INDEX NO. UNASSIGNEDNYSCEF DOC. NO. 1RECEIVED NYSCEF: 04/17/2014SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORKCAPITOL RECORDS, LLC, a Delawarelimited liability corporation; SONY MUSICENTERTAINMENT, a Delaware partnership;UMG RECORDINGS, INC., a Delawarecorporation; WARNER MUSIC GROUPCORP., a Delaware corporation, and ABKCOMUSIC & RECORDS, INC., a New Yorkcorporation,INDEX NO.Plaintiffs,SUMMONSV.PANDORA MEDIA, INC., a DelawareCorporation; and DOES 1 through 10, beingfictitious and unknown to Plaintiffs, beingparticipants in all or some of the acts allegedagainst the Defendants in the Complaint,Defendants.To the above named Defendant(s)You are hereby summoned to answer the complaint in this action and to servea copy of your answer, or, if the complaint is not served with this summons, to servea notice of appearance, on the Plaintiffs attorney within 20 days after the service ofthis summons, exclusive of the day of service (or within 30 days after the service iscomplete if this summons is not personally delivered to you within the State of NewYork); and in case of your failure to appear or answer, judgment will be taken againstyou by default for the relief demanded in the complaint.Plaintiff has designated venue as New York County, pursuant to CPLR § 503.The basis for venue in New York County is made pursuant to CPLR § 503(a) and (c).6032919.1/11224-00128MITCHELL SILBERBERG & KNUPP LLPDATED: New York, New YorkApril 17, 2014By:auren J. Wachtler12 East 49th Street', 30th FloorNew York, New York 10017-1028Telephone: (212) 509-3900Facsimile: (212) 509-7239Russell J. FrackmanMarc E. Mayer11377 West Olympic BoulevardLos Angeles, CA 90064-1683Telephone: (310) 312-2000Facsimile: (310) 312-3100Attorneys for PlaintiffsCapitol Records LLCTo:Pandora Media, Inc2010 Webster Street, Suite 1650Oakland, CA 9461226032919.1/11224-00128SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORKCAPITOL RECORDS, LLC, a Delawarelimited liability corporation; SONY MUSICENTERTAINMENT, a Delaware partnership;UMG RECORDINGS, INC., a Delawarecorporation; WARNER MUSIC GROUPCORP., a Delaware corporation, and ABKCOMUSIC & RECORDS, INC., a New Yorkcorporation,INDEX NO.Plaintiffs,COMPLAINTV.PANDORA MEDIA, INC., a DelawareCorporation; and DOES 1 through 10, beingfictitious and unknown to Plaintiffs, beingparticipants in all or some of the acts allegedagainst the Defendants in the Complaint,Defendants.Plaintiffs Capitol Records, LLC, Sony Music Entertainment, UMG Recordings, Inc.,Warner Music Group Corp., and ABKCO Music & Records, Inc., by their attorneys, MitchellSilberberg & Knupp LLP, allege as follows:INTRODUCTORY ALLEGATIONS1.Plaintiffs bring this action to obtain redress for the massive and continuingunauthorized commercial exploitation by Defendant Pandora Media, Inc. ("Pandora"), via itsPandora digital music service, of thousands of Plaintiffs' classic recordings "fixed" (i.e., created)prior to February 15, 1972 ("Pre-72 Recordings"). Plaintiffs are the owners of many of the mostvaluable sound recordings ever made, including thousands of Pre-72 Recordings by legendaryartists such as the Beatles, the Rolling Stones, the Grateful Dead, the Supremes, the Four Tops,6031682.2/11224-00128the Beach Boys, Miles Davis, Bob Dylan, Elvis Presley, Frank Sinatra, Fleetwood Mac, StevieWonder, Buddy Holly, Chuck Berry, Marvin Gaye, The Mamas and the Papas, Nat King Cole,Louis Armstrong, and hundreds of others. Plaintiffs' Pre-72 Recordings include some of themost iconic music in the world, such as "Hey Jude," "(I Can't Get No) Satisfaction," "Like aRolling Stone," "Good Vibrations," "Heard it Through the Grapevine," "Hound Dog," "JohnnyB. Goode," and "Respect," all of which are on Rolling Stone Magazine's list of the "GreatestSongs of All Time."2.Many of the artists whose Pre-72 Recordings Pandora exploits are deceased or nolonger actively recording, many have recorded only Pre-72 Recordings, and others have had onlyone or two "hits" that remain popular today. These artists and their families rely heavily on theincome they receive from the commercial exploitation of their performances in Pre-72Recordings. However, they receive nothing from Pandora in return for its use of theseperformances.3.Pandora has built an Internet digital music service designed to deliveruninterrupted, high-quality digital music transmissions (often referred to as a "stream") thatPandora ensures each user can precisely tailor and customize to his or her preferences.Pandora's service is the most popular service of its kind in the world, with more than 175 millionregistered users.4.Having copied thousands of Plaintiffs' Pre-72 Recordings to its servers withoutauthorization, Pandora each day transmits and performs (via real-time digital streaming)thousands of Plaintiffs' Pre-72 Recordings to its users "anytime, anywhere," including within the26031682.2/11224-00128State of New York. Pandora profits from subscription fees paid by its users for the ability toreceive these performances and also from advertising revenue, including for advertisements thatare played or displayed in connection with the streaming of Plaintiffs' Pre-72 Recordings.Despite the substantial revenues Pandora receives and the users it attracts as a result ofperforming Plaintiffs' Pre-72 Recordings, it refuses to obtain required licenses or pay for itscommercial and profitable exploitation of Plaintiffs' valuable property.5.Pre-72 Recordings constitute a significant part of the Pandora service and itsappeal. Without Plaintiffs' music, Pandora could not advertise or provide to its users all "themusic they love." Pandora knows that Pre-72 Recordings are popular and valuable to itsbusiness. It actively promotes the availability of these recorded performances by many ofPlaintiffs' most popular recording artists. It also