Eight Mile Style, LLC et al v. Apple Computer, Incorporated
Filing
107
MOTION to Strike 79 Statement, 74 Response to Motion,,,,,,,,,,,,, Declaration of Patrick Sullivan and Statement of Material Facts and Conditional Motion to Strike Plaintiffs' Late-Produced Documents by Aftermath Records, Apple Computer, Incorporated. (Attachments: # 1 Index of Exhibits TO DEFENDANTS AFTERMATH RECORDS AND APPLE INC.S MOTION TO STRIKE DECLARATION OF PATRICK SULLIVAN AND PLAINTIFFS STATEMENT OF MATERIAL FACTS AND CONDITIONAL MOTION TO STRIKE PLAINTIFFS LATE-PRODUCED DOCUMENTS, # 2 Exhibit Declaration of Melinda LeMoine In Support of Defendants Aftermath Records and Apple Inc.s Motion to Strike Declaration of Patrick Sullivan and Plaintiffs Statement of Material Facts and Conditional Motion to Strike Plaintiffs Late-Produced Documents, # 3 Exhibit 1-A: Excerpts of transcript pages from the depositions of Patrick Sullivan taken on September 18, 2008 and October 1, 2008, # 4 Exhibit 1-B: E-mail between Ramona DeSalvo and Patrick Sullivan, dated August 27, 2008, # 5 Exhibit 1-C: E-mail between Ramona DeSalvo and Patrick Sullivan, dated August 20, 2008, # 6 Exhibit 1-D: Plaintiff Eight Mile Style, LLCs Responses to Defendants First Set of Interrogatories, dated March 21, 2008, # 7 Exhibit 1-E: Plaintiff Martin Affiliated, LLCs Responses to Defendants First Set of Interrogatories, dated March 21, 2008, # 8 Exhibit 1-F: Plaintiff Eight Mile Style, LLCs Responses to the Defendants First Set of Requests for Production of Documents, dated March 21, 2008, # 9 Exhibit 1-G: Plaintiff Martin Affiliated, LLCs Responses to Defendants First Requests for Production of Documents, dated March 21, 2008, # 10 Exhibit 1-H: Plaintiff Eight Mile Style, LLCs Responses to the Defendants Second Set of Requests for Production of Documents, dated August 8, 2008, # 11 Index of Exhibits 1-I: Plaintiff Martin Affiliated, LLCs Responses to Defendants Second Set of Requests for Production of Documents, dated August 8, 2008, # 12 Exhibit 1-J: Plaintiff Eight Mile Style, LLCs Responses to Defendants Second Set of Interrogatories, dated August 8, 2008, # 13 Exhibit 1-K: Plaintiff Martin Affiliated, LLCs Responses to Defendants Second Set of Interrogatories, dated August 8, 2008, # 14 Exhibit 2: Anderson v. United States, 39 Fed. Appx. 132, 2002 WL 857742 (6th Cir. May 3, 2002)) (Klaus, Kelly)
<![CDATA[
Eight Mile Style, LLC et al. v. Apple Computer Inc., et al. Case No. 2:07-CV-13164
EXHIBIT 1-D Plaintiff Eight Mile Style, LLC's Responses to Defendants' First Set of Interrogatories, dated March 21, 2008
5005843.1
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION STYLE LLC and MARTIN AFFILIATED LLC
EIGFJT
NILE
Plaintiffs
Case
No
207-ev-13164 Diggs Taylor Judge Donald
Scheer
vs
Hon Anna
Magistrate
COMPUTER INC and AFTERMATH RECORDS cl/b/a AFTERMATH ENTERTAINMENT
APPLE
Defendants
Howard
Hertz
Hertz Schram 1760 South
P26653 PC Road 300
48302
Richard
Busch Ballow
TN BPR14594
Plaza
King
1100
Telegraph
Union
Street Street
Bloemfield Hills
MI
315 Union
Nashville
248
335-5000
TN
37201
hhertz@hertzschram.com
615
259-3456
rbuschkingballow.com
Attorney
for
Plaintiffs
PLAINTIFF EIGHT MILE STYLE LLCS RESPONSES FIRST SET OF INTEROGATORIES
Plaintiff
TO DEFENDANTS
Eight
Mile
Style
LLC Eight Mile
provides
the
following
objections
and
responses
to
the First
Set of Interrogatories
Interrogatories
propounded
by Defendants
Apple
Inc
named
as
Apple
Computer Inc and Aftermath Records
dlb/a
Aftermath Entertainment
GENERAL OBJECTIONS
The
following General Objections apply
to
and
are
incorporated
in
each
and
every
response
to
each
and every
Interrogatory
whether
or not
such
General
Objections
are
expressly
incorporated
by reference
in such
response
Eight
Mile
objects
to
the
Interrogatories
to
the
extent
they
collectively
or
individually
seek
information
subject
to
or protected
by the
attorney-client
privilege
the attorney
work
prcduct
privilege
or any
other privilege or protection
from disclosure
Eight
Mile hereby
invokes
all
such
privileges
to
the
extent
implicated
by each
Interrogatory
and excludes
privileged
and
prcitected
information
from
its
responses
to
the
Interrogatories
Any
disclosure
of
information
protected
by
those
privileges
is
inadvertent
and
is
not
intended
to
waive
any
privilege
or
protection
Eight
Mile objects
to
the
Interrogatories
to
the
extent
they
purport
to
impose on
Eight
Mile any obligation
that
is
different
from or
greater
than
any imposed by the Federal
Rules
of Civil
Procedure the Local
Rules
of the United
States
District
Court
for
the
Eastern
District
of
Michigan
or
any other applicable law or rule
Eight
Mile objects
to
the
Interrogatories
as
duplicative
unduly
burdensome
and
harassing
to
the
extent
they
seek
information
that
is
equally
available
to
Defendants
or
information
that
could
be
derived
or
ascertained
by Defendants
with
substantially
the
same
effort
that
would
be
required
of Eight Mile from review
of the documents
produced
in this
case
Eight
Mile objects
to
the Interrogatories
to
the
extent
they
seek
information
that
is
not
in Eight
Miles
possession
custody
or control
or
that
is
publicly
available
Eight Mile
objects
to
the
Interrogatories
to
the extent
they
seek
information
that
is
confidential
proprietary
trade secret
information
and/or
competitively
sensitive
material
Eight
Mile
will
disclose
such
responsive
non-privileged
information
only
upon
entry
of
and
in
accordance
with
the terms
of an appropriate
protective
order
To
the
extent
that
the
Interrogatories
seek
information
concerning
an
identified
contention
or
factual
issue
Eight
Mile
objects
that
the Interrogatories
are
premature
Discovery
in
this
case
recently
commenced
and Eight
Mile has
not
completed
its
investigation
of the facts
relevant
to this
case
Eight
Miles
responses
are
necessarily
preliminary
and
are
made
without
prejudice
to
its
right
to
disclose
introduce
or rely
upon
information
that
may
be
later
discovered
