1 allison s. hart (bar no. 190409) [email protected] … · 2020-04-07 · 12. dre london...

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1 K:\6820-2\PLE\COMPLAINT COMPLAINT

ALLISON S. HART (BAR NO. 190409) [email protected] J. LEEKER (BAR NO. 313437) [email protected] & SINGER PROFESSIONAL CORPORATION 2049 Century Park East, Suite 2400 Los Angeles, California 90067-2906 Telephone: (310) 556-3501 Facsimile: (310) 556-3615

Attorneys for Plaintiff TYLER ARMES

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

TYLER ARMES,

Plaintiff,

v.

AUSTIN RICHARD POST, publicly known as POST MALONE, an individual; ADAM KING FEENEY publicly known as FRANK DUKES, an individual; UNIVERSAL MUSIC GROUP, INC., a Delaware corporation; DOES 1 through 10, inclusive,

Defendants.

CASE NO. 2:20-CV-3212

COMPLAINT FOR:

1. DECLARATORY JUDGMENT 2. ACCOUNTING 3. CONSTRUCTIVE TRUST

[DEMAND FOR JURY TRIAL]

Plaintiff Tyler Armes alleges as follows:

INTRODUCTION

1. This case arises from Post Malone’s (“Post”) and his producer Frank

Dukes’ (“Dukes”) bad faith refusal to accord Tyler Armes (“Armes”) the credit and

share of the profits he is due as a co-writer of the song Circles, which is perhaps

Case 2:20-cv-03212 Document 1 Filed 04/07/20 of 17 Page ID #:1

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K:\6820-2\PLE\COMPLAINT COMPLAINT

Post’s biggest hit to date and was named by Billboard as among the top 10 best

songs of 2019. Circles was released on August 30, 2019, to much critical praise and

it debuted at Number 7 on the Billboard Hot 100 Chart. It quickly shot to Number

1, where it spent three (3) weeks, and to this day it remains in the Billboard Hot

100’s top 5 most popular songs.

2. Armes is a professional songwriter, musician and producer. He is also

the bandleader, writer and producer for the bands Down With Webster, which was

signed to Motown by Sylvia Rhone in 2009, and Honors. With Armes at the helm,

Down With Webster has sold multiple platinum albums and over One Million

(1,000,000) singles, and it has been nominated for a number of Juno Awards,

MuchMusic Video Awards and Canadian Radio Music Awards. Armes wrote and

produced five (5) of Down with Webster’s top five (5) Canadian singles including,

Rich Girl$, Your Man, Whoa is Me, One in a Million and Chills. Armes, with Down

With Webster, has performed sold-out shows at Toronto’s famed Massey Hall, as

well as performing at the Juno Awards, MuchMusic Video Awards and the Grey

Cup, the championship game of the Canadian Football League. Not only has Armes

been the leader of one commercially successful band, but he also created a second

project called Honors that has also been commercially successful. Honors’ song

Over was the Number 1 Global Viral Track on Spotify in January 2017, and it

charted on the US Alternative Radio charts. Honors was courted by multiple major

record labels and, after receiving multiple offers, it signed with PRMD, the label

helmed by Ash Pournouri, who is best known for managing the artist Avicci. In

addition, Armes individually, has a music publishing deal with Warner Chappell

Music, and Armes’ music has appeared in campaigns for Panasonic, Major League

Baseball, TBS, Fox and The Voice on NBC. Armes has also collaborated with

some of the top writers and producers in the music industry, including Murda Beatz,

Justin Tranter, Jesse Saint John and Timbaland. Armes also co-wrote and produced a

song on Lil Baby’s recent Number 1 charting album My Turn, released on February


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28, 2020, and he co-wrote and produced an upcoming single for $ki Mask “The

Slump God”.

3. On August 8, 2018, after being repeatedly encouraged by Post’s

manager, Dre London (“Dre”), that Armes and Post should collaborate to write

music together, Dre invited Armes to join Post and Dukes at Dukes’ studio to jam

together. When Post found out that Armes was a talented multi-instrumental

musician, he was excited and said, “let’s write a tune!” Armes spent hours in the

studio jamming with Post and Dukes and ultimately co-writing the song Circles.

