Mahan

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

CHAUNCEY MAHAN

Petitioner,

vs.

ROC NATION, LLC,
ROC-A-FELLA RECORDS, LLC,
SHAWN CARTER p/k/a JAY Z

Respondents.

Case No. 14-cv-5075 (LGS)

JUDGE SCHOFIELD

ECF CASE

PETITION FOR DECLARATORY JUDGMENT

COMES NOW the Petitioner, CHAUNCEY M. MAHAN, a citizen of the
United States of America, by and through his counsel, James H.
Freeman, Esq. of JH FREEMAN LAW, 3 Columbus Circle, Floor 15, New
York, NY 10019; to seek a declaration of his ownership and authorship
rights under the Copyright Act of 1976, 17 U.S.C. 1 et seq., vis--vis
the Respondents ROC NATION, LLC, a Delaware limited liability company
registered to do business in the State of New York; ROC-A-FELLA, LLC, a
Delaware limited liability company registered to do business in the State
of New York; SHAWN C. CARTER p/k/a JAY Z, a citizen of the State of
New York; and alleges as follows:

ii
INTRODUCTION
Modern music owes a great debt to the behind-the-studio-glass
magicians. Alan Parsons, A HISTORY OF RECORD PRODUCTION 17 (1998).

Theres definitely a big difference between a beatmaker and a producer
because once you finish the beat, you have to produce the record. Dr.
Dre, Something from Nothing: Art of Rap (2012)

Petitioner Chauncey Mahan (Petitioner) is a Grammy-award
recognized producer and engineer of sound recordings. His work is
embodied on albums released by the respondent Roc-A-Fella Records,
including Jay Z Vol. 3Life and Times of S. Carter (1999); Jay Z The
Dynasty: Roc La Familia: (2000); and Beanie Sigel The Truth (2000).
Count I of the Petition respectfully seeks a declaratory judgment
from the Honorable Court pursuant to 28 U.S.C. 2201, 2202 declaring
Petitioner to be a joint copyright owner and author of forty-five (45)
published sound recordings, plus numerous unpublished copyrightable
materials that are currently in possession of the Los Angeles police
department. In the alternative, Petitioner seeks a declaration, upon good
cause shown, that he is the sole owner of the subject sound recordings.
Count II seeks a declaration that Roc-A-Fellas underlying SR
Copyrights identified in this Petition are invalid as a matter of statutory
law and therefore have no legal effect. The registration forms are
defective on their face, inter alia, for claiming to be employer-for-hire
where no employment relationship existed between the label and authors
and no copyright assignment agreement was signed by Petitioner.
iii
TABLE OF CONTENTS
A. SUBJECT MATTER JURISDICTION """"""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" #
B. PERSONAL JURISDICTION """""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" #
C. VENUE """"""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" $

PARTIES

A. CHAUNCEY M. MAHAN .......................................................................... 2

B. ROC-A-FELLA RECORDS, LLC ............................................................... 4

C. ROC NATION LLC ................................................................................... 5

D. SHAWN CARTER P/K/A JAY Z .............................................................. 6

PART I: THE RELEVANT SOUND RECORDINGS """""""""""""""""""""""""""""""""""""""""""""""""""""""""""" #

A. GENESIS OF THE JOINT COLLABORATION ............................................ 7

"#$ %&' %()(*+, -./01(2 34./&51,/ '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 6

"7$ 890:;:</22(+, ;2=>? 8/2/(,/, @&19& 59 %&' %()(*+, A922(=9&(519*
BC D(E F "#GGH:#GGI$ ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' I

"J$ 890:;:</22( (*K %&' A(&5/& L*M15/ %&' %()(* 59 A922(=9&(5/
9* 5)/ %(N1*O 9P -9>*K 8/09&K1*O, "D>2E:;>O>,5 #GGG$ '''''''''''''''''''''''''''''''''''''''''''''''''''''''' G

"Q$ @/51519*/& -/5, R. -/,,19*, (5 -9*E -5>K19, STA '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' ##

B. PUBLISHED MATERIALS ...................................................................... 12

"#$ %&' ( : U92' J ' ' ' V1P/ (*K W1?/, 9P -' A(&5/& "#GGG$ ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' #7

"7$ %&' ( : 890 V( <(?121(X YE*(,5E "7ZZZ$ ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' #Q

"J$ )*&+,* -,*.*/ [ W)/ W&>5) "7ZZZ$ ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' #H

"Q$ ;OO&/O(5/ 9P @>=21,)/K -9>*K 8/09&K1*O, ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' #6

C. UNPUBLISHED MATERIALS ................................................................. 17

PART II: SR COPYRIGHT REGISTRATIONS """"""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" $#

A. EMPLOYER-FOR-HIRE REGISTRATIONS (1999-2000) ................................. 27

iv
B. ROC-A-FELLAS REPORTED COPYRIGHT ASSIGNMENT (2004) ........................ 27

PART III: PRESENT OWNERSHIP DISPUTE """"""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" %&

A. PETITIONERS CUSTODY OF TANGIBLE SOUND RECORDINGS ......................... 30

"#$ %&' %()(*+, @)E,10(2 @9,,/,,19* \ A>,59KE 9P %>251:W&(0N "@&9 W992,$
(*K WB9:W&(0N "Y;W$ -9>*K 8/09&K1*O, P9& #] E/(&, '''''''''''''''''''''''''''''''''''''''''''''''''''''''''' JZ

"7$ 8/,.9*K/*5,+ V9*O:W/&? ^*9B2/KO/ 9P @/51519*/&+, A>,59KE \
@9,,/,,19* 9P ;22 R*.>=21,)/K -9>*K 8/09&K1*O, ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' JZ

B. RESONDENTS EXPRESS RENUNICATION OF PETITIONERS OWNERSHIP AND
AUTHORSHIP RIGHTS ................................................................................. 32

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"7$ 890 S(519*+, U92>*5(&E `15)K&(B(2 9P a3459&519*b A9?.2(1*5
W)&// `//N, ;P5/& <121*O A)(&O/, "%(E #Q_ 7Z#Q$ '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' JQ

PART IV: ORIGINS OF HIP-HOP SOUND PRODUCTION """""""""""""""""""""""""""""""""""""""""""" %'

A. JAMAICAN DUB MUSIC (1967 - 1973) ................................................ 35

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B. BRONX - NYC: THE BIRTH OF HIP-HOP (1974-1979) ........................... 39

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PART V: AFRICAN-DERIVED MUSICAL AESTHETICS """"""""""""""""""""""""""""""""""""""""""""" ($

A. PERFORMANCE VALUES ..................................................................... 42

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v
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B. SONIC ATTRIBUTES ............................................................................. 45

"#$ 8)E5)? (, 5)/ U15(2 <9&0/ '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' Q]

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"J$ W1?=&(2 Y1M/&,15E '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' Q6

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PART VI: HIP-HOPS TRANSITION TO THE RECORDING STUDIO """""""""""""""""" ()

A. CLASSIC DEFINITIONS OF PRODUCER VS. ENGINEER ................... 49

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B. FROM HIP-HOP DJ TO PRODUCER .................................................... 50

"#$ YD+,X %(,5/&1*O -01/*0/ 59 34.&/,, ;&5 "#G6Z+,$ ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' ]Z

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"Q$ c>12K1*O 5)/ aV(=b "?1K:#GIZ+,$ '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' ]J

"]$ A2(1?1*O 5)/ W152/ 9P a@&9K>0/&b "2(5/ #GIZ+,$ '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' ]J

"H$ c1P>&0(51*O 5)/ YD+, g&1O1*(2 892/ "/(&2E #GGZ+,$ ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' ]J

C. ENTER THE STUDIO MAGICIANS ...................................................... 56

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PART VII: PETITIONERS CONTRIBUTIONS """""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" ')

A. OVERVIEW .......................................................................................... 59

vi
"#$ @/51519*/&+, A9*5&92 gM/& 5)/ <1*(2 -9>*K ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' ]G

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"J$ %9K/&(5/ L*.>5 P&9? 5)/ 8(../&, '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' H#

B. MULTI-TRACKING THE BEAT ............................................................... 61

C. PRE-MIXING ........................................................................................ 62

D. EDITING THE BEAT ............................................................................. 62

E. RECORDING VOCALS .......................................................................... 63

F. COMPOSITING VOCALS ....................................................................... 65

G. MIXING ................................................................................................ 66

H. SONG ARRANGEMENT OR STRUCTURE .............................................. 69

I. PRE-MASTERING ................................................................................. 70

J. DUMPING .......................................................................................... 70

COUNT I: DECLARATORY JUDGMENT """""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" #*

A. PETITIONERS STANDING .................................................................... 71

"#$ A9.E&1O)5 gB*/&,)1. \ ;>5)9&,)1. ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 6#

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B. DECLARATION SOUGHT: JOINT AUTHORSHIP & OWNERSHIP ............ 74

"#$ %&' %()(*+, A9*5&1=>519*, [ @>=21,)/K %(5/&1(2, ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 6Q

"7$ %&' %()(*+, A9*5&1=>519*, [ R*.>=21,)/K %(5/&1(2, ''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 6]

"J$ %>5>(2 L*5/*5 9P 5)/ L*K1M1K>(2 @(&51/, '''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 6]

C. ALTERNATIVE DECLARATION: SOLE OWNERSHIP .............................. 80
COUNT II: DECLARATORY JUDGMENT """"""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" +*

A. PETITIONERS STANDING .................................................................... 81

B. DECLARATION SOUGHT INVALID SR COPYRIGHTS [SCHEDULE C] ........ 81
PRAYER FOR RELIEF """""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" +%
vii

SCHEDULE
OF EXHIBITS
EX. DESCRIPTION DATE
A ! Chauncey Mahans RIAA-certified recording plaque
to commemorate 17x multi-platinum sales of THE
BODYGUARD soundtrack (1992) featuring Whitney
Houstons I Am Every Woman,
! Chauncey Mahans Grammy Award certificate for
engineering/programming re: THE BODYGUARD
soundtrack (1992) featuring Whitney Houstons I Am
Every Woman.
1993
B ! Chauncey Mahans Grammy Award certificate for
engineering a sound recording embodied on the album
MR. SMITH (1996) featuring rapper LL Cool J.
1996
C ! Chauncey Mahans Grammy Award certificates for
producing, engineering and programming certain
sound recordings embodied on LIFE AND TIMES OF S.
CARTERVOL. 3 (1999) featuring rap artist Jay Z et. al.
1999
D ! Credit billings (various sources) re: LIFE AND TIMES
OF S. CARTERVOL. 3 (1999) featuring rap artist Jay Z
et. al.
1999
E ! Credit billings (various sources) re: ROC LA FAMILIA:
THE DYNASTY (2000) featuring Roc-A-Fella rap artist
Jay Z et. al.
2000
F ! Credit billings (various sources) re: THE TRUTH
(2000) featuring Roc-A-Fella rap artist Beanie Sigel,
et. al.
2000
G ! U.S. Copyright registrations (various SR) for
sound recordings embodying the original
contributions of Chauncey Mahan
1999-2000
H ! Jeff Chang w/ Introduction by DJ Kool Herc,
CANT STOP, WONT STOP: A HISTORY OF THE HIP-HOP
GENERATION, Picador / St. Martins Press (New York
2005) [relevant pages only]
2005
I ! Joseph G. Schloss, FOUNDATION: B-BOYS, B-GIRLS,
AND HIP-HOP CULTURE IN NEW YORK, Oxford University
Press (New York 2009) [relevant pages only]
2009
J ! Joseph G. Schloss, MAKING BEATS: THE ART OF
SAMPLE-BASED HIP-HOP, Wesleyan University Press
(Middletown, CT 2009) [relevant pages only]
2004
viii
EX. DESCRIPTION DATE
K ! Daniel J. Levitin, THIS IS YOUR BRAIN ON MUSIC:
THE SCIENCE OF A HUMAN OBSESSION, Plume /
Penguin Books, Ltd. (London 2007) [relevant pages
only]
2006
L ! John Miller Chernoff, AFRICAN RHYTHM AND
AFRICAN SENSIBILITY: AESTHETICS AND SOCIAL ACTION IN
AFRICAN MUSICAL IDIOMS, University of Chicago Press
(Chicago 1979) [relevant pages only]
1979
M ! George Lipsitz, DANGEROUS CROSSROADS: POPULAR
MUSIC, POSTMODERNISM AND THE POETICS OF PLACE,
Verso (London 1994) [relevant pages only]
1994
N ! Marcyliena Morgan & Dionne Bennett, Hip-Hop &
the Global Imprint of a Black Cultural Form, AMERICAN
ACADEMY OF ARTS & SCIENCES (2011) [relevant pages
only]
2011
O ! Shawn Carter, JAY Z DECODED, Spiegel & Grau
(New York 2010) [relevant pages only]
2010
P ! Jake Brown, JAY Z AND THE ROC-A-FELLA RECORDS
DYNASTY, Colossus Books (New York 2005) [relevant
pages only]
2005
Q ! SOMETHING FROM NOTHING: THE ART OF RAP (2012)
[DVD Cover]
2012
R ! Zack OMalley, Jay Zs New Publishing Deal is
Just the Beginning, www.Forbes.com, February 20,
2013
2014
S ! WIKIPEDIA definition of Programming (Music) 5/2/2014
T ! LAPD Receipt for Property Taken Into Custody 4/18/2014
U ! Internet Articles (various) LAPD Kills Extortion
Investigation Over $20 Mil Masters, TMZ.com; Police
Drop Jay Z $20 Million Master Tapes Extortion
Investigation, MTV.com
5/14/2014

1
JURISDICTION AND VENUE
A. SUBJECT MATTER JURISDICTION

1. The Court has original jurisdiction pursuant to the
DECLARATORY JUDGMENT ACT, 28 U.S.C. 2201, 2202; 28 U.S.C. 1338(a);
and under the COPYRIGHT ACT OF 1976, 17 U.S.C. 101, et seq.
B. PERSONAL JURISDICTION

2. Respondent ROC NATION LLC (Roc Nation) is a limited
liability company organized under the laws of the State of Delaware and
is registered to do business in the State of New York. The Court has
personal jurisdiction over Roc Nation because it regularly and
continuously transacts business within this Judicial District and
maintains its principal offices here.
3. Respondent ROC-A-FELLA RECORDS, LLC (Roc-A-Fella) is
a limited liability company organized under the laws of the State of New
York. The Court has personal jurisdiction over Roc-A-Fella because it
regularly and continuously transacts business within this Judicial
District and maintains its principal offices here.
4. Respondent SHAWN C. CARTER p/k/a JAY Z (Carter or
Jay Z) is a citizen of the State of New York who maintains his primary
residence within this Judicial District and is therefore subject to the
Courts personal jurisdiction.
2
C. VENUE