or produced
In
responding
to
the
Interrogatories
Eight
Mile
does
not
waive
or
intend
to
waive
any
privilege
or
objection
including
but
not
limited
to
any
objections
to
the
competency
relevance
materiality
or
admissibility
of
any
of
the
information
disclosed
in
response
to
the
Interrogatories
No
objection
or
response
made
in these
responses
and objections
shall
be deemed
to
constitute
representation
by Eight Mile
as
to
the
existence
or non-existence
of the information
requested
Eight
Mile objects
to
the
Interrogatories
as
vague
ambiguous
overly
broad
and
unduly
burdensome
to
the
extent
any Interrogatory
requires Eight
Mile
to
provide
information
that
is
different
from or
at
different
time
than
as required
under
Federal
Rule of
Civil
Procedure
26a2
Eight
Mile
objects
to
the
Interrogatories
as
vague
ambiguous
overly
broad
and
unduly
burdensome
to
the
extent
any Interrogatory
commands
or requires Eight
Mile
to
provide
responses
or documents
in
any manner
or to
any extent
that
is
different
that
the
scope
provided
by Rules 33 and 34 of the Federal
Rules
of Civil
Procedure
OBJECTIONS AND RESPONSES
TO INTERROGATORIES
INTERROGATORY NO.1
Identify
all
works
for
which You seek
relief
through
Your Complaint
RESPONSE
TO INTERROGATORY NO.1
its
Eight Mile incorporates
General
Objections
above
Subject
to
and without
waiver
of the
foregoing
General
Objections
Eight
Mile responds
that
any
relevant
information
that
may
be
within
the
scope
of
this
Interrogatory
may
be
determined
by
Defendants
examination
of
the
Complaint
filed
in
this
matter
in
particular
paragraph
and
collective
Exhibit
attached
to
the Complaint
Defendants
are
in possession
of
the
Complaint
and Exhibit
referenced
therein
and the burden of deriving
that
information
is
substantially
the
same
for
Defendants
as
for
Eight
Mile
and
therefore
Eight
Mile
refers
Defendants
to
same
See
Fed
Civ
33d
in this
Further
see
Schedule
Plaintiffs
Compositions
attached
hereto
Discovery
case
is
ongoing
and Eight
Mile reserves
the
right
to
supplement
or
amend
this
response
at
later
time
INTERROGATORY NO.2
For each work
identified in
Your
response
to
Interrogatory
No
above
Identify
all
Persons
who have an ownership
interest
in
that
work
RESPONSE
See
TO INTERROGATORY NO.2
Response
to
Interrogatory
INTERROGATORY NO.3
Identify
all
Persons
with
knowledge
of any of the
matters
alleged
in
Your Complaint
RESPONSE
Eight
TO INTERROGATORY NO.3
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work product
doctrine
Eight
Mile
further
objects
to
this
Interrogatory
as
overly
broad
ambiguous
and unduly
burdensome
in that
it
is
not possible
for
Eight
Mile
to
know
all persons
who have knowledge
or the
of the
same
or what
an
unknown
third
person
may have
on
the
read about
the
Complaint
allegations
therein
Eight
Mile
further
objects
grounds
that
the
Interrogatory
is
vague
and ambiguous
with
respect
to
the
term
knowledge
to
of the
Complaint
and
its
allegations
Eight
Mile
fhrther
objects
to
this
Interrogatory
the
extent
the information
requested
is
within
the
possession
custody
or
control
of Defendants
Eight
Mile
further
objects
to
this
Interrogatory
to
the extent
the
information
requested
requires an
expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
Joel Martin
who may
be
contacted
through
Plaintiffs
counsel
of record
INTERROGATORY NO.4
For each
claim
set forth in
Your
Complaint
separately Identify
the
amount
of damages
and/or
losses
that
You
have
allegedly
suffered
under
each
claim
and
provide
detailed
calculation
illustrating
how You
arrived
at
each
amount
and the methodology
used
to
reach
each
damage
calculation
RESPONSE
Eight
TO INTERROGATORY NO.4
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
thjs
Interrogatory
to
the
extent
the
information
requested
is
within
the
possession
custody
or control
of Defendants
Eight
Mile
ftrther
objects
to
this
Interrogatory
to
the
extent
the
information
requested
requires
an
expert
opinion
Subject
to
and without
waiver
of the foregoing
General
and Specific
Objections
Eight
Mile
states
that
any relevant
information
that
may
he
within
the scope
of
this
Interrogatory
may
be
determined
by Defendants
examination
of the Complaint
filed
in this
matter
Defendants
are
in possession
of the Complaint
therefore
the burden of deriving
that
information
is
substantially
the
same
for
Defendants
as for
Eight
Mile
See
Fed
Civ
33d
Affiliated
As
set
forth
in the
Complaint
Eight
Mile and Martin
LLC
contend
that
as
result
of Defendants
willful
copyright
infringement
by the authorized
reproduction
distribution
and
sale
of
Plaintiffs
copyrighted
compositions
identified
in
Exhibit
to
the
Complaint
Plaintiffs
are
entitled
to
their
actual
damages
which
is
the
subject
of expert
opinion
and the
profits
of
Apple
that
are
attributable
to
the
digital
reproduction
sale
and
distribution
of
Plaintiffs
compositions
or
alternatively
statutory
damages
of
up
to
$150000
per
act
of
infringement
Plaintiffs
also
seek
additional
remedies
including
attorneys
fees
and
costs
pursuant
to
17
U.S.C
505
injunctive
relief
and declaratory
relief
Discovery
in
this
case
is
ongoing
and Eight
Mile reserves
the
right
to
supplement
this
response
at
later
time
INTERROGATORY NO.5
Identify
all
facts
that
support
Your
contention
that
Eight Mile and
Martin
have
never
authorized
Universal
to
license
the
works
to
Apple
as
alleged
in
Paragraph
12
of
Your
Complaint
RESPONSE
Eight
TO INTERROGATORY NO.5
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the information
requested
requires an
expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
to
the
best
of
its
knowledge
Plaintiffs
have
never
authorized
Universal
to
license
Plaintiffs
compositions
to
Apple
Plaintiffs
are the
owners
of the
composition
copyrights
set
forth
in Exhibit
to
the Complaint
and Schedule
identified
in
response
to
Interrogatory
As
the
exclusive
owners
of the musical
composition
copyrights
the
exclusive
right
among
others
to
reproduce
and
distribute
those
copyrighted
works
resides
