IHeartMedia Inc. - ABS Entertainment Inc. Missapproriation - Conversion Class Action - USDC CDCA -...

8/20/2019 IHeartMedia Inc. - ABS Entertainment Inc. Missapproriation - Conversion Class Action - USDC CDCA - 8.17.15

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CLASS ACTION COMPLAINT 1116420v1

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M C K O O L S M I T H H E N N I G A N , P . C .

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6 5 S . F I G U E R O A S T R E E T , S U I T E 2 9 0 0

L O S A N G E L E S , C A 9 0 0 1 7

McKOOL SMITH HENNIGAN, P.C.RODERICK G. DORMAN (SBN 96908)[email protected] ROBERT E. ALLEN (SBN 166589)[email protected] LAWRENCE M. HADLEY (SBN 157728)[email protected] ALAN P. BLOCK (SBN 143783)[email protected] 865 S. Figueroa St., Suite 2900Los Angeles, CA 90017T: (213) 694-1200; F: (213) 694-1234

MILLER LAW LLCMARVIN A. MILLER ( pro hac vice application pending)[email protected] SZOT ( pro hac vice application pending)[email protected] KATHLEEN BOYCHUCK ( pro hac vice application pending)[email protected] 115 S. LaSalle Street, Suite 2910Chicago, IL 60603T: (312) 332-3400; F: (312) 676-2676

Attorneys for PlaintiffABS ENTERTAINMENT, INC.

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

ABS ENTERTAINMENT, INC., anArkansas corporation, each individuallyand on behalf of all others similarlysituated.

Plaintiff,

v.

iHEARTMEDIA, INC., a Delawarecorporation;iHEARTCOMMUNICATIONS, INC.,a Texas corporation; IHEARTMEDIA+ ENTERTAINMENT, INC., a Nevadacorporation; and DOES 1 through 10,

Defendants.

Case No. 2:15-cv-6252

CLASS ACTION COMPLAINT

1.

VIOLATION OF CALIFORNIACIVIL CODE § 980(a)(2);

2. MISAPPROPRIATION;3. VIOLATION OF CALIFORNIA

BUSINESS AND PROFESSIONSCODE § 17200; and

4.

CONVERSION.

DEMAND FOR JURY TRIAL

Case 2:15-cv-06252 Document 1 Filed 08/17/15 Page 1 of 20 Page ID #:1


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1 Plaintiff, ABS Entertainment, Inc. ( ABS ) ( Plaintiff'), individually and on

2 behalf of all other similarly situated owners of sound recordings, hereby complains

3 and alleges as follows:

4 PRELIMIN RY ST TEMENT

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1

This is a class action on behalf of owners

of

sound recordings to obtain

injunctive relief and monetary damages sustained by Plaintiff and the Class because

the Defendants delivered music content through broadcast radio channels,

HD

radio

channels, satellite radio, the Internet and mobile devices without consent of or

licenses from the Plaintiff and the Class. As a result

of

their pernicious, improper and

illegal conduct, Defendants have reaped hundreds ofmillions of dollars that rightfully

belong to Plaintiff and the Class.

2

Defendant iHeartMedia, Inc. (through itself and its subsidiaries

iHeartCommunications, Inc. and iHeartMedia +Entertainment, Inc.) (collectively,

iHeart ) is one of the leading operators in the United States ofmedia and

entertainment services via broadcast and digital delivery. Specifically, iHeart

delivers music content through broadcast (AM and FM) radio channels, the Internet

at iHeartRadio.com and its stations' websites, and through one or more iHeartRadio

mobile applications on smart phones, tablets and gaming consoles. According to

iHeart, as ofDecember 31,2014, it owned

858

domestic radio stations, servicing

more than 150 U.S. markets, including 44 of the top 50 markets and 84 of the top 100

markets. (Delivery by iHeart ofmusical content through AM and FM radio stations

shall hereafter be described as the Broadcast Service ). Many

of

its stations in the

Broadcast Service are the most popular music stations in the applicable market,

including in Los Angeles, where iHeart owns and operates KIIS 102.7-FM, KBIG

104.3-FM, KOST 103.5-FM, KYSR 98.7-FM and KRRL 92.3-FM.