offers and advertises stations dedicated to Pre72 Recordings, such as "50s Rock 'n' Roll," "60s Oldies," "Motown," "Doo-Wop," "70s Folk,""Early Jazz," "Standards," "Classic Soul," "Jam Bands," and "Classic Rock." As just oneexample, a page describing Pandora's "Classic Rock" station touts that it "plays the biggestsongs from the iconic bands that defined the genre, from the 60s British Invasion to Woodstock[in 1969] and Supergroups of the 70s...."6.Pandora acknowledged both its cost savings by not securing licenses for Pre-72Recordings, and the importance of these recordings "to attract and retain users," in a recent filingwith the Federal Securities and Exchange Commission:"If we are required to obtain licenses from individual soundrecording copyright owners for the reproduction and publicperformance of pre-1972 sound recordings, then the time, effort,and cost of securing such licenses could be significant and could36031682.2/11224-00128harm our business and operating results. If we are required toobtain licenses for pre-1972 sound recordings to avoid liability andare unable to secure such licenses, then we may have to removepre-1972 sound recordings from our service, which could harm ourability to attract and retain users."7.For more than 100 years, the courts repeatedly have affirmed the policy of thisState that the unique performances embodied in sound recordings are intangible propertyinterests protected from unauthorized use and exploitation. Such state law protection for theserecordings is critical because, while the federal Copyright Act protects sound recordings fixed onor after February 15, 1972 ("Post-72 Recordings") from, among other things, unauthorizeddigital performances, Pre-72 Recordings are not so protected by federal copyright law. Rather,the Copyright Act expressly preserves for Pre-72 Recordings "any rights or remedies under thecommon law or statutes of any States" — which rights and remedies are not in any way annulledor limited. This allows states to continue to freely apply their traditional and evolving commonlaw principles to protect Pre-72 Recordings. New York has done so by recognizing andenforcing exclusive ownership rights in Pre-72 Recordings.8.Plaintiffs have invested substantial time, money, and creative effort to make andto continue to exploit their Pre-72 Recordings. Pandora's refusal to pay Plaintiffs for its use ofthose recordings is fundamentally unfair. Pandora's conduct also is unfair to the recording artistsand musicians whose performances are embodied in Pre-72 Recordings, but who do not get paidfor Pandora's exploitation of Pre-72 Recordings. It is also unfair to other businesses thatcompete with Pandora but obtain licenses and pay for the right to stream Plaintiffs' Pre-72Recordings to the public, while Pandora does not. As a result, Pandora deprives Plaintiffs andtheir artists of compensation, while profiting enormously from and gaining an unfair advantage46031682.2/11224-00128over others who do pay to copy and publicly perform Plaintiffs' Pre-72 Recordings. This casepresents a classic attempt by Pandora to reap where it has not sown. Pandora appropriatesPlaintiffs' valuable and unique property, violates New York law, and engages in common lawcopyright infringement and misappropriation and unfair competition.ALLEGATIONS COMMON TO ALL CAUSES OF ACTIONThe Parties9.Plaintiff Capitol Records, LLC is a limited liability corporation duly formed andexisting under the laws of the State of Delaware, with its principal place of business in theCounty of Los Angeles, State of California.10.Plaintiff Sony Music Entertainment is a partnership duly formed and existingunder the laws of the State of Delaware, with its principal place of business in the County ofNew York, State of New York.11.Plaintiff UMG Recordings, Inc., is a corporation duly formed and existing underthe laws of the State of Delaware, with its principal place of business in the County of LosAngeles, State of California.12.Plaintiff Warner Music Group Corp. is a corporation duly formed and existingunder the laws of the State of Delaware, with its principal place of business in the County ofNew York, State of New York.56031682.2/11224-0012813.Plaintiff ABKCO Music & Records, Inc. is a corporation duly formed andexisting under the laws of the State of New York, with its principal place of business in theCounty of New York, State of New York.14.Upon information and belief, Pandora is a corporation duly organized and existingunder the laws of the State of Delaware, with its principal place of business in the State ofCalifornia. Pandora does business throughout the United States, including in the State of NewYork. Upon information and belief, Pandora transmits music to thousands of users in the Stateof New York on a daily basis; Pandora has actively solicited and contracted with those thousandsof users in the State of New York.15.The true names and capacities, whether individual, corporate, associate, orotherwise, of all Defendants sued herein as Does 1 through 10, are unknown to Plaintiffs, whotherefore sue said Defendants by such fictitious names. Plaintiffs will seek leave of Court toamend this complaint to state Defendants' true names and capacities when they have beenascertained. Said Defendants are liable to Plaintiffs because they either directly performed all orsome of the acts alleged hereinafter, or were acting as the agent, principal, alter ego, employee,representative, or otherwise participated in the acts alleged.Plaintiffs And Their Business16.Plaintiffs are record companies in the business of producing, manufacturing,distributing, selling, and otherwise exploiting sound recordings. Collectively, Plaintiffs own themajority of recorded music commercially distributed in the United States, and are the successorsin-interest