walker v. carter (roc-a-fella logo complaint)
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7/22/2019 Walker v. Carter (Roc-A-Fella Logo Complaint)
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JS44C/SDNY
REV. 7/2012
JUDGE KE12 CiV
CIVIL COVER SHEET
The JS-44 civil cover sheet and the informationcontained herein neither replace nor supplement the filing and service ofpleadings orotherpapersas required by law, except as provided by local rules of court. This form, approved bytheJudicialConferenceof the UnitedStates inSeptember 1974, is requiredfor use of the Clerkof Courtforthe purpose ofinitiating the civildocket sheet.
fc7
PLAINTIFFS
DWAYNE D. WALKER, JR .
DEFENDANTS
SHAWN CARTER ( JAY-Z ), DAMON DAME DASH, KAREEM BIGGSBURKE,UNIVERSAL MUSICGROUP, INC., ISLAND DEF JAMMUSICGROUP, ROC-A-FELLA RECORDS, LLC
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
LAW FIRM OF GREGORY BERRY450 SEVENTH AVENUE SUITE 1608
NEW YORK, NEWYORK 10123
ATTORNEYS (IF KNOWN)
CAUSE OFACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENTOF CAUSE)(DONOTCITE JURISDICTIONAL STATUTESUNLESSDIVERSITY)
17 U.S.C. s. 101, copyright infringement of plaintiffs Original Roc Logo, and common-law breach of contract
Hasthis ora similar casebeenpreviously filed in SDNY at anytime? No |x] Yes JudgePreviously Assigned
If yes, wasthis case Vol. Invol. f j Dismissed. No Q Yes If yes, give date. & Cas e No .
IsTHIS N INTERNATIONAL ARBITRATION CASE? No £3 YeS Q
PLACEAN[x] INONEBOXONLY
TORTS
NATURE OF SUIT
ACTIONS UNDER STATUTES
CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
[ ] 110 INSURANCE [ J 310 AIRPLANE [ ] 362 PERSONAL INJURY- 1)610 AGRICULTURE [ ]422 APPEAL [ ]400 STATE
[ ]120 MARINE I ]315 AIRPLANE PRODUCT MED MALPRACTICE [ ]620 O TH ER FO O D & 28 US C 15 8 REAPPORTIONMENT
[ ]130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY DRUG [ ]423 WITHDRAWAL [ ]410 ANTITRUST
[ ]140 NEGOTIABLE [ ]320 ASSAULT. LIBEL & PRODUCT LIABILITY [ ]625 DRUG RELATED 28 USC 1 57 [ ]430 BANKS & BANKING
INSTRUMENT SLANDER [ ]368 ASBESTOSPERSONAI SEIZURE O F [ ]450 COMMERCE
[ ]150 RECOVERYOF [ J 330 FEDERAL INJURY PRODUCT PROPERTY [ ]460 DEPORTATION
OVERPAYMENT & EMPLOYERS' LIABILITY 21 US C 88 1 PROPERTY RIGHTS [ ]470 RACKETEER INFLU
ENFORCEMENT LIABILITY [ J 630 LIQUOR LAWS ENCED & CORRUPT
OF JUDGMENT [ ]340 MARINE PERSONAL PROPERTY 1 640 RR & TRUCK 6^820 COPYRIGHTS ORGANIZATION ACT
( ] 1 51 MEDICARE ACT [ ]345 MARINE PRODUCT [ ]650 AIRLINE REGS [ ]830 PATENT (RICO)
