Bryan Pringle v. William Adams Jr et al

Filing 108

ANSWER to Amended Complaint,,, 9 , Complaint - (Discovery), Complaint - (Discovery), Complaint - (Discovery), Complaint - (Discovery) 1 DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS ANSWER TO FIRST AMENDED COMPLAINT FOR COPYRIGHT INFRINGEMENT filed by Defendant Interscope Records, UMG Recordings Inc.(Burrow, Linda)

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1 CALDWELL LESLIE & PROCTOR, PC LINDA M. BURROW, State Bar No. 194668 burrow@caldwell-leslie.com 2 HEATHER PEARSON, State Bar No. 235167 pearson@caldwell-leslie.com 3 1000 Wilshire Boulevard, Suite 600 4 Los Angeles, California 90017-2463 Telephone: (213) 629-9040 5 Facsimile: (213) 629-9022 6 Attorneys for Defendants UMG RECORDINGS, INC and 7 INTERSCOPE RECORDS 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 12 13 14 15 BRYAN PRINGLE, an individual, Case No. SACV 10-1656 JST (RZx) Plaintiff, DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT FOR COPYRIGHT INFRINGEMENT v. WILLIAM ADAMS, JR.; STACY 16 FERGUSON; ALAN PINEDA; and JAIME GOMEZ, all individually and 17 collectively as the music group the Black Eyed Peas; DAVID GUETTA; 18 FREDERICK RIESTERER; UMG RECORDINGS, INC.; INTERSCOPE 19 RECORDS; EMI APRIL MUSIC, INC.; HEADPHONE JUNKIE 20 PUBLISHING, LLC.; WILL.I.AM MUSIC, LLC; JEEPNEY MUSIC, 21 INC.; TAB MAGNETIC PUBLISHING; CHERRY RIVER 22 MUSIC, CO.; SQUARE RIVOLI PUBLISHING; RISTER EDITIONS; 23 and SHAPIRO, BERNSTEIN & CO., 24 Trial Date: None Set Defendants. 25 26 27 28 CALDWELL LESLIE & PROCTOR DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 Pursuant to Rule 8(b) of the Federal Rules of Civil Procedure, Defendants 2 UMG Recordings, Inc. (“UMG”) and Interscope Records (“Interscope”) 3 (collectively, the “UMG Defendants”) hereby answer the First Amended Complaint 4 (the “FAC”) of Plaintiff Bryan Pringle (“Plaintiff”). If an averment is not 5 specifically admitted, it is hereby denied. INTRODUCTION 6 7 1. Answering paragraph 1, the UMG Defendants admit that the FAC 8 alleges copyright infringement against the Defendants, but deny any liability to 9 Plaintiff whatsoever. Expect as expressly admitted herein, the UMG Defendants 10 deny each and every allegation contained in paragraph 1. 11 2. Answering paragraph 2, the UMG Defendants admit that this suit seeks 12 the relief stated in this paragraph, but deny that Plaintiff is entitled to such relief. 13 The UMG Defendants lack sufficient information to admit or deny the remaining 14 allegations contained in paragraph 2, and on such basis deny each and every such 15 allegation. 16 3. Answering paragraph 3, the UMG Defendants lack sufficient 17 information to admit or deny the allegations contained in paragraph 3, and on such 18 basis deny each and every such allegation. 19 4. Answering paragraph 4, the UMG Defendants deny each and every 20 allegation contained therein. 21 5. Answering paragraph 5, the UMG Defendants deny each and every 22 allegation contained therein. 23 6. Answering paragraph 6, the UMG Defendants deny each and every 24 allegation contained therein. JURISDICTION AND VENUE 25 26 7. Answering paragraph 7, the UMG Defendants admit that Plaintiff 27 purports to bring this action pursuant to 17 U.S.C. §§ 101 et seq. and 1338(a) but 28 deny any liability to Plaintiff whatsoever. CALDWELL LESLIE & PROCTOR -1- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 8. Answering paragraph 8, the UMG Defendants admit that their principal 2 places of business are in this District. The UMG Defendants lack sufficient 3 information to admit or deny the remaining allegations contained in paragraph 8, 4 and on such basis deny each and every such allegation. GENERAL ALLEGATIONS 5 6 A. Parties 7 9. Answering paragraph 9 the UMG Defendants lack sufficient 8 information to admit or deny the allegations contained in this paragraph, and on 9 such basis deny each and every such allegation. 