to, and/or the owners of, many classic and famous record labels such as Mercury,66031682.2/11224-00128RCA Victor, Reprise, Columbia, Blue Note, Motown, Decca, Elektra and Sire. Recordings thatPlaintiffs own or in which they possess exclusive ownership interests include both federallycopyrighted recordings, i.e., Post-72 Recordings ("fixed" on or after February 15, 1972) and Pre72 Recordings ("fixed" before February 15, 1972).17.Plaintiffs' catalogs of Pre-72 Recordings include some of the most famous,popular, and valuable recordings in the world, span virtually every genre, and feature most majorrecording artists who recorded before February 15, 1972. A representative list of Plaintiffs' Pre72 Recordings is attached hereto as Schedule A and incorporated herein by reference. Theserecordings include, among many others, the classic recordings of the "Rock Era." (Whereapplicable, the Rolling Stone Magazine ranking of a representative Pre-72 Recording onSchedule A is denoted by "(#)"). Pandora copied and repeatedly digitally transmits (streams)each of the recordings listed on Schedule A (among many others) by making them available toits millions of users without Plaintiffs' authorization or consent.18.Plaintiffs have invested an enormous amount of time, effort, money, and creativetalent to discover and develop recording artists, and to create, manufacture, advertise, promote,and sell Pre-72 Recordings. Plaintiffs continue to invest substantial sums of money, time, andeffort to promote, advertise, sell, and license their Pre-72 Recordings.19.Plaintiffs exploit their Pre-72 Recordings in a number of ways: They offer themfor sale as CDs and digital music downloads. They authorize digital services (including Internetstreaming services and mobile "Apps") to exploit them. Plaintiffs also license Pre-7276031682.2/11224-00128Recordings for use in audiovisual works such as commercials, motion pictures, televisionprograms, and music videos.20.The transmission of digital music by streaming over the Internet and throughmobile Apps has become an integral part of Plaintiffs' business and one of the primary means bywhich the public pays for, receives, and enjoys musical performances. As evidenced byPandora's massive and featured use of them, Pre-72 Recordings remain valuable and popular,and attract both old and new fans to this day.21.Plaintiffs continue to invest in their Pre-72 Recordings because they rightlyexpect that they will be rewarded by the revenues, royalties, and other compensation that theyreceive from uses of these works, including from streaming to the public. Payments that arereceived from authorized uses of Plaintiffs' Pre-72 Recordings help Plaintiffs recover theirongoing investment and expenses. These payments also enable Plaintiffs to compensate therecording artists, musicians, and other creative personnel whose talent and work went intocreating Pre-72 Recordings.The Pandora Digital Music Service22.Pandora owns and operates the Pandora digital music service, through which itprovides paying and non-paying members of the public, in New York State and elsewhere, acontinuous on-demand stream (i.e., a real-time digital transmission) of music programming.Pandora has solicited users, in significant part, by promoting the availability of Plaintiffs' Pre-72Recordings and by providing numerous "stations" on its service dedicated to the exploitation ofPlaintiffs' property.86031682.2/11224-0012823.Pandora streams music to its users in a variety of ways, including via its website(www.pandora.com), smartphones and tablets (through its downloadable Android and iOS App),Apps pre-installed on "smart" TVs, Internet-enabled stereo receivers, and DVD and Blu-Rayplayers.24.According to Pandora, it streamed a total of 16.70 billion hours of music during2013 alone, to over 250 million registered users. It also claims to have a seventy percent (70%)share of its market. These numbers have increased rapidly in the recent past, as have Pandora'srevenues. Both certainly will continue to grow in the future.25.Accessing Pandora's service is easy. Users simply need to create an account byproviding just an email address and password. Pandora offers two "tiers" of memberships: freeand subsciption. Any member of the public can obtain a free Pandora account, which allows theuser full access to the music Pandora makes available. To generate revenue from these freeaccounts, Pandora delivers audio advertisements to its users inbetween songs and displays visualads while music is actually playing. Alternatively, for a monthly fee of $3.99 or an annual fee of$48.00, Pandora offers a premium "Pandora One" account, which is advertising-free.26.After a user creates a Pandora account, he or she may select a pre-existing music"station" based on a particular genre of music. Pandora offers its users a wide variety of thesepre-created "genre stations," including stations focused on or dedicated to Pre-72 Recordings(e.g., "Classic Rock," "70s Folk," "Motown"), which perfonn Plaintiffs' Pre-72 Recordings aspart of a continuous, uninterrupted stream.96031682.2/11224-0012827.Pandora advertises the availability of Pre-72 Recordings on these genre stations,including on its "Pandora Blog." Pandora entices users with statements such as: "Noll downthe windows and turn up Summer Oldies for classic hits from the 60s & 70s by The Beach Boys,Martha and the Vandellas, Bob Seger and Olivia Newton John" and "[y]ou don't have to be asurfer to enjoy that classic American rock & roll of the early 60s distinguished by reverbdrenched guitar and rolling instrumentals. Surf Rock features The Beach Boys, The Ventures,Dick Dale, Jan & Dean and The Safaris...."28.Pandora states that its "mission" is to be unlike traditional, over-the-air radiostations. In pursuit of this goal, Pandora also