5. Venue is proper under 28 U.S.C. 1391(b) and (c) in this
case because the named Respondents transact business in this Judicial
District and a substantial part of the events or omissions giving rise to
Petitioners requests for declaratory judgment and relief took place within
this Judicial District.
PARTIES
A. CHAUNCEY M. MAHAN

6. Petitioner Chauncey M. Mahan is a professional record
producer, sound engineer, music composer, arranger, mixer and
programmer.
(1) Formal Education & Training
7. In 1982, Petitioner studied musical composition at Brooklyn
College in New York City.
8. In 1985, Petitioner graduated from Mannes College of Music,
the New Schools music conservatory in New York, where he majored in
musical composition & arranging.
9. In 1987, Petitioner received certification as a sound engineer
from the Center for the Media Arts in New York City.
(2) Recording Industry Experience
10. Petitioner was actively engaged in the professional recording
industry from 1987 through 2002. During this period, Mr. Mahan
collaborated with chart-topping, major label recording artists in the
3
popular genres of hip-hop, R&B, dancehall and house / dance music,
including Whitney Houston, Chaka Khan, LL Cool J, Kurtis Blow, Doug
E. Fresh, D-Nice, Beanie Man, Super Cat, Clives & Coles, Funkmaster
Flex, Notorious B.I.G., 112, Total, Da Brat, Missy Elliot, R Kelly, Debra
Cox, Christopher Williams, The Lox, Eve, Beanie Siegel, Memphis Bleek,
and Jay Z.
11. At all relevant times, Petitioner exhibited the advanced
technical skills and unique artistic sensibility required to collaborate
meaningfully in the co-authorship of professionally realized sound
recordings featuring chart-topping recording artists signed to major
record labels.
12. Petitioners subjective ear for what makes certain sound
recordings popular, particularly in the rhythmic genres of hip-hop,
house, dancehall, techno and electronica, was acquired over decades of
listening to music in nightclubs or on the radio, combined with extensive
formal training in musical composition and arrangement; a certified
degree in sound engineering; plus years of hands-on experience
controlling then-current state-of-the-art technology to create high-quality
sound recordings suitable for major label release.
(3) Grammy Award and RIAA Recognition
13. In 1993, Petitioners authorship contributions as a sound
engineer and programmer (i.e., musical composer, writer and arranger)
were recognized in connection with Whitney Houstons smash hit Im
4
Every Woman, which was featured on the original soundtrack for THE
BODYGUARD, a blockbuster motion picture released in 1992. The
soundtrack won the Grammy award for Album of the Year and was
certified as 17x multi-platinum by the Recording Industry Association of
America (RIAA).

[see Exhibit A].
14. In 1996, Petitioners authorship contributions as a sound
engineer were again recognized by the National Academy of Recording
Arts and Sciences (NARAS) in connection with rapper LL Cool Js
Grammy-award nominated album Mr. Smith. [see Exhibit B].
15. In 2000, Petitioners authorship contributions as a record
producer, sound engineer and music programmer were again recognized
by NARAS in connection with the Grammy-award nominated album Vol.
3 . . . Life and Times of S. Carter, featuring Jay Z as the principal rapper.
[see Exhibit C].
(4) Mr. Mahans Good Will in His Trade and Profession
16. At all relevant times (prior to April 18, 2014), Mr. Mahan
enjoyed good will in the professional recording industry; an upstanding
reputation amongst his colleagues; and well-earned recognition in the
trade for his advanced knowledge of state-of-the-art technology.
B. ROC-A-FELLA RECORDS, LLC

17. In 1995, Respondent Carter co-founded Roc-a-Fella as an
independent record label based in New York City. Roc-A-Fella marketed
recording artists in the genres of hip-hop music.
5
18. In 1997, Def Jam Recordings reportedly acquired a 50%
ownership interest of Roc-A-Fella.
19. In 1998, Universal Music Group, Inc. (UMG) reportedly
purchased Def Jam Recordings and merged it with Island Records to
form the Island / Def Jam Music Group (Def Jam).
20. At all relevant times after UMGs acquisition of Def Jam in
1998, Roc-A-Fella operated under the direct supervision and control of
UMG or Def Jam.
21. As of mid-1999, the roster of artists signed to Roc-a-Fella
included the rappers Jay Z, Beanie Sigel, Memphis Bleek, Amil, and
Freeway, as professionally known. (collectively referred to herein as the
Roca-A-Fella Rappers)
22. At times relevant to this matter, the hip-hop beatmakers
(credited as producers) who collaborated with Petitioner and others in
the making of sound recordings at issue included Timbaland, Swizz
Beats, Rockwilder, Just Blaze, DJ Clue, and Bink, as professionally
known.
C. ROC NATION LLC

23. In 2008, Respondent Carter founded Roc Nation. The
company is described on its website as a full-service entertainment
company, inclusive of artist, songwriter, producer and engineer
management; music publishing; touring & merchandising; film and
television; new business ventures; and a music label.
6
www.rocnation.com (accessed June 11, 2014).
D. SHAWN CARTER P/K/A JAY Z

24. Mr. Carter is a popular American rapper from Brooklyn, New
York who has enjoyed substantial success in the music, fashion and
entertainment industries.
25. At times relevant to this action, Mr. Carter was a principal of
Roc-A-Fella and was signed as a recording artist to Roc-A-Fella or Def
Jam or UMG.
26. Mr. Carter is a principal of Roc Nation.

[Next Page]

7
PART I.
THE RELEVANT
SOUND RECORDINGS

! ! !

A. GENESIS OF THE JOINT COLLABORATION
(1) MR. MAHANS SPECIAL EXPERTISE

27. In or about 1996, Petitioner became an early adopter of a
digital audio workstation called Pro Tools, which is a computer software
program used for the professional multi-track recording, mixing and pre-
mastering of sound recordings.
28. In 1997, the manufacturer of Pro Tools, Avid Technology,
introduced a 24-bit, 48-track version of the software. It was at that point
that sound recording professionals began to migrate from more
conventional, hardware-based studio technology to the Pro Tools platform.
29. By 1998, Pro Tools had gained increased recognition in the
hip-hop, R&B, and dance/electronic genres for the softwares innovative
sound editing and arrangement capabilities. Major record labels,
including Def Jam, began to recruit sound engineers with professional
working knowledge of the Pro Tools platform.
30. By the time Petitioner began collaborating with Roc-A-Fellas
roster of artists and beatmakers in mid-1999, Petitioner had acquired
advanced proficient with Pro Tools, on both Windows and Mac OSX
operating systems. At the time, Mr. Mahans expertise was regarded as
8
highly specialized, particularly because professional recording facilities,
including Sony Studios in New York, were either not equipped to operate
the Pro Tools digital platform or were in the early stages of (reluctantly)
transitioning to such technology. Accordingly, major record labels
including Def Jam relied on independent contractors, including Petitioner,
to supply the Pro Tools technology and provide the professional expertise
required to both operate the digital platform and interface it with other
devices then currently available in state-of-the-art recording studios.
31. To meet the growing demand for Pro Tools expertise,
Petitioner purchased his own then-current state-of-the-art computer
hardware and peripheral devices needed to operate the Pro Tools platform
in a professional recording environment.
(2) ROC-A-FELLAS ALBUM RELEASES PRIOR TO MR. MAHANS
COLLABORATION W/ JAY Z (1996-1998)

32. On June 25, 1996, Roc-A-Fella released its first album
entitled Reasonable Doubt, featuring Jay Z as the principal recording
artist. The album peaked at #23 on the Billboard 200 album charts and
was eventually certified platinum in sales by the RIAA in the United
States.
33. On November 4, 1997, Roc-A-Fella released the second
studio album featuring Jay Z as the principal recording artist, entitled
Vol. 1Hard Knock Life. The album peaked at #3 on the Billboard 200
album charts and was certified platinum by the RIAA.
9
34. On September 29, 1998, Roc-A-Fella released the third
studio album featuring Jay Z as the principal recording artist, entitled
Vol. 2Hard Knock Life. The album debuted at #1 on the Billboard 200.
The album catapulted the rapper Jay Z to international fame and earned
three Grammy Award nominations (1999). In February 1999, the album
won the Grammy award for Best Rap Album. Vol. 2Hard Knock Life
has sold more than 5 million copies in the United States and remains the
best selling album of Mr. Carters recording career.
35. From April through August 1999, Jay Z and the other
rappers signed to Roc-A-Fella embarked on a nationwide stadium tour
called the Hard Knock Life Tour.
(3) ROC-A-FELLA AND MR. CARTER INVITE MR. MAHAN TO COLLABORATE
ON THE MAKING OF SOUND RECORDINGS (JULY-AUGUST 1999)

36. In or about July 1999, Petitioner was invited by Roc-A-Fellas
A&R (i.e., artist and repertoire) department to contribute his efforts as a
record producer, sound engineer, musical composer, song arranger,
programmer, Pro Tools editor, mixer and studio project manager to the
making of professional quality sound recordings.
37. Roc-A-Fellas A&R executives sought out Petitioners
expertise on account of his unique sound and special expertise working
with the Pro Tools recording platform, which was then considered state-
of-the-art. The label executives also knew that Mr. Mahan had
substantial administrative skills and was capable of project managing
and setting up recording sessions at state-of-the-art Manhattan-based
10
recording studios.
38. In or about August 1999, Mr. Carter heard some of the
sound recordings engineered and programmed by Mr. Mahan via Roc-A-
Fella rapper Beanie Sigel. Mr. Carter thereafter sought to collaborate
with Mr. Mahan in the making of sound recordings in connection with
the release of the fourth studio album featuring Jay Zs performances as
the principal rapper. The album, to be entitled Vol 3 . . . The Life and
Times of S. Carter (Vol. 3), was then scheduled for release just days
before New Years 2000.
39. Mr. Carter and Roc-A-Fellas A&R executives explained to Mr.
Mahan that given the party atmosphere surrounding the turn of the
millennium and Jay Zs newfound international success, they preferred
the upcming album to sound more pop, futuristic, upbeat and, above
all, dance-oriented. They sought to distinguish the overall sound of Vol.
3 from the 1990s era sample-based hip-hop sound that had largely
characterized Jay Zs first three studio albums. For that reason, Mr.
Mahans past experience in collaborating with Whitney Houston on I Am
Every Woman, one of the most popular dance tracks of Ms. Houstons
career, was relevant to the genesis of the collaboration.
40. Mr. Mahan expressed his confidence to Mr. Carter that
Petitioner could originate a soundscape of greater three-dimensional
depth and overall clarity than any record which had been previously
released by Roc-A-Fella. Accordingly, Mr. Carter and Mr. Mahan verbally
11
agreed to work together as creators toward the goal of completing the
songs for the new album.
1

(4) PETITIONER SETS UP SESSIONS AT SONY STUDIOS NYC

41. Shortly after reaching this consensus ad idem, Petitioner
began setting up studio sessions at Sony Music Studios (Studio E), at
460 W. 54
th
Street in Manhattan, where Petitioner had had a working
relationship with one of the studio managers. Petitioner set up Studio E
as the homebase for his collaboration with Jay Z, as well as other
rappers signed to Roc-A-Fella. Petitioner brought his own Pro Tools
system into Studio E and interfaced his then-current state-of-the-art
equipment with Sonys built-in technology.
42. From on or about August 21, 1999 through mid-November
1999, Mr. Carter and Mr. Mahan worked together at Sony Studios in
Studio E to make individual sound recordings, some of which would
come to be published by Roc-A-Fella.
43. Significantly, none of the twelve (12) beatmakers who were
billed as producer on the Vol. 3 album were actually present during the
making of the sound recordings at Sony Studios Studio E.
44. On November 24, 1999, MTV News published a news article
entitled Jay Z Has Thriller-Lie Aspirations for New Album, Singles and
reported that Mr. Carter had recently finished recording the tracks for

1
Accord David Miles Huber & Robert E. Runstein, MODERN RECORDING

12
his fourth studio album and said hes hoping that the new album will
prove to be as hit-filled as Michael Jacksons epochal Thriller (which
spawned seven top-ten hits).
2
[In 2010, Mr. Carter described Thriller
as the greatest album ever made. See JAY-Z - DECODED (Kindle Location
807)].
45. Based on the success of their joint collaboration on Vol. 3,
Mr. Mahan was again asked by Mr. Carter in early 2000 to continue his
contributions to the making of sound recordings with Roc-A-Fella
recording artists.
B. PUBLISHED MATERIALS
(1) JAY Z - VOL. 3 . . . LIFE AND TIMES OF S. CARTER (1999)

46. On December 28, 1999, Roc-A-Fella released the album
entitled Vol. 3. Life and Times of S. Carter.
(a) Commercial Success

47. The Vol. 3 album debuted at #1 on the Billboard 200 album
chart and sold more than 2 million copies in just two months. The
album embodied some of the most recognizable tracks of Jay-Zs career
including, amongst others, Big Pimpin (feat. UGK); Do it Again (Put Your
Hands Up) (feat. Amil and Beanie Sigel); Things That You Do (feat. Mariah
Carey), and S. Carter (feat. Amil), all of which were tracked, recorded,
edited, arranged and mixed by Petitioner at Sony Studios.