[ 1152 RECOVERY OF LIABILITY [ ] 3 70 OTHER FRAUD [ J 660 OCCUPATIONAL [ ] 840 TRADEMARK [ ] 480 CONSUMER CREDIT
DEFAULTED [ ]350 MOTOR VEHICLE [ ] 371 TRUTH INLENDING SAFETY/HEALTH [ ]490 CABLE/SATELLITE TV
STUDENT LOANS [ ]355 MOTOR VEHICLE [ ] 380 OTHER PERSONAL [ ]690 OTHER [ ]810 SELECTIVE SERVICE
(EXCLVETERANS) PRODUCT LIABILITY PROPERTY DAMAGE SOCIAL SECURITY [ ]850 SECURITIES/
[ ]153 RECOVERY OF [ ]360 OTHER PERSONAL [ ] 385 PROPERTYDAMAGE COMMODITIES/
OVERPAYMENT INJURY PRODUCT LIABILITY LABOR [ ]861 HIA(1395ff) EXCHANGE
OF VETERAN'S [ ] 862 BLACKLUNG(923) [ ]875 CUSTOMER
BENEFITS [ ]710 FA IR LABOR [ ]863 DIWC/DIWW (405(g)) CHALLENGE
1)160 STOCKHOLDERS STANDARDSACT [ ]864 SSID TITLEXVI 12 US C 3410
SUITS [ ]720 LABOR/MGMT [ ]865 RSI (405(9) ) ( )890 OTHER STATUTORY
[ ]190 OTHER PRISONER PETITIONS RELATIONS ACTIONS
CONTRACT [ 730 LABOR/MGMT 1 1891 AGRICULTURALACTS
[ ]195 CONTRACT [ ]510 MOTIONS TO REPORTING & FEDERAL TA X SUITS [ ]892 ECONOMIC
PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE DISCLOSUREACT STABILIZATION ACT
LIABILITY 20 US C 2255 [ )740 RAILWAY LABOR ACT [ ]870 TAXES (U.S. Plaintiffor [ ]893 ENVIRONMENTAL
I 1196 FRANCHISE CIVIL RIGHTS [ ] 5 30 HABEASCORPUS [ ]790 OTHER LABOR Defendant) MATTERS
[ ] 535 DEATHPENALTY LITIGATION [ ] 871 IRS-THIRDPARTY [ ]894 ENERGY
[ ]441 VOTING [ ] 540 MANDAMUS&OTHER [ ]791 EMPL RE T INC 26 US C 7609 ALLOCATION ACT
[ ]442 EMPLOYMENT SECURITY ACT [ ]895 FREEDOM OF
REAL PROPERTY [ ]443 HOUSING/INFORMATION ACT
ACCOMMODATIONS IMMIGRATION [ ]900 APPEAL OF F E E
[ ]210 LAND [ J 44 4 WELFARE PRISONER CML RIGHTS DETERMINATION
CONDEMNATION [ ]445 AMERICANS WITH [ ]462 NATURALIZATION UNDER EQUAL
[ )220 FORECLOSURE DISABILITIES - [ ] 550 CIVILRIGHTS APPLICATION ACCESS TO JUSTICE
[ ]230 RENT LEASE & EMPLOYMENT [ ] 555 PRISON CONDITION [ ]463 HABEAS CORPUS- [ ]950 CONSTITUTIONALITY
EJECTMENT [ ]446 AMERICANS WITH ALIEN DETAINEE OF STATE STATUTES
[ ]240 TORTSTO LAND DISABILITIES -OTHER [1465 OTHER IMMIGRATION
[ ]245 TORT PRODUCT
LIABILITY
[ ]440 OTHER CIVIL RIGHTS
(Non-Prisoner)
ACTIONS
[ ]290 ALL OTHER
REAL PROPERTY
heckif demanded in complaint:
CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
EM N OTHER
Check YES only ifdemandedin complaint
JURYDEMAND: S YES NO
DOYOU CLAIMTHIS CASE IS RELATED TO A CIVILCASE NOW PENDING INS.D.N.Y.?
IF SO , STATE:
JU GE DOCKET NUM ER
NOTE: Please submitat the time offiling an explanation ofwhycases are deemed related.
