ORDER granting [112] and [113] Having satisfied the requirements of Local Rule 83.01(b), the Amended Motions for Frank Scibilia and Maya Katalan to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 03/04/2024. (lh)
REPLY to Response to re [102] MOTION For Leave to File Amicus Curiae filed by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America. (Clabo, Jacob)
REPLY to Response to re [97] MOTION for Leave to Request Oral Argument re [40] MOTION for Preliminary Injunction filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven)
RESPONSE in Opposition re [97] MOTION for Leave to Request Oral Argument re [40] MOTION for Preliminary Injunction filed by Anthropic PBC. (Harwell, Aubrey)
Amended MOTION to Amend/Correct [101] MOTION for attorney Maya Katalan to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-4013463) by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America. (Attachments: # (1) Exhibit Ex.1-Supplemental Declaration-Katalan, # (2) Exhibit Ex.2-Supplemental Certificate of Good Standing - Katalan)(Kilgore, Lauren)
Amended MOTION to Amend/Correct [100] MOTION for attorney Frank Scibilia to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-4013462) by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America. (Attachments: # (1) Exhibit Ex.1-Supplemental Declaration Scibilia, # (2) Exhibit Ex.2-Supplemental Certificate of Good Standing - Scibilia)(Kilgore, Lauren)
CERTIFICATE Certificate of Service DE 103 filed by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America re [103] Memorandum in Support, filed by Black Music Action Coalition, Recording Industry Association of America, News/Media Alliance, Songwriter of North America, Association of American Publishers, Inc., National Music Publishers' Association. (Kilgore, Lauren)
CERTIFICATE Certificate of Service DE 102 filed by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America re [102] MOTION For Leave to File Amicus Curiae filed by Black Music Action Coalition, Recording Industry Association of America, News/Media Alliance, Songwriter of North America, Association of American Publishers, Inc., National Music Publishers' Association. (Kilgore, Lauren)
CERTIFICATE Certificate of Service DE 101 filed by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America re [101] MOTION for attorney Maya Katalan to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-4013463) filed by Black Music Action Coalition, Recording Industry Association of America, News/Media Alliance, Songwriter of North America, Association of American Publishers, Inc., National Music Publishers' Association. (Kilgore, Lauren)
CERTIFICATE Certificate of Service DE 100 filed by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America re [100] MOTION for attorney Frank Scibilia to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-4013462) filed by Black Music Action Coalition, Recording Industry Association of America, News/Media Alliance, Songwriter of North America, Association of American Publishers, Inc., National Music Publishers' Association. (Kilgore, Lauren)
DECLARATION of Ben Y. Zhao filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [92] Reply to Response to Motion,. (Chung, Timothy)
CERTIFICATE Certificate of Service filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re [95] Declaration, filed by Songs of Universal, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Universal Music - Z Tunes LLC, Universal Music - MGB NA LLC, ABKCO Music, Inc., Universal Music Corp., Polygram Publishing, Inc.. (Chung, Timothy)
CERTIFICATE Certificate of Service filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re [94] Declaration, filed by Songs of Universal, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Universal Music - Z Tunes LLC, Universal Music - MGB NA LLC, ABKCO Music, Inc., Universal Music Corp., Polygram Publishing, Inc.. (Chung, Timothy)
Amended MOTION for Leave to File Document Under Seal by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Memorandum in Support of Amended Motion for Leave to File Under Seal, # (2) Attachment Proposed Order Granting Amended Motion for Leave to File Under Seal)(Chung, Timothy)
Attachment 1 Attachment Memorandum in Support of Amended Motion for Leave to File Under Seal
Attachment 2 Attachment Proposed Order Granting Amended Motion for Leave to File Under Seal
Filed: None, Entered: None
Annotation - Deficiency Notice
NOTICE TO FILER re DE# [100] and [101]: The pending pro hac vice motion does not comply with the Court's local rules, because the motion fails to state whether disciplinary proceedings by any disciplinary authority, a finding of contempt or a sanction under 28 U.S.C. ยง 1927 by any court, or criminal charges have been instituted against the attorney seeking pro hac vice admission. Local Rule 83.01(b)(2). By no later than five (5) business days from the date of this docket annotation, the pro hac vice motion must be supplemented by the filing of a statement under oath of the attorney seeking pro hac vice admission disclosing such matters. Failure to do so will result in denial of the pro hac vice motion. (kc) Modified on 2/15/2024 (kc).