with
Plaintiffs
or
those
who
Plaintiffs
authorize
to
reproduce
or distribute
said
works
Plaintiffs
have
not
authorized
Apple
and
or permitted
Aftermath on
Plaintiffs
behalf
to
authorize
Apple
to
reproduce
distribute
sell
Plaintiffs
copyrighted
compositions
much
less
reproduce
distribute
and
sell
them
without
compensation
to
either
or both
of the Plaintiffs
Plaintiffs
specifically
have
rejected
licenses
requested
and proposed
by
Aftermath
for
digital
phonorecord
delivery
DPD
licenses
to
Plaintiffs
and
Plaintiffs
advised
Aftermath
that
Plaintiffs
would
not
execute
the
DPD
prepared
by
or
for
Aftermath
Specifically
Joel
Martin
advised
Chad
Gary
Pat Blair
and others
at
UMG
for
Aftermaths
co-venturer
that
Plaintiffs
would
not
execute
Aftermaths
standard
licenses
digital
phonorecord
deliveries
If
any
digital
licenses
were
to
be
executed
at
all
they
would
have
to
contain
restrictions
and
limitations
as
dictated
by
Plaintiffs
including
but
not
limited
to
limit
on duration
of term
specified
territory
and
requirements
regarding
accounting
Aftermath was
advised
that
Plaintiffs
would
only
execute
digital
license
prepared
by
Plaintiffs
For
each
proposed
license
sent to
Plaintiffs
by Aftermath
which
contained
provision
purporting
to
license
the
digital
reproduction
and
distribution
of Plaintiffs
compositions such
licenses
were
denied
were
not
executed
and were
not
returned
to
Aftermath
but
such
rejected
licenses
were
retained
by
Plaintiffs
Aftermath
subsequently
sent modified
licenses
for
the reproduction
and
distribution
of Plaintiffs
works
in
Defendant
joint
Aftermath Records between
doing
business
as
Aftermath Entertainment Records
an
to
Aftermath
partnership division
is
venture
three entities
Interscope
California general unincorporated
the
Interscope Recordings
Partnership
Interscope corporation
Records
authorized
of
UMG
UMO
Inc
and
is
Delaware
do business
ARY
general division
Inc
of
California
corporation of
three
ARY
entities
in
the
State
of California Records Records
an
The
Interscope Interscope
Partnership unincorporated Corporation
partnership
comprised
UMU
UMG
and
PM
Productions
Inc
Delaware
physical
format
only
and omitted
provisions
regarding
the
digital
reproduction
and
distribution
of Plaintiffs
compositions which
modified
licenses
comported with
Plaintiffs
refusal
to
execute
Aftermaths
proposed
digital
licenses
of Plaintiffs
works
Further
Joel
Martin
advised
Pat
Blair
of
Aftermath
see
th.l
to
segregate
all
of
Plaintiffs
licenses
such
that
none of
Plaintiffs
licenses
would
authorize digital
reproduction
and
distribution
but only the mechanical
reproduction
and
distribution
of physical
product
In
addition
Plaintiffs
are cognizant
of the
difference
between
mechanical
license
for
physical
product
such as
compact
disc
and
DPD
license
for
the reproduction
and
distribution
of Plaintiffs compositions
in
digital
format
INTERROGATORY NO.6
Identi
all
facts
that
support
Your
contention
that
Eight Mile and
of the
Martin
have
never
authorized
Universal
to
engage
in
reproduction
or
distribution
digital
transmissions
through
third
parties
or otherwise
as
alleged
in Paragraph
12
of Your
Complaint
RESPONSE
TO INTERROGATORY NO.6
to
See Response
Interrogatory
INTERROGATORY NO.7
Identi
all
facts
that
support
Your
contention
that
Universal
has
on any
number
of
occasions
asked
Eight
Mile or Martin
to
execute
agreements
allowing
Apple
to
reproduce
and
distribute
the
digital
transmissions
but
Eight
Mile
and
Martin
have
not
provided
that
permission
as alleged
in Paragraph
12
of Your
Complaint
RESPONSE
See
TO INTERROGATORY NO.7
Response
to
Interrogatory
Further
on
single
occasion
Plaintiffs
may have
entered
into
contract
with
Universal
with
very
narrow
scope
of rights
granted
for mastertones
to
cell
phones
with
limited term
and
carefully
constructed
limitation
of rights
INTERROGATORY NO.8
Identify
all
facts
that
support
Your
contention
that
Eight
and
Mile
and
Martin
have
demanded
that
Apple
cease
and
desist
its
reproduction
distribution
of
the
digital
transmissions
of
the
Compositions
and Apple
has
refused
to
cease
and desist
as
alleged
in
Paragraph
14
of Your Complaint
RESPONSE
Eight
TO INTERROGATORY NO.8
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by
the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the
information
requested
requires
an
expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
that
subsequent
to
the audit performed
by the Gary Cohen Corporation
Plaintiffs
put
Aftermath on notice
of the
accounting
irregularities
including
those
with
respect
to
the
digital
distribution
of Plaintiffs
composition
Plaintiffs
also
sent
letter
to
Apple
on July
27
2007
instructing
Apple
to
cease
and
desist
from
the
further
unauthorized
use
of
Plaintiffs
compositions
See Fed
Civ
33d
INTERROGATORY NO.9
Identify
all
facts
that
support
Your contention
that
Apples
conduct
has
at
all
times been
knowing
and willful
as alleged
in Paragraph
18
of Your Complaint
RESPONSE
Eight
TO INTERROGATORY NO.9
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the
information
requested
requires
an
expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
at
no time did Apple
enter
into
any agreement with
Plaintiffs
owners
of the
musical
composition
copyrights
to
digitally
reproduce
synchronize
publicly
perform and/or
distribute
Plaintiffs
copyrighted
compositions yet Apple
reproduced
synchronized
publicly
performed
and/or
distributed
and
continues
to
do so
Plaintiffs
compositions
without
authorization
from
Plaintiffs
or Plaintiffs
authorized
agent
Further
Plaintiffs
sent
cease
and
desist
letter to
Apple
on July
27 2007 however
compositions
Apple has knowingly
and
willfully
failed
to
stop the infringement
of
Plaintiffs
Moreover
this action
commenced
on July
30
2007 and Apple
filed
its
Answer
to
Plaintiffs
Complaint
on September
14 2007
however
Apple
has
knowingly
and
willfully
failed
to
stop the
infringement
of Plaintiffs
compositions
despite
the
commencement
of
legal
action