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3 iHeart utilizes the Internet to give users instant access to thousands of live

27 radio stations from across the country. In addition, iHeart uses the Internet to provide

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Because iHeart has chosen to operate the Music Service without licenses

2 for Pre-1972 Recordings, iHeart

is

now liable under California law for violation of

3 California Civil ode§ 980(a)(2), misappropriation, violation of California Business

4 Professions ode§ 17200, and conversion for its unauthorized reproduction,

5 distribution, and public performance

of

those recordings.

6

THE P RTIES

7 8 ABS is a corporation duly organized and existing under the laws of

8 Arkansas, with its principal place ofbusiness in West Memphis, Arkansas.

9

9

Through a series

of

transactions, ABS acquired the exclusive ownership

10 in the sound recordings

of

Al Green, Willie Mitchell, Ann Peebles, Syl Johnson, Otis

11

Clay, Bill Black Combo, and O.V Wright, a representative sample

of

the titles

of

12

which are specified on the attached Schedule A and incorporated herein by

13

reference (the Recordings ).

14 10 Plaintiffhas been and continues to be engaged in the business

of

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distributing, selling, and/or licensing the reproduction, distribution, sale, and

16 performance

of

the Recordings including in records, audiovisual works, and for

17 streaming (i.e., performing) and downloading over the Internet.

18 11 iHeartMedia, Inc. is a corporation duly organized and existing under the

19 laws of Delaware, with its principal place ofbusines'3 in San Antonio, Texas, and

20 with its executive offices in New York, New York. iHeartMedia, Inc.

is

the parent

21 company of iHeartCommunications, Inc. and iHeartMedia +Entertainment, Inc., and

22 owns and operates the Music Service, which broadcasts music to its listeners and

23 delivers uninterrupted, high quality streams ofmusic tailored and customized to its

24 users' preferences.

25 12. iHeartCommunications, Inc. is a corporation duly organized and existing

26 under the laws ofTexas, with its principal place

of

business in San Antonio, Texas,

27 and with its executive offices in New York, New York. iHeartCommunications, Inc.

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Service, iHeart offers and advertises both (a) custom radio programming, which

allows a user to select one or more favorite artists and then iHeart s internal algorithm

selects other sound recordings that the user might enjoy, and (b) live radio simulcast,

which allows a user to select and listen to the live audio simulcast of hundreds of

radio stations throughout the United States and Mexico, inclusive of radio stations

either owned by iHeart or owned by third parties.

Many of

these radio stations are

dedicated to Pre-1972 Recordings. iHeart promotes these stations in order to

establish and increase its user base, popularity, and revenue.

23. Plaintiff is informed and believes, and on that basis alleges, that in order

to populate the Music Service s databases and in order to broadcast and stream

musical recordings to the public, iHeart has reproduced and copied and continues to

reproduce and copy Pre-1972 Recordings to one or more servers and storage devices,

and uses technology or systems that results in one

or

more copies ofPre-1972

Recordings being distributed to its users computers or storage devices.

24. iHeart knows that it does not have any license, right, or authority to

reproduce, perform, distribute or otherwise exploit

vi

the Music Service any Pre-

1972 Recordings (including the Recordings). iHeart also knows which of the

recordings its reproduces, performs, distributes or otherwise exploits vi the Music .

19 Service are Pre-1972 Recordings.

20 25. iHeart s entire business is built around selling access to music and selling

2 the music. iHeart delivers audio advertisements to its users in between songs and

22 displays visual ads while music is playing.

23 CL SS CTION LLEG TIONS

24 26. Plaintiff brings this action, pursuant to Fed. R. Civ. P. 23, on behalf

of

25 itself individually and on behalfof all other similarly situated owners

of

Pre-1972

26 recordings, which recordings were reproduced, performed, distributed or otherwise

27 exploited by iHeart via the Music Service in California. The proposed Class is

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1 comprised of and defined as follows:

2 All owners of sound recordings of musical performances that

3 initially were fixed

i.e.,

recorded) prior to February 15, 1972,

4 which sound recordings were reproduced, performed, distributed

5 and/or otherwise exploited by iHeart via any form or method

of

6 delivery or storage (e.g., terrestrial broadcast, satellite, Internet,

7 computer, server, etc.) in California (the Class ).

8 27. This action may be properly brought and maintained as a class action

9 because there is a well-defined community of interest in the litigation and the

1 members of the proposed Class are clearly and easily ascertainable and identifiable.

11 28. The Class for whose benefit this action is brought is so numerous and

12 geographically dispersed that joinder of all members of the Class is impracticable.