invites and enables its users to request personalizedstations, including stations based on the performances of popular Pre-72 Recordings or recordingartists. Pandora lists hundreds of Pre-72 recording artists around whom users may create stations(for example a "Beatles" station or an "Elvis Presley" station).29.A user creates an "artist station" by specifying the name of a particular recordingartist, song, or genre. Pandora then generates a playlist comprised of music that "exemplifies"the overall style of music performed by the recording artist, song, or genre that the user selected.Pandora describes this process as "seeding" the station. It claims that "[p]ersonalized stationslaunch instantly with the input of a single 'seed' — a favorite artist, song or genre." According toPandora, its users have created more than six billion stations.30.With respect to a "Beatles" station, for example, Pandora populates its playlistwith recordings by the Beatles such that the user can expect to hear recordings by the Beatlesapproximately four times during each three-hour period. In addition, Pandora advises the user106031682.2/11224-00128that it will play a selection of recordings in the "musical style of the Beatles which featuresmellow rock instrumentation, folk influences, acoustic rhythm piano, mixed acoustic and electricinstrumentation and major key tonality." Many, if not most, of the selected recordings for a"Beatles" station are Pre-72 Recordings.31.Pandora enables users to further customize stations by collecting their feedback.For example, Pandora allows users to click a "thumbs up" or "thumbs down" button as a specificrecording is played. Pandora adapts the playlist it provides to the user based on that feedback."The result [Pandora advertises] is a much more personalized radio experience — stations thatplay music you'll love — and nothing else." A significant part of this "personalized radioexperience" involves the streaming of Plaintiffs' Pre-72 Recordings.32.Pandora could not have created its personalized digital music service withouthaving copied to its servers thousands of Plaintiffs' Pre-72 Recordings, for which it has not paidPlaintiffs. In addition, Pandora publicly performs, every day, tens of thousands of Pre-72Recordings to millions of subscribers via digital streaming. Upon information and belief,Pandora has publicly performed Plaintiffs' Pre-72 Recordings millions of times throughout theUnited States, including in the State of New York. The list of Pre-72 Recordings identified onSchedule A is only a sample of Plaintiffs' Pre-72 Recordings that Pandora has performed andstreamed to the public, and represents only a small fraction of the total number of Pre-72Recordings streamed by Pandora on an ongoing and regular basis, without compensatingPlaintiffs for that use.116031682.2/11224-00128New York's Protection Of Pre-72 Sound Recordings33.Before 1972, "sound recordings" were excluded from the categories of workssubject to the federal copyright law. However, even before Congress afforded any federalcopyright protection to sound recordings, New York developed robust common law protectionfor Pre-72 Recordings that was distinct from and independent of federal copyright law. Thiscommon law protection was based on the existence of a property right in the intangibleperformances embodied in Pre-72 Recordings, a right that has been enforced by New Yorkcourts for decades.34.When the Copyright Act was amended in 1972 to make "sound recordings"eligible for the first time for federal copyright, Congress extended that protection onlyprospectively to those sound recordings "fixed" on or after February 15, 1972 (i.e., Post-72Recordings). At that same time, Congress specifically preserved until February 15, 2067, "anyrights or remedies under the common law or statutes of any State" with respect to soundrecordings "fixed" before February 15, 1972 (i.e., Pre-72 Recordings), expressly stating thatthese rights and remedies were not annulled or limited. As a result, New York possesses andcontinues to exercise the power to protect Pre-72 Recordings under the theories of common lawcopyright and misappropriation and unfair competition.35.In providing "rights and remedies" to protect Pre-72 Recordings, the common lawof this State has kept pace with constantly evolving technology and changing marketplaceconditions. Congress intended that the owner of rights to a Pre-72 sound recording should relyon the broad and flexible power of state common law to protect their property rights. New Yorklaw never has limited, either explicitly or implicitly, the scope of protection for Pre-72126031682.2/11224-00128Recordings or the intangible property right in the performances embodied in Pre-72 Recordings.Just as with other property, these protections encompass virtually any commercial exploitationby which individuals or entities use and profit from Pre-72 Recordings and thereby appropriate,for their own benefit, the skill and labor of Plaintiffs and their recording artists.36.Digital streaming technology has provided a new and growing opportunity toprofit by widely disseminating Pre-72 Recordings to the public. As digital technology hasimproved, music consumption habits have changed, and a greater percentage of the public listensto performances of music via digital streaming services instead of purchasing those sameperformances as embodied in CDs or digital music files. Thus, record companies and theirrecording artists rely increasingly on revenues from licensing the digital public performances ofmusic, including Pre-72 Recordings. It is crucial that record companies and their recordingartists be fairly compensated for such public performances. Therefore, those who profit from thedigital performances of music must obtain authorization and pay record