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PLACEAN x INONEBOX ONLY
131 Original fj 2 Removed fromProceeding state Court
ORIGIN
| | 3 Remanded I—I 4 Reinstated or [ | 5 Transferred from 6 Multidistrictfrom Reopened (Specify District) Litigation
a. all parties represented Appellate1—' Court
I I b. Atleastoneparty is pr o se .
I I 7 Appeal toDistrictJudge from
Magistrate Judge
Judgment
PLACEAN x INONEBOXONLY BAS IS OF JURISDICTION
1 U.S. PLAINTIFF 2 U.S. DEFENDANT [X] 3 FEDERAL QUESTION D4 DIVERSITY(U.S. NOT A PARTY)
IFDIVERSITY, INDICATE
CITIZENSHIP ELOW
28 USC 1332, 1441)
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITYCASES ONLY)
(Place an [X] in one box for Plaintiffand one box for Defendant)
CITIZEN OF TH IS STATE
PT F DE F
[ ]1 [ H CITIZEN O R S UB JE C T O F A
FOREIGN COUNTRY
PT F DE F
[ ]3 [ ]3
PT F DEF
INCORPORATED an d PRINCIPAL PLACE [ ] 5 [ ] 5
OF BUSINESS IN ANOTHER STATE
CITIZEN OF ANOTHER STATE [ ] 2 [ ] 2 INCORPORATED or PRINCIPAL P LACE [ ] 4 [ ] 4
OF BUSINESS IN THIS STATE
PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
DWAYNE D. WALKER, JR .2805 DEWEY AVE., APT. 5E
BRONX, NY 10465
FOREIGN NATION
DEFENDANT(S) ADDRESS(ES) ANDCOUNTY(IES)
UNIVERSAL MUSIC GROUP, INC., c/o CT CORP. SYSTEM, 111 8th AVE., NY, NY 10011ISLAND DEF JAM MUSIC GROUP, c /o CT CORP. SYSTEM, 111 8th AVE., NY, NY 10011
ROC-A-FELLA RECORDS, LLC, c/o CT CORP. SYSTEM, 111 8th AVE., NY, NY 10011
[ ]6 [ ]6
DEFENDANT(S) ADDRESS UNKNOWNREPRESENTATION IS HEREBY MADETHAT, ATTHIS TIME, I HAVEBEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE
RESIDENCE ADDRESSES OF TH E FOLLOWING DEFENDANTS:
SHAWN CARTER ( JAY-Z )DAMON DAME DASH
KAREEM BIGGS BURKE
Check one: THIS ACTION SHOULD BE ASSIGNED TO: WHITE PLAINS |X| MANHATTAN(DONOTcheck either box ifthis a PRISONER PETITION/PRISONER CIVIL RIGHTS COMPLAINT.)
DATE 7/12/2012 SIGNATUREOF EY OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT
[ ] NON YES (DATE ADMITTED Mo. £7 Yr. 2011 )AttorneyBar Code gb2730 (NY Bar 4960845)ECEIPT
M BMagistrate Judge is to be designated by the Clerk oflt|jj y 4JV iJV'u • i J
Magistrate Judge is so Designated.
Ruby J. Krajick, Clerk of Court by. Deputy Clerk, DATED
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
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JUDGE RTER
,12 cwNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YO
^384
DWAYNE D. WALKER, JR.,
Plaintiff,
SHAWN CARTER ( JAY-Z ), DAMON
DAME DASH, KAREEM BIGGS
BURKE, UNIVERSAL MUSIC GROUP, INC.,
ISLAND DEF JAM MUSIC GROUP,
ROC-A-FELLA RECORDS, LLC,
Defendants.
Cas e N o.
COMPLA INT AND
DEMAND FOR JURY TR IA L
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Plaintiff Dwayne D. Walker, Jr., by and through his counsel Gregory S. Berry, Esq., a^
andforhis complaint against the defendants ShawnCarter(knownprofessionally as Jay-Z ),
Damon Dame Dash,Kareem Biggs Burke,UniversalMusicGroup ( UMG ), IslandDef
Jam Music Group ( IDJ ), and Roc-A-Fella Records, alleges as follows:
NATURE OF ACT ION
1. This action for damages,declaratory relief, and permanent injunctive relief is brought
bytheplaintiffpursuant to theCopyright Act, 17U.S.C. § 101 et seq., and common-law breach
o f contract.