Filed: None, Entered: None
Annotation - Deficiency Notice
NOTICE TO FILER re DE# [94], [95], [100], [101], [103]: Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not include a certificate of service. Please FILE a conformed Certificate of Service for this document. (kc)
Filed: None, Entered: None
Annotation - Bar Status
NY State Bar status verified as active for Maya B. Katalan, Frank P. Scibilia not admitted to this court - Local counsel secured. (kc)
Filed: None, Entered: None
Annotation - Bar Status
TN State Bar status verified as active for Lauren E. Kilgore, Jacob T. Clabo admitted to this court. (kc)
MEMORANDUM in Support of [102] MOTION For Leave to File Amicus Curiae filed by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America . (Kilgore, Lauren)
MOTION For Leave to File Amicus Curiae by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America. (Attachments: # (1) Exhibit Exhibit A - Amicus Curiae Brief)(Kilgore, Lauren)
Attachment 1 Exhibit Exhibit A - Amicus Curiae Brief
MOTION for attorney Maya Katalan to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-4013463) by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America. (Attachments: # (1) Exhibit Exhibit 1 - Declaration of Maya Katalan, # (2) Exhibit Certificate of Good Standing - Maya Katalan)(Kilgore, Lauren)
Attachment 1 Exhibit Exhibit 1 - Declaration of Maya Katalan
Attachment 2 Exhibit Certificate of Good Standing - Maya Katalan
MOTION for attorney Frank Scibilia to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-4013462) by Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America. (Attachments: # (1) Exhibit Exhibit 1 - Declaration of Frank Scibilia, # (2) Exhibit Exhibit 2 - Certificate of Good Standing - Frank Scibilia)(Kilgore, Lauren)
Attachment 1 Exhibit Exhibit 1 - Declaration of Frank Scibilia
Attachment 2 Exhibit Exhibit 2 - Certificate of Good Standing - Frank Scibilia
NOTICE of Appearance by Jacob T. Clabo on behalf of Association of American Publishers, Inc., Black Music Action Coalition, National Music Publishers' Association, News/Media Alliance, Recording Industry Association of America, Songwriter of North America (Clabo, Jacob)
NOTICE of Appearance by Lauren E. Kilgore on behalf of Recording Industry Association of America, National Music Publishers' Association, Association of American Publishers, Inc., News/Media Alliance, Songwriter of North America, Black Music Action Coalition (Kilgore, Lauren)
MOTION for Leave to Request Oral Argument re [40] MOTION for Preliminary Injunction by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven)
DECLARATION of Michael D. Smith filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [92] Reply to Response to Motion,. (Attachments: # (1) Exhibit Exhibit A - Sealed Anthropic Emails, # (2) Exhibit Anthropic Hugging Face Finetuning Prompts)(Chung, Timothy)
Attachment 1 Exhibit Exhibit A - Sealed Anthropic Emails
Attachment 2 Exhibit Anthropic Hugging Face Finetuning Prompts
SEALED DOCUMENT DECLARATION of Ben Y. Zhao filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [92] Reply to Response to Motion,. (Chung, Timothy) Modified on 2/15/2024 (kc).