13 Plaintiff is informed and believes that there are hundreds or thousands of members of

14 the Class whose identity can be readily ascertained from third party, music industry

15 sources and from iHeart 's database files and records. Therefore, the Class can be

16 readily located and notified

of

this action.

17 29. Plaintiff's claims are typical

of

the claims

of

the members of the Class,

18 and Plaintiff's interests are consistent with and not antagonistic to those of the Class

19

it seeks to represent. Plaintiff and all members of the Class have sustained actual

20 pecuniary loss and face irreparable harm arising out ofiHeart s continued course

of

21 conduct as complained ofherein.

22 30. Plaintiff does not have any interests that are adverse to, or which conflict

23 with, the interests of the absent members

of

the Class and it is able to fairly and

24 adequately represent and protect the interests of such Class. Plaintiff has raised

25 viable statutory, misappropriation, unfair business practices, and conversion claims of

26 the type reasonably expected to be raised by members

of

the Class, and will

27 vigorously pursue those claims. Plaintiff is represented by experienced, qualified and

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(H) Whether iHear t s conduct is continuing thereby entitling the

members of the Class to injunctive or other relief.

32. A class action is superior to other available methods for the fair and

efficient adjudication

of

this controversy since individual litigation

of

the claims

of

all class members is impracticable. Thus, for the vast majority

of

the members of the

Class, the expense and burden of individual litigation would not justify pursuing the

claims individually. Even if every member of the Class could afford to pursue

individual litigation, the Court system could not. It

would

be unduly burdensome to

the courts

in

which individual similar litigation of numerous cases would proceed.

Individualized litigation would also present the potential for varying, inconsistent, or

contradictory judgments and would magnify the delay

and

expense to all parties and

to the court system resulting from multiple trials of the same factual issues. By

contrast, the maintenance of this action

as

a class action presents few,

if

any,

management difficulties, conserves the resources of

the parties and

of

the court

system,

and

protects the rights

of

each member of the Class. Plaintiff does not

anticipate any difficulty in the management

of

this action as a class action.

FIRST CLAIM FOR RELIEF

For Violation

of

California Civil

ode§

980 a) 2) Against All Named

Defendants and Does 1 through 10)

33. Plaintiff hereby incorporates the allegations set forth above in paragraphs

1 through 32 above, as though fully set forth herein.

34. Pursuant to California Civil Code§ 980(a)(2), Plainti ff and the members

of the Class possess exclusive ownership interests in and to the Pre-1972 Recordings,

including the artistic performances embodied in those recordings.

35. Through its unauthorized reproduction, performance, distribution, or other

exploitation via the Music Service of Pre-1972 Recordings (including the

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Recordings) in California, iHeart has infringed the exclusive ownership interests in

and to the Pre-1972 Recordings in violation of California Civil

Code§

980(a)(2).

36. As a direct and proximate consequence

ofiHeart's

violation

of

California

Civil

Code§

980(a)(2), iHeart has received and retained money and value that

rightfully belongs to Plaintiff and the members of the Class.

37. As a direct and proximate consequence

ofiHeart's

violation

of

California

Civil

Code§

980(a)(2), Plaintiff and the Class have been damaged in an amount that

is not

as

yet fully ascertained but which Plaintiff will ascertain and present through

competent evidence at trial, but which is no less than 5 million.

38. iHeart s conduct is causing, and unless enjoined and restrained by this

Court will continue to cause Plaintiff and the Class great and irreparable injury that

cannot fully be compensated or measured in money. Plaintiff and each member of

the Class do not have an adequate remedy at law. Plaintiff and each member of the

Class are entitled to temporary, preliminary and permanent injunctions, prohibiting

further violation of the ownership interests

of

Plaintiff and each member

of

the Class

in the Pre-1972 Recordings.

SECOND CLAIM

FOR R LI F

For Misappropriation Against All Named Defendants and Does 1 Through 10)

39. Plaintiff hereby incorporates the allegations set forth above in paragraphs

1 through 32 above, as though fully set forth herein.

40. Pursuant to California Civil Code§ 980(a)(2) and California common

law, Plaintiff and the Class possess exclusive ownership interests in and to the Pre-

1972 Recordings, including the artistic performances embodied in those recordings.

24

41. Plaintiff and its predecessors in interest invested substantial time and

25

money in developing the Recordings.