companies for the use ofPre-72 Recordings.37.The need for effective protection of Pre-72 Recordings and the right to controltheir digital transmission is especially great with respect to services such as Pandora. The musicperformed by Pandora is of extremely high quality, rivaling that of digital music services thatpay Plaintiffs for Pre-72 Recordings. Moreover, Pandora ensures that the user experiences amusic stream that reflects the style and type of music he or she wishes to hear at any time orvirtually anywhere by creating individualized stations that are tailored to each user's tastes andlistening habits. Listening to such customized high-quality digital music can substitute for thepurchase of that music on CD or by digital download.136031682.2/11224-0012838.Under the common law of this State, companies like Pandora that build theirbusinesses on and profit from the copying and public performance of Pre-72 Recordings mustobtain the right to do so, and must compensate the owners of such recordings for theirexploitation. Selling unauthorized streams of performances embodied in Pre-72 Recordings tothe public is no less violative of Plaintiffs' property rights than selling unauthorized copies of thesame music. No logic or policy basis supports excluding the commercial use of Pre-72Recordings from protection while permitting Pandora to exploit the performances embodied inthose recordings for profit without compensation to Plaintiffs.FIRST CAUSE OF ACTION(COMMON LAW COPYRIGHT INFRINGEMENT / MISAPPROPRIATION)39.Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1through 38, as if fully set forth herein.40.Pre-72 Recordings are subject to common law copyright protection under the lawof the State of New York.41.Plaintiffs own valid common law copyrights in and to their Pre-72 Recordings,and possess the exclusive rights to manufacture, copy, sell, distribute, publicly perform, andotherwise exploit their Pre-72 Recordings, including by digital streaming.42.Plaintiffs have not authorized or licensed Pandora the right to exploit their Pre-72Recordings in any manner, including by copying and/or publicly performing them as part of itscommercial enterprise.146031682.2/11224-0012843.Through its conduct, Pandora has violated Plaintiffs' exclusive ownershipinterests in and to their Pre-72 Recordings, and has infringed Plaintiffs' common law copyrights.44.Pandora has misappropriated, and continues to misappropriate, for its owncommercial benefit, Plaintiffs' property rights in their Pre-72 Recordings.45.Plaintiffs are hail ied, and a new act of infringement and misappropriation occursgiving rise to a new liability, each time that Pandora reproduces or digitally publicly performsone of Plaintiffs' Pre-72 Recordings without the right to do so.46.As a direct and proximate result of Pandora's conduct in violation of Plaintiffs'exclusive ownership interests in and to their Pre-72 Recordings, Pandora has received andretained monetary proceeds that rightfully belong to Plaintiffs. As a result of Pandora's conduct,Plaintiffs have been damaged in an amount to be proven at trial.47.Pandora has acted with a malicious intent designed to harm and cause damage toPlaintiffs, such that, in addition to actual damages, Plaintiffs are entitled to recover exemplaryand punitive damages against Pandora.48.Pandora's conduct is causing, and unless enjoined and restrained by this Court,will continue to cause, Plaintiffs great and irreparable injury that cannot fully be compensated ormeasured in money.49.Plaintiffs have no adequate remedy at law, thus entitling them to an injunctionprohibiting further violation of their property rights in their Pre-72 Recordings.156031682.2/11224-00128SECOND CAUSE OF ACTION(UNFAIR COMPETITION)50.Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1through 38, as if fully set forth herein.51.Plaintiffs possess exclusive ownership interests in and to their Pre-72 Recordings,which ownership interests are protected under New York unfair competition law.52.Plaintiffs are engaged in the business of selling, distributing, and licensing theirPre-72 Recordings, both in tangible form and for digital audio transmission over the Internet.53.Plaintiffs have expended and continue to expend substantial sums of money toproduce and exploit their rights in and to their Pre-72 Recordings.54.Plaintiffs have the exclusive right to control the use of their Pre-72 Recordingsand the performances embodied therein, and to receive compensation for the exploitation of suchworks.55.Pandora's conduct constitutes unfair competition under New York common law.56.Pandora has used Plaintiffs' property to its commercial benefit and to Plaintiffs'detriment.57.Pandora has acted in bad faith by digitally publicly performing, copying, andotherwise using and exploiting Plaintiffs' Pre-72 Recordings.166031682.2/11224-0012858.Pandora is competing directly with Plaintiffs and their lawful licensees, andtaking further advantage of and undermining Plaintiffs' substantial investment in their Pre-72Recordings.59.Plaintiffs are harmed, and a new act of unfair competition occurs giving rise to anew liability, each time that Pandora reproduces or digitally publicly performs one of Plaintiffs'Pre-72 Recordings without the right to do so.60.As a direct and proximate result of Pandora's conduct, Plaintiffs are entitled torecover, in addition to other relief, all proceeds and other compensation received or to bereceived by Pandora arising from Plaintiffs' Pre-72 Recordings.61.Pandora would be unjustly enriched at the expense of the Plaintiffs should it bepermitted to retain the proceeds and/or any compensation derived or received by Pandora arisingfrom Plaintiffs' Pre-72 Recordings.62.As a direct and proximate result of Pandora's unfair competition, Plaintiffs havebeen damaged in an