4. Although Post has freely admitted that Armes co-wrote Circles with

him and Dukes during the August 2018 session at Dukes’ studio, Post and Dukes

have refused to credit Armes as a co-writer and have refused to pay Armes a fair

share of the monies derived from the exploitation of Circles. Despite repeated

efforts by Armes to amicably resolve this matter, Post and Dukes have steadfastly

refused to give Armes the credit and share of the profits he is due.

JURISDICTION AND VENUE

5. Plaintiff’s first claim for relief arises under the copyright laws of the

United States, as amended (17 U.S.C. § 101, et seq.) The Court has subject matter

jurisdiction over this claim pursuant to 28 U.S.C. §§ 1331, 1332 and 1338, and

supplemental jurisdiction over the remaining claims pursuant to 28 U.S.C. § 1367.

6. Venue is proper in this district 28 U.SC. § 1391(b)(2) because

Defendant has committed acts directed at this judicial district, where Plaintiff

resides.

THE PARTIES

7. Plaintiff Tyler Armes (“Plaintiff” or “Armes”) is a songwriter,

producer and composer, and at all times relevant hereto was, an individual residing

in the County of Los Angeles, California.


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8. Plaintiff is informed and believes and based thereon alleges that

Defendant Austin Richard Post, publicly known as Post Malone (“Post”), is, and at

all times relevant hereto was, an individual residing and doing business in the

County of Los Angeles, State of California.


Defendant Adam King Feeney, publicly known as Frank Dukes (“Dukes”) is, and at

all times relevant hereto was, an individual doing business in the County of Los

Angeles, State of California.


Defendant Universal Music Group, Inc. (“UMG”) is, through its Republic Records

division, the distributor of the song entitled Circles, and at all times relevant hereto

was a Delaware corporation with its principal place of business in the County of Los

Angeles, State of California.

11. The true names and capacities of the Defendants sued herein as Does 1

through 10, inclusive, are currently unknown to Plaintiff, who therefore sues such

Defendants by fictitious names. Plaintiff will amend this Complaint to allege the

true identities of such Doe Defendants when their identities are discovered. Plaintiff

is informed and believes, and thereon alleges, that each such fictitiously named Doe

Defendant is responsible in some manner for the events alleged in this Complaint

and that Plaintiff’s damages as alleged herein were proximately caused by the

conduct of such Doe Defendants, and each of them, and that Defendants in

committing the acts and omissions alleged herein acted as agents and servants of one

another, acted within the scope of their authority as agents and servants of each

other, and/or approved and ratified the acts and/or omissions of each other.

ALLEGATIONS COMMON TO ALL CLAIMS

12. Dre London (“Dre”) is a music manager whose best known client is

Post. Armes first met Dre in approximately 2015. After Armes’ band Honors’ hit


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single Over was released and became a viral hit in 2017, Dre began actively courting

Armes and Honors to sign with him. On a number of occasions, Dre has also

encouraged Armes to get into the studio with Post to collaborate.

13. In early August 2018, at Dre’s invitation, Armes attended a private

concert at which Post was performing in Toronto, Canada. The following evening,

Dre again invited Armes to get into the studio with Post to write music together.

14. The following evening, Armes, Dre, Post and Dukes went to see a

band that Post was a fan of play at a club in Toronto. After the show, Dre again

invited Armes to go to Duke’s Toronto studio with Post and Dukes to write music

together. Dre told Post that Armes is “an amazing musician” and that he should

check out Armes’ band. When Post learned that Armes was a legitimate musician

and composer and proficient with multiple instruments, he was excited to jam with

Armes, and write music together.

15. From approximately 2:00 a.m. on August 8, 2018 until 9:00 a.m. that

morning, Armes, Post and Dukes worked together in the studio, with Armes on bass,

Post on drums and Dukes playing guitar and keyboards. That collaboration resulted

in the song Circles (the “Song”), Post’s fourth number one song on the US Billboard

Hot 100, and his first as the only credited artist on the track.

16. At Dukes’ studio on August 8, 2018, Armes and Dukes co-wrote the

chords for the Song on the keyboard, and Armes co-wrote and had significant input

in the bassline for the Song. Armes also had input on the guitar parts in the Song,

including co-writing the guitar melody which is played in the introduction to the

Song and which repeats throughout the Song.