26 42. Because iHeart does not obtain licenses, it does not incur any of the costs

27 that a licensee is otherwise obligated to pay in order to reproduce, perform, distribute

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1 or otherwise exploit via the Music Service Pre-1972 Recordings (including the

2 Recordings).

3 43. iHeart has misappropriated, and continues to misappropriate, for its own

4 commercial benefit, the exclusive ownership interests in and to the Pre-1972

5 Recordings reproducing, performing, distributing or otherwise exploiting via the

6 Music Service Pre-1972 Recordings (including the Recordings).

7 44. As a direct and proximate consequence ofiHeart s

misappropriation,

8 iHeart has received and retained money and value that rightfully belongs to Plaintiff

9 and the Class.

1 45. As a direct and proximate consequence

ofiHeart s

misappropriation,

11 Plaintiff and the Class have been damaged in an amount that is not as yet fully

12 ascertained but which Plaintiff will ascertain and present through competent evidence

13 at trial.

14 46. Plaintiff is informed and believes, and on that basis alleges, that in

15 engaging in the conduct described herein, iHeart acted with oppression, fraud and/or

16

malice. iHeart s conduct has been despicable and undertaken in conscious disregard

17

of

the rights

of

Plaintiff and the Class. Accordingly, Plaintiff and the Class are

18 entitled to an award

of

punitive damages against iHeart in an amount sufficient to

19

punish and make an example

of

it.

20 47. iHeart s conduct is causing, and unless enjoined and restrained by this

21 Court, will continue to cause, Plaintiff and the Class great and irreparable injury that

22 cannot fully be compensated or measured in money. Plaintiff and the Class do not

23

have an adequate remedy at law. Plaintiff and the Class are entitled to temporary,

24 preliminary and permanent injunctions, prohibiting further violation

of

the ownership

25

interests

of

Plaintiff and the Class in the Pre-1972 Recordings.

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1

THIRD CLAIM FOR RELEIF

2

For Unfair Business Practices Against All Named Defendants and Does 1

3 Through 10)

4 48. Plaintiff hereby incorporates the allegations set forth above in paragraphs

5 1 through 32 above, as though fully set forth herein.

6 49. Pursuant to California Civil

Code§

980(a)(2) and California common

7 law, Plaintiff and the Class possess exclusive ownership interests in and to the Pre-

8 1972 Recordings, including the artistic performances embodied in those recordings.

9 50. iHeart s conduct in reproducing, performing, distributing, or other

10 exploitation via the Music Service Pre-1972 Recordings (including the Recordings)

11 constitutes a misappropriation

of

the property rights of the Plaintiff and the Class in

12 the Pre-1972 Recordings and a violation of California Civil

Code§

980(a)(2).

13

51. By misappropriating the property rights

of

the Plaintiff and each member

14 of the Class in the Pre-1972 Recordings and by violating California Civil Code §

15 980(a)(2), iHeart has engaged in unfair business practices in violation of California

16 Business Professions Code § 17200.

17 52. As a direct and proximate consequence of its violation of California

18 Business Professions Code § 17200, iHeart has received and retained money and

19 value that rightfully belongs to Plaintiff and the Class.

20 53. As a direct and proximate result

ofiHeart s

conduct, Plaintiff and each

21

member of the Class are entitled to restitution and disgorgement under California

22 Business Professions Code § 17200 in an amount that is not as yet fully ascertained

23 but which Plaintiff will ascertain and present through competent evidence at trial.

24 54. Plaintiff is informed and believes, and

on

that basis alleges, that in

25 engaging in the conduct described herein, iHeart acted with oppression, fraud and/or

26 malice. The conduct of iHeart has been despicable and undertaken in conscious

2 7 disregard of the rights of Plaintiff and the Class. Accordingly, Plaintiff and the Class

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1 malice. iHeart s conduct has been despicable and undertaken in conscious disregard

2 of the rights of Plaintiff and each member

of

the Class. Accordingly, Plaintiff and the

3 Class are entitled to an award

of

punitive damages against iHeart in an amount

4 sufficient to punish and make an example

of

it.

5 62. iHeart s conduct is causing, and unless enjoined and restrained by this

6 Court, will continue to cause Plaintiff and the Class great and irreparable injury that

7 cannot fully be compensated or measured in money. Plaintiff and the Class do not

8 have an adequate remedy at law. Plaintiff and the Class are entitled to temporary,

9 preliminary and permanent injunctions, prohibiting further violation

of

the ownership

10 interests

of

Plaintiff and the Class in the Pre-1972 Recordings.