amount to be proven at trial for which damages and/or restitution anddisgorgement is appropriate.63.Such damages and/or restitution and disgorgement should include a declaration bythis Court that Pandora is a constructive trustee for the benefit of Plaintiffs, and an order thatPandora account for and turn over to Plaintiffs the gross receipts received or to be received by itthat are attributable to its infringement of Plaintiffs' Pre-72 Recordings.176031682.2/11224-0012864.Pandora has acted with malicious intent designed to cause harm to Plaintiffs, suchthat Plaintiffs, in addition to their actual damages, are entitled to recover exemplary and punitivedamages against Pandora.65.Pandora's conduct is causing, and unless enjoined and restrained by this Courtwill continue to cause, Plaintiffs great harm and irreparable injury that cannot fully becompensated by monetary damages.66.Plaintiffs have no adequate remedy at law, thus entitling them to an injunctionprohibiting further acts of unfair competition.THIRD CAUSE OF ACTION(DECLARATORY RELIEF)67.Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1through 38, as if fully set forth herein.68.An actual dispute has arisen and now exists between Plaintiffs and Pandora,creating a justiciable controversy.69.Pandora's ongoing and future copying and digital public performance ofPlaintiffs' Pre-72 Recordings, as described herein, without Plaintiffs' authorization or consentand without compensation to Plaintiffs, violates Plaintiffs' exclusive reproduction and publicperformance rights in their Pre-72 Recordings.186031682.2/11224-0012870.Plaintiffs request a declaration that Pandora's ongoing and future reproductionand digital public performances of Plaintiffs' Pre-72 Recordings, without authorization, consent,or payment, violate Plaintiffs' exclusive property rights in their Pre-72 Recordings.71.Such a declaration is necessary to resolve present and continuing disputesbetween the parties, to prevent further violation of Plaintiffs' exclusive rights in their Pre-72Recordings, and to avoid a multiplicity of future actions.72.Plaintiffs have no adequate remedy at law.WHEREFORE, Plaintiffs request the following relief:1.A preliminary and permanent injunction preventing, enjoining, and restrainingPandora and its respective agents, servants, directors, officers, principals, employees,representatives, subsidiaries and affiliated companies, successors, assigns, and those acting inconcert with them or at their direction, from directly or indirectly infringing in any manner anyright in any and all Pre-72 Recordings in which any Plaintiff owns or controls an exclusive rightunder statutory or common law, including without limitation by directly or indirectlyreproducing and digitally publicly performing any of Plaintiffs' Pre-72 Recordings, including butnot limited to those identified on Schedule A.2.The imposition of a constructive trust on any and all monies, proceeds, or othercompensation derived from Pandora's unauthorized use of Plaintiffs' Pre-72 Recordings.3.Restitution and an accounting of any and all proceeds taken, derived, or obtainedin any way by Pandora from the use of Plaintiffs' Pre-72 Recordings, including Pandora's grossreceipts attributable to its unauthorized use of Plaintiffs' Pre-72 Recordings.4.Compensatory damages in an amount to be determined at trial.196031682.2/11224-001285.Punitive damages in an amount to be determined at trial based on Pandora'swilfull conduct designed to harm and cause damage to Plaintiffs.6.A declaration that Pandora's unauthorized, ongoing, and future reproductions andpublic performances of Plaintiffs' Pre-72 Recordings without authorization, consent, or payment,violate Plaintiffs' exclusive rights.7.The costs, including attorneys' fees, incurred by Plaintiffs in connection with this8.Such other and further relief as the Court may deem just and proper.action.DATED: New York, New YorkApril 17, 2014MITCHELL SILBERBERG & KNUPP LLP,L'aurL J. Wachtler12 East 49th Street, 30th FloorNew York, New York 10017-1028Telephone: (212) 509-3900Facsimile: (212) 509-7239Russell J. FrackmanMarc E. Mayer11377 West Olympic BoulevardLos Angeles, CA 90064-1683Telephone: (310) 312-2000Facsimile: (310) 312-3100Attorneys for PlaintiffsCapitol Records LLC206031682.2/11224-00128Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtist1910 Fruitgum Company1910 Fruitgum CompanySimon SaysAdam FaithAlice CooperIt's AlrightI'm Eighteen (#487)Allman BrothersAllman BrothersMidnight RiderRevivalIndian GiverAllman Brothers BandHoochie Coochie ManAllman Brothers BandAndrews SistersWhipping Post (#393)Don't Sit Under The Apple TreeAndrews SistersNear YouAndrews SistersAndrews SistersPennsylvania PolkaStrip PolkaAndrews SistersAngelsWell All Right!AnimalsDon't Let Me Be Misunderstood (#322)It's My LifeAnimalsMy Boyfriend's BackAnimalsAnimalsThe House of the Rising Sun (#123)Anne MurraySnowbirdApplejacksArchie Bell & The DrellsMexican Hat Rock(There's Gonna Be A) ShowdownArchie Bell & The DrellsTighten Up (#270)Aretha Franklin(You Make Me Feel Like) A Natural WomanBaby I Love YouAretha FranklinAretha FranklinAretha FranklinWe Gotta Get Out of This Place (#235)Call MeChain of Fools (#252)Aretha FranklinAretha FranklinDo Right Woman, Do Right Man (#476)Aretha FranklinRespect (#5)Aretha FranklinAretha FranklinRock SteadyThinkAretha FranklinArgentYou're All I Need To Get ByHold Your Head UpI Never Loved a Man (the Way I Love You) (#189)Arthur ConleyFunky StreetArthur ConleySweet Soul MusicArtie ShawArtie ShawBack Bay ShuffleBegin the BeguineArtie ShawArtie ShawMoonglowTraffic JamArtie ShawWhat Is This Thing Called Love?Artie Shaw v/Helen ForrestB.B. KingComes LoveThe Thrill Is Gone (#185)1 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistBaby WashingtonTitleThat's How Heartaches Are