REPLY to Response to re [40] MOTION for Preliminary Injunction Plaintiffs' Reply in Support of Motion for Preliminary Injunction filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Chung, Timothy)
91
Filed: 2/14/2024, Entered: 2/14/2024
Sealed document
Sealed Document Plaintiffs' Reply in Support of Motion for Preliminary Injunction filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Declaration of Michael Smith, # (2) Exhibit Exhibit A to Declaration of Michael Smith - Anthropic Emails)(Chung, Timothy)
MOTION for Leave to File Document Under Seal by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Motion for Leave to File Document under Seal, # (2) Attachment Proposed Order Granting Motion for Leave to File Under Seal)(Chung, Timothy)
Attachment 1 Attachment Motion for Leave to File Document under Seal
Attachment 2 Attachment Proposed Order Granting Motion for Leave to File Under Seal
REPLY to Response to re [54] MOTION to Dismiss for Lack of Personal Jurisdiction and Improper Venue or, in the Alternative, to Transfer Venue filed by Anthropic PBC. (Harwell, Aubrey)
Filed: None, Entered: None
Annotation - Bar Status
TN State Bar status verified as active for Grace Peck admitted to this court. (kc)
ORDER granting [73]and [74]: Having satisfied the requirements of Local Rule 83.01(b), the Motions for Eric P. Tuttle and Nicole Saad Bembridge to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 01/24/2024. (lh)
REPLY to Response to re [75] MOTION for Leave to File Amicus Brief in Opposition to Plaintiffs' Motion for Preliminary Injunction re [40] MOTION for Preliminary Injunction filed by Chamber of Progress, NetChoice, LLC. (Klein, Kevin)
ORDER: On January 22, 2024, the parties filed a notice stating they have met and conferred regarding the timing and scope of Defendant's preliminary injunction discovery production and ask that the telephone conference regarding that discovery set on January 23, 2024, be cancelled. [78]. The motion is GRANTED. The telephone conference set on January 23, 2024 (Doc. No. 65), is CANCELLED. Signed by Magistrate Judge Alistair Newbern on 1/23/2024. (kc)
DECLARATION of David Kokakis (UMPG) filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [79] Response in Opposition to Motion,. (Riley, Steven) Modified on 1/23/2024 (kc).
DECLARATION of Kenton Draughon (CCMG) filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [79] Response in Opposition to Motion,. (Attachments: # (1) Exhibit Claude Search Queries)(Riley, Steven) Modified on 1/23/2024 (kc).
DECLARATION of Duff Berschback (Concord) filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [79] Response in Opposition to Motion,. (Attachments: # (1) Exhibit Exhibit A - Clause Search Queries)(Riley, Steven) Modified on 1/23/2024 (kc).
Attachment 1 Exhibit Exhibit A - Clause Search Queries
DECLARATION of Alisa Coleman (ABKCO) filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [79] Response in Opposition to Motion,. (Riley, Steven) Modified on 1/23/2024 (kc).
DECLARATION of Attorney Timothy Chung filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [79] Response in Opposition to Motion,. (Attachments: # (1) Exhibit Exhibit A - CNBC Article, # (2) Exhibit Exhibit B - Anthropic Product, # (3) Exhibit Exhibit C - Supported Countries and Regions, # (4) Exhibit Exhibit D - Claude Signup, # (5) Exhibit Exhibit E - Glossary, # (6) Exhibit Exhibit F - TN Prompts in Hugging Face Data Set, # (7) Exhibit Exhibit G - Thompson Paine LinkedIn, # (8) Exhibit Exhibit H - Thompson Paine Tweet, # (9) Exhibit Exhibit I - Thompson Paine Twitter Repost, # (10) Exhibit Exhibit J - Thompson Paine LinkedIn Post, # (11) Exhibit Exhibit K -Laura Holmes LinkedIn Post, # (12) Exhibit Exhibit L - Thompson Paine LinkedIn Hiring Post, # (13) Exhibit Exhibit M - Brian Kustera Nashville - LinkedIn, # (14) Exhibit Exhibit N - Getting Access to Claude Webpage, # (15) Exhibit Exhibit O - Claude API Access, # (16) Exhibit Exhibit P - Lonely Planet Registration, # (17) Exhibit Exhibit Q - Claude 2 on Amazon Bedrock, # (18) Exhibit Exhibit R- Expanding access to safer AI with Amazon, # (19) Exhibit Exhibit S - Amazon steps up AI race with Anthropic investment, # (20) Exhibit Exhibit T - Preverity Anthropic Story, # (21) Exhibit Exhibit U - LivTech Anthropic Story, # (22) Exhibit Exhibit V - Preverity home page, # (23) Exhibit Exhibit X - LivTech Homepage)(Riley, Steven) Modified on 1/23/2024 (kc).
RESPONSE in Opposition re [54] MOTION to Dismiss filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven) Modified on 1/23/2024 (kc).
NOTICE by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. Notice re Jan 23 Telephone Conference (Riley, Steven) Modified on 1/23/2024 (kc).
RESPONSE in Opposition re [75] MOTION for Leave to File Amicus Brief in Opposition to Plaintiffs' Motion for Preliminary Injunction re [40] MOTION for Preliminary Injunction filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven) Modified on 1/23/2024 (kc).