11

PR YER

12 WHEREFORE, Plaintiff, on behalf of themselves and all other members of the

13 Class, pray for Judgment against iHeart and the Doe defendants, and each

of

them, as

14 follows:

15

A.

Determining that this is a proper class action maintainable pursuant to

16 Rule

23

of

the Federal Rules Civil Procedure, and certifying Plaintiff as a Class

17 Representative, and appointing

Plaintiffs

counsel as Class Counsel.

18

B. On all claims other than the Third, compensatory damages in excess

of

5

19 million according to proof.

20 C. On the third claim, restitution and disgorgement

ofiHeart's

unlawful

21 proceeds and revenues, including iHeart s gross profits, in excess

of 5

million.

22 D. On all claims other than the first, punitive and exemplary damages

23 according to

proof

at trial.

24 E. On all claims, a temporary, preliminary, and permanent injunction

25 enjoining and restraining iHeart, and their respective agents, servants, directors,

26 officers, principals, employees, representatives, subsidiaries and affiliated companies,

27 successors, assigns, and those acting in concert with them or at their direction, from

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1 infringing, misappropriating, or converting, directly or indirectly, in California the

2 exclusive ownership interests in and to the Pre-1972 Recordings, including the artistic

3 performances embodied in those recordings, including without limitation by directly

4 or indirectly copying, reproducing, downloading, distributing, communicating to the

5 public, uploading, linking to, transmitting, publicly performing, or otherwise

6 exploiting in any manner any o the Pre-1972 Recordings, via the Music Service or

7 otherwise.

8 F On all claims, pre- and post-judgment interest.

9 G For such fees and costs (including reasonable attorneys' fees) incurred

10

herein as permitted by law.

11

H

For such other and further relief as the Court deems just and proper.

12

3

DATED: August 17,2015

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McKOOL SMITH HENNIGAN, P.C.

MILLER LAW LLC

By:

Is

Robert

E

llen

6

Robert

E

Allen

Attorneys for Plaintiff

ABS ENTERTAINMENT, INC.




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Artist

Ace Cannon

Ace Cannon

Ace Cannon

Ace Cannon

I Green

I Green

I

Green

I Green

I

Green

I Green

I Green

I Green

Ann Peebles

Ann Peebles

Ann Peebles

Ann Peebles

Ann Peebles

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Bill Black Combo

Otis Clay

Otis Clay

Otis Clay

Schedule A

Representative Sampling

o

Plaintiff s Pre-1972

Sound Recordings Infringed

Title

Tuff

Bllues (Stay Away From Me)

Cotton Fields

Search in

Want to Hold Your Hand

One Woman

You

Say

It

Right Now, Right Now

I Can t Get Next To You

Driving Wheel

Tired of Being Alone

Let s Stay Together

WalkAway

Give Me Some Credit

Generation Gap Between

Us

Part Time Love

I Pity The Fool

Smokie, Part 2

White Silver Sands

Josephine

Don t

Be

Cruel

Blue Tango

Hearts of Stone

Ole

Buttermilk

Sky

Movin

Twist Her

Do It -

Rat

Now

Money Shine

That s How It Is (When You re

In

Love

A Lasting Love

She s About A Mover

1

SCHEDULE A



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O.V. Wright

O.V. Wright

O.V. Wright

O.V. Wright

O V

Wright

O.V. Wright

O.V.

Wright

O.V. Wright

Syl Johnson

Syl

Johnson

Syl Johnson

Syl Johnson

Syl

Johnson

Syl

Johnson

Syl

Johnson

Wilie Mitchell

Wilie Mitchell

Wilie

Mitchell

Wilie

Mitchell

Wilie

Mitchell

Wilie Mitchell

Wilie Mitchell

Wilie

Mitchell

Wilie

Mitchell

You re Gonna Make Me Cry

Eight

Men,

Four

Women

Heartaches, Heartaches

Oh

Baby

Mine

I ll Take Care

of

You

Ace

of

Spades

When You Took Your Love From

Me

A Nickel and a Nail

Come On Sock It To Me

Different

Strokes

Dresses Too Short

Is It Because I m Black

Concrete Reservation

One Way Ticket to Nowhere

Get Ready

20 75

Percolatin

Buster Browne

Bad Eye

Slippin and Slidin

Soul Serenade

Prayer

Meetin

30 60 90

My Babe

-2-

SCHEDULE A


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