2
See http://www.mtv.com/news/1430543/jay-z-has-thriller-like-aspirations-for-new-
album-singles/ (accessed July 6, 2014).
13
48. Vol. 3Life and Times of S. Carter eventually sold 3.1 million
copies in the United States and stands as the third-highest selling album
of Jays Zs career. It is also ranked as one of the top 50 highest selling
hip-hop albums of all time (at #46).
49. Big Pimpin would become the most commercially successful
single on the album. In Rolling Stones updated 2010 list of the The 500
Greatest Songs of All Time, the song ranked at #467.
50. Mr. Carter has described Big Pimpin as one of the records
that served as the foundation of my career. See Jay Z Interview at The
Breakfast Club (Power 105.1 radio interview. Accessible at
http://www.youtube.com/watch?v=qqAFi_uiquA (@ 42:50). Notably,
Petitioner made substantial original contributions to the making of Big
Pimpin and is credited on the original CD liner notes with both recording
and mixing the song. See Exhibit D.
(b) Album Reviews

51. Upon release of Vol. 3., NME.com proclaimed that the album
inevitably will triumph at the global musical box office [Jay Z] treats
the listener[to] a series of uptempo party tunes much leavened by
threats to the masculinity of competitors. Quoted in JAY-Z AND THE ROC-
A-FELLA RECORDS DYNASTY (Kindle Locations 1470-1472).
52. ROLLING STONE magazine reviewed Vol. 3 upon its release and
concluded that this is his strongest album to date, with music thats
filled with catchy hooks, rump-shaking beats and lyrics fueled by Jays
14
hustlers vigilance Jay has become a better architect of songs.
(c) Credit Billings

53. As further detailed in Part VII of this Petition, Mr. Mahan
contributed his scientific expertise and artistic sensibility as a record
producer, tracking engineer, recording engineer, vocal compositor,
mixing engineer, music programmer, song arranger, editor, pre-
mastering engineer and studio project manager to a total of 14 out of 17
individual sound recordings embodied on Vol. 3 . . . Life and Times of S.
Carter (including the bonus tracks).
54. As per Schedule B, Petitioner was credited on the various
album release formats of Vol. 3 as a record producer, recording engineer,
mixing engineer and music programmer. [See Exhibit D]
(d) Written Agreements

55. Petitioner did not sign any written agreement with any of the
Respondents nor any other third party concerning his contributions to
the making of the Schedule A Recordings embodied on Vol. 3.
(2) JAY Z - ROC LA FAMILIA: DYNASTY (2000)

56. On October 31, 2000, Roc-A-Fella released an album entitled
Roc La Familia: Dynasty (Dynasty) featuring Jay Z as the principal
rapper.

57. The Dynasty debuted at #1 on the Billboard 200 album chart
15
and eventually sold 2.3 million copies.
58. According to Billboard, The Dynasty becoming the 20
th

highest selling R&B/Hip-Hop Album of the 2000-2010 decade.
(b) Album Reviews

individual sound recordings embodied on The Dynasty.
(c) Credit Billings

individual sound recordings embodied on The Dynasty.
61. Petitioner was credited for some of his original contributions
to the sound recordings embodied on THE DYNASTY as per Schedule B.
[See Exhibit E].

16
the making of the Schedule A Recordings embodied on THE DYNASTY.
(3) BEANIE SIEGEL THE TRUTH (2000)

63. On February 29, 2000, Roc-A-Fella released the debut album
of rapper Beanie Sigel entitled The Truth.
64. The album reached #5 on the Billboard 200 album chart and
embodied the popular singles Anything and Remember Them Days
(feat. Eve).
(b) Album Reviews

65. Upon the albums release, ROLLING STONE published a review
observing that the production is very similar to Jay Zs album 3Life
and Times of S. Carter [characterized] by a club-friendly synthesized
bounce.
(c) Credit Billings

contributed his technical expertise and artistic sensibility as a record
individual sound recordings embodied on The Truth.
67. Petitioner was credited for some of his original contributions
17
to the sound recordings as per Schedule B. [See Exhibit F.]

the making of the Schedule A Recordings embodied on THE TRUTH.
(4) AGGREGATE OF PUBLISHED SOUND RECORDINGS

69. As per Schedule A, Petitioner made original contributions to
a total of forty-five (45) individual sound recordings embodied on the
following albums released by Roc-A-Fella:
! Jay Z VOL. 3 THE LIFE AND TIMES OF S. CARTER (1999)
! Jay Z ROC LA FAMILIA: THE DYNASTY (2000)
! Beanie Sigel THE TRUTH (2000)
! Beanie Sigel THE REASON (2000)
! Memphis Bleek THE UNDERSTANDING (2000)
! Amil MONEY IS LEGAL (2000)
C. UNPUBLISHED MATERIALS

70. In November 2000, after the commercial release of The
Dynasty, Petitioner ended his professional collaborations with Roc-a-
Fella recording artists.
71. At the time, Mr. Mahans proprietary computer hard drives
and storage peripherals contained the original Pro Tools multi-track
recordings, preliminary mixes, outtakes, alternative takes, rough drafts,
18
freestyle sessions, dubs, extended versions, and other unpublished
materials originated by Petitioner (and the putative joint authors) in 1999
and 2000.
72. The Pro Tools multi-track sound recordings embodied in
Petitioners hard drives and peripherals are pre-mastered versions that
existed prior in time to the actual rendering of the so-called master
versions, i.e. the works that were released to the public.
73. As of November 2000, Petitioner also had in his possession
two-track mix down versions that had been dumped to digital audio
tape (DAT). These DATs are known as safety copies of the master
recordings which had already been sent to the record label. Roc-A-Fella
A&R executives placed Petitioner in charge of safekeeping these DATs.
74. Some of the two-track mix down DAT tapes also contain
instrumental versions, 7-inch single mixes for television and acapella
versions of some of the Schedule A Recordings.

19
SCHEDULE A
INDEX OF SOUND RECORDINGS RELEASED BY ROC-A-FELLA
WHICH EMBODY THE ORIGINAL CONTRIBUTIONS OF MR. MAHAN

# SONG TITLE ALBUM RAPPERS
(& SINGERS)
PRIMARY
BEATMAKER
SOUND
ENGINEER(S)
1 Hova Song
(Intro)
VOL. 3
(1999)
Jay Z K ROB MAHAN,
Duro
2 Do It Again
(Put Ya Hands
Up)
VOL. 3
(1999)
Jay Z,
Beanie
Sigel,
Amil
RICK ROCK MAHAN,
DURO
3 Dope Man VOL. 3
(1999)
Jay Z,
Serena
Altschul
JUST BLAZE MAHAN,
DURO,
YOUNG GURU
4 Things That U
Do
VOL. 3
(1999)
Jay Z,
Mariah Carey
SWIZZ BEATZ

MAHAN
5 It's Hot (Some
Like It Hot)
VOL. 3
(1999)
Jay Z TIMBALAND MAHAN
6 S. Carter VOL. 3
(1999)
Jay Z,
Amil
BINK MAHAN,
DURO
7 Pop 4 Roc

VOL. 3
(1999)
Jay Z,
Beanie Sigel,
Memphis
Bleek,
Amil
DJ CLUE MAHAN
8 Watch Me VOL. 3
(1999)
Jay Z,
Dr. Dre
IRV GOTTI
LIL ROBB
MAHAN
9 Big Pimpin' VOL. 3
(1999)
Jay Z,
UGK
TIMBALAND MAHAN,
JIMMY DOUGLAS
10 "There's Been a
Murder"
VOL. 3
(1999)
Jay Z

RUSS HOWARD MAHAN,
DURO
11 "NYMP" VOL. 3
(1999)
Jay Z

ROCKWILDER MAHAN,
DURO
12 Hova Song
(Outro)
VOL. 3
(1999)

Jay Z

K ROB MAHAN
13 Is That Yo
Bitch
VOL. 3
(1999)
Jay Z
Missy Elliot
TIMBALAND MAHAN
20
(& SINGERS)
PRIMARY
BEATMAKER
SOUND
ENGINEER(S)
(bonus track)

14 Girl's Best
Friend
(bonus track)

VOL. 3
(1999)

Jay Z,
Theresa
Rodriguez

SWIZZ BEATZ MAHAN
15 Intro DYNASTY
(2000)
Jay Z

JUST BLAZE MAHAN
16 "Change the
Game"
DYNASTY
(2000)
Jay Z

Memphis
Bleek,
Beanie Sigel,
Static Major
RICK ROCK MAHAN
DURO
17 "Streets Is
Talking"

DYNASTY
(2000)
Jay Z
Beanie Sigel
JUST BLAZE MAHAN
18 "This Can't Be
Life"

DYNASTY
(2000)
Jay Z
Beanie Sigel,
Scarface
KANYE WEST MAHAN
DURO
19 "Get Your Mind
Right Mami"
DYNASTY
(2000)
Jay Z
Memphis
Bleek,
Snoop Dogg,
Rell
RICK ROCK MAHAN
20 "Stick 2 the
Script
DYNASTY
(2000)
Jay Z
Beanie Sigel,
DJ Clue
JUST BLAZE MAHAN
21 You, Me, Him
and Her
DYNASTY
(2000)
Jay Z
Beanie Sigel,
Memphis
Bleek,
Amil
BINK MAHAN
22 Guilty Until
Proven Innocent
DYNASTY
(2000)
Jay Z
R. Kelly
ROCKWILDER MAHAN
23 Parking Lot
Pimpin'

DYNASTY
(2000)
Jay Z
Beanie Sigel,
Memphis
Bleek, Lil' Mo
RICK ROCK MAHAN
24 Holla DYNASTY
(2000)
Jay Z
Memphis
Bleek
B-HIGH MAHAN
25 1-900-Hustler DYNASTY
(2000)
Jay Z
Beanie Sigel,
BINK MAHAN
21
(& SINGERS)
PRIMARY
BEATMAKER
SOUND
ENGINEER(S)
Memphis
Bleek,
Freeway
26 The R.O.C. DYNASTY
(2000)
Jay Z,
Beanie Sigel,
Memphis
Bleek
JUST BLAZE MAHAN
27 Soon You'll
Understand
DYNASTY
(2000)
Jay Z JUST BLAZE MAHAN
28 Squeeze 1
st

DYNASTY
(2000)
Jay Z RICK ROCK MAHAN
29 Where Have
You Been"
DYNASTY
(2000)
Jay Z,
Beanie Sigel,
L. Dionne
T.T. MAHAN
30 Who Want
What

THE
TRUTH
(2000)
Beanie Sigel,
Memphis
Bleek
JUST BLAZE MAHAN
DURO
31 Raw &
Uncut
THE
TRUTH
(2000)
Beanie Sigel,
Jay Z

BINK MAHAN
32 Mac Man THE
TRUTH
(2000)
Beanie Sigel,

SHIM KIRKLAND MAHAN
33 Everybody
Want to be a
Star
THE
TRUTH
(2000)
Beanie Sigel

BERNARD
PARKER
MAHAN
34 Remember
Them Days
THE
TRUTH
(2000)
Beanie Sigel

LOFEY MAHAN
35 Stop, Chill THE
TRUTH
(2000)
Beanie Sigel

ROCKWILDER MAHAN
DURO
36 Mac and Brad THE
TRUTH
(2000)
Beanie Sigel

J-5 MAHAN
DURO
37 What a Thug
About
THE
TRUTH
(2000)
Beanie Sigel

BUCKWILD MAHAN
38 What You Life
Like
THE
TRUTH
(2000)
Beanie Sigel

SHIM KIRKLAND MAHAN
39 Ride 4 My THE
TRUTH
Beanie Sigel

BINK MAHAN
22
(& SINGERS)
PRIMARY
BEATMAKER
SOUND
ENGINEER(S)
(2000)
40 Die THE
TRUTH
(2000)
Beanie Sigel

PRESTIGE
VANDERPOOL
MAHAN
DURO
41 Tales of a
Hustler
THE
REASON
Beanie Sigel SHA-SELF MAHAN
42 The Change
Up
THE
UNDERST-
ANDING
Memphis
Bleek
SHIM KIRKLAND MAHAN
43 My Mind Right THE
UNDERST-
ANDING
Memphis
Bleek
DJ TWINZ MAHAN
44 Is That Your
Chick
THE
UNDERST-
ANDING
Memphis
Bleek,
Twista, Missy
Elliot
TIMBALAND MAHAN
45 4 Da Family MONEY IS
LEGAL
Amil,
Jay Z,
Memphis
Bleek,
Beanie Sigel
TYFIFE MAHAN

23
SCHEDULE B
CREDIT BILLING TO
CHAUNCEY MAHAN

# SONG TITLE ALBUM LINER NOTE CREDITS
1 Hova Song (Intro) VOL. 3
(1999)
RECORDED BY:
CHAUNCEY MAHAN

2 Do It Again (Put Ya
Hands Up)
VOL. 3
(1999)

RECORDED BY:
CHAUNCEY MAHAN

3 Dope Man VOL. 3
(1999)

PRODUCED & RECORDED BY:
CHAUNCEY MAHAN

4 Things That U Do

VOL. 3
(1999)

PRODUCED & RECORDED BY:
CHAUNCEY MAHAN
5 S. Carter VOL. 3
(1999)

PRODUCED AND RECORDED BY:
CHAUNCEY MAHAN

6 Pop 4 Roc

VOL. 3
(1999)
RECORDED BY:
CHAUNCEY MAHAN

7 Watch Me VOL. 3
(1999)
RECORDED BY:
CHAUNCEY MAHAN

8 Big Pimpin' VOL. 3
(1999)
RECORDED & MIXED BY:
CHAUNCEY MAHAN

9 "There's Been a Murder" VOL. 3
(1999)
RECORDED & PRODUCED BY:
CHAUNCEY MAHAN

10 "NYMP" VOL. 3
(1999)
RECORDED BY:
CHAUNCEY MAHAN

11 Hova Song (Outro) VOL. 3
(1999)

RECORDED BY:
CHAUNCEY MAHAN
12 Girl's Best Friend
(bonus track)
VOL. 3
(1999)
RECORDED BY:
CHAUNCEY MAHAN
24

13 Is That Yo Bitch
(bonus track)
VOL. 3
(1999)

RECORDED & EDITED BY:
CHAUNCEY MAHAN
14 Girl's Best Friend
(bonus track)

VOL. 3
(1999)

RECORDED BY:
CHAUNCEY MAHAN
15 Intro DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
16 "Change the Game" DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
17 "Streets Is Talking"

DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
18 "This Can't Be Life"

DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
19 "Get Your Mind Right DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
20 "Stick 2 the Script DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
21 You, Me, Him and Her DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
22 Guilty Until Proven
Innocent
DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
23 Parking Lot Pimpin'

DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
24 Holla DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
25 1-900-Hustler DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
26 The R.O.C. DYNASTY
(2000)
RECORDED BY:
25
CHAUNCEY MAHAN
27 Soon You'll Understand DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
28 Squeeze 1
st

DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
29 Where Have You Been" DYNASTY
(2000)
RECORDED BY:
CHAUNCEY MAHAN
30 Who Want What

THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
31 Raw & Uncut THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
32 Mac Man THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
33 Everybody Want to be a
Star
THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
34 Remember Them Days THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
35 Stop, Chill THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
36 Mac and Brad THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
37 What a Thug About THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
38 What You Life Like THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
39 Ride 4 My THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
26
40 Die THE TRUTH
(2000)
RECORDED BY:
CHAUNCEY MAHAN
41 Tales of a Hustler THE REASON
(2000)
RECORDED BY:
CHAUNCEY MAHAN
42 The Change Up THE
UNDERSTANDING
RECORDED BY:
CHAUNCEY MAHAN
43 My Mind Right THE
UNDERSTANDING
RECORDED BY:
CHAUNCEY MAHAN
44 Is That Your Chick THE
UNDERSTANDING
RECORDED BY:
CHAUNCEY MAHAN
45 4 Da Family MONEY IS
LEGAL
RECORDED BY:
CHAUNCEY MAHAN

27
PART II:
SR COPYRIGHT
REGISTRATIONS
! ! !
A. EMPLOYER-FOR-HIRE REGISTRATIONS (1999-2000)

75. As per Schedule C, Roc-A-Fella Records, LLC filed SR
copyright registrations with the U.S. Copyright Office relating to the
Schedule A Recordings. True and correct copies of the SR registration
forms on file with the U.S. Copyright Office is attached hereto as Exhibit
76. Roc-A-Fella registered all sound recording works listed in
Schedule C as employer-for-hire despite the fact that Roc-A-Fella was
not the Petitioners employer.
B. ROC-A-FELLAS REPORTED COPYRIGHT ASSIGNMENT (2004)

77. In December 2004, Mr. Carter reportedly negotiated the
contractual reversion of SR copyrights registered by Roc-A-Fella as part
of a transaction in which Mr. Carter divested his ownership interests in
Roc-A-Fella Records and became President of Def Jam.
78. Under the purported terms of the 2004 agreement between
Mr. Carter and Roc-A-Fella (or UMG or Def Jam) the reversion of the SR
copyrights are scheduled to trigger ten (10) years after the 2004
transaction, a period which is set to expire by the end of 2014. [See
Exhibit R].

