Hall v. Warner Music Group Corp.

CourtDistrict Court, M.D. Tennessee
DecidedFebruary 21, 2025
Docket3:22-cv-00457
StatusUnknown

This text of Hall v. Warner Music Group Corp. (Hall v. Warner Music Group Corp.) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hall v. Warner Music Group Corp., (M.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION JOHN HALL, an individual; and ) LANCE HOPPEN, on behalf of ) themselves and all others ) similarly situated, ) ) Plaintiffs, ) ) v. ) Case No. 3:22-cv-00457 ) Judge Aleta A. Trauger WARNER MUSIC GROUP CORP. and ) ELEKTRA ENTERTAINMENT ) GROUP, INC., ) ) Defendants. ) MEMORANDUM Before the court is the plaintiffs’ Motion for Class Certification (Doc. No. 74), seeking to certify this case as a class action for two “Classes” under Federal Rule of Civil Procedure 23: a Rule 23(b)(2) Class and a Rule 23(b)(3) Class. The defendants oppose the motion. For the reasons set forth herein, the motion will be denied. I. BACKGROUND AND PROCEDURAL HISTORY Plaintiffs John Hall and Lance Hoppen, on behalf of themselves and others similarly situated, initiated this action in June 2022 against defendants Warner Music Group Corp. (“WMG”), Warner Music, Inc., and Warner Records, Inc. (Doc. No. 1.) The Second Amended Complaint (“SAC”) (Doc. No. 38), filed in September 2022, added new defendants, including Elektra Entertainment Group, Inc. (“EEG”), Elektra Music Group, Inc., and Atlantic Recording Corp. In June 2023, the court granted in part and denied in part the defendants’ Motion to Dismiss the SAC, dismissing all claims against defendants Warner Music, Inc., Warner Records, Inc., Elektra Music Group, Inc., and Atlantic Recording Corp., and leaving intact the plaintiffs’ claims against defendants WMG and EEG only for (1) breach of contract (Count I) (in part), fraud (Count III), accounting (Count IV), and breach of the covenant of good faith and fair dealing (Count V). See Hall v. Warner Music Grp. Corp., No. 3:22-cv-00457, 2023 WL 3909671 (M.D. Tenn. June

8, 2023). While this opinion presumes familiarity with the ruling on the Motion to Dismiss, which describes in detail the plaintiffs’ factual allegations in the SAC, a brief summary of the parties’ positions is warranted here. The plaintiffs are musicians who entered into a recording agreement with EEG’s predecessor in 1974 (“1974 Agreement”) (Doc. No. 38-1), which provides for the payment of royalties to the plaintiffs for musical recordings made by them and distributed by the defendants both domestically and internationally. Although the corporate relationships are complex, WMG is EEG’s corporate parent.1 The 1974 Agreement does not expressly cover the distribution of musical recordings through digital streaming, which had not been invented at the time the parties contracted. However,

it does include a catch-all licensing provision that sets out a rate formula for licensing-based uses not explicitly contemplated elsewhere in the contract. (1974 Agreement ¶ 4.) This provision cross- references ¶ 3(a)(i) of the Agreement, which stipulates royalties of 8% on the suggested retail price of vinyl records sold in the United States. (Id. ¶ 3(a)(i).) Despite this provision, once the plaintiffs’ music began to be distributed through streaming media (apparently around 2005), the defendants

1 The plaintiffs did not contract directly with WMG. Their claims against it are based on allegations that WMG as corporate parent has total control over EEG and its corporate affiliates and that it abused the corporate form to reduce the royalty amounts to which the plaintiffs would otherwise be entitled. (See, e.g., Doc. No. 38 ¶ 38.) began, and have continued, to pay the plaintiffs royalties on those sales, but at a much higher rate (50%) than the 1974 Agreement contemplated for the distribution of recordings in any medium. The plaintiffs did not object to that arrangement. Rather, their claims stem from their purported discovery that the defendants have not been fully accounting for and paying royalties to

the plaintiffs and putative class members based on all revenue received by the defendants from foreign digital streaming of musical recordings. Instead, according to the plaintiffs, the defendants “secretly retain a substantial portion of foreign streaming revenue, referred to as an intercompany charge,” and they pay royalties to the plaintiffs and other artists based on that reduced revenue, after assessment of the intercompany charge. The plaintiffs allege that they were never notified of, and never agreed to, this arrangement. (See Doc. No. 58 at 1.) They maintain that the intercompany charges are not reflected in the royalty statements they have received since the defendants unilaterally began paying royalties on digitally streamed recordings. Instead, the plaintiffs’ royalty statements reflect only that they are receiving a 50% royalty without any applicable deductions. The plaintiffs allege that they accepted royalty payments in reliance on the royalty statements’

contents. (Doc. No. 38 ¶ 32.) For their part, the defendants maintain that the plaintiffs do not have a contractual right under the 1974 Agreement to foreign streaming royalties calculated at a 50% rate based on 100% of the revenues received “at source”—that is, prior to the assessment of intercompany fees. (Doc. No. 58 at 2.) According to the defendants, there was no meeting of the minds to amend the 1974 Agreement to impose such an obligation on the defendants; the plaintiffs did not provide consideration to support an implied amendment to the 1974 Agreement; and any such purported amendment to that effect would be unenforceable for a number of other reasons. They also assert that the plaintiffs and other artists have known for decades that foreign royalties are calculated on the amounts received in the United States—that its, the amounts the entity with which the plaintiffs (or other artists) contracted actually receives (that is, in the named plaintiffs’ case, EEG), after payment of the intercompany charges to the foreign affiliate that distributed the musical recording internationally, rather than being calculated “at source,” prior to the assessment of the

intercompany charges. The defendants allege that they never told the plaintiffs or other artists that the foreign digital streaming royalties would be calculated any differently than how they had always been calculated. (Id.) Following the court’s ruling on the Motion to Dismiss in June 2023, the parties entered into an agreed scheduling order and then embarked on a year of discovery leading up to the filing of the plaintiffs’ Motion for Class Certification. The motion is supported by a “Memorandum of Points and Authorities” (Doc. No. 73)2 and a substantial quantity of evidentiary material. The defendants filed their Response in Opposition to the Motion to Certify (Doc. No. 88), along with additional evidentiary material, and the plaintiffs filed a Reply (Doc. No. 98), which largely reiterates the points made in their opening Memorandum. The defendants thereafter filed a Notice

of Supplemental Authority, to highlight a Sixth Circuit opinion issued in November 2024, after briefing on the Motion to Certify was closed. (Doc. No. 99 (citing In re Nissan N. Am., Inc. Litig., 122 F.4th 239 (6th Cir. 2024)).) II. LEGAL STANDARDS In contravention of the “usual rule that litigation is conducted by and on behalf of the individual named parties only,” Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 348 (2011) (quoting Califano v. Yamasaki, 442 U.S. 682, 700–01 (1979)), Rule 23 of the Federal Rules of Civil

2 Many of the documents filed by the parties are in the docket twice: an unredacted version filed under seal, and a redacted version that is publicly available. The court refers herein to the sealed versions of the documents.

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Hall v. Warner Music Group Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-v-warner-music-group-corp-tnmd-2025.