Filed: None, Entered: None
Annotation - Bar Status
State Bar status verified as active for Eric P. Tuttle (CA), Nicole Saad Bembridge (DC) not admitted to this court - Local counsel secured. (kc)
MEMORANDUM in Support of [75] MOTION for Leave to File Amicus Brief in Opposition to Plaintiffs' Motion for Preliminary Injunction re [40] MOTION for Preliminary Injunction filed by Chamber of Progress, NetChoice, LLC . (Klein, Kevin)
MOTION for Leave to File Amicus Brief in Opposition to Plaintiffs' Motion for Preliminary Injunction re [40] MOTION for Preliminary Injunction by Chamber of Progress, NetChoice, LLC. (Attachments: # (1) Exhibit Amicus Brief)(Klein, Kevin)
MOTION for attorney Nicole Saad Bembridge to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3994001) by Chamber of Progress, NetChoice, LLC. (Attachments: # (1) Exhibit Certificate of Good Standing)(Klein, Kevin)
MOTION for attorney Eric P. Tuttle to Appear Pro Hac Vice (paid $150 PHV fee; receipt number BTNMDC-3993993) by Chamber of Progress, NetChoice, LLC. (Attachments: # (1) Exhibit Certificate of Good Standing)(Klein, Kevin)
ORDER SETTING CASE FOR TRIAL: Jury Trial is set for 11/18/2025 at 09:00 AM in Courtroom 6B before Chief Judge Waverly D. Crenshaw Jr. Exhibit List due by 11/3/2025. Witness List due by 11/3/2025. Pretrial Conference is set for 11/10/2025 at 10:00 AM in Courtroom 6B before Chief Judge Waverly D. Crenshaw Jr. Proposed Pretrial Order due by 11/3/2025. Signed by Chief Judge Waverly D. Crenshaw, Jr on 1/17/2024. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
68
Filed: 1/16/2024, Entered: 1/16/2024
Sealed document
Sealed Document Defendant Anthropic PBC's Opposition to Plaintiffs' Motion for Preliminary Injunction filed by Anthropic PBC. (Attachments: # (1) Attachment 1 - Declaration of Jared Kaplan, # (2) Exhibit B to Kaplan Declaration, # (3) Exhibit C to Kaplan Declaration, # (4) Attachment 2 - Declaration of Julia Lowd, # (5) Exhibit H to Lowd Declaration, # (6) Exhibit I to Lowd Declaration, # (7) Exhibit J to Lowd Declaration, # (8) Exhibit K to Lowd Declaration, # (9) Attachment 3 - Declaration of Dawn R. Hall, # (10) Attachment 4 - Declaration of Steven R. Peterson PhD, # (11) Attachment 5 - Declaration of Andrew M. Gass, # (12) Exhibit A to Gass Declaration)(Harwell, Aubrey)
RESPONSE in Opposition re [40] MOTION for Preliminary Injunction , [66] MOTION for Leave to File Document Under Seal filed by Anthropic PBC. (Attachments: # (1) Attachment 1 - REDACTED Declaration of Jared Kaplan, # (2) Exhibit A to Kaplan Declaration, # (3) Exhibit B to Kaplan Declaration, # (4) Exhibit C to Kaplan Declaration, # (5) Attachment 2 - REDACTED Declaration of Julia Lowd, # (6) Exhibit A to Lowd Declaration, # (7) Exhibit B to Lowd Declaration, # (8) Exhibit C to Lowd Declaration, # (9) Exhibit D to Lowd Declaration, # (10) Exhibit E to Lowd Declaration, # (11) Exhibit F to Lowd Declaration, # (12) Exhibit G to Lowd Declaration, # (13) Exhibit H to Lowd Declaration, # (14) Exhibit I to Lowd Declaration, # (15) Exhibit J to Lowd Declaration, # (16) Exhibit K to Lowd Declaration, # (17) Attachment 3 - REDACTED Declaration of Dawn R. Hall, # (18) Exhibit A to Hall Declaration, # (19) Attachment 4 - REDACTED Declaration of Steven R. Peterson, PhD, # (20) Exhibit A to Peterson Declaration, # (21) Attachment 5 - Declaration of Andrew M. Gass, # (22) Exhibit A to Gass Declaration, # (23) Exhibit B to Gass Declaration, # (24) Exhibit C to Gass Declaration, # (25) Exhibit D to Gass Declaration, # (26) Exhibit E to Gass Declaration, # (27) Exhibit F to Gass Declaration)(Harwell, Aubrey)
Attachment 1 Attachment 1 - REDACTED Declaration of Jared Kaplan
MOTION for Leave to File Document Under Seal by Anthropic PBC. (Attachments: # (1) Attachment Memorandum in Support of Motion for Leave to file Under Seal, # (2) Attachment Proposed Order Granting Motion for Leave to File Under Seal)(Harwell, Aubrey)