17. A recording engineer at the studio observed Armes working alongside

Post and Dukes to create the Song, and set up Dukes’ equipment and Dukes

recorded the music composed by Armes, Post and Dukes that night with Dukes

playing the bass parts co-written by Armes and Post playing guitar parts co-written

by Armes. At the end of the session that morning, Dukes played back the recording


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for Armes and Post, and the three of them were thrilled with the results of their

collaboration. Dukes exclaimed, “It’s so fucking good! It’s a whole new sound

man. Post said, “It’s super special,” and “that’s gonna be the next … we’re just

gonna, for the next album we’re just gonna use a fuck load of reverb,” and Dukes

said, “this kind of track would be insane to play live.”

18. Although the lyrics had not yet been completed, other than the main

lyric and title of the Song, i.e., “circles”, all instrumentation and vocal melodies in

the song recorded at Dukes’ studio on August 8, 2018 are note for note rhythmically

and melodically identical to the Song and have the same main lyric, title and

concept, including without limitation the guitar introduction co-written by Armes,

and the bassline and chords co-written by Armes. Everything but the bridge vocal

melody was conceived that night.

19. The Song is also dramatically different from other music previously

released by Post. Significantly, although Post is well known as a hip-hop artist,

typically performing lyrics over a rap track, the Song is the first major release by

Post not to appear on any hip-hop charts. As Chris Molanphy observed about the

Song in a December 5, 2019 article for Slate entitled, “Post Malone Might Finally

Be Getting His Wish to Escape Hip Hop,” unlike Post’s prior music, “the melody is

sparkling, with prominent guitar arpeggios and a wistful sigh of a chorus that,

dare I say it, soars. Post Malone has never been about the soar.” Indeed, the style

and sound of the Song is more similar to music created by Armes for his bands

Down With Webster and Honors than it is to any of Post’s prior music.

20. On August 5, 2019, Dre posted a snippet of the Song on Instagram,

and Post premiered the Song live that night during his Bud Light Dive Bar Tour

show in New York City. The Song was released by Defendant UMG through its

Republic Records label on August 30, 2019. The Song debuted at Number 7,

reached Number 1 on the US Billboard Hot 100 for the week of November 30, 2019,

where it remained for three (3) non-consecutive weeks, and to this day it remains


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one of the top 5 most popular songs on the Billboard charts. The Song received

critical praise, with Billboard naming it the seventh (7th) best song of 2019, and

describing it as consisting of a “bouncy, melancholy” melody alongside a “gentle

acoustic groove,” and as being “backed by sunny acoustic guitars, swirling

percussion and infectious melodies” with a “funky feel”.

21. When Dre posted the Song on Instagram on August 5, 2019, Armes

immediately reached out to him and sent him the following text message:

Dre, I need you to ask Post about this please….

Post asked me to write with them and jam and we did for well over an hour

in the live recording room coming up with the jam that lead into the

recording of circles.

I was there until long after the sun came up with them in the main room

working on the song and playing different instruments and contributing to

ideas from start to finish.

Specifically the bass and guitar parts, post ended up tracking them after I

was playing. I was beside him giving input on both of them. I was not just

someone hanging out in the room, I’m a writer/producer in the room with

two other writer/producers working on a song.

I have never asked for anything I don’t deserve. I’ve been in 100 studio

sessions with Lou while he was working at EF with different artists, I know

when I am just hanging out. This was much different.

I was part of the writing process. The entire song (minus the lyrics other

than “circles) was laid down that night with the 3 of us in the room

together, working together.

Trying to just be fair here. Not asking for much. Would just like credit and

minimal pub. Please speak to post. I’ll have Cory my manager hit up

frank’s manager. Thanks brother, excited for the song.


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22. On August 9, 2019, Dre responded to Armes, “Just showed Posty the

message [¶] He said he remembers [¶] U played a tune on the bass then he played

more of it after”. Thus Post acknowledged that Armes co-wrote the Song with him

at Dukes’ studio. In particular, Post recalled Armes’ contributions to the bass line in

the Song. Notwithstanding the foregoing, to date, Defendants have refused to credit

Armes as a co-writer of the Song and have refused to pay him any share of the

publishing royalties for the Song.

