2 Chainz, Offset, and UMG Recordings Inc. convinced a federal judge in Manhattan to dismiss a copyright infringement suit brought by a hip-hop artist who alleged their 2018 track “Proud” ripped off his 2015 song of the same name.
Soloman Clanton, professionally known as Slugga, claimed that 2 Chainz and Offset directly copied his lyric “I’m tryna make my momma proud.” But this expression isn’t original enough to be protected by copyright law, Judge Lewis J. Liman said Monday.
Copyright doesn’t protect general ideas and themes like “familial love or pride,” which has been used in artistic works for centuries, the court said in granting the motion to dismiss in favor of UMG; Tauheed Epps, known as 2 Chainz; and Kiari Cephus, known as Offset.
There’s also nothing unique or unconventional about the way the lyric expresses this theme, the court said. It uses basic English words and grammar to communicate the idea, without employing any poetic, figurative, or rhetorical style.
Further, Clanton failed to put forth enough specific facts to show his song was commercially successful or widely available to the extent that 2 Chainz, Offset, or anyone at the label would have listened to it, the U.S. District Court for the Southern District of New York said.
Clanton alleged his song, which was released on his 2015 mixtape, was “widely shared” online via handful of hip-hop music websites and on YouTube, where he posted the accompanying music video in 2017.
But the song’s internet presence alone isn’t enough to prove it was “widely disseminated,” the court said. As such, Clanton failed to plausibly allege the defendants had access to the work.
2 Chains, Offset, UMG, and the other defendants are represented by Shapiro Arato Bach LLP. Clanton is represented by Doniger/Burroughs and Michael D. Steger of Orangeburg, N.Y.
The case is Clanton v. UMG Recordings, Inc., 2021 BL 308204, S.D.N.Y., No. 20-cv-5841 (LJL), 8/16/21.