Jones v. Atl. Recording Corp.

CourtCourt of Appeals for the Second Circuit
DecidedJuly 8, 2025
Docket23-1348
StatusUnpublished

This text of Jones v. Atl. Recording Corp. (Jones v. Atl. Recording Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. Atl. Recording Corp., (2d Cir. 2025).

Opinion

23-1348 Jones v. Atl. Recording Corp.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 8th day of July, two thousand twenty-five.

PRESENT: RICHARD J. SULLIVAN, STEVEN J. MENASHI, MARIA ARAÚJO KAHN, Circuit Judges. _____________________________________

DENISE JONES,

Plaintiff-Appellant,

v. No. 23-1348

ATLANTIC RECORDING CORPORATION; WARNER MUSIC GROUP CORP.; 1501 CERTIFIED ENTERTAINMENT, LLC; 300 ENTERTAINMENT LLC; CRAIG KALLMAN; STEPHEN COOPER; CARL CRAWFORD; and KEVIN LILES,

Defendants-Appellees. * _____________________________________

For Plaintiff-Appellant: DENISE JONES, pro se, Pittsburgh, PA.

For Defendants-Appellees: ILENE S. FARKAS (Jessica L. Rosen, on the brief), Pryor Cashman LLP, New York, NY.

Appeal from a judgment of the United States District Court for the Southern

District of New York (Andrew L. Carter, Jr., Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the August 30, 2023 judgment of the district

court is AFFIRMED.

Denise Jones, proceeding pro se, appeals from the district court’s dismissal

with prejudice of her complaint alleging copyright infringement and various state-

law claims against Atlantic Recording Corporation and others responsible for the

recording of songs that Jones contends substantially copy her own. We assume

the parties’ familiarity with the underlying facts, procedural history, and

arguments on appeal.

* The Clerk of Court is respectfully directed to amend the official case caption as set forth above. 2 “We review de novo a [district court’s] dismissal of a complaint under

Federal Rule of Civil Procedure 12(b)(6), accepting all factual allegations in the

complaint as true and drawing all reasonable inferences in the plaintiff’s favor.”

Bangs v. Smith, 84 F.4th 87, 95 (2d Cir. 2023) (internal quotation marks omitted).

Because Jones represented herself, we “liberally construe [her] pleadings and

briefs . . . , reading such submissions to raise the strongest arguments they

suggest.” McLeod v. Jewish Guild for the Blind, 864 F.3d 154, 156 (2d Cir. 2017)

(internal quotation marks omitted).

I. Copyright-Infringement Claims

A plaintiff asserting a claim for copyright infringement must show that she

has “ownership of a valid copyright” and that the defendant improperly copied

“constituent elements of the work that are original.” Feist Publ’ns, Inc. v. Rural Tel.

Serv. Co., 499 U.S. 340, 361 (1991). To demonstrate that a defendant improperly

copied the protected work, the plaintiff must, among other things, prove that the

defendant’s work is substantially similar to the “protectible material” of the

plaintiff’s work. Laureyssens v. Idea Grp., Inc., 964 F.2d 131, 140 (2d Cir. 1992). The

Supreme Court has described protectible material as the creator’s “original

contributions,” Feist Publ’ns, Inc., 499 U.S. at 350 (internal quotation marks

3 omitted), that were “independently created by the author (as opposed to copied

from other works),” and possess “some minimal degree of creativity,” id. at 345.

On appeal, Jones appears to argue that her song “Grab Em By The P****”

(“GEBTP”) is substantially similar to Defendant Pete’s song, “Thot Sh*t,” and

Defendant Almanzar’s song, “WAP,” and that the similarities between Jones’s

song and the defendants’ songs relate to protectible material. 1 We disagree.

Jones’s claims fail for the simple reason that she has not demonstrated that

the defendants’ purported copies are substantially similar to “GEBTP’s”

“protectible material.” Laureyssens, 964 F.2d at 140. We agree with the district

court that the various lyrics that Jones insists were copied in “Thot Sh*t” and

“WAP” are plainly different from those in “GEBTP.” See, e.g., Jones v. Atl. Recs.,

No. 22-cv-893 (ALC), 2023 WL 5577282, at *5–6 (S.D.N.Y. Aug 29, 2023) (explaining

that the lyrics of “GEBTP” share only a handful of words with “WAP” and “Thot

Sh*t” and that those shared words arise in different contexts). And even if it could

be argued that the lyrics are substantially similar, Jones merely alleges that the

defendants’ songs and “GEBTP” share what amount to general themes, common

1 Given the explicit nature of the song titles and lyrics, we use asterisks when spelling certain terms. 4 phrases, and individual words – none of which is protectible under copyright law.

See Williams v. Crichton, 84 F.3d 581, 587 (2d Cir. 1996) (explaining that copyright

does not protect ideas or themes); Acuff-Rose Music, Inc. v. Jostens, 155 F.3d 140, 144

(2d Cir. 1998) (finding the phrase “you’ve got to stand for something, or you’ll fall

for anything” too common to be afforded copyright protection). Because Jones has

failed to demonstrate that the defendants’ compositions are substantially similar

to “GEBTP’s” protected elements, we agree with the district court that Jones failed

to assert a claim for copyright infringement as a matter of law.

II. Remaining Claims

Jones’s remaining claims – for criminal copyright, intentional infliction of

emotional distress, and negligent infliction of emotional distress – and her request

for a default judgment against the defendants likewise fail.

There is no private right of action for a plaintiff to enforce a federal criminal

copyright claim under 17 U.S.C. § 506 and 18 U.S.C. § 2319. See, e.g., Kelly v. L.L.

Cool J., 145 F.R.D. 32, 39 (S.D.N.Y. 1992) (“[T]here is no private cause of action

under the criminal provisions of the copyright law.”), aff’d, 23 F.3d 398 (2d

Cir.1994); see also Eden Toys, Inc. v. Florelee Undergarment Co., 697 F.2d 27, 37 n.10

(2d Cir. 1982) (“[Section] 506 is a criminal [copyright] provision that does not

5 appear to provide a private right of action.”), superseded on other grounds as stated

in Fed. Treasury Enter. Sojuzplodoimport v.

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Related

Williams v. Crichton
84 F.3d 581 (Second Circuit, 1996)
Acuff-Rose Music, Inc. v. Jostens, Inc.
155 F.3d 140 (Second Circuit, 1998)
Ornstein v. New York City Health & Hospitals Corp.
881 N.E.2d 1187 (New York Court of Appeals, 2008)
City of New York v. Mickalis Pawn Shop, LLC
645 F.3d 114 (Second Circuit, 2011)
McLeod v. the Jewish Guild for the Blind
864 F.3d 154 (Second Circuit, 2017)
Chanko v. American Broadcasting Companies, Inc.
49 N.E.3d 1171 (New York Court of Appeals, 2016)
Howell v. New York Post Co.
612 N.E.2d 699 (New York Court of Appeals, 1993)
Krumme v. WestPoint Stevens Inc.
238 F.3d 133 (Second Circuit, 2000)
Laureyssens v. Idea Group, Inc.
964 F.2d 131 (Second Circuit, 1992)
Kelly v. L.L. Cool J.
145 F.R.D. 32 (S.D. New York, 1992)
Steven Bangs v. Walter William Smith
84 F.4th 87 (Second Circuit, 2023)
Henry v. Oluwole
108 F.4th 45 (Second Circuit, 2024)
Thompson v. Booth
122 F.4th 61 (Second Circuit, 2024)

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