PART IE S
2. PlaintiffDwayne Walkeris a naturalpersoncurrently residingin Bronx,New York.
3. Upon information andbelief, defendant ShawnCarter,knownprofessionally as Jay-
Z, is a naturalpersoncurrently residing inNewYork,NewYork, and doing businessin New
York, New York.
4. Upon information and belief, defendant Damon Dame Dash is a naturalperson
currently residing inNewYork,New York,anddoingbusiness inNewYork, New York.
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5. Upon information and belief, defendant Kareem Biggs Burke is a natural person
currently residing inNew York, New York, and doing business in New York, New York.
6. Upon information and belief, defendant Universal Music Group, Inc., is a Delaware
corporationregisteredwith theNew York Secretaryof State as a foreign business corporation.
7. Upon information and belief, defendant Island Def Jam Music Group, a division of
UMG, is a Delawarecorporation,registeredwith the New York Secretaryof State as a foreign
business corporation.
8. Upon information and belief, defendant record label Roc-A-FellaRecords,LLC, is a
New York limited liability company. Upon information and belief, Roc-A-Fella Records is a
subsidiary ofUMG, and is distributed by IDJ.
JURI SD IC T ION AND VENUE
9. This Court has subject-matterjurisdiction over the first claim in this action pursuant
to 28 U.S.C. §§ 1331 & 1338because it arises under a federal statute, the Copyright Act, 17
U.S.C. §101 etseq
10. This Court has supplemental jurisdiction over the second claim in this action pursuant
to 28U.S.C. § 1367, because it is so related to the claim within the original jurisdiction of this
Court that they formpart of the samecase or controversywithin the meaning ofArticle IIIof the
Uni ted S tat e s Consti tut ion.
11. Upon information and belief, venue is proper in this District pursuant to 28 U.S.C.
§§ 1391 & 1400.
S TATEMENT OF FACTS
12. In or around August 1995, a coworker ofplaintiffDwayne Walker's, David
( Everlast ) Sierra, introducedhim to defendant Damon Dash, who was a long-time friendof
Sierra 's .
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13. Plaintiff soon thereafter beganworking for April Walker, owner ofWalkerWear, a
well-known urban clothing line. During this time,defendant Dash, alongwithdefendants Carter
and Burke, were putting together what would become Roc-A-Fella Records. AsDash andthe
plaintiff became better acquainted, theplaintiff accompanied and assisted Dash with several
matters relating tothe record label. The plaintiffassisted Dash in purchasing sewing machines
withwhichto createsamples for a Roc-A-Fella clothing line, andplaintiffwas presentwhen
Roc-A-Fella first tookpossession of its WallStreetoffice. At that time, the plaintiff and Dash
livednear eachother,and theybecameclose enoughsocially that the plaintiffwas frequently a
guest inDash'sapartment, andtheplaintiffs girlfriend even looked afterDash's sononat least
one occasion.
14. In or aroundNovember 1995, the plaintiff sawwhat Dash had in mind for the Roc-A-
Fella logo, andtoldDashhe could do better. Innegotiating withDash, theplaintiffasked for 5%
royalty onRoc-A-Fella revenues. Dash feltthatwastoohigh, andtheyeventually agreed to 2%.
Theplaintiffthen entered intoa Contract withdefendants Carter, Dash, Burke, andRoc-A-Fella
Records (collectivelythe RAF Defendants ) to create a logo for the nascent record company.