Attachment 1 Attachment Memorandum in Support of Motion for Leave to file Under Seal
Attachment 2 Attachment Proposed Order Granting Motion for Leave to File Under Seal
ORDER: A telephone conference with the magistrate judge is set on January 23, 2024, at 2:00 p.m. Counsel for the parties shall call (888) 557-8511 and enter access code 7819165# to participate. Signed by Magistrate Judge Alistair Newbern on 1/12/2024. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
INITIAL CASE MANAGEMENT ORDER: Amended Pleadings due by 8/12/2024. Discovery due by 11/22/2024. Dispositive Motions due by 6/6/2025. Signed by Magistrate Judge Alistair Newbern on 1/11/2024. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc) Modified on 1/18/2024 (kc).
Filed: None, Entered: None
Case Management Conference by Telephone
Minute Entry for proceedings held before Magistrate Judge Alistair Newbern: Case Management Conference by Telephone held on 1/11/2024. (Hearing lasted 00:42)(sd)
PROPOSED CASE MANAGEMENT ORDER Joint filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Exhibit Proposed ESI Protocol)(Riley, Steven)
STIPULATED PROTECTIVE ORDER. Signed by Magistrate Judge Alistair Newbern on 1/5/2024. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
ORDER granting [60] Joint Motion for Entry of Stipulated Protective Order. Signed by Magistrate Judge Alistair Newbern on 1/5/2024. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
Joint MOTION for Protective Order by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Proposed Stipulated Protective Order)(Riley, Steven)
Attachment 1 Attachment Proposed Stipulated Protective Order
ORDER granting [58] Unopposed Motion to Correct. Signed by Magistrate Judge Alistair Newbern on 12/6/2023. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
Unopposed MOTION to Amend/Correct [57] Order,,, Set Motion and R&R Deadlines/Hearings,, Plaintiffs' Unopposed Motion to Correct the Court's Order in Regard to Page Limits for Plaintiffs' Preliminary Injunction Motion Briefing by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven)
ORDER: Briefing of the motion for a preliminary injunction [40] and the motion to dismiss [54] will be concurrent. Defendant shall respond to Plaintiffs' motion for a preliminary injunction by January 16, 2024, and Plaintiffs shall file any optional reply by February 14, 2024. Plaintiffs shall respond to Defendant's motion to dismiss by January 22, 2024, and Defendant shall file any optional reply by February 14, 2024. Signed by Magistrate Judge Alistair Newbern on 12/1/2023. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
Filed: None, Entered: None
scheduling conference
Minute Entry for proceedings held before Magistrate Judge Alistair Newbern: Scheduling Conference held on 11/29/2023. (Hearing lasted 00:23)(sd)
JOINT Statement Regarding Briefing Schedule filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. in support of [39] Order on Motion for Miscellaneous Relief,. (Riley, Steven)
MEMORANDUM in Support of [54] MOTION to Dismiss filed by Anthropic PBC . (Attachments: # (1) Attachment Declaration of Jared Kaplan, # (2) Exhibit Exhibit A-Model Card and Evaluations for Claude Models, # (3) Exhibit Exhibit B-Anthropic's Terms of Service, # (4) Exhibit Exhibit C-Anthropic's Prior Terms of Service)(Harwell, Aubrey)
Attachment 1 Attachment Declaration of Jared Kaplan
Attachment 2 Exhibit Exhibit A-Model Card and Evaluations for Claude Models
Attachment 3 Exhibit Exhibit B-Anthropic's Terms of Service
Attachment 4 Exhibit Exhibit C-Anthropic's Prior Terms of Service
ORDER granting [37]: Having satisfied the requirements of Local Rule 83.01(b), the Motion for Audrey L. Adu-Appiah to Appear Pro Hac Vice is granted. Signed by Lynda M. Hill, Clerk of Court, on 11/21/2023. (lh)