INTERROGATORY
Identi
all
NO 10
that
facts
support
Your
contention
that
Apples
Miles
intentionally
wrongful
conduct
described
herein
has
intentionally
interfered
in
Eight
and Martins
existing
and
prospective
relationships
with
end users of the
Compositions
who
download
the
Compositions
via
iTunes
as
alleged
in Paragraph
21
of Your
Complaint
10
RESPONSE
Eight
TO INTERROGATORY
Mile incorporates
its
NO 10
Objections
General
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seek
legal
conclusion
and
to
the
extent
the
information
requested
requires
an
expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
Plaintiffs
own
interests
in
copyrighted
musical
compositions
see
Response
to
Interrogatory
No
and Schedule
Absent
violation
of
any of
Plaintiffs
exclusive
rights
Plaintiffs
would
have
entered
into
agreements
with
end users
of
Plaintiffs
works
however
Apple
deprived
Plaintiffs
of the right to
enter into
such
agreements
by usurping
Plaintiffs
role
as
the exclusive
rights
holder
INTERROGATORY
Identify
all
NO 11
that
facts
support
Your
contention
that
Apples
as
actions
described
above
constitute
unfair competition
with
respect
to
Eight
Mile and Martin
alleged
in Paragraph
24
of Your
Complaint
RESPONSE
Eight
TO INTERROGATORY
Mile incorporates
its
NO 11
Objections
General
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the
information
requested
requires
an expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
II
Mile
states
see Response
to
Interrogatory
10
The
same
facts
set
forth
in Interrogatory
10
cause
Apples
conduct
to
be
unfair
competition
Plaintiffs
as
owners
of
the
copyrighted
musical
compositions
identified
in
Interrogatory
No
who
and Schedule
attached
hereto
have proprietary
rights
to
deal
with
or not
third
parties
wish
to
use
Plaintiffs
works
Apple
has
entered
into
business
relationship
with
end users and with
Aftermath
that
effectively
competes
with
Plaintiffs
for
the
use
of
Plaintiffs
works
Holding
themselves
out
as
owners
of
Plaintiffs
copyrighted
works when
they
are
not
constitutes
unfair competition
among
other violations
of
law
INTERROGATORY
Identify
all
NO 12
that
facts
support
Your
contention
that
Apples
wrongful conduct
has
been
knowing
and willful
as
alleged
in Paragraph
25 of Your Complaint
RESPONSE
Bight
TO INTERROGATORY
Mile incorporates
its
NO 12
Objections
General
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the
information
requested
requires
an expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Bight
Mile
states
Defendants
have
knowledge
that
neither
of
them
are
owners
of
Plaintiffs
copyrighted
works
Further
Apple
is
aware
that
the
unauthorized
use
of copyrighted
works
is
impermissible
Punch
Andrews
of Michigan
who
is
the manager
for
Kid Rock
and Bob Seger
put
Apple on notice
that
Apple
did not
have the proper
publishing
licenses
and demanded
those
works
be
taken
down
from
Apples
store
iTunes
Apple
responded
by
taking
down
the
12
unlicensed
works
from iTunes
Thus
on demand
Apple
removed
the
unauthorized
material
thereby
recognizing
its
obligation
to
remove
those
works from
its
store
because
Apple
did not
have valid licenses
for
those
works
In
this
action
despite
knowledge
of
the
foregoing
Apple
continued
to
reproduce
distribute
sell
and display
Eminem
recordings
containing
Plaintiffs
musical
compositions
in
violation
of Plaintiffs
rights
Plaintiffs
sent
cease
and
desist
letter
to
Apple
on July
27
2007
which
was
ignored
Finally
this
lawsuit
was
filed
on July
30
2007
and Apple
continues
to
infringe
in
knowing
willful
disregard
of Plaintiffs
rights
INTERROGATORY
Identify
all
NO 13
that
facts
support
Your contention
that
Apples
wrongful conduct
constitutes
unfair competition
under
state
law
as
alleged
in Paragraph
28 of Your Complaint
RESPONSE
Eight
TO INTERROGATORY
Mile incorporates
its
NO 13
Objections
General
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the information
requested
requires an expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
see Response
to
Interrogatory
10
INTERROGATORY
Identify
all
NO 14
that
facts
support
Your
contention
that
Apples
conduct
conduct
constitutes
an unfair
unconscionable
deceptive
method
act
or practice
in
the
of trade or commerce
under
13
MCL
445.903
as
alleged
in Paragraph
31
of Your
Complaint
RESPONSE
Eight
TO INTERROGATORY NO
Mile incorporates
its
14
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the information
requested
requires an
expert
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
see
Response
to
Interrogatory
10
Further
Defendants
do not
own
do not
control
and
do not
have
the
right
to
reproduce
synchronize
publicly
perform
distribute
or
display
Plaintiffs
copyrighted
works
INTERROGATORY
Identify
all
NO 15
that
facts
support
Your contention
that
the terms
of
March
1998 and July
2003 Agreements
including
without
limitation
the terms
of Paragraph
captioned
Mechanical
Royalties
of each
such Agreement
do not provide
any defense
to
any
of the
claims
in
Your
Complaint
RESPONSE
Eight
TO INTERROGATORY
Mile incorporates
its
NO 15
Objections
General
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
the
extent
this
Interrogatory
to
the
extent
it
seeks
legal
conclusion
and
to
the
extent
the
information
requested
requires
an
expert
opinion
14
Subject
to
and without
waiver
of
the
foregoing
General
and Specific
Objections
Eight
Mile
states
The
language
used
in
the
Agreements
demonstrate
that
digital
uses
were
not
contemplated
or
covered
under
Paragraph
Furthermore
the
Agreements
do not
contain
or
constitute
or even
purport
to
constitute
license
of
any kind
Paragraph
merely speaks
to
certain royalty rates
that
will
apply
under
certain
licenses
that
will
be given
to
Aftermath and
its
distributors/licensees
but
omits
numerous
material
terms
and
conditions
that
are
essential
to
creating
such
license
Further
the
parties
subsequent
conduct
demonstrates
their
understanding
as
to
the
actual
granting
of
licenses
and
the
procedures
therefor
For
example
even
with