10 10. Answering paragraph 10, the UMG Defendants admit that Defendant 11 William Adams Jr. is an individual professionally known as Will.I.Am and one of 12 the members of the Black Eyed Peas. The UMG Defendants lack sufficient 13 information to admit or deny the remaining allegations in paragraph 10 and on such 14 basis deny each and every such allegation. 15 11. Answering paragraph 11, the UMG Defendants admit that Stacy 16 Ferguson is an individual professionally known as Fergie and one of the members of 17 the Black Eyed Peas. The UMG Defendants lack sufficient information to admit or 18 deny the remaining allegations in paragraph 11, and on such basis deny each and 19 every such allegation. 20 12. Answering paragraph 12, the UMG Defendants admit that Allan Pineda 21 is an individual professionally known as apl.de.ap and one of the members of the 22 Black Eyed Peas. The UMG Defendants lack sufficient information to admit or 23 deny the remaining allegations in paragraph 12, and on such basis deny each and 24 every such allegation. 25 13. Answering paragraph 13, the UMG Defendants admit that Jaime 26 Gomez is an individual professionally known as Taboo and one of the members of 27 the Black Eyed Peas. The UMG Defendants lack sufficient information to admit or 28 CALDWELL LESLIE & PROCTOR -2- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 deny the remaining allegations in paragraph 13, and on such basis deny each and 2 every such allegation. 3 14. Answering paragraph 14, the UMG Defendants admit that David 4 Guetta is an individual songwriter and music producer who has, among other things, 5 co-produced sound recordings by the Black Eyed Peas. The UMG Defendants lack 6 sufficient information to admit or deny the remaining allegations in paragraph 14, 7 and on such basis deny each and every such allegation. 8 15. Answering paragraph 15, the UMG Defendants admit that Frederick 9 Riesterer is an individual songwriter and music producer who has, among other 10 things, co-produced sound recordings by the Black Eyed Peas. The UMG 11 Defendants lack sufficient information to admit or deny the remaining allegations in 12 paragraph 15, and on such basis deny each and every such allegation. 13 16. Answering Paragraph 16, the UMG Defendants admit that UMG 14 Recordings, Inc. (“UMG”) is a Delaware corporation and that UMG is in the 15 business of releasing sound recordings through various record labels. The UMG 16 Defendants deny that UMG’s principal place of business is in Los Angeles, 17 California. To the extent that any further response is required, the UMG Defendants 18 lack sufficient information to admit or deny the remaining allegations in paragraph 19 16, and on such basis deny each and every such allegation. 20 17. Answering paragraph 17, the UMG Defendants admit that Defendant 21 Interscope Records (“Interscope”) is a California general partnership and that UMG 22 is the managing partner of Interscope. The UMG Defendants further admit that the 23 Black Eyed Peas are signed as artists to the Interscope Records label. Except as 24 expressly admitted herein, the UMG Defendants deny each and every allegation 25 contained in paragraph 17. 26 18. Answering paragraph 18, the UMG Defendants lack sufficient 27 information to admit or deny the allegations contained in this paragraph, and on 28 such basis deny each and every such allegation. CALDWELL LESLIE & PROCTOR -3- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 19. Answering paragraph 19, the UMG Defendants lack sufficient 2 information to admit or deny the allegations contained in this paragraph, and on 3 such basis deny each and every such allegation. 4 20. Answering paragraph 20, the UMG Defendants lack sufficient 5 information to admit or deny the allegations contained in this paragraph, and on 6 such basis deny each and every such allegation. 7 21. Answering paragraph 21, the UMG Defendants lack sufficient 8 information to admit or deny the allegations contained in this paragraph, and on 9 such basis deny each and every such allegation. 