28

SCHEDULE C
ROC-A-FELLAS SR COPYRIGHTS
! ! !
Registered Claimant: Roc-A-Fella Records, LLC (employer for hire)

Type of Work: Sound Recording(s)

U.S.
Registration
#
Date

Title
(Rap Artist)
Basis of
Claim
Description

Note
1 SR0000272-
074
10-17-
1999
Jigga my Nigga
(Jay Z) /
What a Thug
About (Beanie
Sigel)
New
Matter:
Remix
12 Vinyl
(33 1/3 rpm)
n/a
2 SR0000270-
611
10-19-
1999
Jigga my Nigga
(Jay Z) /
What a Thug
About (Beanie
Sigel) / When
Will You See
(Memphis
Bleak)
New
Matter:
all other
sound
recordings;
pictorial
matter
CD Single

Two (2)
Selections
are Pre-
existing
3 SR0000279-
081
2-28-
2000
Do it again (put
ya hands up) /
So ghetto (Jay
Z)
n/a 12 Vinyl
(33 1/3 rpm)
Three (3)
Versions of
Each
Selection
4 SR0000278-
208
3-20-
2000
THE TRUTH
(explicit)
(Beanie Sigel)
n/a CD n/a
5 SR0000279-
270
4-12-
2000
LIFE AND TIMES
OF S. CARTER
VOL. 3 (Jay Z)
New
Matter:
Remix,
additional
recordings
CD

Collection
6 SR0000295-
613
12-11-
2000
THE DYNASTY:
ROC LA FAMILIA:
(Jay Z)
n/a CD n/a
7 SR0000286-
397
9-18-
2000
Remember
Them Days
New
Matter:
12 Vinyl
(33 1/3 rpm)
Three (3)
versions of
29
U.S.
Registration
#
Date

Title
(Rap Artist)
Basis of
Claim
Description

Note
(Raw & Uncut) remixes of
sound
recordings
Each
Selection
8 SR0000298-
140
06-04-
2001
Guilty until
proven
innocent; 1-
900-hustler
New
Matter:
remixes of
sound
recordings
12 Vinyl
(33 1/3 rpm)
n/a
9 SR0000293-
532
2-21-
2001
Anything; Big
Pimpin (Jay Z)
New
Matter:
remixes of
sound
recordings
12 Vinyl
(33 1/3 rpm)
Three (3)
Versions of
Each
Selection
10 SR0000293-
539
01-09-
2001
Change the
Game; You, me
and her / (Jay
Z)
New
Matter:
remixes of
preexisting
sound
recordings
12 Vinyl
(33 1/3 rpm)
Three (3)
Versions of
Each
Selection
11 SR00002935
38
02-21-
2001
Parking lot
pimpin (Jay Z)
New
Matter:
remixes of
preexisting
sound
recordings
12 Vinyl
(33 1/3 rpm)
Three (3)
Versions of
Each
Selection
12 SR00002673
65
12-27-
2000
THE
UNDERSTANDING
(Memphis
Bleek)
n/a CD n/a

.

30
PART III
PRESENT
OWNERSHIP DISPUTE
! ! !

A. PETITIONERS CUSTODY OF TANGIBLE SOUND RECORDINGS
(1) MR. MAHANS PHYSICAL POSSESSION & CUSTODY OF MULTI-TRACK (PRO
TOOLS) AND TWO-TRACK (DAT) SOUND RECORDINGS FOR 15 YEARS

79. From the moment of the recordings tangible fixation into
digital waveform in 1999 and 2000 up through April 18, 2014, Petitioner
was in legal custody, possession and control of all multi-track sound
recordings to which he contributed his aesethic sensibilities.and
technical skills.
80. After ending his collaboration with Roc-A-Fella recording
artists, Petitioner continued to archive his proprietary computer
hardware, electronic storage devices (e.g., external hard-drives and
cartridges) and movable media (e.g., digital audio tapes, CDs, cassettes)
[collectively the chattel].
(2) RESPONDENTS LONG-TERM KNOWLEDGE OF PETITIONERS CUSTODY &
POSSESSION OF ALL UNPUBLISHED SOUND RECORDINGS

81. On November 16, 2000, Petitioner transmitted written
notification to several Def Jam and Roc-A-Fella record label executives,
including Mr. Tony Vanias, Ms. Linda Lee and Mr. Kyambo Hip-Hop
Joshua, amongst others. In these notifications, Petitioner informed the
Def Jam record label executives that he was in possession of multi-track
31
sound recordings made in collaboration with Roc-a-Fella artists, which
he described as masters.
3

82. Petitioner never received a response from Def Jam or Roc-A-
Fella record label executives.
83. For a period of almost 14 years, key Def Jam and UMG
record label executives who administered sound recordings released on
the Roc-A-Fella imprint knew that the Schedule A Sound Recordings and
unpublished materials were in Petitioners custody, possession and
control. Despite this knowledge, Def Jam or Roc-A-Fella record label
executives never took care to inquire as to what sound recordings
Petitioner had in his custody, possession and control.
84. Neither Mr. Carter nor any of his agents contacted Petitioner
at any time after November 2000.
85. Mr. Carter knew or should have known that all of the multi-
track sound recordings created during Petitioners collaboration with
Roc-a-Fella artists had been archived by Petitioner in his Pro Tools
system, which saved digital multi-track audio files on Petitioners
computer hard-drives and external peripheral devices.
86. Mr. Carter knew that Petitioner maintained in his possession
a comprehensive library of safe copy DAT tapes containing two-track
versions of songs that Petitioner could download from Petitioners Pro
Tools system.

3
Such materials were not actually masters, in the technical sense of that term, because
the materials embodied in the chattel were not those sent to the mastering facility.
32
87. At all relevant times, Mr. Carter knew or should have known
that Petitioner was the chief custodian of two-track, hard copy versions
on DAT because Mr. Carter routinely requested that Petitioner make two-
track copies in cassette format for Mr. Carters own personal use outside
of the studio. Mr. Carter took care to request cassette format of pre-
mastered material to prevent digital bootlegging of CDs or DATs.
88. At all relevant times, Mr. Carter knew or should have known
that Petitioner was the chief custodian of all two-track copies of the
Schedule A Recordings in DAT format, which Petitioner provided to Mr.
Carter or Roc-A-Fella A&R executives, upon their request, in advance of
Jay Zs live performances or television appearances.
89. UMG, Def Jam and Roc-A-Fella have been in possession of
the finalized two-track master recordings since the date they were first
delivered to the third-party mastering facility back in 1999 or 2000.
B. RESONDENTS EXPRESS RENUNICATION OF PETITIONERS
OWNERSHIP AND AUTHORSHIP RIGHTS

(1) RESPONDENT ROC NATIONS FALSE CRIMINAL CHARGES AGAINST
PETITIONER (APRIL 18, 2014)

90. On April 18, 2014, Respondents Roc Nation and Mr. Carter,
via their Los Angeles-based civil litigation counsel, orchestrated a
makeshift sting operation in which Respondents agents met Petitioner
in person at his commercial storage unit in Los Angeles, California.
Shortly after cataloguing an inventory of the copyrightable materials and
33
DAT tapes in Petitioners possession, Respondents called the LAPD
(Devonshire precint) to seize Petitioners chattel at the storage unit based
on patently false accusations that Petitioner was in possession of stolen
property.
91. On April 18, 2014, the LAPD seized Petitioners chattel,
which upon information and belief continues to be held in the evidence
locker of the LAPD. [A true and correct copy of the Receipt of the
Property form, dated April 18, 2014, is attached hereto as Exhibit T].
92. Concurrent with the LAPDs seizure of Petitioners chattel,
Respondents Roc Nation and Mr. Carter lodged three separate criminal
complaints against Petitioner based on false accusations of grand
larceny in New York (Manhattan); extortion in Los Angeles (Beverly
Hills); and possession of stolen property in Los Angeles (Devonshire).
93. Before the date of April 18, 2014, none of the Respondents,
nor any third party, had ever reported the Sound Recordings at issue as
missing, lost or stolen. Nor did they make any ownership claim with
respect to the chattel.
94. Petitioner was not arrested by police in connection with the
April 18, 2014 incident.
95. As of the date of filing this complaint, Petitioner has not been
charged with any crime by any one of the three police departments in
New York City or Los Angeles.

34
(2) ROC NATIONS VOLUNTARY WITHDRAWAL OF EXTORTION COMPLAINT
THREE WEEKS AFTER FILING CHARGES (MAY 14, 2014)

96. On May 6, 2014, Petitioners counsel participated in a
teleconference with Roc Nations lead counsel during which Petitioner
asserted a joint copyright ownership interest in the Sound Recordings.
Several days later, Petitioners counsel shared these same views with
UMGs in-house counsel.
97. On May 14, 2014, it was widely reported that Respondents
Roc Nation and Mr. Carter unilaterally withdrew the criminal charges
pending with the LAPD (Beverly Hills division). The media also reported
that the LAPD had killed the investigation. [Attached as Exhibit U are
true and correct copies of various news reports, dated May 14, 2014].

[next page]

35
PART IV
ORIGINS OF HIP-HOP
SOUND PRODUCTION

! ! !

99. Each musical genre has its own set of rules and its own
form. [quoting THIS IS YOUR BRAIN ON MUSIC (2006), Exhibit K, p. 239]
100. When we try to understand the music of a different culture
or historical period, we must be prepared to open our minds . . . to the
possibility that they may have an entirely different conception of what
music itself is. [quoting AFRICAN RHYTHM & SENSIBILITY (1979), Exhibit L,
p. 31]
101. Defining the ways a producer can contribute to a sound
recording requires a more accurate understanding of the record making
process than authorities have demonstrated. See Note, Fix it in the Mix:
Disaggegating the Record Producers Copyright, 26 HARVARD JOURNAL OF
LAW & TECHNOLOGY 325 (Fall 2012).
A. JAMAICAN DUB MUSIC (1967 - 1973)
(1) THE INVENTION OF THE SOUND SYSTEM

102. Reggae, it has often been said, is rap music's elder kin.
The blues had Mississippi, jazz had New Orleans. Hip-hop has Jamaica.
[quoting Jeffrey Chang, CANT STOP WONT STOP: HIP-HOP GENERATION
(2004), pp. 22-23]. Jamaican musical forms have been particularly
significant in the development of hip-hop aesthetic practices. [quoting
36
Morgan and Bennett, Hip-Hop and the Global Imprint, Exhibit N, p. 1].
103. By the early 1960s, portable sound equipment had largely
supplanted the use of live musicians to play large Jamaican dancehalls
and yards, i.e. schoolyards converted into venues for dancing. Outfitted
with powerful amplifiers and homemade speakers, a single DJ, or
selector, could now organize a musical gathering for the entire
community.
104. During the 1960s, the Jamaican sound engineer who both
provided the sound equipment and who also knew how to leverage the
technology to stage a better sound system became the dominant
contributor to the evolution of Jamaican musical forms.
105. As per Jeff Cheng, the pop audience demanded heroes and
icons, but reggae, perhaps more than any other music in the world, also
privileged the invisible music men, the sonic architects - the studio
producer and the sound system selector. Together, during the seventies,
these two secretive orders emerged as sources of power in Jamaica.
[quoting HIP-HOP GENERATION (2004), Exhibit H, p. 29]

(2) DUBPLATES AS A NEW VERSION BASED ON ISOLATED DRUM TRACKS

106. In the mid-1960s, as the Jamaican music industry
expanded, sound systems began to record local artists songs onto vinyl
acetates called dubplates.
107. In 1967, a Jamaican sound engineer was in the process of
37
cutting dubplates in a record plant when he accidentally pressed up a B-
side without any vocals on the rhythm track. Jamaican DJs successfully
incorporated these alternative instrumental mixes, called dubs, into
their selections for the dancehall
108. With the invention of dub, the Jamaican sound engineers
recognized that a single studio session with musicians could now be
used as source material to produce multiple versions or alternate mixes
of the same track. The concept of the remix was thus born.
109. The dub versions predominantly featured drum, percussive
and bass elements whose frequencies were manipulated through the use
of electronic sound mixers and dynamic processors. Jamaican sound
engineers produced these instrumentals by adding layers of electronic
sound effects to forge a new sonic collage that became its own exclusive
recording. As such, the sound engineer leveraged his knowledge of
progressive audio techniques to create derivative works of the source
material.
(3) THE SOUND ENGINEER AS MUSICAL COMPOSER AND PRODUCER