MadeBadfingerCome And Get ItNo Matter WhatBadfingerBarbara GeorgeI Know (You Don't Love Me No More)Hello StrangerBarbara LewisBarbara Mandrel!Tonight My Baby's Commn' HomeBarbara MasonOh How It HurtsBar-KaysBarrett StrongSoul FingerMoney (That's What I Want) (#294)Barry & The TamerlanesI Wonder What She's Doing TonightBarry MannBeach BoysWho Put The BompBe True To Your SchoolBeach BoysCalifornia Girls (#72)Caroline, No (#214)Beach BoysBeach BoysCatch a WaveBeach BoysDo It AgainBeach BoysBeach BoysDon't Worry Baby (#178)Fun, Fun, FunBeach BoysGod Only Knows (#25)Beach BoysBeach BoysGood Vibrations (#6)Hang On To Your EgoBeach BoysHelp Me RhondaBeach BoysBeach BoysHere TodayBeach BoysIn My Room (#212)Little Deuce CoupeBeach BoysI Get AroundBeach BoysBeach BoysSloop John B (#276)Beach BoysSurfin' SafariSurfer GirlBeach BoysWouldn't It Be NiceBeatlesA Day in the Life (#28)BeatlesBeatlesA Hard Day's Night (#154)Across The UniverseBeatlesAll You Need Is Love (#370)And I Love HerBeatlesBeatlesBeatlesBeatlesBeatlesAnother GirlBaby's In BlackBirthdayBlackbirdBeatlesCan't Buy Me Love (#295)BeatlesBeatlesCome Together (#205)Dig It2 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistBeatlesBeatlesBeatlesDoctor RobertDon't Bother MeBeatlesDrive My CarEleanor Rigby (#138)BeatlesFor You BlueBeatlesBeatlesFrom Me to YouGood Morning Good MorningBeatlesBeatlesHello GoodbyeBeatlesBeatlesBeatlesBeatlesHelp! (#29)Here Comes The SunHey BulldogHey Jude (#8)I Am The WalrusBeatlesI Me MineI Saw Her Standing There (#140)BeatlesI Want to Hold Your Hand (#16)BeatlesBeatlesI Want You (She's So Heavy)BeatlesBeatlesI'll Cry InsteadI'm Looking Through YouBeatlesIn My Life (#23)BeatlesBeatlesLet It Be (#20)BeatlesBeatlesI'll Be BackMichelleNorwegian Wood (This Bird Has Flown) (#83)BeatlesBeatlesNot A Second TimeBeatlesOh! DarlingBeatlesPenny Lane (#456)BeatlesPiggiesPlease Please Me (#186)BeatlesBeatlesBeatlesNowhere ManRain (#469)She Loves You (#64)BeatlesBeatlesSlow DownSomething (#278)Strawberry Fields Forever (#76)BeatlesThe Ballad Of John And YokoBeatlesThe Long And Winding RoadThe Night BeforeBeatlesBeatlesBeatlesBeatlesBeatlesBeatlesThings We Said TodayTicket To Ride (#394)Tomorrow Never KnowsWhile My Guitar Gently Weeps (#136)3 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistBeatlesBeatlesBeatlesBeatlesBeatlesBen E. KingTitleWith a Little Help From My Friends (#311)Yellow SubmarineYesterday (#13)You Won't See MeYou've Got To Hide Your Love AwayDon't Play That SongBen E. KingBen E. KingI (Who Have Nothing)Spanish Harlem (#358)Ben E. KingBenny Goodman v/Helen WardStand By Me (#122)Goody GoodyBenny Goodman v/Peggy LeeWhy Don't You Do Right?Benny SpellmanBetty WrightLipstick Traces (On A Cigarette)Clean Up WomanBig BopperChantilly LaceBig Brother and the Holding CompanyBig Dee IrwinPiece of My Heart (#353)Swinging on a StarBill AndersonBill AndersonBright Lights and Country MusicBill AndersonBill AndersonBill AndersonI Get The FeverThat's What It's Like To Be LonesomeWalk Out BackwardsWild WeekendBill Haley & His CometsRock Around the Clock (#159)Bill Haley & His CometsSee You Later, AlligatorBill WithersAin't No Sunshine (#285)Bill WithersLean On Me (#208)Body And SoulBillie HolidayBillie HolidayBilly FuryBilly GrammerBilly J. Kramer & The DakotasBilly Joe RoyalBilly Joe RoyalNice Work If You Can Get ItNothin' Shakin' (But the Leaves on the Trees)Gotta Travel OnLittle ChildrenDown in the BoondocksI Knew You WhenBilly PrestonOuta-SpaceBilly StewartI Do Love YouBilly StewartSitting In The ParkBilly WalkerBilly WalkerBilly WalkerCharlie's ShoesCircumstancesBilly WalkerBing CrosbyBing CrosbyCross The Brazos At WacoWillie the WeeperRed Sails In The SunsetRemember Me4 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistBing CrosbySwinging on a StarBirdsYou're On My MindBlind FaithBlood, Sweat & TearsWell All RightAnd When I DieBlood, Sweat & TearsBlood, Sweat & TearsSpinning WheelYou've Made Me So Very HappyBlues ImageBlues MagoosBo DiddleyBo DiddleyBo DiddleyBo DiddleyBo DiddleyRide Captain Ride(We Ain't Got) Nothing YetBo Diddley (#62)Hey Bo Diddley!I'm a Man (#378)Say ManWho Do You Love? (#133)Bob DylanAll Along The WatchtowerBob DylanBob DylanBlowin' in the Wind (#14)Desolation Row (#187)Bob DylanBob DylanDown Along the CoveBob DylanFrom A Buick 6Highway 61 Revisited (#373)Bob DylanBob DylanHouse CarpenterBob DylanJust Like A Woman (#232)Bob DylanLay Lady LayLeopard-Skin Pill-Box HatBob DylanI Want YouBob DylanBob DylanLike A Rolling Stone (#1)Bob DylanMr. Tambourine Man (#107)Obviously 5 BelieversBob DylanBob DylanBob DylanMillion Dollar BashOutlaw BluesPlease Mrs. HenryBob DylanPositively 4th Street (#206)Bob DylanBob DylanStuck Inside Of Mobile With The Memphis Blues AgainBob DylanBob DylanThe Times They Are A-Changin' (#59)Visions of Johanna (#413)Bob LindElusive ButterflyBob WillsBobbie GentryRight or WrongFancyBobbie GentryBobby BareOde To Billie Joe (#419)500 Miles Away From HomeBobby BareDetroit CityBobby BareMargie's At The Lincoln Park InnSubterranean Homesick Blues (#340)5 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistBobby BareBobby DarinMiller's CaveBobby Darin18 Yellow RosesBeyond the SeaBobby DarinBobby DarinClementineDream LoverBobby DarinBobby DarinMack the Knife (#255)Bobby DarinBobby DarinQueen of the HopSplish SplashBobby FreemanThingsBetty Lou Got a New Pair of ShoesBobby FreemanBobby Fuller FourI Fought the Law (#177)Bobby GoldsboroAutumn of My LifeBobby GoldsboroIt's Too LateSunnyBobby HebbBobby HelmsBobby RydellBobby RydellDo You Wanna DanceMy Special AngelForget HimI've Got BonnieBobby RydellSwingin' SchoolBobby RydellBobby RydellThat Old Black MagicWe Got LoveBobby ShortBye Bye BlackbirdBobby VeeBeautiful PeopleBobby VeeBobby VeeCome Back When You Grow UpRubber BallBobby VeeBobby VeeRun to HimBobby