10 22. Answering paragraph 22, the UMG Defendants lack sufficient 11 information to admit or deny the allegations contained in this paragraph, and on 12 such basis deny each and every such allegation. 13 23. Answering paragraph 23, the UMG Defendants lack sufficient 14 information to admit or deny the allegations contained in this paragraph, and on 15 such basis deny each and every such allegation. 16 24. Answering paragraph 24, the UMG Defendants lack sufficient 17 information to admit or deny the allegations contained in this paragraph, and on 18 such basis deny each and every such allegation. 19 25. Answering paragraph 25, the UMG Defendants lack sufficient 20 information to admit or deny the allegations contained in this paragraph, and on 21 such basis deny each and every such allegation. 22 26. Answering paragraph 26, the UMG Defendants lack sufficient 23 information to admit or deny the allegations contained in this paragraph, and on 24 such basis deny each and every such allegation. 25 B. Plaintiff’s Creation and Protection of His Original Work 26 27. Answering paragraph 27, the UMG Defendants lack sufficient 27 information to admit or deny the allegations contained in this paragraph, and on 28 such basis deny each and every such allegation. CALDWELL LESLIE & PROCTOR -4- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 28. Answering paragraph 28, the UMG Defendants admit that a copyright 2 registration for the album “Dead Beat Club: 1998” is attached to the FAC as Exhibit 3 “B.” The UMG Defendants lack sufficient information to admit or deny the 4 remaining allegations contained in paragraph 28, and on such basis deny each and 5 every such allegation. 6 29. Answering paragraph 29, the UMG Defendants lack sufficient 7 information to admit or deny the allegations contained in this paragraph, and on 8 such basis deny each and every such allegation. 9 30. Answering paragraph 30, the UMG Defendants lack sufficient 10 information to admit or deny the allegations contained in this paragraph, and on 11 such basis deny each and every such allegation. 12 C. Defendants’ Access to and Copying of Plaintiff’s Copyrighted Song 13 “Take a Dive” 14 31. Answering paragraph 31, the UMG Defendants lack sufficient 15 information to admit or deny the allegations contained in this paragraph, and on 16 such basis deny each and every such allegation. 17 32. Answering paragraph 32, the UMG Defendants lack sufficient 18 information to admit or deny the allegations contained in this paragraph, and on 19 such basis deny each and every such allegation. 20 33. Answering paragraph 33, the UMG Defendants lack sufficient 21 information to admit or deny the allegations contained in this paragraph, and on 22 such basis deny each and every such allegation. 23 34. Answering paragraph 34, the UMG Defendants admit that, at various 24 times, Defendant Adams has performed consulting services to Interscope. The 25 UMG Defendants deny each and every remaining allegation contained in paragraph 26 34 to the extent it pertains to Interscope. The UMG Defendants lack sufficient 27 information to admit or deny the remaining allegations contained in paragraph 34, 28 and on such basis deny each and every such allegation. CALDWELL LESLIE & PROCTOR -5- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 35. Answering paragraph 35, the UMG Defendants deny each and every 2 allegation contained therein. 3 36. Answering paragraph 36, the UMG Defendants deny each and every 4 allegation contained therein. 5 37. Answering paragraph 37, the UMG Defendants deny each and every 6 allegation contained therein. 7 38. Answering paragraph 38, the UMG Defendants lack sufficient 8 information to admit or deny the allegations contained in this paragraph, and on 9 such basis deny each and every such allegation. 10 39. Answering paragraph 37, the UMG Defendants deny each and every 11 allegation contained therein. 