respect
to
the
granting
of mechanical
licenses
for
physical
product
Plaintiffs
have
used
their
own
license
forms
with
terms
and
conditions
that
are
acceptable
to
them
and
Paragraph
was
not
understood
by the
parties
to
constitute
mechanical
license
Furthermore
the
course
of
conduct
between
Plaintiffs
and Aftermath
including
Interscope
and Universal
shows
that
Plaintiffs
would
only
enter
into
licenses
for
digital
uses
i.e
the
mastertone
agreement
approved
by
and
acceptable
to
Plaintiffs
including
but
not
limited
to
limit
to
duration
territory
and
requirements
for
accounting
and
Universal
sent
proposed
licenses
to
Plaintiffs
for
digital
use
that
were
rejected
as
not
being
acceptable
As
discovery
is
ongoing
Plaintiffs
reserve
the right
to
supplement
this
response
INTERROGATORY
IdentifS
all
NO 16
acts that
wrongful
You
contend
Aftermath
has
committed
regarding
any
of
the matters
alleged
in
Your Complaint
RESPONSE
Eight
TO INTERROGATORY
Mile incorporates
its
NO 16
Objections
General
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
15
and work
product
doctrine
Eight
Mile objects
to
this
Interrogatory
to
the extent
it
seeks
expert
opinion
or
expert
testimony
Eight
Mile
objects
to
this
Interrogatory
as
vague
ambiguous
overly
broad
unduly
burdensome
irrelevant
and
not
reasonably
calculated
to
lead
to
the
discovery
of admissible
evidence
Eight
Mile
further
objects
to
this
Interrogatory
to
the extent
the information
requested
is
within
the
possession
custody
or control
of Defendants
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
Aftermath purported
to
license
Eight
Miles
copyrighted
musical
compositions
to
Defendant
Apple
which
such
compositions
Aftermath
neither
owns
or
controls
See
also
Response
to
Interrogatory
Nos
67 89
10 11 13 14 and 15
INTERROGATORY
Identify
all
NO 17
who
have had any
involvement whatsoever
in the
Persons
draffing
negotiation
execution
or
performance
of
any
agreement
relating
to
the
distribution
in
digital
format
of any of the works
at
issue in Your Complaint
RESPONSE
Eight
TO INTERROGATORY NO 17
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile objects
to
this
Interrogatory
to
the
extent
it
seeks
expert
opinion
or
expert
testimony
Eight
Mile
objects
to
this
Interrogatory
as
vague
ambiguous
overly
broad
unduly
burdensome
irrelevant
and
not
reasonably
calculated
to
lead
to
the
discovery
of admissible
evidence
Eight
Mile
further
objects
to
this
Interrogatory
to
the
extent
the information
requested
is
within
the possession
custody
or control
of Defendants
Eight
Mile
further
objects
to
this
Interrogatory
to
the extent
it
seeks
confidential
or commercial
information
trade secrets
or confidential
research
16
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
it
only enters
into
licenses
for
the
digital
distribution
of
its
compositions
which
Eight
Mile has
prepared
Eight
Mile has
entered
into
certain
ringtone
and mastertone
licenses
which
have been drafted and/or
negotiated
by Joel Martin
Mark Levinsobn
and Alan Skiena
do Mark
Levinsohn
Universal
and
Aftermath
have
knowledge
of
those
individuals
within
their
organization
with
knowledge
INTERROGATORY
Identif5t
all
NO 18
involved
in the
Persons
drafting
negotiation
execution
or performance
of any
part
of the
March
1998 Agreement including
without
limitation
Paragraph
thereof
RESPONSE
Eight
TO INTERROGATORY
Mile incorporates
its
NO 18
Objections
General
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile objects
to
this
Interrogatory
to
the
extent
it
seeks
expert
opinion
or
expert
testimony
Eight
Mile
further
objects
to
this
Interrogatory
as
vague
ambiguous
overly
broad
unduly
burdensome
and
not
reasonably
calculated
to
lead
to
the
discovery
of admissible
evidence
Eight
Mile
further
objects
to
this
Interrogatory
to
the
extent
the information
requested
is
within
the possession
custody
or control
of Defendants
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
Joel
Martin
Howard
Hertz
Esq
Peter
Hertz
Schram
PC
1760
South Telegraph
Road
300
LLP
Scott
Bloomfield Hills
Michigan
48302
Patemo
Esq
King Holmes
Patemo
Berliner
1900 Ave Of The Stars
25th
Floor Los Angeles
California
90067
and Marnie Nieves and
Aronson do
Kelly
Klaus
Esq Munger
90071-1560
Tolles
Olson
LLP
355 South
Grand
Ave 35
Floor Los Angeles
California
and Paul Rosenberg
New York
17
INTERROGATORY
IdentifS
all
NO 19
involved
in the
Persons
drafting
negotiation
execution
or performance
of any
part of the July
2003 Agreement including
without
limitation
Paragraph
thereof
RESPONSE
Eight
TO INTERROGATORY NO 19
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
objects
to
this
Interrogatory
to
the
extent
it
seeks
expert
opinion
or
expert
testimony
Eight
Mile
further
objects
to
this
Interrogatory
as
vague
the
ambiguous
overly
broad
unduly
burdensome
and
not
reasonably
calculated
to
lead
to
discovery
of admissible
evidence
Eight
Mile
further
objects
to
this
Interrogatory
to
the
extent
the information
requested
is
within
the possession
custody
or control
of Defendants
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
states
Joel
Martin
Mark Levinsohn
York
Esq
Gary
Levinsoim
Amay LLP
Ziffren
1790 Broadway
10th
Floor
New York New
Stiffelman
10019
Stiffleman
Brittenham
Branca
Fischer
Gilbert-Lurie
Cook
LLP
1801
Century
Park
Los Angeles
California
90067
and Rand
Hoffman and
Lisa Rogell
Interscope
Records
2220
Colorado
Avenue
Santa
Monica
CA 90404
INTERROGATORY
Identify
all
NO 20
You have had
with
communications
any Person
including
without
limitation
Eminem
captioned
or
any of
Eminems
representatives
regarding
this
lawsuit
or
regarding
the
lawsuit
Productions
LLC
et
at
Aftermath
Records
cl/b/a
Aftermath
Entertainment
et
at
Case
No
CV-07-033l4
C.D Cal
or any of the matters
alleged
in either
action
IS
RESPONSE
Eight
TO INTERROGATORY
Mile incorporates
its
NO
20
above Mile
General
Objections
Eight
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
objects
to
this
Interrogatory
to
the extent
it
seeks
expert