15. Under the settled terms of the Contract, the plaintiffwould design a logo for the Roc-
A-Fella record label and license the artwork to the RAF Defendants. Upon approval of the logo,
the RAFDefendantswould pay the plaintiff $3500 cash, and subsequently2% of all revenues
madefrom the sale of items(records, merchandise, marketing materials, other items)bearingthe
logofor ten yearsafter the first yearof use, payable at the end of that period.
16. In or aroundDecember 1995, the plaintiff, a United States citizen, created a work of
visual art entitled Original Roc Logo (the Artwork ).
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17. Thisvisual Artwork is an original workthat maybe copyrighted underUnitedStates
law. A copyof the Artworkis attached asExhibitA.
18. Inor around December 1995, the plaintiffinformed defendant Dashhe hadcompleted
theArtwork. Dash metthe plaintiff in the lobby ofplaintiffs apartment building andapproved
thedesign onbehalfof theRAF Defendants. However, Dash didnothave the cash payment
withhim at that time. Plaintiff met with Dashagain at D&D Studios (wheredefendant Carter—
Jay-Z—in the coming months would record his first hip-hop album, Reasonable Doubt, under
theRoc-A-Fella record label, bearing a logo virtually identical to theplaintiffs Artwork). Dash
paid theplaintiff 3500, andtheplaintiffdelivered toDash a hard copy ofhisArtwork.
19. The defendantshave used the Artwork,with only slight and insignificant changes (the
Logo ), continuously since 1996 on records i.e., CDs andothersound recordings),
merchandise, marketing materials, andelsewhere underthe Roc-A-Fella Records label, andare
still doing so today. A printout oftheRoc-A-Fella website (http://www.rocafella.com, accessed
July 6, 2012) with the infringing Logo prominently displayed, is attached asExhibit B. (A
detailed image of the infringing Logo is attached asExhibitC.) TheLogohasbecome
universally recognized asan iconic symbol of Jay-Z (defendant Shawn Carter), oneof themost
successful recording artists in the history of popularmusic. (Jay-Z hashad 11 number one
albums to date, surpassing Elvis Presley as the solo act withthemostNo. 1 albums of all time. )
20. Since the creation of the Artwork in 1995, the plaintiff has remained the sole owner
of the copyright in compliance with the copyright laws.
21. Per the Contractbetweenthe parties,the paymentof the 2% royalty was due at the
end o f 2006.
http://www.billboard.comycolumn-chartbeat/1004013732.story, accessed July9, 2012.
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22.Upon information andbelief, through2006 the defendants' salesof productsbearing
the Logo have been in excess of $350 million.
23. Nonetheless the defendants have failed to pay the plaintiffhis contractual 2% royalty
of at l ea st 7 million.
24. The statute of limitations for breach of contract in the State ofNew York is six years
(N.Y. C.P.L.R. § 213), so this action is timely.
25. Alternatively, the defendants infringed on the copyright by selling records and other
merchandise labeled with the infringingLogo. The defendantshave infringed on the plaintiffs
copyright continuously since 1996, and are still doing so today.
26. The plaintiffhas notified the defendants in writing of the infringement.
27. The defendants continue to infringe the copyright by continuing to publish and sell
CDs and other merchandise with the infringing Logo prominently displayed, and further have
engaged in unfairtradepractices andunfaircompetition in connection withtheirpublication and
sale of the infringing merchandise, thus causing irreparable damage.
28. InMarch 2010, the plaintiff applied to the copyright office and received a certificate
of registrationdatedApril 22, 2010, and identified as VAu001040257/ 2010-04-22.
FIRST CAUSE OF ACT ION
Copyright Infringement)
29. The plaintiff repeats and reasserts the allegations in paragraphs 1 through 28 as
though fully set forth herein.
30. In or around December 1995, the plaintiff, a United States citizen, created an Artwork
entitled Original RocLogo, whichis an original work thatmaybe copyrighted underUnited
States law see Exh. A).
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31. From that time, theplaintiffhasremained the soleownerof the copyright in
compliance with the copyright laws.