12 D. Substantial Similarity Between “Take a Dive” and “I Gotta Feeling” 13 40. Answering paragraph 40, the UMG Defendants admit that a copy of “I 14 Gotta Feeling” is contained as Track 3 on Exhibit “A” to the FAC. Except as 15 expressly admitted herein, the UMG Defendants deny each and every allegation 16 contained in paragraph 40. 17 41. Answering paragraph 41, the UMG Defendants deny each and every 18 allegation contained therein. 19 42. Answering paragraph 42, the UMG Defendants deny each and every 20 allegation contained therein. 21 43. Answering paragraph 43, the UMG Defendants deny that “Take a 22 Dive” is substantially similar to “I Gotta Feeling,” and further deny that the 23 purported similarities described in subparagraphs (a) through (l) evidence any 24 infringement. The UMG Defendants lack sufficient information to admit or deny 25 the remaining allegations contained in paragraph 43, and on such basis deny each 26 and every such allegation. 27 28 CALDWELL LESLIE & PROCTOR -6- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 E. The Aftermath of “I Gotta Feeling’s” Release 2 44. Answering paragraph 44, The UMG Defendants admit that the song “I 3 Gotta Feeling” was released in or around June 2009 as the second single from the 4 Black Eyed Peas album entitled The E.N.D. 5 45. Answering paragraph 45, the UMG Defendants admit the allegations in 6 sub-paragraph (c) and further admit that “I Gotta Feeling” was licensed for 7 commercials. Except as expressly admitted herein, the UMG Defendants deny the 8 allegations contained in paragraph 45. 9 46. Answering paragraph 46, the UMG Defendants lack sufficient 10 information to admit or deny the allegations contained in this paragraph, and on 11 such basis deny each and every such allegation. 12 E. Defendants’ Conspiracy to Engage in and Conduct a Pattern and 13 Practice of Ongoing Willful Copyright Infringement as to Others 14 47. Answering paragraph 47, the UMG Defendants deny each and every 15 allegation contained therein. 16 48. Answering paragraph 48, the UMG Defendants deny each and every 17 allegation contained therein. 18 49. Answering paragraph 49, the UMG Defendants deny each and every 19 allegation contained therein. 20 50. Answering paragraph 50, the UMG Defendants deny each and every 21 allegation contained therein. 22 51. Answering paragraph 51, the UMG Defendants deny each and every 23 allegation contained therein. 24 52. Answering paragraph 52, the UMG Defendants deny each and every 25 allegation contained therein. 26 53. Answering paragraph 53, the UMG Defendants deny each and every 27 allegation contained therein. 28 CALDWELL LESLIE & PROCTOR -7- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 54. Answering paragraph 54, the UMG Defendants deny each and every 2 allegation contained in this paragraph as it pertains to the UMG Defendants. The 3 UMG Defendants lack sufficient information to admit or deny the remaining 4 allegations contained in this paragraph, and on such basis deny each and every such 5 allegation. 6 55. Answering paragraph 55, the UMG Defendants are aware of other un- 7 proven allegations against the Black Eyed Peas, but deny the remaining allegations 8 contained in this paragraph as they pertain to the UMG Defendants. The UMG 9 Defendants lack sufficient information to admit or deny the remaining allegations 10 contained in this paragraph, and on such basis deny each and every such allegation. 11 56. Answering paragraph 56, the UMG Defendants lack sufficient 12 information to admit or deny the allegations contained in this paragraph, and on 13 such basis deny each and every such allegation. 14 57. Answering paragraph 57, the UMG Defendants lack sufficient 15 information to admit or deny the allegations contained in this paragraph, and on 16 such basis deny each and every such allegation. 17 58. Answering paragraph 58, the UMG Defendants deny each and every 18 allegation contained therein. 