110. By the early 1970s, Jamaican sound mixing engineers, such
as Osbourne Ruddock p/k/a King Tubby, pioneered the dub sound
and thereby elevated the role of mixing engineers to the creative ranks
traditionally reserved for composers and musicians. In recognition of
their technological expertise, these avant-garde musicmakers were called
dub scientists.
38
111. In the privacy of their own recording studios, the 70s era
dub scientist could produce numerous, distinct versions of a single
sound recording through electronic manipulation of the multi-tracks
sonic frequencies.
112. By accentuating certain sounds and removing others, or by
applying various special effects such as echoes, reverb, filters and
phasers, Jamaican dub scientists found success by reworking the
original sound recording of studio musicians into unique instrumental
configurations which highlighted the core rhythms of their bass and
drum parts.
113. With dub music [a] single [live] band session could be
recycled as a dub version in which the mixing engineer himself
became the central performer-experimenting with levels, equalization and
effects to alter the feel of the riddim [rhythm]; and break free of the
constraints of the standard song. [quoting HIP-HOP GENERATION (2004),
Exhibit H, p. 30]
114. Through the exploratory use of new technology, dub
scientists - rather than the original studio musicians or vocalists
became the individuals responsible for producing the final sound of the
instrumental derivatives called dubs and B-sides.
115. Dubs birth . would become a diagram for hip-hop music
. . . A space had been pried open for the break, for the possibility [of
hearing] versions not represented in the official version. [HIP-HOP
39
GENERATION (2004), Exhibit p. 30]
B. BRONX - NYC: THE BIRTH OF HIP-HOP (1974-1979)

116. Hip-Hop music originated in the South Bronx, New York City
in the mid-1970s and was founded upon the innovations of three
visionary sound engineers DJ Kool Herc, Grandmaster Flash, and
African Bambaataa who, like their Jamaican counterparts, pioneered
technological developments in the presentation of sound systems at local
community dances.
(1) DJ KOOL HERC

117. As the recognized founder of Hip-Hop music, Clive Campbell
p/k/a DJ Kool Herc, spent his childhood years in Kingston and
witnessed the advent of the Jamaican sound systems first-hand. His
parents would later emigrate to the West Bronx in the late 60s.
118. In 1973, Kool Herc began to DJ parties at the local
recreational center. Herc wanted to summon the same kind of
excitement he felt as a child in Jamacia.by translating the Kingstonian
vibe of sound system DJs. [HIP-HOP GENERATION (2004), Exhibit H, p. 68]
119. After observing the enthusiastic response of dancers to
certain parts of the records he was playing, DJ Kool Herc discovered how
to extend these momentary breaks into full-length songs consisting of
nothing but a breakbeat which was looped into a repeating cycle.
120. The breakbeat is a section of the vinyl record where the
40
melodic elements of the original piece are suspended and the rhythm
section of the band the drums, bass and conga - are isolated and
brought center stage in the mix.
4
[quoting MAKING BEATS (2002) p. 36].
121. The central innovation of early Hip-Hop was the use of two
turntables and a mixer with two copies of the same record to achieve
isolation of the break . . . At some point in the late 1970s, the isolation
of the break, along with other [turntable] effects began to be considered a
musical form unto itself . . . The break-beat focus of the Bronx DJs set in
motion a number of social trends that would give birth to the music now
known as hip-hop. [quoting MAKING BEATS (2004), Exhibit J, pp. 31-33]
(2) GRANDMASTER FLASH

122. In 1975, Mr. Joseph Saddler p/k/a Grandmaster Flash
was a teenager living in the Bronx who shared Kool Hercs love of music
and electrical engineering. Grandmaster Flash tried to figure out how to
turn beat-making and crowd-rocking into a science before venturing out
to conquer the scene. [quoting HIP-HOP GENERATION (2004), Exhibit H, p.
112].
123. Grandmaster Flash studied the turntable and mixer for
years trying to understand which model and what cartridges and styli
were the most durable, which platters had the best torque he

4
Most breaks upon which the foundation of Hip-Hop musical production is based
were recorded by bands of musicians who were active during the late 1960s and early-
mid 1970s.

41
understood that each record's rhythm had its own circumference to
trace, that the break could be measured from point-to-point, and he
developed a theory based on sectioning off the record like a clock.
[quoting HIP-HOP GENERATION (2004), Exhibit p. 112].
(3) AFRIKA BAMBAATAA

124. Completing the trinity of hip-hops three kings was another
Bronx youth of Caribbean descent named Afrika Bambattaa.
125. According to Dangerous Crossroads (Lipsitz, G.):
The first visible manifestations of what we have come to call
hip-hop culture . . . appeared in the early 1970s when . . .
Afrika Bambaataa organized the Zulu Nation. . . .
Bambaataa tried to channel the anger and enthusiasm of
young people in the South Bronx away from gang fighting
and into music, dance, and graffiti. He attracted African-
American, Puerto Rican, Afro-Caribbean, and Euro-American
youths into his nation. . . . [quoting DANGEROUS
CROSSROADS (1994), Exhibit M, p. 26].

126. When Kool Herc first come on the scene, he stayed ahead of
the other DJs with the power of his sound system, Bambattaa changed
the game with his programming genius. [quoting HIP-HOP GENERATION
(2004), Exhibit H, p. 111].
127. As a DJ, Bam became known for being able to find a
danceable break in any kind of record He staged dances featuring his
estimable talents as a mixer and sound system operator capable of
providing a non-stop flow of danceable beats from an enormous range of
musical styles. [quoting Dan Charnas, The BIG PAYBACK: THE HISTORY OF
THE BUSINESS OF HIP-HOP (2009), p. 20]
42
PART V
AFRICAN-DERIVED
MUSICAL AESTHETICS

! ! !
A. PERFORMANCE VALUES
(1) PARTICIPATORY COLLABORATION

128. According to DJ Kool Herc: Hip-hop is a family so everybody
has got to pitch in. East, west, north or south - we come from one coast
and that coast was Africa. [See HIP-HOP & THE GLOBAL IMPRINT (2011),
Exhibit N, p. 31]
129. As per DANGEROUS CROSSROADS (Lipsitz, G.), hip-hop brings
a community into being through performance based on the same
customs and aesthetic values that are prevalent in traditional music-
making societies throughout sub-Saharan regions of Africa:
Hip-hop culture brings to a world audience the core values of
music from most sub-Saharan African cultures. It blends
music and life into an integrated totality, uniting performers,
dancers, and listeners in a collaborative endeavor . . . African
music is participatory, collective and collaborative. Rhythms
are layered on top of one another as a dialogue . . . The
incorporation of these African elements into hip-hop raises
challenges to Western notions of musical (and social) order
[quoting Dangerous Crossroads (1994), Exhibit M, p. 36]

130. In his ethnomusicology piece AFRICAN RHYTHM & SENSIBILITY,
John Miller Chernoff explains:
In an African musical event, everyone present plays a part
The most successful performance will involve everyone present
43
on various levels of participation and appreciation, and their
enjoyment is the chief criterion of excellence . . . [F]rom a[n
African] musician's standpoint, making music is a matter of
expressing the sense of an occasion, the appropriateness at that
moment of the part the music is contributing to the rest . . . For
African musicians, each new situation is the fundamental
setting of artistic creativity. [quoting AFRICAN RHYTHM (1978),
Exhibit L, p. 87, 50]

(2) MUSIC-MAKING ROLES

131. Hip-hop culture promotes the mythological DJ as the
cornerstone of the musical form and, by extension, the community itself.
Hip-hop DJs are seen as artists in their own right, creating a collage of
hip-hop songs. [quoting MAKING BEATS (2004), Exhibit J, p. 50]
132. In traditional African drum circles, the ensemble leader is
known as the master drummer. His role is remarkably similar to that of
the live Hip-Hop DJ. According to AFRICAN RHYTHM & SENSIBILITY
(Chernoff, J.), the master drummer:
has an audience, consisting of players and dancers as well
as spectators, and he creates for them as well as for himself.
He is a master of ceremonies in a way, whose responsibility
is that everyone have a good time. He will invite honored
guests to dance; . . . he times the length of the movements,
sets the tempo of the dance drumming and keeps his
musicians up to the mark . . . .. [quoting AFRICAN RHYTHM &
SENSIBILITY (1978), Exhibit L, p. 50]

133. Music scholars have often compared modern rappers to
ancient African griots, who are described by Chernoff as a hereditary
caste of musicians whose political duty it is to preserve and recite the
great historical traditions. [quoting AFRICAN RHYTHM & SENSIBILITY (1978),
44
Exhibit L, p. 50].
(3) IMPROVISATION

134. The ability to freestyle, or improvise ones performance in
the moment, is a critical value in the expressive manifestation of hip-
hop.
135. Whatever feeling demands a release at a given moment finds
its way out in the songs. The music is as deep and varied as life. Jay-Z
- DECODED (Kindle Locations 2892-2893).
136. African music, like other African arts, is admired mostly as
a spontaneous and emotional creation, an uninhibited, dynamic
expression of vitality [p. 28]. . . The musician who can add an extra
dimension of excitement, the cutting edge, to a performance will
demonstrate both his mastery of all the elements of the music and his
involvement with the progress of the social event. [quoting AFRICAN
RHYTHM & SENSIBILITY (1979), Exhibit L, p. 82]
(4) UNIQUE STYLE

137. A distinctive performance style is one of the core values of
the hip-hop aesthetic, e.g., It fits my style to rhyme with high stakes
riding on every word and to fill every pause with pressure and
possibility. Jay-Z - DECODED (Kindle Locations 2077-2078). I also make
choices in technique and style to make sure that it can touch as many
people as possible without it losing its basic integrity. Id. at Kindle
45
Locations 1478-1480).
138. Similarly, [i]n Africa, people are interested in the special
quality of a given performance, and they pay attention to the distinctive
touch of a musician who through his central role in the event
characterizes it with his personality. African [musicians] cultivate this
kind of critical refinement because the style of a performance is such a
significant issue . . . [quoting AFRICAN RHYTHM (1979), Schedule L, p. 82]
(5) CHOREOGRAPHIC DIALOGUE

139. Although the commercialization of hip-hop music has
positioned the rapper as the most visible expositor of the musical form, it
has been observed that the key to the whole hip-hop culture is built on
the DJs playing for the dancers. [quoting FOUNDATION (2009), Exhibit I,
p. 37]
140. Likewise, African music, with few exceptions, is to be
regarded as music for the dance, although the "dance" involved may be
entirely a mental one. [quoting AFRICAN RHYTHM (1979), Schedule L, p.
50]
B. SONIC ATTRIBUTES
(1) RHYTHM AS THE VITAL FORCE

141. Hip-hop is considered a revolutionary art form because it
tends to invert the Western concept of music by bringing the drums to
the forefront of the soundscape. According to jazz musician Max Roach,
46
hip-hop is rhythm for rhythms sake. See Exhibit M, p. 37.
142. What makes it hip-hop is the drums. [quoting MAKING
BEATS (2004), Exhibit J, p. 144].
143. According to AFRICAN RHYTHM & SENSIBILITY (Chernoff, J.),
rhythmic complexity is the heart of African music . . . Rhythm is to the
African what harmony is to the Europeans, and it is in the complex
interweaving of contrasting rhythmic patterns that he finds his greatest
aesthetic satisfaction. [quoting A. M. Jones in AFRICAN RHYTHM &
SENSIBILITY (1979), Exhibit L, p. 40]
(2) KALEIDOSCOPIC SOUNDSCAPES

144. Sampling allows producers to take musical performances
from a variety of recorded contexts and organize them into a new
relationship with each other. It is this relationship that represents the
producers' art, and it is this relationship that reveals the producers'
aesthetic goals. [quoting MAKING BEATS (2004), Exhibit J, p. 150].
145. Hip hop emphasizes and calls attention to its layered
nature. The aesthetic code of hip-hop does not seek to render invisible
the layers of samples, sounds, references, images, and metaphors.
Rather, it aims to create a collage in which the sampled texts augment
and deepen the song[s] meaning to those who can decode the layers of
meaning. [quoting Richard L. Schur, HIP HOP AESTHETICS AND
CONTEMPORARY AFRICAN AMERICAN LITERATURE (2008)].
146. Just as the beat of an ensemble is made interesting by the
47
master drummer, so a rhythm is interesting in terms of its potential to be
affected by other rhythms . . . though the rhythms are played apart, the
music is unified by the way the separate parts fit together into a cross-
rhythmic fabric. Only through the combined rhythms does the music
emerge. [quoting AFRICAN RHYTHM (1979), Schedule L, p. 31]
147. The accents of a singer or a master drummer will engage
and highlight various rhythms in order to increase the effect. [quoting
AFRICAN RHYTHM (1979), Schedule L, p. 52]
148. Describing a parallel dynamic in hip-hop music, Mr.
Carter states:
Its been said that the thing that makes rap special, that
makes it different both from pop music and from written
poetry, is that its built round two kinds of rhythm . . .
the beat is only one half of a rap songs rhythm. The
other is the flow. When a rapper jumps on a beat, he
adds his own rhythm. Sometimes you stay in the pocket
of the beat and just let the rhymes land on the square so
that the beat and flow become one . . . beats and flows
work together . . . [quoting Jay Z, DECODED (2010),
Exhibit M, pp. 10-12]

(3) TIMBRAL DIVERSITY

149. Hip-hops sonic aesthetic firmly rests on pulsating drums
and percussive elements and therefore incorporates key properties such
as tonal quality, pitch, duration, intensity, and especially timbre.
150. Timbre . . . is the most important and ecologically relevant
feature of auditory events . . . . We employ the term timbre to refer to
the overall sound or tonal color of an instrument - that indescribable
48
character that distinguishes a trumpet from a clarinet when they're
playing the same written note . . . . [quoting THIS IS YOUR BRAIN ON MUSIC
(2006), Exhibit K, p. 45]
151. Timbre is a consequence of the overtones. Different
materials have different densities metal and wood-tend to produce
energy at several frequencies at once because of the way they are
internally structured. [quoting THIS IS YOUR BRAIN ON MUSIC (2006),
Exhibit K, p. 19]
152. The timbre and other qualities of potential samples are a
particular concern for hip-hop producers. Nowhere is this interest more
manifest than in the selection of drum sounds. In fact, hip-hop
producers often comment on the apparent lack of concern for drum
timbres among musicians in other genres. [quoting MAKING BEATS
(2004), Exhibit J, p. 144].
153. Changing the part of one drum in a composition, therefore,
would alter the effect of the total rhythmic fabric. [quoting AFRICAN
RHYTHM & SENSIBILITY (1979), Exhibit J, p. 57].
(4) DEEP LOW-END FREQUENCIES