32. Thedefendants acquired theArtwork directly from theplaintiff, andhave infringed
the copyright bypublishing and selling records, merchandise, marketing materials, and other
items bearing a Logo which is copied directly from theplaintiffs Artwork, with only
insignificant changes see Exh. C).
33.InMarch 2010,the plaintiffapplied to the copyright officeand received a certificate
of registration datedApril22, 2010, and identified asVAu001040257 / 2010-04-22.
34.Theplaintiffhas notifiedthe defendants inwritingof the infringement.
35.Thedefendants continue to infringe the copyright by continuing to publish and sell
items with the infringing Logo in violation ofthecopyright, andfurther have engaged in unfair
trade practices and unfair competition in connection with its sale ofthe infringing items, thus
causing irreparable damage.
SECOND CAUSE OF ACT ION
Breach of Contract)
36.Theplaintiffrepeats andreasserts the allegations in paragraphs 1 through 35 as
though fully set forth herein.
37. In or aroundNovember 1995, the plaintiff and the RAF Defendantsentered into a
Contract .
38.TheContract contained promises andconsideration byeachpartyto the other.
39. Pursuantto the Contract, the plaintiff agreedto designArtworkto license for use as a
logo for Roc-A-Fella Records.
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40. TheRAF Defendants agreed, in return, to pay the plaintiff$3500in cash,plus2%of
revenues generated bythe sale of records and other items bearing theplaintiffsArtwork, due ten
years after the first year ofuse of the Artwork.
41.Theplaintiffperformed his obligations under theContract, delivering to defendant
Dash the Artwork, which Dash approved on behalfof the RAF Defendants.
42.Dashpaidtheplaintiff 3500 in cashupondelivery of theArtwork. However, the
defendants have failed to paythe2%royalty payment thatwasdue to the plaintiffat the endof
2006 .
43.Theplaintiffhas beendamaged bythedefendants' breach of contract in an amount to
be determined at trial, but not less than $7 million.
PRAYER FOR REL IEF
WHEREFORE, the plaintiffrespectfully demands that:
(a) until this case is decided, the defendants and the defendants' agentsbe enjoinedfrom
disposing ofanycopies ofthe infringing records or anyotherinfringing merchandise bysaleor
otherwise;
(b) the defendants accountfor and pay as damages to the plaintiff all profits and
advantages gained from unfairtradepractices andunfaircompetition in sellingthe defendants'
records andmerchandise bearing the infringing Logo, andall profitsandadvantages gained from
infringing theplaintiffs copyright (butno lessthanthe statutory minimum whereapplicable);
(c) the defendantsdeliver for impoundment all copies of the records and other
merchandise in the defendants' possessionor controland deliver for destruction all infringing
copies and all plates, molds, and other materials for making infringingcopies;
(d) the defendants pay compensatorydamagesfor breachof the Contract in an amount to
be determined at trial , but no less than $7 million.
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(e) the defendantspay the plaintiffs interest, costs, and reasonable attorney's fees; and
(f) the plaintiff be awarded any other such further reliefas the Court deems just and
proper.
DEMAND FOR JURY TR IAL
Plaintiff respectfully demands a trial byjury for all issues so triable in this action.
Dated: July 12, 2012
New York, New York
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Respectfully submitted,
LAW OFFICE OF GREGORY BERRY
By:
450 Seventh Avenue, Suite 1608
New York, New York 10123
(646) 380-8115 phone
(646) 514-5827 facsimile
Attorneyfor Plaintiff
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EXHIB IT A
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Original Roc Logo designed by Plaintiff DwayneWalker
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EXHIB IT B
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cafella website.JPG (JPEG Image, 839 x 591 pixels) file:///C:/Documents and Settings/Gregory Berry/My Documents/Cl
o f l 7 / 5/ 2012 7 : 3
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EXHIBIT C
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ROCAFELLAR E CO RD S
Infringing Logo used by Roc A Fella Records since 996