23. The credited writers on the song are Post, Dukes, Billy Walsh, who

Armes is informed wrote the lyrics, Louis Bell, a producer with whom Post and

Dukes frequently collaborate and who Armes is informed recorded the vocal track

for the Song, and Kaan Gunesberk, another producer who also frequently

collaborates with Dukes. Other than Post and Dukes, none of the foregoing credited

co-writers of the Song was present with Armes, Post and Dukes at Dukes’ studio

when they composed the guitar, bass and melody of Song on August 8, 2018.

24. After Dre informed Armes that Post remembered and acknowledged

that Armes co-wrote the Song, Post initially offered to give Armes a five percent

(5%) share of the publishing royalties. In response, Armes attempted to negotiate to

receive a larger percentage of the royalties that more fairly reflected his significant

contributions to the Song, and one of his representatives requested that he be

credited as a co-writer and co-producer of the Song while they attempted to reach an

agreement on Armes’ share of the publishing royalties. Defendants refused. Instead,

Austin Rosen, who manages both Post and Dukes, threatened Armes’ manager, Cory

Litwin, that if Armes was unwilling to accept Post’s so-called “gift” of five percent

(5%) of the publishing, then he would get nothing – no credit and no publishing

royalties. Thus, Defendants have retaliated and attempted to punish Armes for not

accepting their low-ball offer on the publishing royalties by refusing to credit Armes

as a co-writer and co-producer of the Song, notwithstanding the fact that Post has

acknowledged that Armes co-wrote the Song.


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25. On November 15, 2019, Plaintiff filed a copyright registration for the

Song, identifying Armes and Defendants Post and Dukes as co-writers of the music

(composition) and sound recording of the Song. A true and correct copy of said

copyright registration is attached hereto as Exhibit A.

26. Defendants’ refusal to credit Armes’ as a co-writer and co-producer of

the Song has resulted in significant harm to Armes’ reputation, career and cost him a

host of opportunities that otherwise would have been available had Armes been

properly credited as a co-writer and co-producer of the Song when it was initially

released. Composers credited with writing hit songs are invited to work with the top

artists in the music industry, among other potentially lucrative opportunities.

27. Songwriters and composers work their entire lives to create a

commercially successful and critically acclaimed song like the Song. As a direct

result of Defendants’ retaliatory refusal to grant Armes the co-writing credit he

admittedly deserves on the Song, which would have been Armes’ biggest musical

credit to date, Defendants have prevented Armes from capitalizing on the success of

the Song in order to further his career in the music industry.

FIRST CLAIM FOR RELIEF

(For Declaratory Judgment against all Defendants)

28. Plaintiff repeats, realleges and incorporates by reference each and

every allegation contained in Paragraphs 1 through 27, inclusive, of this Complaint

as if fully set forth herein.

29. An actual and present controversy now exists between Plaintiff and

Defendants regarding Plaintiff’s status as a co-writer and co-producer of the Song.

Defendants have denied recognition of Plaintiff’s status as a co-writer and co-

producer of the sound recording and composition of the Song, which entitles

Plaintiff to writer credit and a share of the monies generated from the exploitation of

the Song.


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30. Plaintiff contends that he is a co-writer and co-producer with

Defendants Post and Dukes on the sound recording and the composition of the Song.

Plaintiff and Defendants Post and Dukes each jointly contributed separate and

distinct copyrightable chord progressions, melody, and rhythm to the Song. They

each possessed independent creative control over their respective contributions.

31. Plaintiff and Defendants Post and Dukes each manifested an intent to

be co-writers of the Song, and worked together jointly to create the Song. Plaintiff,

Post and Dukes intended that their separate contributions be merged into inseparable

or interdependent parts of a unitary composition.

32. Plaintiff contributed significantly to the Song, including composing the

guitar introduction at the beginning and which repeats throughout the Song, as well

as making significant contributions to the bass line of the Song and the chords in the

Song.

33. An actual and present controversy exists regarding the parties’

respective rights to the Song. Pursuant to the Federal Declaratory Judgment Act, 28

U.S.C. § 2201, Plaintiff is entitled to a declaration of rights as follows: (a) Plaintiff

is a co-writer and co-producer of the sound recording entitled Circles; (b) Plaintiff is

a co-writer of the composition entitled Circles; (c) Plaintiff is entitled to a co-writer

and co-producer credit on the copyright to the Song and on subsequently released

versions of the Song; and (d) Plaintiff is entitled to prospective and retroactive

royalties and other money owed with respect to his interest in the Song.