DECLARATION of Michael D. Smith filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [40] MOTION for Preliminary Injunction , [41] Memorandum in Support,. (Attachments: # (1) Exhibit A - Dr. Smith CV)(Riley, Steven)
DECLARATION of Dr. Robert Leonard filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [40] MOTION for Preliminary Injunction , [41] Memorandum in Support,. (Attachments: # (1) Attachment Appendix A - Dr. Leonard's CV, # (2) Attachment Appendix B - Indirect Claude Response Additional Lyrics, # (3) Attachment Appendix C - Entirely Similar Lyrics, # (4) Attachment Appendix D - Similar Lyrics with Non-Substantive Dissimilarities, # (5) Attachment Appendix E - Similar Lyrics with Missing or Different Lyrics, # (6) Attachment Appendix F - Indirect Claude Responses)(Riley, Steven)
Attachment 1 Attachment Appendix A - Dr. Leonard's CV
Attachment 2 Attachment Appendix B - Indirect Claude Response Additional Lyrics
Attachment 3 Attachment Appendix C - Entirely Similar Lyrics
Attachment 4 Attachment Appendix D - Similar Lyrics with Non-Substantive Dissimilarities
Attachment 5 Attachment Appendix E - Similar Lyrics with Missing or Different Lyrics
Attachment 6 Attachment Appendix F - Indirect Claude Responses
DECLARATION of Dan Seymour filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [40] MOTION for Preliminary Injunction , [41] Memorandum in Support,. (Attachments: # (1) Exhibit A - List of Compositions by BCG ID, # (2) Exhibit B part 1 - Claude Responses to Explicit Prompts, # (3) Exhibit B part 2 - Claude Responses to Explicit Prompts, # (4) Exhibit B part 3 - Claude Responses to Explicit Prompts, # (5) Exhibit C - Claude Responses to Indirect Prompts, # (6) Exhibit D part 1 - LyricFind Lyrics, # (7) Exhibit D part 2 - LyricFind Lyrics)(Riley, Steven)
Attachment 1 Exhibit A - List of Compositions by BCG ID
Attachment 2 Exhibit B part 1 - Claude Responses to Explicit Prompts
Attachment 3 Exhibit B part 2 - Claude Responses to Explicit Prompts
Attachment 4 Exhibit B part 3 - Claude Responses to Explicit Prompts
Attachment 5 Exhibit C - Claude Responses to Indirect Prompts
DECLARATION of Timothy Chung filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [40] MOTION for Preliminary Injunction , [41] Memorandum in Support,. (Attachments: # (1) Exhibit A - O&Z Attorneys and Staff Queries to Claude, # (2) Exhibit B - Billboard Article, Google Licenses LyricFind for Search Results, # (3) Exhibit Exhibit C -Spotify Web Page, Lyrics, # (4) Exhibit D - Musixmatch Web Page, Where will my lyrics be distributed, # (5) Exhibit E - Reuters Article, Google-backed Anthropic raises $450 mln in latest AI funding, # (6) Exhibit F - Anthropic Web Page, Meet Claude, # (7) Exhibit G - Anthropic Web Page, FAQ, # (8) Exhibit H - Anthropic Web Page, Claude's Constitution, # (9) Exhibit I - Anthropic Trademark Registration No 6,616,966, # (10) Exhibit J - Anthropic Federal Trademark Applications, # (11) Exhibit K - Anthropic Terms of Service, # (12) Exhibit L - Engadget Article, Amazon bets $4 billion on OpenAI rival Anthropic, # (13) Exhibit M - Anthropic Web Page, Glossary, # (14) Exhibit N - Anthropic Web Page, Introduction to Prompt Design, # (15) Exhibit O - Anthropic Model Pricing Chart, # (16) Exhibit P - Anthropic Web Page, Introducing Claude Pro, # (17) Exhibit Q - Anthropic Web Page, Introducing Claud, # (18) Exhibit R - Anthropic Web Page, Product)(Riley, Steven)
Attachment 1 Exhibit A - O&Z Attorneys and Staff Queries to Claude
Attachment 2 Exhibit B - Billboard Article, Google Licenses LyricFind for Search Results
Attachment 3 Exhibit Exhibit C -Spotify Web Page, Lyrics
Attachment 4 Exhibit D - Musixmatch Web Page, Where will my lyrics be distributed
Attachment 5 Exhibit E - Reuters Article, Google-backed Anthropic raises $450 mln in latest AI funding