opinion
or
expert
testimony
Eight
Mile
further
objects
to
this
Interrogatory
as
vague
ambiguous
overly
broad
unduly
burdensome
and
not
reasonably
calculated
to
lead
to
the
discovery
of admissible
evidence
Eight
Mile
further
objects
to
this
Interrogatory
to
the
extent
the information
requested
is
within
the possession
custody
or control
of Defendants
Bight
Mile
further
objects
to
this
Interrogatory
to
the
extent
it
seeks
discovery
in
separate
action
entitled
F.B
Productions
LLC
et
al
Aftermath
Records
d/b/a
Aftermath
Entertainment
et
al
Case
No
CV-07-033 14
C.D Cal
action
which
such
discovery
is
subject
to
separate
scheduling
order
inapplicable
to
this
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Bight
Mile
states
it
communicated
with
Gary Stiffleman
Ziffren
Brittenham Branca
Fischer
Gilbert
Lurie Stiffelman
Cook
LLP
1801
Century
Park
Los Angeles
California
90067
INTERROGATORY
Identify
all
NO 21
who
participated in
Persons
the
preparation
of
Your
responses
to
these
Interrogatories
RESPONSE
Bight
TO INTERROGATORY NO 21
Mile incorporates
its
General
Objections
above
Eight
Mile
specifically
objects
to
this
Interrogatory
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and work
product
doctrine
Eight
Mile
further
objects
to
this
Interrogatory
as
vague ambiguous
19
overly
broad
unduly
burdensome
and not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Subject
to
Eight
Miles
General
and
Specific
Objections
Eight
Mile
responds
that
Plaintiffs
counsel
and
Plaintiffs
participated
in the
preparation
of Eight
Miles
responses
DATED
March 21 2008
Respectfully
submitted
KING
BALLOW
Richard
Busch
Street Street
TN
Bar
No
014594
1100 Union 315 Union
Plaza
Nashville
TN
37201
615
259-3456
rbusehkingba1low.com
Howard
Hertz
Hertz
Schram
P26653 PC
Road
Suite 300
1760
Telegraph
Bloomfield Hills
MI
48302
248
335-5000
hhertz@hertzschram.com
Attorneys
for Plaintiffs
20
CERTIFICATE
The
postage
OF SERVICE
foregoing
undersigned
hereby
certifies the
that
the
document
was
served
via
U.S
Mail
pre-paid
and via
e-mail to
following
Counsel
Daniel
On
Quick Esq
Wright
behalf
of Inc and Aftermath Records
d/b/a
Apple
Aftermath
Dickinson 38525
PLLC
Ave
Entertainment
Woodward
Suite 2000
Bloomfield Hills
MI
48304
248
433-7200
corn
dquickdickinsonwright
Kelly
Klaus
Tolles
Esq
Olson
Munger
LLP
355 South Grand
Suite 3500
Ave
Los Angeles
CA
90071-1560
213
683-9238
kelly.klausmto.com
this
21
day of March 2008
21
2:07-civ- Eight Mile Style, et al. v. Apple Computers, et. Al SCHEDULE 1 - PLAINTIFFS' COMPOSITIONS
COMPOSITION TITLE 40 OZ ALBUM TITLE D12 WORLD REGISTRATION NUMBER CLAIMANT PA 1-245-114 Eight Mile Style Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Martin Affiliated Runyon Avenue/EMI April Music Tarpo Music /Nottingdale Songs PA 1-245-103 Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music PA 1-204-555 Eight Mile Style Martin Affiliated PA 1-204-569 Carter Boys Music / EMI April Music Efartooee Music/Raha Music/Mafia Boy Music Eight Mile Style Martin Affiliated Ain't Nothin' Goin on But Funkin Music / Warner PA 1-325-368 Chappell Music Eight Mile Style Elvismambo/Music Of Windswept Hits From Da Bong/BMG Songs Idiotic Biz/EMI April Music Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music Ain't Nothin' Goin on But Funkin Music / Warner PA 1-295-394 Chappell Music Bat Future Music / Songs of Universal Inc. Eight Mile Style Elvismambo/Music Of Windswept Jenellerene/Hard Workin' Black Folks / Warner Chappell Music Inc. Martin Affiliated
6 In the Morning
D12 WORLD
8 Mile 8 Miles & Running
8 Mile S/T 8 Mile S/T
American Psycho 2
D12 WORLD
Ass Like That
Encore (Deluxe Version)
COMPOSITION TITLE Average Man
ALBUM TITLE Cheers
Big Weenie
Encore (Deluxe Version)
Bitch
D12 WORLD
Business
The Eminem Show
REGISTRATION NUMBER CLAIMANT PA 1-245-073 Eight Mile Style Martin Affiliated Obie Trice Publishing / Almo Music Corp. Ain't Nothin' Goin on But Funkin Music / Warner PA 1-295-392 Chappell Music Bat Future Music / Songs of Universal Inc. Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Jenellerene/Hard Workin' Black Folks / Warner Chappell Music Inc. PA 1-245-115 Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Martin Affiliated Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music Ain't Nothin' Goin on But Funkin Music / Warner PA u 2-696-276 Chappell Music Eight Mile Style Elvismambo/Music Of Windswept Feemstro Music / Universal Music Z-tunes, LLC Sony ATV Music Publishing Eight Mile Style Martin Affiliated Obie Trice Publishing / Almo Music Corp. Eight Mile Style Eight Mile Style Sony ATV Music Publishing Andorra Music / Sony ATV Tunes Eight Mile Style Martin Affiliated
Cheers
Cheers
PA 1-245-074
Cleaning Out My Closet Cleaning Out My Closet Crazy In Love
The Eminem Show Curtain Call - The Hits (Deluxe Version) Encore (Deluxe Version)
PA 1-073-403 PA 1-073-403 (COHM) PA 1-295-397
COMPOSITION TITLE Curtains Close Curtains Up Curtains Up Don't Come Down
ALBUM TITLE Encore (Deluxe Version) The Eminem Show Encore (Deluxe Version) Cheers
Don't Push Me
Get Rich or Die Trying
REGISTRATION NUMBER CLAIMANT PA 1-295-390 Eight Mile Style Martin Affiliated PA u 2-673-526 Eight Mile Style PA 1-295-387 Eight Mile Style Martin Affiliated PA 1-245-078 Eight Mile Style Heavy Crate Publishing / Reach Global Inc. Martin Affiliated Obie Trice Publishing / Almo Music Corp. Warner Chappel Music PA 1-204-560 Eight Mile Style Lloyd Banks Music / Almo Music Corp. Martin Affiliated Universal Music Publishing / High On Life Music Dertyworks Publishing/EMI April Music Eight Mile Style Obie Trice Publishing / Almo Music Corp. Sony ATV Music Publishing Eight Mile Style Martin Affiliated Eight Mile Style Martin Affiliated 50 Cent Music / Universal Music Corp. Ain't Nothin' Goin on But Funkin Music / Warner Chappell Music Bat Future Music / Songs of Universal Inc. Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Jenellerene/Hard Workin' Black Folks / Warner Chappell Music Inc.