154. Another chief distinguishing factor of hip-hop music is the
emphasis on low end bass frequencies that give the music a thump or
warmth. The challenge of obtaining the ideal low-end frequency on hip-
hop records is usually the task of a sound engineer.
49
PART VI
HIP-HOPS TRANSITION TO
THE RECORDING STUDIO

! ! !
A. CLASSIC DEFINITIONS OF PRODUCER VS. ENGINEER

(1) RECORD PRODUCER

155. In the North American phonograph industry of the 1970s,
the term producer was primarily used to describe the person charged
with supervision over all aspects of the sound recording process, which
included selecting the location of the recording studio, hiring the studio
musicians or engineers, choosing the recording methodology, scheduling
sessions with the recording artist, coaching the in-the-booth
performances, contributing to song arrangements, and mixing the tracks
on the album to achieve the desired optimal sound.
156. It was customary for the record label or recording artists to
select ONE individual to produce an entire album of songs (e.g., Phil
Spector or Quincy Jones). No one but the record producer could take the
credit (or the blame) for the final sound of the master recordings. This
was because the classic record producer was present in the recording
studio at all times, directing all of the movements of the team players not
unlike the conductor of an orchestra.
157. In todays music industry, the role of the 1970s record
50
producer remains largely the same in genres which continue to record
music through acoustic instrumentation, such as rock, folk and country.
(2) SOUND ENGINEER

158. As a rule, the intent of recorded music until the 1960s was
to reproduce the sound of live performance as accurately as possible.
Therefore, the role of the recording engineer was to use recording
equipment to capture a sound on tape. [quoting MAKING BEATS (2004),
Exhibit J, p. 41].
159. Sound engineers in the pre-digital recording era were usually
retained on a work-for-hire basis as studio personnel who, more often
than not, operated under the direct control and supervision of the
albums record producer. Under this scenario, it was the unique ear of
the record producer that was prized by labels and recording artists. As
such, the record producer was present in the studio at all times giving
specific instructions.
160. A sound engineer may consist of multiple persons each
performing different engineering functions. For example, there may be a
tracking engineer, recording engineer, mixing engineer and mastering
engineer.
B. FROM HIP-HOP DJ TO PRODUCER
(1) DJS: MASTERING SCIENCE TO EXPRESS ART (1970S)

161. During the 1970s, the artistic expression of authentic hip-
51
hop DJs required an in-depth knowledge of electrical and sound
engineering, as well as an advanced facility for operating state-of-the-art
technology in a live performance setting. In other words, to become a
real hip-hop DJ, there was a strict rite of passage: an aspirant had to
first acquire the scientific knowledge to operate his own technology
before expressing his voice. This meant that there was no true distinction
between art and science in the quest to stage the ultimate soundscape.
162. In the culture of hip-hop, a DJ and a sound engineer are one
in the same person, e.g., DJ Kool Herc, Grandmaster Flash, Afrika
Bambaataa. The founders of hip-hop knew that mastery over the
technology would lead to infinite possibilities in their artistic mode of
expression. To that end, unification of style and technique was
considered fundamental.
(2) THE BIRTH OF RAP MUSIC (1979)

163. During the first six years of its evolution, hip-hop music
largely remained an expression of local youth culture performed live at
community block parties and special events in the Bronx and Harlem.
164. In October of 1979, a song entitled Rapper's Delight
became the first studio recording to galvanize hip-hop music as a
commodity which crossed over from New York's insular hip-hop scene to
Black radio, then charged up the American Top 40, and swept around
the globe. [quoting HIP-HOP GENERATION (2004), Exhibit H, p. 129-131].
165. Once record executives observed that money could be
52
generated from the sales of recorded hip-hop music, which was coined by
the media as rap music, the focus of production shifted from live
performance in the streets of the Bronx to professional recording studios
in Manhattan. [HIP-HOP GENERATION (2004), Exhibit H, p. 129-131].
(3) ACQUIRING TOOLS OF THE TRADE (EARLY 1980S)

166. The move by hip-hop DJs into the [recording] studio was
part of a larger trend throughout the spectrum of popular music toward
the increased use of technology in the creation of music. [quoting
MAKING BEATS (2002), Exhibit J, p. 40-41]. This transition was propelled
by the introduction of digital samplers, sequencers, drum machines and
synthesizers in the early-mid 1980s.
167. The transition from the use of turntables and live
instruments to the use of looping samplers in the mid-1980s is almost
universally viewed within hip-hop as a natural evolution. [quoting
MAKING BEATS (2002), Exhibit J, p. 137)].
168. In 1986, E-Systems introduced the first sampling percussion
machine manufactured by, model no. SP-12.
169. The SP-12, and its more advanced progeny the SP-1200,
revolutionized the field by enabling a composer of hip-hop instrumentals
to construct the primary musical layer of a rap song through use of
sampled sounds or breakbeats.

53
(4) BUILDING THE LAB (MID-1980S)

170. Virtually all sample-based hip-hop producers do the
majority of their work in home studios. [quoting MAKING BEATS (2002),
Exhibit J, p. 46].
171. The democratization of music-making technology in the mid-
1980s enabled beatmakers to construct hip-hop instrumentals in the
privacy of their own homes. This set the stage for a creative explosion in
the art of beatmaking because it granted the creators access to music-
making tools on a 24/7 basis.
(5) CLAIMING THE TITLE OF PRODUCER (LATE 1980S)

172. Because live musicians were no longer an essential part of
the recording process, the roles of composer and musician became
integrated into that of the producer. [quoting MAKING BEATS (2004),
Exhibit J, p. 41]
173. Back then [in the mid-1980s] it wasnt labeled as
production. You had a drum machine and you made beats for your
MCs. And next thing you know, when it came to making records, you
are known as a producer. quoting Prince Paul, BEAT KINGS: THE
HISTORY OF HIP-HOP (2007) [DVD].
(6) BIFURCATING THE DJS ORIGINAL ROLE (EARLY 1990S)

174. Many successful hip-hop producers from the late 1980s and
early 1990s era, such as DJ Premier, had backgrounds as respected hip-
54
hop DJs and were largely capable of engineering their own sound
recordings. [On Vol. 3, Petitioner did not work on the DJ Premier track
because Premier handled it in his own studio environment].
175. Although there was a steep learning curve, the top producers
of the Golden Age era of hip-hop aspired to learn the mathematics
necessary to engineer a state-of-the-art hip-hop record from start to
finish; and therefore bridged the gap between making beats vs. actually
making records.
176. Andre Young p/k/a Dr. Dre is one of the most successful
producers of hip-hop records in the history of the art form. He began his
early career as a DJ and studied sound engineering and audio
techniques for years before establishing himself as a record producer.
He is now hip-hops first billionaire. Dr. Dre has made it a point to
publicly distinguish the role of a beatmaker from the role of a hip-hop
record producer:
Theres definitely a big difference between a beatmaker
and a producer because once you finish the beat, you have
to produce the record. Dr. Dre, Art of Rap @ Netflix,
1:36:20.

177. Q-Tip, another successful producer and rapper with A
Tribe Called Quest, who made the beats for many of Tribes legendary
90s hip-hop records, has made the exact same point (in a wholly
different interview):
[T]heres a difference between producers and beatmakers. I think
that's a thing that should be discussed more. Anybody can do dope
beats and you rhyme over them and it's like, yeah, OK, but a
55
producer will do more to challenge you and what you're saying,
really guide you through your performance on the song. In hip-
hop, theres not many true producers
5
Q-Tip

178. There are many beatmakers in the hip-hop genre who simply
lack the expertise, time or motivation to learn the craft of making a
record. But from the perspective of the music industry, this is not
necessarily a problem:
a. First, the beatmakers ability to perform his contribution in
the lab, outside of a professional recording studio and on
his own time, meant that there was no corresponding
requirement for him to learn the sophisticated recording,
mixing, editing, or pre-mastering techniques involved in the
production of the master recording.
b. Second, the professional recording studios utilized by major
labels often employed in-house engineers who already knew
how to operate the console.
c. Third, beatmakers had already solidified their claim to the
title of producer, and whatever fame and income that
became associated with such title, and there was not much
incentive for them to learn the craft of making a record
(unless, of course, it was their passion to do so).
179. As the 1990s progressed, major label rappers were no longer
seen pairing up with only one DJ / beatmaker to record an entire album.

5
http://www.redbullmusicacademy.com/lectures/q
tip?template=RBMA_Lecture%2Ftranscript (accessed June 2, 2014).
56
Instead, the rappers or A&R executives selected beats from a wide range
of materials based on a single-to-single basis. This meant even less
participation by the beatmakers in the professional sound studios
recording process.
C. ENTER THE STUDIO MAGICIANS
(1) THE HIP-HOP ENGINEER

180. In hip-hop, the sound engineer takes on a substantial role in
the production process of sound recordings, in part, because [s]ample-
based hip-hop is a studio-oriented music. [quoting MAKING BEATS (2002),
p. 41].
181. According to Dan Levitin in THIS IS YOUR BRAIN ON MUSIC:
Recording engineers and musicians have learned to create
special effects that tickle our brains by exploiting neural
circuits that evolved to discern important features of our
auditory environment. These special effects are similar in
principle to 3-D art, motion pictures, or visual illusions,
none of which have been around long enough for our brains
to have evolved special mechanisms to perceive them; rather,
they leverage perceptual systems.

Recording engineers have learned to mimic those cues to
imbue recordings with a real-world, life like quality even
when theyre made in sterile recording studios. [quoting
THIS IS YOUR BRAIN ON MUSIC, Exhibit K, p. 107].

182. The contributions of a sound engineer to a hip-hop sound
recording are analogous to the contributions of a photographer who uses
her knowledge of camera technology to express a creative eye by
capturing the optimal light directed at a subject and developing the
selected image into versions deemed suitable for professional exhibition.
57
183. Given that hip-hop music is produced in the digital domain,
the role of the sound engineer takes on greater significance in the core
processes of beat editing, instrumentation, synthesizing, musical
composition, song arrangement, mixing, and pre-mastering.
6

184. In digitally produced music, the sound engineer (or
programmer) ultimately controls the frequency (i.e., rate of vibration); the
amplitude (i.e., intensity of vibration); and the pitch (the rate of vibration
expressed as musical notes (A, A#, etc.) of the sonic elements which are
interwoven into the sound recordings.
185. The role of the sound engineer is also critical in hip-hop
musical production, as compared to the traditional role played by sound
engineers in the acoustic recording process, because the foundation of
hip-hop culture stresses an individuals mastery over a technique in their
chosen field. For example, rappers strive to master the technique of
vocal delivery, b-boys strive to master the technique of a lexicon of dance
moves, and DJs strive to master the techniques involved in live sound
presentation.
186. Not unlike a stunt pilot who must master the aviation
controls in the cockpit before showcasing the aircrafts manuevers as a
work of performance art, hip-hop sound engineers are required to exhibit

6
Whereas analog recording is a continuous process that captures and stores the
musical waveforms directly in the tangible recording medium (i.e. vinyl or tape), a
digital recording system encodes a description of the musical waveforms in a binary
code that can be reduced to numbers. Sounds recorded into a digital format are
therefore subject to endless variations of manipulation by the sound engineer.

58
a high degree of mastery over the complex technical aspects that are
involved in producing a professional sound recording in the field of hip-
hop.
(2) THE PROGRAMMER

187. A programmer is a recording industry term used to
describe a studio composer, arranger, instrumentalist or synthesist who
engages in musical composition through use of electronic devices such
as digital samplers, drum machines, synthesizers, audio sequencers, or
software programs.
188. Programming is musicianship by virtual simulation of a
manually-played instrument. Through use of hardware (e.g., the SP-1200,
Akai MPC-60 or Ensoniq ASR-10) or a digital audio workstation (e.g., Pro
Tools, Apple Logic), the programmer can originate a musical composition
and sound recording simultaneously.

59
PART VII
PETITIONERS
CONTRIBUTIONS

! ! !
A. OVERVIEW
(1) PETITIONERS CONTROL OVER THE FINAL SOUND

189. For each of the 45 tracks listed in Schedule A, as well as
with respect to all unpublished materials, Petitioners collaborative role
in the recording studio vis--vis the putative joint authors was typically
the same: Mr. Mahan was in charge of setting up or scheduling the
recording sessions and studio time, tracking the prototype beat of the so-
called producer, pre-mixing the beat, sample editing, choosing the
recording methodology and setting up the microphones, vocal recording,
vocal coaching, vocal compositing, multi-track mixing, song arranging,
pitch shifting, additional editing, and pre-mastering a final version
through use of a digital audio workstation such as Pro Tools.
7

190. There were other joint collaborators in the process, of course,
but they often came and went quickly. Petitioners role was to be
physically present in the studio for the entire process, at all times

7
To the extent more sonic detail or descriptions will be required on a
track-by-track basis to establish Petitioners original contributions to the
recording in question, the Court should note that the actual sound
recordings that need to be analyzed are no longer in Petitioners
possession, having been seized by the LAPD, and therefore could not
have been individually analyzed by Petitioners counsel in preparing this
petition.
60
monitoring the various sonic elements at play; and he was constantly
working on his own without any supervision - towards molding and
shaping the optimal soundscape.
191. The reason why Petitioner ultimately came to possess all of
the multi-track recordings on his Pro Tools system is because he
maintained full control over the entire process of actually making the
record.
(2) COMPLETE ABSENCE OF THE BEATMAKER

192. Once the various beatmakers had completed a rough version
of the beat, which more often than that existed in an undeveloped,
truncated or demo form (hereinafter, the prototype beat), the beat was
then delivered to Mr. Mahan directly or to the record labels A&R
department.
193. During the Fall of 1999, when the Schedule A Recordings
embodied on Vol. 3Life and Times of S. Carter were tracked, recorded,
mixed, arranged, edited, and pre-mastered at Sony Studios Studio E
none of the beatmakers who were credited as producers on Vol. 3 were
in the building.
194. Once the beatmaker delivered his beat to the Petitioner,
either directly or through the Roc-A-Fella A&R executive, the respective
contributions of the beatmaker had ended before the actual process of
making the record had begun. Thus, regardless of whatever title or credit
was ascribed to his role, Chauncey Mahan is the only collaborator on Vol.
61
3 who truly functioned in all of the same capacities as the classic 1970s
record producer.
(3) MODERATE INPUT FROM RAPPERS