Attachment 6 Exhibit F - Anthropic Web Page, Meet Claude
DECLARATION of Ben Y. Zhao filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [40] MOTION for Preliminary Injunction , [41] Memorandum in Support,. (Attachments: # (1) Exhibit A - Ben Zhao CV, # (2) Exhibit B - Transcript of Claude Queries and Responses)(Riley, Steven)
DECLARATION of Bart Herbison filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [40] MOTION for Preliminary Injunction , [41] Memorandum in Support,. (Attachments: # (1) Exhibit A - (NSAI Board of Directors Letter))(Riley, Steven)
Attachment 1 Exhibit A - (NSAI Board of Directors Letter
DECLARATION of Kenton Draughon filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [41] Memorandum in Support, [40] MOTION for Preliminary Injunction . (Riley, Steven)
DECLARATION of David Kokakis filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [41] Memorandum in Support, [40] MOTION for Preliminary Injunction . (Riley, Steven)
DECLARATION of Alisa Coleman filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [41] Memorandum in Support, [40] MOTION for Preliminary Injunction . (Riley, Steven)
DECLARATION of Duff Berschback filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. re: [41] Memorandum in Support, [40] MOTION for Preliminary Injunction . (Riley, Steven)
MEMORANDUM in Support of [40] MOTION for Preliminary Injunction filed by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp. . (Riley, Steven)
MOTION for Preliminary Injunction by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven)
ORDER granting [33] Joint MOTION Requesting a Scheduling Conference. A conference is set on November 29, 2023, at 11:00 a.m. Counsel for the parties shall call (888) 557-8511 and enter access code 7819165# to participate. Signed by Magistrate Judge Alistair Newbern on 11/16/2023. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
Filed: None, Entered: None
set/reset hearings
Set Hearing per Order [39]: Scheduling Conference is set for 11/29/2023 at 11:00 AM before Magistrate Judge Alistair Newbern. (kc)
Filed: None, Entered: None
Annotation - Deficiency Notice
NOTICE TO FILER re DE# [30]: Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not include a certificate of service. Please FILE a conformed Certificate of Service for this document. (kc)
Filed: None, Entered: None
Annotation - Bar Status
TN State Bar status verified as active for Aubrey B. Harwell, III, Nathan C. Sanders, Olivia Rose Arboneaux admitted to this court. (kc)
ORDER: Joint MOTION [34] for Leave to File Excess Pages for Briefing of Motion for Preliminary Injunction GRANTED. Signed by Chief Judge Waverly D. Crenshaw, Jr on 11/15/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
MOTION for attorney Audrey L. Adu-Appiah to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3955243) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
ORDER granting [28], [29], [31], and [32]: Having satisfied the requirements of Local Rule 83.01(b), the Motions for Allison Stillman, Sarang Damle, Joseph Wetzel, and Andrew Gass to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 11/14/2023. (lh) Modified on 11/15/2023 (lh).
ORDER granting [17], [18], [19], [20], [21], [22], [23], and [24]: Having satisfied the requirements of Local Rule 83.01(b), the Motions for Jonathan Z. King, Richard S. Mandel, Richard Dannay, Timothy S. Chung, Andrew L. Guerra, Nicholas C. Hailey, Matthew J. Oppenheim, and Jennifer L. Pariser to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 11/14/2023. (lh)
Filed: None, Entered: None
Annotation - Bar Status
State Bar status verified as active for Allison Stillman (NY), Sarang Damle (DC), Joseph Wetzel (CA), and Andrew Gass (CA) not admitted to this court - Local counsel secured. (lh) Modified on 11/15/2023 (lh).
