Judge Rules Against Copyright Claim In Universal Music’s Favour In High-profile Sampling Case
Mary J. Blige’s “Real Love” clears copyright infringement claims in New York federal court
In a significant ruling on Tuesday, a federal court in New York dismissed a copyright infringement lawsuit filed against Universal Music Group regarding an alleged unauthorized sample in Mary J. Blige’s 1992 hit single, “Real Love.” The lawsuit, initiated by Tuff City Records, claimed that UMG had unlawfully used a drum part from the Honey Drippers’ 1973 song “Impeach the President.” The suit contended that this sample was incorporated without proper clearance.
Court’s Decision
Presiding U.S. District Judge Dale Ho ruled in favour of UMG, finding that “Real Love” was not sufficiently similar to “Impeach the President” to support the infringement claims. Judge Ho emphasized that the two compositions did not share substantial auditory similarity and that a typical listener would not perceive “Real Love” as having been appropriated from the earlier work.
In his statement, the judge remarked, “The songs do not sound the same; a lay listener would not recognize ‘Real Love’ as having been appropriated from ‘Impeach the President.’” Consequently, the court dismissed the case, concluding that the evidence presented did not meet the threshold for copyright infringement.
Context and Previous Litigation
Tuff City Records is a music label that owns thousands of copyrights spanning various genres including Blues, Rhythm and Blues, Jazz, Funk, Soul, Hip-Hop, New Orleans, and Latin Music. The label has a history of initiating copyright lawsuits aimed at protecting these rights, particularly concerning works that might otherwise fade into obscurity.
Previously, Tuff City filed lawsuits against several high-profile artists and their labels, including the Beastie Boys, Jay-Z, Kanye West, and Frank Ocean. The cases against the Beastie Boys and Jay-Z were ultimately dismissed, while the dispute with Ye’s label was settled out of court. The lawsuit involving Frank Ocean’s label was dropped shortly after being filed.
Mary J. Blige’s “Real Love” and Its Significance
“Real Love” is one of Mary J. Blige’s breakthrough tracks from her debut album “What’s the 411?” released in 1992. The song achieved considerable commercial success, peaking at number seven on the Billboard Hot 100 chart. Despite the lawsuit implicating the track, Blige herself was not named as a party in the litigation.
Legal Representation and Next Steps
The case, officially titled Tuff City Records v. Universal Music Publishing Inc., was heard in the U.S. District Court for the Southern District of New York under case number 1:24-cv-02585.
Tuff City Records was represented by attorney Hillel Parness of the Parness Law Firm, while Universal Music Group’s legal counsel included Joelle Milov and Richard Mandel of Cowan Liebowitz & Latman.
Neither party issued immediate public comments following the ruling.
The dismissal of this lawsuit underscores the challenges in proving copyright infringement based on sampling in the music industry, especially when claims hinge on the degree of similarity between songs. The decision also highlights the court’s role in balancing the protection of intellectual property rights against artistic creativity and evolution.
As music sampling continues to be a common practice, cases such as this set important precedents for how courts evaluate claims of unauthorized use and substantial similarity.