19 59. Answering paragraph 59, the UMG Defendants lack sufficient 20 information to admit or deny the allegations contained in this paragraph, and on 21 such basis deny each and every such allegation. 22 60. Answering paragraph 60, the UMG Defendants deny each and every 23 allegation contained therein. 24 25 ANSWER TO CLAIM FOR COPYRIGHT INFRINGEMENT 61. Answering paragraph 61, the UMG Defendants hereby incorporate 26 their answers to Paragraphs 1 through 60, inclusive. 27 62. Answering paragraph 62, the UMG Defendants deny each and every 28 allegation contained therein. CALDWELL LESLIE & PROCTOR -8- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 63. Answering paragraph 63, the UMG Defendants deny each and every 2 allegation contained therein. 3 64. Answering paragraph 64, the UMG Defendants deny each and every 4 allegation contained therein. 5 65. Answering paragraph 65, the UMG Defendants deny each and every 6 allegation contained therein. 7 66. Answering paragraph 66, the UMG Defendants deny each and every 8 allegation contained therein. 9 67. Answering paragraph 67, the UMG Defendants deny each and every 10 allegation contained therein. 11 68. Answering paragraph 68, the UMG Defendants deny each and every 12 allegation contained therein. 13 69. Answering paragraph 69, the UMG Defendants deny each and every 14 allegation contained therein. 15 16 ANSWER TO PRAYER FOR RELIEF Answering paragraphs (a) to (g) of the prayer for relief, the UMG Defendants 17 deny that Plaintiff is entitled to the relief sought in these paragraphs, and deny that 18 Plaintiff is entitled to any relief whatsoever. AFFIRMATIVE DEFENSES 19 20 The UMG Defendants plead the following separate and distinct affirmative 21 defenses without conceding that they bear the burden of proof as to any of these 22 issues. The UMG Defendants reserve the right to assert additional affirmative 23 defenses that discovery indicates are proper. 24 FIRST AFFIRMATIVE DEFENSE 25 (Failure to State a Claim) 26 1. Plaintiff’s FAC, and each cause of action alleged therein, fails to state a 27 claim upon which relief can be granted. 28 CALDWELL LESLIE & PROCTOR -9- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 SECOND AFFIRMATIVE DEFENSE 2 (Indemnity) 3 2. To the extent that Plaintiff is entitled to recover from the UMG 4 Defendants, the UMG Defendants are entitled to equitable and contractual 5 indemnity from other persons and parties causing or contributing to such damages. 6 THIRD AFFIRMATIVE DEFENSE 7 (Apportionment of Fault) 8 3. Plaintiff’s damages, if any, were caused by the negligence and/or acts 9 or omissions of parties other than the UMG Defendants, whether or not parties to 10 this action. By reason thereof, Plaintiff’s damages, if any, as against the UMG 11 Defendants, must be reduced by the proportion of fault attributable to such other 12 parties, and to the extent that this is necessary, the UMG Defendants may be entitled 13 to partial indemnity from others on a comparative fault basis. 14 FOURTH AFFIRMATIVE DEFENSE 15 (Intervening and Superseding Cause) 16 4. Assuming Plaintiff suffered or sustained any loss, damage or injury, 17 which Defendants specifically deny, such loss, damage or injury was proximately 18 caused or contributed to by the negligence or wrongful conduct of other parties, 19 persons or entities, including Plaintiff, and that their negligence or wrongful conduct 20 was an intervening and superseding cause of the purported loss, damage or injury of 21 which Plaintiff complains. 22 FIFTH AFFIRMATIVE DEFENSE 23 (Justification and Privilege) 24 5. Plaintiff’s FAC, and each cause of action alleged therein, is barred by 25 the doctrine of justification and privilege, in that all actions by the UMG Defendants 26 were lawful and were fair and reasonable under the circumstances. 27 28 CALDWELL LESLIE & PROCTOR -10- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 SIXTH AFFIRMATIVE DEFENSE 2 (Waiver) 3 6. Plaintiff’s FAC, and each cause of action alleged therein, is barred in 4 whole or in part by the doctrine of waiver. 