Joint MOTION for Leave to File Excess Pages for Briefing of Motion for Preliminary Injunction by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven)
Joint MOTION Requesting a Scheduling Conference by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Riley, Steven)
MOTION for attorney Andrew Gass to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3951963) by Anthropic PBC. (Attachments: # (1) Attachment Certificate of Good Standing)(Harwell, Aubrey)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Joseph Wetzel to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3951962) by Anthropic PBC. (Attachments: # (1) Attachment Certificate of Good Standing)(Harwell, Aubrey)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Sarang Damle to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3951959) by Anthropic PBC. (Attachments: # (1) Attachment Certificate of Good Standing)(Harwell, Aubrey)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Allison Stillman to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3951957) by Anthropic PBC. (Attachments: # (1) Attachment Certificate of Good Standing)(Harwell, Aubrey)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Jennifer L. Pariser to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950903) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Matthew J. Oppenheim to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950900) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Nicholas C. Hailey to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950897) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Andrew L. Guerra to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950872) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Timothy S. Chung to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950848) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Richard Dannay to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950590) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Richard S. Mandel to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950585) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
MOTION for attorney Jonathan Z. King to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3950575) by ABKCO Music, Inc., Capitol CMG, Inc., Concord Music Group, Inc., Polygram Publishing, Inc., Songs of Universal, Inc., Universal Music - MGB NA LLC, Universal Music - Z Tunes LLC, Universal Music Corp.. (Attachments: # (1) Attachment Certificate of Good Standing)(Riley, Steven)
Attachment 1 Attachment Certificate of Good Standing
SUMMONS returned executed by Universal Music Corp., Songs of Universal, Inc., ABKCO Music, Inc., Polygram Publishing, Inc., Universal Music - MGB NA LLC, Concord Music Group, Inc., Universal Music - Z Tunes LLC, Capitol CMG, Inc.. Anthropic PBC served on 10/23/2023. (Riley, Steven)
ORDER: This case is REFERRED to the Magistrate Judge for customized case management in accordance with Local Rule 16.01 and 28 U.S.C. ยง 636(b)(1)(A). Signed by Chief Judge Waverly D. Crenshaw, Jr on 10/19/2023. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(af)
COMPLAINT against Anthropic PBC (Filing fee $402, Receipt number ATNMDC-3934414), filed by Universal Music Corp., Songs of Universal, Inc., ABKCO Music, Inc., Polygram Publishing, Inc., Universal Music - MGB NA LLC, Concord Music Group, Inc., Universal Music - Z Tunes LLC, Capitol CMG, Inc.. (Attachments: # (1) Attachment - Civil Cover Sheet, # (2) Attachment - Civil Cover Sheet List of Plaintiffs)(kc) (Additional attachment(s) added on 10/18/2023: # (3) Exhibit A to Complaint (List of Works Infringed)). (kc). Modified on 10/18/2023 (kc).
Attachment 2 Attachment - Civil Cover Sheet List of Plaintiffs)(kc) (Additional attachment(s) added on 10/18/2023:
Attachment 3 Exhibit A to Complaint (List of Works Infringed
Filed: None, Entered: None
Annotation - Deficiency Notice
***DISREGARD. ENTERED IN ERROR.*** NOTICE TO FILER re DE# [1]: Counsel failed to include the mandatory description of the attached exhibits. Counsel is directed to file a notice that lists each exhibit with a brief description. (kc) Modified on 10/18/2023 (kc).
Filed: None, Entered: None
Annotation - PHV
NOTICE TO COUNSEL Richard Mandel, Jonathan Z. King, Richard Dannay, Matthew J. Oppenheim, Nicholas C. Hailey, Audrey Adu-Appiah, Jennifer Pariser, Andrew Guerra, Timothy Chung: WITHIN 21 DAYS, counsel shall file a Motion to Appear Pro Hac Vice, a Certificate of Good Standing signed by the Clerk of a United States District Court or a U. S. appellate court where admitted, and pay a fee of $150.00 (LR 83.01(b)). PHV due by 11/8/2023. (kc) Modified on 10/20/2023 (kc).
Filed: None, Entered: None
Annotation - Bar Status
State Bar status verified as active for Richard Mandel (NY), Jonathan Z. King (NY), Richard Dannay (NY), Matthew J. Oppenheim (DC), Nicholas C. Hailey (DC), Audrey Adu-Appiah (DC), Jennifer Pariser (NY), Andrew Guerra (NY), Timothy Chung (NY) not admitted to this court - Local counsel secured. (kc)
Filed: None, Entered: None
Annotation - Bar Status
TN State Bar status verified as active for Steven Allen Riley, Timothy G. Harvey admitted to this court. (kc)