
Swanepoel, Karma Ann ( Other )

Legal Issues
Civil Procedure / Evidence / Discovery
Copyrights / Infringement / Sampling & Distribution/Dissemination
General / Equitable Actions / Unjust Enrichment

Courts
E.D. Louisiana (highest court)


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