Kanye West’s label, Universal, scored a legal victory last week in securing partial dismissal of a lawsuit concerning Kanye’s 2007 hit song “Good Life.”
Dayna Staggs, a singer and songwriter, filed a copyright infringement action in the United States District Court for the District of Maryland claiming that “Good Life” was identical in sound and melody to the chorus of Staggs’ song, “Volume of the Good Life.” On August 14, the Court granted, in part, Universal’s request to dismiss the case.
The Court’s ruling related to Staggs’ claim that “Good Life” violated his copyright in the musical composition and lyrics of “Volume of the Good Life.”
The Court stated that “an ordinary listener . . . would quickly determine that the melodies of the songs are not similar. In fact, the Court was unable to hear any portions of the songs that contained similar melodies.”
As to the lyrics, Staggs claimed that Kanye’s lyrics “Now throw ya’ hands up in the sky” are identical to Staggs’ lyrics “Hold your head up high.” The Court ruled that these allegedly identical phrases, and other similar words or phrases, such as “good life” are simply not copyrightable.
The Court cited Section 202.1(a) of the Copyright Office regulations which states:
The following are examples of works not subject to copyright and applications for registration of such works cannot be entertained:
(a) Words and short phrases such as names, titles, and slogans; familiar symbols or designs; mere variations of typographic ornamentation, lettering or coloring; mere listing of ingredients or contents;
While the Court dismissed the case as to the musical work claim, the Court left open the question of whether Staggs holds a copyright in the sound recording and whether Kanye’s song violated that right, presumably by sampling Staggs’ song. The Court gave Universal 30 days to challenge Staggs’ sound recording copyright claim.
As an aside, note that the “Good Life” samples from Michael Jackson’s “P.Y.T.”
Check it out. The sample used throughout “Good Life” appears at 3:15 of “P.Y.T.”:
I understand that the “P.Y.T” sample was cleared for “Good Life.”
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