Drips
The Eminem Show
PA 1-104-808
Dude Em Calls Paul Encore
D12 WORLD Encore (Deluxe Version) Encore (Deluxe Version)
PA 1-245-084 PA 1-295-393 PA 1-295-406
COMPOSITION TITLE Evil Deeds
ALBUM TITLE Encore (Deluxe Version)
REGISTRATION NUMBER PA 1-295-402
Final Thought
Encore (Deluxe Version)
PA 1-295-389
CLAIMANT Ain't Nothin' Goin on But Funkin Music / Warner Chappell Music Bat Future Music / Songs of Universal Inc. Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Jenellerene/Hard Workin' Black Folks / Warner Chappell Music Inc. Eight Mile Style Martin Affiliated Cackleberry Entertainment / Karam's kids Songs Eight Mile Style Karam's Kids Songs / Arthouse Entertainment Inc. Martin Affiliated Obie Trice Publishing / Almo Music Corp. Eight Mile Style Martin Affiliated Dertyworks Publishing/EMI April Music Eight Mile Style Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Martin Affiliated Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music Eight Mile Style Martin Affiliated Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music
Follow My Life
Cheers
PA 1-245-107
Gatman And Robbin Get My Gun
The Massacre D12 World
PA 1-364-299 PA 1-245-109
Git Up
D12 World
PA 1-245-111
COMPOSITION TITLE Got Some Teeth
ALBUM TITLE Cheers
REGISTRATION NUMBER CLAIMANT PA 1-245-108 Buffalo Music / Bug House Inc. Eight Mile Style Martin Affiliated Nuez Music / Reach Global Songs Obie Trice Publishing / Almo Music Corp. Sony ATV Music Publishing Unforgettable Music Ltd. Universal music Publishing / Polygram International Ain't Nothin' Goin on But Funkin Music / Warner Chappell Music Sony ATV Music Publishing Eight Mile Style Eight Mile Style Eight Mile Style Martin Affiliated Obie Trice Publishing / Almo Music Corp. 221 Publishing / Universal Music Corp Eight Mile Style Martin Affiliated Headrush Tunes / Serving You Musically Publishing Universal Music Publishing Universal Music Publishing / High On Life Music Eight Mile Style Martin Affiliated Heavy Crate Publishing / Reach Global Inc. Obie Trice Publishing / Almo Music Corp. Dertyworks Publishing/EMI April Music Eight Mile Style Full Proof Publishing/EMI Blackwood Martin Affiliated Reach Global Songs
Guilty Conscience
Curtain Call - The Hits (Deluxe Version)
PA 954-422 (COHM)
Hailie's Song Hands On You
The Eminem Show Cheers
PA u 2-725-252 PA 1-245-080
High All The Time
Get Rich or Die Trying
PA 1-204-559
Hoodrats
Cheers
PA 1-245-106
How Come
D12 World
PA 1-245-112
COMPOSITION TITLE I'm Supposed To Die Tonight
ALBUM TITLE The Massacre
REGISTRATION NUMBER PA 1-364-300
CLAIMANT Eight Mile Style Martin Affiliated Nueve Music Universal Music Corp. Eight Mile Style Ain't Nothin' Goin on But Funkin Music / Warner Chappell Music Bat Future Music / Songs of Universal Inc. Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Jenellerene/Hard Workin' Black Folks / Warner Chappell Music Inc. Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Idiotic Biz/EMI April Music Maffy Music Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music Universal Music Corp. Zomba Enterprizes Eight Mile Style Martin Affiliated Obie Trice Publishing / Almo Music Corp. Andy Thelusma Publishing / EMI Blackwood Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Full Proof Publishing/EMI Blackwood Runyon Avenue/EMI April Music Eight Mile Style Martin Affiliated Sony ATV Music Publishing
Just Don't Give a Fuck Just Lose It
Curtain Call - The Hits (Deluxe Version) Encore (Deluxe Version)
PA u 2-333-090 PA 1-268-078
Keep Talkin'
D12 World
PA 1-245-110
Lady
Cheers
PA 1-245-102
Leave Dat Boy Alone
D12 World
PA 1-245-085
Like Toy Soldiers
Encore (Deluxe Version)
PA 1-295-400
COMPOSITION TITLE Lose Yourself Lose Yourself (Parody done by Weird Al "Couch Potato") Love Me
ALBUM TITLE 8 Mile S/T
REGISTRATION NUMBER PA 1-152-688 Eight Mile Style Martin Affiliated
CLAIMANT
Poodle Hat 8 Mile S/T
PA 1-152-688 PA 1-204-567
Love You More Loyalty
Encore (Deluxe Version) D12 World
PA 1-295-408 PA 1-245-104
Eight Mile Style Martin Affiliated 50 Cent Music / Universal Music Corp. Eight Mile Style Martin Affiliated Obie Trice Publishing / Almo Music Corp. Eight Mile Style Martin Affiliated Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Obie Trice Publishing / Almo Music Corp. Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music Eight Mile Style Martin Affiliated Figga Six Music / Downtown Music Publishing, LLC Universal Music Publishing Universal Music Publishing / High On Life Music Eight Mile Style Martin Affiliated Ain't Nothin' Goin on But Funkin Music / Warner Chappell Music Bat Future Music / Songs of Universal Inc. Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Jenellerene/Hard Workin' Black Folks / Warner Chappell Music Inc.