SECOND CLAIM FOR RELIEF

(For Accounting against all Defendants)





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35. Plaintiff, as joint author and co-owner of the copyright of the sound

recording and composition of the Song is entitled to his pro rata share of the profits

that Defendants have enjoyed from the exploitation of the Song.

36. By commercially exploiting the Song without accounting to Plaintiff

for profits, Defendants have wrongfully deprived Plaintiff of his rightful share of

income therefrom.

37. Defendants are in sole control of the books and records needed to

ascertain the amounts due to Plaintiff pursuant to their special relationship as joint

authors and co-owners of the composition of the Song. Plaintiff has no means by

which he can assemble the information necessary to calculate what is owed to him

by Defendants.

38. Plaintiff is entitled to an order of this Court directing Defendants to

render a complete and honest accounting of all revenues derived from the

exploitation of the Song and all sums due to Plaintiff and to pay Plaintiff the sums

shown due by such accounting.

THIRD CLAIM FOR RELIEF

(For Constructive Trust against all Defendants)




40. By virtue of the foregoing, any interest that Plaintiff has in the Song,

and any and all profits received by Defendants Post and Dukes from the commercial

exploitation of the Song, are the property of Plaintiff, Post and Dukes in equal

shares.

41. Post and Dukes have wrongfully deprived Plaintiff of his share of the

profits that they have enjoyed from the commercial exploitation of the Song.


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42. By virtue of Defendants’ acts, Defendants hold the profits derived

from the exploitation of the Song as constructive trustees for the benefit of Plaintiff

and Defendants.

43. Plaintiff is entitled to immediate possession of his pro rata share of the

profits held by Defendants as constructive trustees.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment against Defendants as follows:

1. That the Court declare that as follows: (a) Plaintiff is a joint author

and has an ownership interest in the sound recording entitled Circles; (b) Plaintiff is

a joint author of the composition entitled Circles; (c) Plaintiff is entitled to a co-

writer and co-producer credit on the copyright to the sound recording and

composition entitled Circles, and on subsequently released versions of Circles; and

(d) Plaintiff is entitled to prospective and retroactive royalties and other money

owed with respect to his respective interest in the sound recording and composition

entitled Circles, in a percentage to be proven at trial;

2. That the Court order an accounting of all revenues derived from the

exploitation of the Song by Defendants;

3. That the Court impose a constructive trust over the proceeds from the

exploitation of the Song pending the final disposition of this action;

4. That Plaintiff be awarded his reasonable attorney’s fees and costs

pursuant to Section 505 of the U.S. Copyright Act (17 U.S.C. § 505); and

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /


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5. For such other and further relief as the Court deems to be just and

proper.

DATE: April 7, 2020 ALLISON S. HART

KELSEY J. LEEKER

LAVELY & SINGER PROFESSIONAL CORPORATION

By: ______________________________

ALLISON S. HART Attorneys for Plaintiff TYLER ARMES


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DEMAND FOR JURY TRIAL

Plaintiff Tyler Armes hereby demands a trial by jury.

DATE: April 7, 2020 ALLISON S. HART

KELSEY J. LEEKER

LAVELY & SINGER PROFESSIONAL CORPORATION

By: ______________________________

ALLISON S. HART Attorneys for Plaintiff TYLER ARMES


EXHIBIT A


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This Certificate issued under the seal of the Copyright Office in accordance with title 17, United States Code., 1')attests that registration has been made for the wor ). identified below. The information on this certificate hai' been made a part of the Copyright Office records. -L;

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Acting United States Register o opyrig

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Title of Work: Circles

Completion/Publication

Year of Completion: Date of 1st Publication:

Nation of 1st Publication: - -' International Standard Number:

Author

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201 , August 30, 2019 United States ISRC USUM71915699

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Author Created: Citizen of:

Domiciled in: Year Born:

Author: Author Created:

Work made for hire: Citizen of:


(4*,-Tyler Armes _et sound recording, music and production-,Canada Canada 1985 • <D ° :2)

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Austin R. PoSt sound recording, music and lyrics,,,No United States United States 1995

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Author: Adam K. Feeney 4r8(

Author Created: sound recording, music and production Citizen of:


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1 allison s. hart (bar no. 190409) [email protected] … · 2020-04-07 · 12. dre london...

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