195. Mr. Carters role in the process of making the sound
recordings embodied on Vol. 3 was largely focused on performing his
vocals. Otherwise, Mr. Carter would stop by Sony Studios from time to
time to listen to the progress of what Petitioner was doing. But, aside
from the vocal performance process, Mr. Mahan largely performed his
contributory role in solitude, expending dozens of hours manipulating
the sound to make it hot.
B. MULTI-TRACKING THE BEAT

196. Petitioners first step in the professional recording studio was
called tracking, which describes the technique of separating the
individual sonic elements of the prototype beat and sliding them into
divisible, numbered tracks.
197. For each of the 45 songs listed in Schedule A, Petitioner
performed the tracking process via his Pro Tools multi-track system.
198. The purpose of multi-tracking the prototype beat in Pro Tools
is to enable the Petitioner to exercise his aesthetic command over the
individual sonic elements that comprise the beat; namely, the snare
drum, kick drum, hand clap, bassline, closed hi-hat, open hi-hat, conga,
sampled loop, or some kind of abstract noise, etc.
62
C. PRE-MIXING

199. After Petitioner multi-tracked the sonic components of the
prototype beat, he then individually analyzed, modified, EQd,
compressed, filtered, phased, layered or refined the elements of the
prototype beat through a variety of tools provided in his digital audio
workstation.
200. Petitioner always manipulated the different timbres of the
sonic elements and expended time cycling the tracks to achieve what he
perceived to be the ideal cross-fabric or sweet spot of multiple timbral
qualities.
201. The only limitation on Petitioners use of Pro Tools to pre-mix
and edit the prototype beat was Petitioners own imagination and
aesthetic preference.
202. Petitioners contributions to the pre-mixing process were
routinely improvised by leveraging his own expertise and experimenting
in the moment using a progressive style of trial and error over the
course of multiple sessions.
D. EDITING THE BEAT

203. After the prototype beat was tracked and pre-mixed in Pro
Tools, Petitioner edited the sampled sounds or loops to eliminate any
defects, such as unwanted clicks, hums, or buzzes.
204. During the beat editing process, Petitioner sometimes
(although not always) substituted his own preferred sound samples for
63
those originally selected by the beatmaker. For example, the specific
timbre of the snare drum used in any given hip-hop beat carries a
special, heightened reverence in hip-hop production circles. By simply
changing the snare drum sample in an underlying beat, the entire song
is likely to take on a distinct groove or feel that can determine whether
the song is successful with audiences. Petitioner had the discretion to
render such alterations.
205. In tracks where Petitioner actually substituted sampled
sounds in his own mixing console that had the effect of modifying key
elements of the prototype beat, e.g., by substituting the snare drum or
kick drum for other drum samples, then Petitioner contributed to the
beatmaking process.
E. RECORDING VOCALS

206. In hip-hop sound production, the process of recording
refers to the methodology used by the professional sound engineer to
capture the in-studio performance of the rapper or other featured
vocalists.
207. With respect to the Schedule A Recordings, Petitioner made
original contributions as the recording engineer charged with selecting
the model, make and quantity of microphones and other audio devices
for use in the vocal recording process depending on the songs original
timbre or number of vocalists, physically positioning the microphone(s),
providing direction or motivation to the vocalists during their
64
performances in the sound booth, and regulating against potential
sibilance.
208. The process of recording a professional-sounding vocal
performance in the field of hip-hop is a craft performed by formally
trained sonic artisans. Petitioner is such an artisan, having acquired
unique expertise in capturing the human voice, a naturally-occurring
analog phenomenon, and transmuting that voice into digital waveforms
that consist of a mathematically reconfigured or time-and-space-shifted
reflection.
209. Mr. Carter has himself recognized that the voice going into a
microphone is not quite the same as the sound coming out of the
speaker on the other end. It is, in effect, a distorted simulation of the
human voice that carries distinct tonal properties.
We] started practicing our rhymes into a heavy-ass tape
recorder with a makeshift mic attached. The first time I
heard our voices playing back on tape, I realized that a
recording captures you, but plays back a distortion a
different voice from the one you hear in your own head,
even though I could recognize myself instantly, I saw an
opening, a way to re-create myself and reimagine my world.
After I recorded a rhyme, it gave me an unbelievable rush
to play it back, to hear that voice. Jay Z, DECODED (2010)

210. Sibilance occurs where the recording of a performers vocal
generates pops or distortion because of the rappers pronunciation of
hard consonants, e.g., p or t. Because rappers often enunciate in
percussive tones, the elimination of sibilance is a particular challenge for
every recording engineer, including Petitioner. Petitioner utilized a de-
65
esser plug-in to cut the sibilance down during in-studio performances
while leaving the vocals sounding clean and bright.
211. Because a rapper is inspired to move about physically during
his performance while the rhythm track is playing, unwanted sibilance
may also occur due to audible drop-outs in the vocal tracks. Petitioner
coached the Roc-A-Fella recording artists in terms of their physical
performance on the microphone and suggested ideal spatial dynamics
necessary to capture what Petitioner believed would be the ideal
performance.
212. At all relevant times, Petitioner maintained full aesthetic
command over the process of vocal recording the Schedule A Recordings
and retained decision-making authority concerning the ideal
methodology to optimize the sound of the captured performances.
213. Recording vocals particularly percussive vocals as is the
case in rap is a daunting challenge and very much an art form unto
itself.
F. COMPOSITING VOCALS

214. The process of compositing vocals is a form of musical
arrangement which requires the engineer or producer of a hip-hop record
to engage her aesthetic sensibilities to generate an optimal-sounding
vocal performance.
215. After Petitioner electronically captured the performances of
the vocalists, including Jay-Z, Petitioner expended several hours on his
66
own time compositing the vocals by compiling together or splicing
together the best performance parts from each of the numerous different
takes. This is a tedious process, but one which generates the best
results.
G. MIXING

216. The process of mixing involves the careful and nuanced
infusion of all of the individual sonic components together into a unitary
whole.
217. The process of mixing is performed by a mixing engineer
and includes the use of dynamic sound processors and equalization to
shape and balance the final soundscape of the record.
218. Petitioner mixed every one of the 45 sound recordings listed
on Schedule A. As indicated, another mixing engineer named Duro
also contributed his skills to mixing some of the records. But there was
never a case where Duro simply mixed the entire song himself.
219. The fact that Duro was credited as the mixer on the majority
of tracks listed where the two engineers shared the mixing duties had
more to do with Duros longstanding personal relationship with Mr.
Carter than with the actual relative contributions that took place.
220. With respect to each mix, Petitioner routinely used the
processes or techniques of equalization, reverb, delay, expansion,
filtering, phasing and amplifiication to add balance, depth, color, and
tonality to each of the diverse instruments or distinct sounds located in
67
the multi-track mix of the Sound Recordings. For example, to accentuate
or balance the drum or percussive sounds of any given recording,
Petitioner used an expander/gate to decrease the amplitude of a signal
when it fell below a certain threshold.
221. The goal of equalization for the mixing engineer is to make
subtle adjustments that allow all of the tracks to inhabit their own
frequency areas. This allows the song to be clear and each instrument
distinguishable. As once said by jazz musician Sun Ra, space is the
place. The spatial dimensions of the recording, i.e., the gaps between
individual sounds and accents, is often what gives the final sound its
appeal.
222. Petitioner also used high or low pass filters on the Schedule
A Recordings to eliminate any unneeded frequencies or to enhance the
low-end of the bass or crackle of the snare.
223. Automation tools are designed to recreate the effect of sound
waves traveling through the space of a room, providing a more natural
sound to recordings. Petitioner also applied automation techniques to
certain tracks in each mix by increasing or fading volume, echo, or
reverb at certain points along each songs continuum. Alternatively,
Petitioner used automation techniques to pan an individual track from
left to right in a stereo spectrum to achieve a wider sound or special
effect in the listeners ear.
224. Petitioner also experimented with increasing the volume of
68
certain frequencies in the mixes of the Schedule A Recordings without
causing any distortion. Petitioners expertise was necessary to regulate
the deep low-end frequencies of the tracks, which always present a
particular challenge in the field of hip-hop sound production. Too much
bass can muffle or overwhelm the mix; but not enough will render the
track less appealing to audiences. It was Petitioners task to find the
right warmth in the low end frequency and to manipulate the overall
duration and tonality of the extended kick drum.
225. During a mixing session, Petitioner also utilized digital audio
compression plug-ins to modulate the ratio, attack, and threshold of
each song with the intent of substantially altering the sonic impact of the
recording.
226. There is a sonic imperative in sampled-based hip-hop to
make electronically produced elements sound natural: to create a
virtually enhanced simulation of a live band.
227. Hip-Hop producers must balance the requirement of
precision with the requirement that the rhythm be conducive to dancing
(a quality often characterized by hip-hop heads as having "bounce.).
The beat must neither be too mechanical nor too sloppy. [quoting
MAKING BEATS (2004), Exhibit J, p. 144].
228. All of the mixing tasks described herein were performed by
Petitioner with respect to each of the Schedule A Recordings, as well as
with respect to some of the unpublished materials.
69
H. SONG ARRANGEMENT OR STRUCTURE

229. Petitioner also contributed to the process of arranging or
sequencing the songs different component parts, such as the into, hook,
chorus, bridge, break, climax, or ending. Petitioner was able to exercise
a high degree of aesthetic command in the arrangement process by using
the digital audio workstation such as Pro Tools.
230. In hip-hop music, the process of arranging a song involves
deciding upon the ideal introduction to catch the DJs or listeners ear.
There is usually only 10-15 seconds to catch someones ear, so structure
and arrangement of the intro is critical.
231. Petitioner also contributed to the placement of the hook or
chorus in strategic places throughout the song to keep listeners engaged.
Through Pro Tools, he was able to effect subtle changes or quick
transitions in the song, often spaced out at 4 or 8 bars, to build the
suspense or dynamic tension throughout the song, or to accentuate a
key vocal performance. He used Pro Tools to create dynamic effects or
suspense, and to structure a moment of release of energy at some
climatic point along the songs continuum.
232. At all relevant times, there existed virtually unlimited
possibilities for Petitioner to achieve the optimal sound of the hip-hop
sound recording through the song arrangement or song structure
process.
233. Petitioner performed these functions according to his own
70
aesthetic sensibilities and without the direct or even indirect supervision
of other putative joint authors.
I. PRE-MASTERING

234. Pre-mastering describes the final process performed by a
sound engineer in the recording studio environment before the entire
album of songs is sent to a third-party mastering facility.
235. The engineers goal in pre-mastering is to provide high
fidelity and clarity to the soundscape experienced by audiences across
multiple platforms via any audio source.
236. In those cases where Petitioner pre-mastered one of the
songs listed on Schedule A (it is not known which of the 45 tracks he
pre-mastered as of the date of this filing), then he would have utilized
nothing more than subtle finishing touches to the songs by making slight
adjustments primarily to the EQ, compression, limiting, and stereo
enhancement.
J. DUMPING

237. After Petitioner mixed or pre-mastered a particular sound
recording, he was often asked to dump the entire Pro Tools multi-track
version to a two-track version consisting of a stereo audio file.
238. In some cases, Petitioner needed to ensure that all songs on
a single DAT tape were of comparable volume so that the two-track tapes
sounded cohesive.
71
COUNT I
DECLARATORY JUDGMENT

COPYRIGHT ACT, 17 U.S.C. 101, et seq.

! ! !

OWNERSHIP & AUTHORSHIP
[Sound Recordings]

! ! !

A. PETITIONERS STANDING

239. Petitioner incorporates by reference all of the factual
allegations stated in paragraphs 1 to 238 of the Petition as if fully set
forth in this Count I.
240. The district court has jurisdiction to render a declaratory
judgment pursuant to the DECLARATORY JUDGMENT ACT, 28 U.S.C. 2201
where an actual controversy exists.
241. As set forth in section B of Part III , the adverse positions of
the parties have crystallized and the conflict of interests is real and
immediate.
(1) COPYRIGHT OWNERSHIP & AUTHORSHIP

242. Legal ownership in a copyright vests initially in the author
or authors of the work. 17 U.S.C. 201(a).
243. [A]n author is he to whom anything owes its origin;
originator; maker. Medforms, Inc. v. Healthcare Mgmt. Solutions, Inc.,
72
290 F.3d 98, 107 (2d Cir. 2002). The word author refers to a person
who is the source of some form of intellectual or creative work.
WEBSTER'S THIRD INTERNATIONAL DICTIONARY 146 (2002).
244. The creator of a work is, at least presumptively, its author
and the owner of the copyright. See Community for Creative Non-
Violence v. Reid, 490 U.S. 730, 737 (1989).
245. [C]opyrights goal of fostering creativity is best served . . . by
rewarding all parties who labor together to unite idea with form, and that
copyrightable protection should extend both to the contributor of the
skeletal ideas and the contributor who fleshes out the project. See Nimmer
6.07[A][3][a] (emphasis added)
(2) THE ENGINEER OR PRODUCER IS A CLASSIC JOINT AUTHOR OF SOUND
RECORDINGS

246. As per the Copyright Act of 1976, [c]opyright protection
subsists ... in original works of authorship ....[including] ... (7) sound
recordings. See 17 U.S.C. 102(a)(7).
247. Copyright law protects a sound recording from the time it is
created in a tangible format and thereafter becomes the property of the
author who created it. See Circular No. 9, U.S. COPYRIGHT OFFICE.
248. In 1971, Congress specifically addressed the joint ownership
rights in sound recordings split between the performers and record
producers who contributed to the origination of sound recordings:
[t]he copyrightable elements of a sound recording
will usually, though not always, involve
73
authorship both on the part of the performers
whose performance is captured and on the part
of the record producer responsible for setting up
the session, capturing and electronically
processing the sounds, and compiling and
editing them to make a final sound recording.

- Five years later, when Congress enacted the Copyright Act of 1976,
it quoted the above 1971 passage into the House Report. See HR
Rep. No. 941476, 94th Cong. 2nd sess. 56 (1976)
249. Discussing the 1976 House Report, Professor Nimmer
recognizes that the Congressional committee was actually referring to the
contributions of sound engineers (as opposed to record producers)
observing that it is the sound engineer who actually performs the
task of capturing and electronically processing the sounds and
concluding that an executive record producers copyright must be
derivative, through employment for hire or assignment. See 1 Melville B.
Nimmer & David Nimmer, NIMMER ON COPYRIGHT 2.10[A][2]-143
(2006), quoting H.R. REP. No. 94-1476, 94th Cong., 2d. Sess. 1 (1976)
(emphasis added).
8

250. Discussing the 1976 House Report, Professor William Patry
states that [w]ith audio recording of a live musical performance, and the
making of sound recordings, the performers and the sound
engineer/producer, are, absent any special circumstances, classic
joint authors. http://williampatry.blogspot.com/2006/08/joint-
ownership-of-sound-recordings.html; citing H.R. Rep. No. 1476, 94th

8
See also Forward v. Thorogood, 985 F.2d 604, (1st Cir. 1993) (It is apparent from this
passage that the producer envisaged by the [House] committee is one who engaged in
artistically supervising and editing the production.).