Many Men (aka Death Wish)
Get Rich or Die Trying
PA 1-204-558
Mockingbird
Encore (Deluxe Version)
PA 1-295-396
Mosh
Encore (Deluxe Version)
PA 1-295-401
COMPOSITION TITLE My 1st Single My Band
ALBUM TITLE Encore (Deluxe Version) D12 World
My Dad's Gone Crazy
The Eminem Show
REGISTRATION NUMBER CLAIMANT PA 1-295-405 Eight Mile Style Martin Affiliated PA 1-245-105 Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music Ain't Nothin' Goin on But Funkin Music / Warner PA u 2-697-183 Chappell Music Eight Mile Style Elvismambo/Music Of Windswept Feemstro Music / Universal Music Z-tunes, LLC Sony ATV Music Publishing 50 Cent Music / Universal Music Corp. Ain't Nothin' Goin on But Funkin Music / Warner Chappell Music Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Nate Dogg Music / Reach Global Songs Eight Mile Style Martin Affiliated Obie Trice Publishing / Almo Music Corp. Sony ATV Music Publishing 50 Cent Music/Universal Music Corp Bros. Grimm/Embassy Music Eight Mile Style Martin Affiliated Embassy Music Corp. (BMI) Lloyd Banks Music
Never Enough
Encore (Deluxe Version)
PA 1-295-403
Never Forget Ya
Cheers
PA 1-245-101
On Fire
Hunger for More
PA 1-256-131
COMPOSITION TITLE One Shot, 2 Shot
ALBUM TITLE Encore (Deluxe Version)
Outro
Cheers
REGISTRATION NUMBER CLAIMANT PA 1-295-398 Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Idiotic Biz/EMI April Music Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music PA 1-245-076 Eight Mile Style Martin Affiliated Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Obie Trice Publishing/Almo Music/Rondor Music Intl Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Universal Music Corp. / High On Life Music Eight Mile Style Martin Affiliated 50 Cent Music/Universal Music Corp Eight Mile Style Martin Affiliated Eight Mile Style Martin Affiliated Eight Mile Style Martin Affiliated Ain't Nothin' Goin on But Funkin Music/ Warner Music Corp Bat Future Music/Songs of Universal Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Jenellerene/Hard Workin' Black Folks
Patiently Waiting
Get Rich or Die Trying
PA 1-204-561
Paul Places To Go
Encore (Deluxe Version) 8 Mile S/T
PA 1-295-388 PA 1-204-556
Puke Rabbit Run
Encore (Deluxe Version) 8 Mile S/T
PA 1-295-404 PA 1-204-568
Rain Man
Encore (Deluxe Version)
PA 1-295-391
COMPOSITION TITLE Rap Game
ALBUM TITLE 8 Mile S/T
Ricky Ticky Toc
Encore (Deluxe Version) Curtain Call - The Hits (Deluxe Version)
Role Model
REGISTRATION NUMBER CLAIMANT PA 1-204-570 Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music PA 1-295-409 Eight Mile Style Martin Affiliated Ain't Nothin' Goin on But Funkin Music/ Warner PA 954-427 (COHM) Music Corp Sony ATV Music Publishing Eight Mile Style WB Music / Hardworking Black Folks PA 1-104-945 (COHM) Eight Mile Style Elvismambo/Music Of Windswept Sony ATV Music Publishing Ain't Nothin' Goin on But Funkin Music/ Warner Music Corp Elvismambo/Music Of Windswept Eight Mile Style Sony ATV Music Publishing Feemstro Music/Universal Music - Z Tunes LLC Ain't Nothin' Goin on But Funkin Music/ Warner Music Corp Eight Mile Style Martin Affiliated Elvismambo/Music Of Windswept Obie Trice Publishing/Almo Music/Rondor Music Intl
Say Goodbye To Hollywood
The Eminem Show
Say What You Say
The Eminem Show
PA 1-073-017
Shit Hit's The Fan
Cheers
PA 1-245-077
COMPOSITION TITLE Shit On You
ALBUM TITLE Curtain Call - The Hits (Deluxe Version)
REGISTRATION NUMBER PA 1-164-487 (COHM)
CLAIMANT Dertyworks Publishing/EMI April Music Sony ATV Music Publishing Eight Mile Style Idiotic Biz/EMI April Music Runyon Avenue/EMI April Music Screen Gems/EMI Swifty McVay Publishing/EMI April Music Eight Mile Style Sony ATV Music Publishing Sony/Daskel, LLC Eight Mile Style Sony ATV Music Publishing 50 Cent Music/Universal Music Corp Eight Mile Style Martin Affiliated Obie Trice Publishing/Almo Music/Rondor Music Intl Universal Music Corp. Yel-Nats Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Hennessey for Everyone Music/Alexra Music Dertyworks Publishing/EMI April Music Eight Mile Style Martin Affiliated Obie Trice Publishing/Almo Music/Rondor Music Intl Eight Mile Style Sony ATV Music Publishing Eight Mile Style Eight Mile Style Martin Affiliated Eight Mile Style Sony ATV Music Publishing
Sing For The Moment Again
The Eminem Show
PA 1-104-947 (COHM)
Soldier Spend Some Time
The Eminem Show Encore (Deluxe Version)
PA 1-073-064 (COHM) PA 1-295-395
Spit Shine
8 Mile S/T
PA 1-204-557
Spread Yo Shit
Cheers
PA 1-245-081
Square Dance Steve Berman (Skit) Steve's Coffee House Superman
The Eminem Show The Eminem Show D12 World The Eminem Show
PA 1-073-065 (COHM) PA u 2-697-161 PA 1-245-086 PA 1-073-066
COMPOSITION TITLE The Kiss The Real Slim Shady
ALBUM TITLE The Eminem Show Curtain Call - The Hits (Deluxe Version)
Till I Collapse Till The End
The Eminem Show Hunger for More
Warrior part 2
Hunger for More
We All Die One Day
Cheers
REGISTRATION NUMBER CLAIMANT PA u 2-782-860 Eight Mile Style Ain't Nothin' Goin on But Funkin Music/ Warner PA 980-855 (COHM) Music Corp Eight Mile Style Bug Music / Strawberry Blond Elvismambo/Music Of Windswept Sony ATV Music Publishing PA u 2-697-181 Eight Mile Style Nate Dogg Music / Reach Global Songs PA 1-256-130 Eight Mile Style Martin Affiliated Lloyd Banks Music PA 1-256-133 50 Cent Music/Universal Music Corp Eight Mile Style Martin Affiliated Lloyd Banks Music Nate Dogg Music / Reach Global Songs PA 1-245-075 50 Cent Music/Universal Music Corp Eight Mile Style Martin Affiliated Lloyd Banks Music Obie Trice Publishing/Almo Music/Rondor Music Intl Eight Mile Style Martin Affiliated Dertyworks Publishing/EMI April Music Sony ATV Music Publishing Eight Mile Style Feemstro Music/Universal Music - Z Tunes LLC Full Proof Publishing/EMI Blackwood Idiotic Biz/EMI April Music Runyon Avenue/EMI April Music Swifty McVay Publishing/EMI April Music
We As Americans When the Music Stops
Encore (Deluxe Version) The Eminem Show
PA 1-295-407 PA 1-073-063 (COHM)
COMPOSITION TITLE Without Me
ALBUM TITLE Curtain Call - The Hits (Deluxe Version)
REGISTRATION NUMBER PA 1-073-070 (COHM)
CLAIMANT Buffalo Music /BUG ADMIN. Eight Mile Style Sony ATV Music Publishing Nuez Music / Reach Global Songs Satisfaction Fufilled Ltd. Unforgettable Music Buffalo Music /BUG ADMIN. Eight Mile Style Sony ATV Music Publishing Nuez Music / Reach Global Songs Satisfaction Fufilled Ltd. Unforgettable Music Buffalo Music /BUG ADMIN. Eight Mile Style Sony ATV Music Publishing Nuez Music / Reach Global Songs Satisfaction Fufilled Ltd. Unforgettable Music Eight Mile Style Martin Affiliated
Without Me
Curtain Call - The Hits (Deluxe Version)
PA 1-153-337 (COHM)
Without Me
The Eminem Show
PA 1-073-070 (COHM)
Yellow Brick Road
Encore (Deluxe Version)
PA 1-295-399
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