5 SEVENTH AFFIRMATIVE DEFENSE 6 (Consent) 7 7. Plaintiff’s FAC, and each cause of action alleged therein, fails because 8 Plaintiff, and/or the persons and/or entities acting on their behalf, consented to and 9 acquiesced in the subject conduct. 10 EIGHTH AFFIRMATIVE DEFENSE 11 (Laches) 12 8. Plaintiff’s FAC, and each cause of action alleged therein, is barred in 13 whole or in part by the doctrine of laches. 14 NINTH AFFIRMATIVE DEFENSE 15 (Estoppel) 16 9. Plaintiff’s FAC, and each cause of action alleged therein, is barred in 17 whole or in part by the doctrine of estoppel. 18 TENTH AFFIRMATIVE DEFENSE 19 (Failure to Mitigate) 20 10. Assuming that any loss, injury or damage occurred as Plaintiff alleges, 21 which the UMG Defendants specifically deny, Plaintiff has failed to mitigate those 22 damages. 23 ELEVENTH AFFIRMATIVE DEFENSE 24 (Unclean Hands) 25 11. Plaintiff’s FAC, and each cause of action alleged therein, is barred in 26 whole or in part by the doctrine of unclean hands. 27 28 CALDWELL LESLIE & PROCTOR -11- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 TWELFTH AFFIRMATIVE DEFENSE 2 (Speculative Damages) 3 12. The damages alleged in Plaintiff’s FAC are impermissibly remote and 4 speculative, and, therefore, Plaintiff is barred from the recovery of any such 5 damages against the UMG Defendants. 6 THIRTEENTH AFFIRMATIVE DEFENSE 7 (Innocent Infringement) 8 13. As to each and all claims for relief based upon the UMG Defendants’ 9 alleged infringement of alleged copyrights owned by Plaintiff, Plaintiff is barred 10 from recovering damages arising from such alleged infringement, or such damages 11 should be reduced, because any infringement by the UMG Defendants was innocent 12 and without notice or knowledge of Plaintiff’s purported rights. 13 FOURTEENTH AFFIRMATIVE DEFENSE 14 (Misuse of Copyright) 15 14. As to any and all claims for relief based upon the UMG Defendants’ 16 alleged infringement of alleged copyrights owned by Plaintiff, Plaintiff’s actions 17 constitute misuse of copyright. 18 FIFTEENTH AFFIRMATIVE DEFENSE 19 (Fraud on the Copyright Office) 20 15. As to each and all of the claims for relief based on alleged infringement 21 of alleged copyrights owned by Plaintiff, Plaintiff’s claims are barred because any 22 copyright registrations by Plaintiff were obtained by fraud on the Copyright Office. 23 24 WHEREFORE, the UMG Defendants pray for relief as follows: 25 1. That the FAC be dismissed, with prejudice and in its entirety; 26 2. That Plaintiff take nothing by reason of this FAC and that judgment is 27 entered against Plaintiff and in favor of the UMG Defendants; 28 CALDWELL LESLIE & PROCTOR -12- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 3. That the UMG Defendants be awarded attorneys’ fees and costs 2 incurred in defending this action; and 3 4. That the UMG Defendants be granted such other and further relief as 4 the Court may deem just and proper. 5 DATED: February 14, 2011 Respectfully submitted, 6 CALDWELL LESLIE & PROCTOR, PC LINDA M. BURROW HEATHER PEARSON 7 8 9 10 11 12 13 By /s/ LINDA M. BURROW Attorneys for Defendants UMG RECORDINGS, INC and INTERSCOPE RECORDS 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CALDWELL LESLIE & PROCTOR -13- DEFENDANTS UMG RECORDINGS, INC. AND INTERSCOPE RECORDS’ ANSWER TO FIRST AMENDED COMPLAINT 1 2 DEMAND FOR JURY TRIAL The UMG Defendants hereby demand trial by jury in this action. 3 DATED: February 14, 2011 Respectfully submitted, 4 CALDWELL LESLIE & PROCTOR, PC LINDA M. BURROW HEATHER PEARSON 5 6 7 8 9 10 11 By /s/ LINDA M. BURROW Attorneys for Defendants UMG RECORDINGS, INC. and INTERSCOPE RECORDS 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CALDWELL LESLIE & PROCTOR -1- UMG RECORDINGS, INC. AND INTERSCOPE RECORDS ANSWER TO COMPLAINT FOR COPYRIGHT INFRINGEMENT

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