74
Cong. 2d Sess. 56 (1976) (emphasis added).
251. Federal courts that have addressed the joint authorship
requirement within the specific context of the music industry have
consistently recognized that sound engineering contributions, if deemed
appreciable, are sufficient to accord copyright authorship and ownership
status to the engineer or producer.
9

B. DECLARATION SOUGHT: JOINT AUTHORSHIP & OWNERSHIP
(1) MR. MAHANS CONTRIBUTIONS PUBLISHED MATERIALS

252. Petitioners original contributions to the Schedule A
Recordings have been alleged elsewhere in this Petition and were of an
artistic, musical, scientific and intellectual nature.
253. Petitioners contributions to the Schedule A Recordings,

9
See, e.g., Diamond v. Gillis, 2005 U.S. Dist. LEXIS 2410 (E.D. Mich. Feb. 17, 2005)
(finding that Petitioners work as an engineer, co-producer, and mixer is within the
ambit of authorship for purposes of a copyright in sound recording); Ulloa v. Universal
Music and Video Distribution Corp., 303 F.Supp.2d 409, 418 (S.D.N.Y. 2004) (Jones, J.)
(recognizing that an original contribution by a sound engineer, editor, or producer may
result in a joint ownership between the record producer and a performing artist in a
sound recording.) citing 1 Nimmer 2.10[A][3]; JCW Investments, Inc. v. Novelty Inc.,
289 F. Supp. 2d 1032 (N.D. Ill. 2003) (finding that a sound engineer may be deemed an
author when he is responsible for setting up the session, capturing and electronically
processing the sounds, and compiling and editing them to make a final sound
recording.) (quoting H.R. Rep. No. 94-1476, at 56 (1976); Staggers v. Real Authentic
Sound, 77 F.Supp.2d 57, 63 (D.D.C. 1999) (stating that where a sound engineers
creative contributions to the sound recording are substantial, a joint authorship may
exist); Systems XIX, Inc. v. Parker, 30 F.Supp.2d 1225, 1228-30 (N.D. Cal. 1998)
(finding joint ownership where plaintiff undertook the arrangement and administration
of recording equipment, electronic processing of sounds, and balancing or equalization
of vocal and instrumental components into a blended whole); quoting UNITED STATES
COPYRIGHT OFFICE, Compendium of Copyright Office Practices 495.01 at 400-37
(noting that both the performer and the record producer usually contribute to the
authorship of a sound recording); see also Morrill v. J.M. Productions, 157 F. Supp. 2d
1120, 1122-26 (C.D. Cal. 2001) (finding that the plaintiffs contributions in producing
and editing a music video satisfied the requisite level of copyrightable expression
necessary to support a claim of joint authorship.).

75
particularly when viewed in the aggregate and in the proper context of
the hip-hop musical genre, constitute an appreciable amount of original
authorship.
254. Petitioners contributions to the Schedule A Recordings are
independently copyrightable, i.e., the original elements he contributed
exist independent of the final mastered sound recordings published by
Roc-A-Fella.
(2) MR. MAHANS CONTRIBUTIONS UNPUBLISHED MATERIALS

255. Mr. Mahan seeks a separate declaration of joint ownership in
connection with the unpublished materials that are currently embodied
on the hardware and storage devices seized by the LAPD.
(3) MUTUAL INTENT OF THE INDIVIDUAL PARTIES
(a) Chauncey Mahan

256. The element of Mr. Mahans intent has been alleged
elsewhere in this Petition.
257. At the time of his collaboration with Mr. Carter, Petitioner
had the full intent that his original contributions to the Schedule A
Recordings would be merged into inseparable or interdependent parts of
a unitary whole.
258. As the magician behind the glass in the recording studio
who spent hundreds of hours supervising and substantially participating
in the hands-on creation of all forty-five tracks identified in Schedule A,
76
Petitioner exercised a high degree of control over every sound recording
to which he contributed.
259. Petitioner exercised unfettered control over the specific
artistic elements he contributed to the Schedule A Recordings; which
means that none of the other putative joint authors provided him verbal
instructions or guidance as to how he should perform his role during the
collaborative process.
260. Petitioners contributions to the Schedule A Recordings
embodied on Vol. 3 were appropriately billed and credited by Mr. Carter
and Roc-A-Fella with respect to his role as a recording engineer and co-
producer. However, with the exception of the record entitled Big Pimpin,
Petitioner did not receive the full credit to which he was entitled for the
substantial contributions he made as a mixing engineer.
(b) Shawn Carter

261. The element of Mr. Carters intent has been alleged
elsewhere in this Petition.
262. Mr. Carter has publically recognized that hip-hop music-
making is a joint collaborative effort.
When you go in and make an album, you have to put all ego
aside, Im putting ego aside, everyone has to put ego aside for the
sake of the project. Jay Z Zane Lowe Interview, Part 1 (9:52)

263. Mr. Carter has stated that the mutual contributions of
rappers and producers are necessary to achieve the ideal sound
77
recordings:
you can write the greatest songs in the world, if you dont
have the producers in that same zone, you know, everyone
has to align at the same time, and thats difficult. You
know, sometimes you are writing greater things than the
producers are coming up with, and sometimes the producers
are just carrying the day, so in those rare times when
everything aligns, thats when its like - those magic moments
Jay Z BB1 INTERVIEW W/ ZANE LOWE, PART 1 (9:52)
10

264. As a hip-hop recording artist working in an intrinsically
collaborative musical form, Mr. Carter had the collegial intent to
collaborate with Petitioner (as well as the other putative joint authors)
towards the common goal of creating the Schedule A Recordings
embodied on VOL. 3 and The DYNASTY, as well as the unpublished
materials.
265. At all relevant times, Mr. Carter had the full intention that
his contributions to the Schedule A Recordings embodied on VOL. 3 and
THE DYNASTY, which consists of vocal performances in his capacity as the
rapper Jay Z, would be merged into inseparable or interdependent parts
of a unitary whole recording.
266. From August 1999 through October 2000, Mr. Carter
expended dozens of hours in the recording studio working one-on-one
with Mr. Mahan to create the Schedule A Recordings embodied on VOL. 3
and THE DYNASTY, as well as the unpublished materials. Mr. Carter also
knew that Mr. Mahan expended hundreds of hours in the recording

10
http://www.hiphopdx.com/index/videos/id.13702/title.jay-z-zane-lowe-interview-part-
1

78
studio by himself editing and manipulating the various sonic elements
which are interwoven into the final sound recordings.
267. During Petitioners collaboration with Roc-A-Fella recording
artists, Mr. Carter never addressed the issue of legal ownership of the
sound recordings with Mr. Mahan. Nor did Mr. Carter discuss any
contractual arrangements or terms with Mr. Mahan at any time.
268. Mr. Carter was responsible for crediting and billing Mr.
Mahan on the liner notes that were published along with the release of
the Schedule A Recordings embodied on Vol. 3 and THE DYNASTY.
269. With respect to the liner notes published in connection with
VOL. 3, Mr. Carter personally thanked Mr. Mahan for his contributions to
the album in the same paragraph line as all other artistic collaborators
whose respective talents contributed to the creation of the recordings
embodied on Vol. 3. These artistic collaborators included the beatmaker,
guest rappers, and a mixing engineer.
270. Mr. Carter did not consider Mr. Mahan to be his personal
employee, nor did he consider Mr. Mahan to be a corporate employee of
Roc-A-Fella. To the contrary, Mr. Carter knew that Mr. Mahan was an
independent contractor or professional freelancer.
271. Upon information and belief, Mr. Carter was not a common
law employee of Roc-A-Fella nor Def Jam nor UMG as of the time the
Schedule A Recordings were created.
272. Upon information and belief, Mr. Carter conveyed his
79
copyright ownership interests in all sound recordings to Roc-A-Fella, Def
Jam and UMG by way of contractual assignment under 17 U.S.C.
Accordingly, Mr. Carter was vested with a joint authorship interest in the
Schedule A Recordings as of the time the sound recordings were created.
(c) Intent of Putative Joint Authors (i.e., third parties)

273. Each of the beatmakers identified in Schedule A had the full
intention that his contribution of a prototype beat would be merged into
inseparable or interdependent parts of a unitary whole recording.
274. As a hip-hop beatmaker working in an intrinsically
collaborative musical form with other rappers and sound engineers, each
of the Beatsmith identified in Schedule A had the collegial intent to
collaborate with the Petitioner (and the other putative joint authors)
towards the common goal of creating the specific Schedule A Recording
for which they provided the prototype beat.
275. Each of the Roc-A-Fella rappers and guest vocalists
identified in Schedule A had the full intention that his or her
contribution of a vocal performance would be merged into inseparable or
interdependent parts of a unitary whole recording.
276. As a hip-hop artist or R&B vocalist working in an
intrinsically collaborative musical form with other rappers, beatmakers
and sound engineers to achieve an optimal-sounding record, each of the
rappers or vocalists identified in Schedule A had the collegial intent to
collaborate with the Petitioner (and the other putative joint authors)
80
towards the common goal of creating the Schedule A Recording and the
unpublished materials.
C. ALTERNATIVE DECLARATION: SOLE OWNERSHIP

277. Petitioner respectfully seeks an declaration of sole ownership
in the alternative as to the Schedule A Recordings, as well as the
unpublished materials, in the event that the putative joint authors
identified in this petition are deemed a work-for-hire or common law
employee of UMG, Def Jam or Roc-A-Fella.
278. In such an event, then Petitioner Chauncey Mahan should
be rightfully declared the sole owner of that specific sound recording to
which the work-for-hire ruling applies. This is because:
(a) the work-for-hire status conferred means that the putative joint
author-employee who conveyed their rights to the label was never
actually an author as of the time of creation; and
(b) a corporate entity cannot be a joint author with another natural
human being under the Copyright Act of 1976. Accordingly,
Petitioner would necessarily establish sole ownership in the
subject SR copyrights by virtue of the labels status as an artificial
entity.

81
COUNT II

COPYRIGHT ACT, 17 U.S.C. 101, et seq.

! ! !

INVALIDATION OF ROC-A-FELLAS
SR COPYRIGHTS AS VOID AB INITIO
[Sound Recordings]

! ! !

A. PETITIONERS STANDING

279. Petitioner incorporates by reference all of the factual
allegations stated in paragraphs 1 to 278 of the Petition as if fully set
forth in this Count II.
280. The district court has jurisdiction to render a declaratory
judgment pursuant to the DECLARATORY JUDGMENT ACT, 28 U.S.C. 2201
where an actual controversy exists.
281. As set forth in section B of Part III, the adverse positions of
the parties have crystallized and the conflict of interests is real and
immediate.
282. Moreover, the SR copyrights at issue are void ab initio as a
matter of statutory law and are therefore subject to invalidation.
B. DECLARATION SOUGHT SR COPYRIGHTS [SCHEDULE C]

283. With respect to all of the SR copyright registrations listed in
Schedule C of this Petition, all such registrations with the U.S. Copyright
82
Office are effectively null and void and should be declared by the
Honorable Court as having no legal effect. This is because Roc-A-Fella
filed the registration listing it as an employer-for-hire which is a
patently false and material misrepresentation given that Petitioner was
not a common law employee of Roc-A- Fella or UMG or Def Jam at the
time the sound recordings came into existence.
284. Roc-A-Fellas misrepresentation is material because
Petitioner did not sign a written agreement to assign his copyright as
statutorily required by section 202 of the Copyright Act of 1976.
285. Moreover, even if a copyright assignment agreement were to
exist as between Roc-A-Fella and the other putative joint authors
identified in this Petition, the misrepresentation is material because Roc-
A-Fellas false registration of the SR copyrights unlawfully impedes the
Joint Authors termination rights under section 203 of the Copyright Act.
286. In addition, Roc-A-Fellas SR copyright for the album entitled
Vol 3Life and Times of S. Carter is void ab initio on additional grounds
that it has been registered as a collective work without the required
listing of the names of the actual authors of the sound recording on the
face of the registration.
287. Finally, Roc-A-Fellas SR copyright for the albums entitled
The Dynasty and The Truth are void ab initio as a matter of statutory law
because Roc-A-Fella clearly omitted to specify the basis of the copyright
registration on the face of the registration
83

PRAYER FOR RELIEF
WHEREFORE, Petitioner CHAUNCEY MAHAN prays for
Declaratory Judgment Against Respondents ROC NATION, LLC, ROC-A-
FELLA RECORDS, LLC and SHAWN CARTER, p/k/a JAY Z as follows:

COUNT I


JOINT OWNERSHIP AND AUTHORSHIP

1. Upon good cause shown, Petitioner respectfully seeks a
declaratory judgment from the Honorable Court pursuant to 28 U.S.C.
2201, 2202 and in the further interests of justice declaring Petitioner to
be a joint owner and author of the individual sound recordings listed in
Schedule A of this Petition as well as all of the unpublished materials
that are currently in possession of the LAPD in Los Angeles.
SOLE OWNERSHIP

2. In the alternative, Petitioner seeks a declaration, upon good
cause shown, that he is the sole owner of the individual sound
recordings listed in Schedule A of this Petition as well as all of the
unpublished materials that are currently in possession of the LAPD in
Los Angeles.
COUNT II


3. Upon good cause shown, Petitioner respectfully seeks a
84
declaratory judgment from the Honorable Court pursuant to 28 U.S.C.
2201, 2202 and in the further interests of justice declaring the SR
Copyrights identified in Schedule C of this Petition as invalid as a matter
of statutory law and therefore having no legal effect.
4. Petitioner respectfully seeks his costs and an award of
reasonable attorneys fees for Counts I and II as per 17 U.S.C. 505.

Dated: July 8, 2014
New York, New York

RESPECTFULLY SUBMITTED

____________________________
James H. Freeman, Esq.
JH FREEMAN LAW
3 Columbus Circle, 15
th
Floor
New York, NY 10019
Telephone: (212) 931-8535
james@jhfreemanlaw.com

Counsel for Petitioner Chauncey Mahan

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