VeeTake Good Care of My BabyThe Night Has a Thousand EyesBobby VeeBobby VintonWalkin' With My AngelBobby VintonBlue VelvetBobby WomackBooker T. & The MG'sThat's The Way I Feel About 'ChaGreen Onions (#183)Booker T. & The MG'sTime Is TightBreadBrenda LeeBrenda LeeBrenda LeeBrenda LeeBrenda LeeBrenda LeeBrenda LeeBlue on BlueMake It With YouAll Alone Am IAs UsualBigelow 6-200Dum DumLosing YouSweet Nothin'sThat's All You Gotta Do6 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistBrook BentonBrook BentonBrook BentonBrooklyn BridgeBrooklyn BridgeBruce ChannelBuddy HollyBuddy HollyFools Rush InHotel HappinessThank You Pretty BabyBlessed Is The RainThe Worst That Could HappenHey! BabyEveryday (#238)Buddy HollyIt Doesn't Matter AnymoreIt's So EasyBuddy HollyPeggy Sue (#197)Buddy HollyBuddy HollyBuddy HollyRaining in My HeartBuddy Holly & The CricketsBuddy Holly & The CricketsBuddy Holly & The CricketsTrue Love WaysWords of LoveNot Fade Away (#108)Oh, Boy!Rave On (#155)Buddy Holly & The CricketsThat'll Be The Day (#39)Buddy KnoxBuddy KnoxHula LoveParty DollBuddy MorrowMoreBuffalo SpringfieldBluebirdBuffalo SpringfieldFor What It's Worth (#63)Buffalo SpringfieldBunny BeriganHung Upside DownA Study in BrownBunny BeriganI Can't Get StartedBunny BeriganBurl IvesPeg 0' My HeartBuzz CliffordBabysittin' BoogieAll I Really Want To DoByrdsByrdsByrdsFunny Way Of Laughin'Ballad Of Easy RiderByrdsDraft MorningEight Miles High (#151)ByrdsI'll Feel A Whole Lot Better (#237)ByrdsByrdsJohn RileyByrdsByrdsByrdsByrdsByrdsByrdsCab CallowayIt's All Over Now, Baby BlueMr. SpacemanMr. Tambourine Man (#79)My Back PagesShe Don't Care About TimeSo You Want To Be A Rock 'N' Roll StarTurn! Turn! Turn!A Chicken Ain't Nothin' But a Bird7 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleCadillacsCanned HeatMy GirlfriendGoing Up The CountryCanned HeatCarl Dobkins Jr.Carl Dobkins Jr.On The Road AgainLucky DevilMy Heart Is An Open BookCarly SimonAnticipationCarole KingCarpentersI Feel The Earth MoveCascadesWe've Only Just Begun (#414)Rhythm Of The RainCat StevensPeace TrainChantelsCharley PrideCharlie BarnetCharlie BarnetCharlie DrakeCherMaybe (#199)Just Between You and MeLeapin' At The LincolnWhere Was I?My Boomerang Won't Come BackChicagoGypsys, Tramps & Thieves25 Or 6 To 4ChicagoBeginningsChicagoChicagoDoes Anybody Really Know What Time It IsChick Webb/Ella FitzgeraldChipsChubby CheckerChubby CheckerChubby CheckerChubby CheckerChubby CheckerMake Me SmileUndecidedRubber BiscuitHey, Bobba NeedleHucklebuckPony TimeSlow Twistin'The FlyChubby CheckerThe Twist (#457)Chubby CheckerChuck BerryTwist It UpChuck BerryBrown Eyed Handsome Man (#383)Guitar BoogieChuck BerryChuck BerryChuck BerryChuck BerryAround & AroundJohnny B. Goode (#7)Let It RockLittle QueenieChuck BerryMaybellene (#18)Chuck BerryChuck BerryNo Particular Place to GoRock And Roll Music (#129)Chuck BerryChuck BerryRoll Over Beethoven (#97)School DayChuck BerryChuck BerryToo Much Monkey BusinessSweet Little Sixteen (#277)8 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleChuck WillisC.C. RiderCilia BlackClarence CarterYou're My WorldSlip AwayClarence 'Frogman' HenryClarence 'Frogman' Henry(I Don't Know Why) But I DoClassics IVAin't Got No HomeEvery Day With You GirlClassics IVSpookyClassics IVClassics IV & Dennis YostTracesClaude KingClint MillerCloversCloversStormyWolverton MountainBertha LouDevil Or AngelLove Potion No. 9A Lover's QuestionClyde McPhatterClyde McPhatterTreasure Of LoveConnie Francis(He's My) DreamboatConnie FrancisConnie FrancisEverybody's Somebody's FoolIf My Pillow Could TalkConnie FrancisLipstick on Your CollarConnie FrancisConnie FrancisMany Tears AgoConnie FrancisSecond Hand LoveVacationConnie SmithCincinnati, OhioConnie SmithConway TwittyNobody But A Fool (Would Love You)Fifteen Years AgoConway TwittyIt's Only Make BelieveLonely Blue BoyConway TwittyCornelius Bros. & Sister RoseCount BasieTreat Her Like A LadyCount BasieRobbin's NestCount BasieSomebody Stole My GalBadgeCreamCream9-20 SpecialDeserted Cities of the HeartCreamCreamSunshine of Your Life (#65)Tales Of Brave UlyssesCreamWhite Room (#376)Crosby Stills & NashLong Time GoneCarry OnCrosby Stills Nash & YoungCrosby Stills Nash & YoungOhio (#395)Crosby Stills Nash & YoungCrosby Stills Nash & YoungTeach Your ChildrenWoodstockCrosby, Stills and NashSuite: Judy Blue Eyes (#426)9 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleCurtis Mayfield and The ImpressionsGypsy WomanDale HawkinsDale WardSusie-QLetter From SherryDanny & The JuniorsDanny & The JuniorsAt the HopDarlene LoveA Fine, Fine BoyRinky DinkDave "Baby" CortezDave DudleyDave MasonDavid BowieDavid BowieDavid BowieDavid BowieDottieSix Days On The RoadOnly You Know And I KnowChanges (#128)Queen BitchSpace OddityStarmanDavid BowieZiggy Stardust (#282)Dean Martin w/The Easy RidersMemories Are Made of ThisDee Dee SharpDeep PurpleMashed Potato TimeHighway StarDeep PurpleHushDeep PurpleSmoke on the Water (#434)Space Truckin'Deep PurpleDelaney & BonnieSoul ShakeDelfonicsDelfonicsDidn't I (Blow Your Mind This Time)La - La Means I Love YouDelfonicsReady or NotDelfonicsTrying To Make A Fool Of MeDel-VikingsCome Go with Me (#449)DerekDerek & The DominosCinnamonDerek & The DominosHave You Ever Loved A WomanLayla (#27)Derek & The DominosDiamondsThe StrollDiana RossLittle WingDiana Ross & The SupremesAin't No Mountain High EnoughLove ChildDiane RenayKiss Me SailorDick & Dee DeeDick & Dee DeeTell MeDick & Dee DeeDick HaynnesDickey LeeDionDionThe Mountain's HighYoung And In LoveYou'll Never KnowPatchesAbraham, Martin & JohnDrip Drop10 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleDionLittle DianeDionDionRunaround Sue (#351)The Wanderer (#243)Dion & The BelmontsDion & The BelmontsA Teenager in LoveIn The Still Of The NightDionne WarwickDionne WarwickDobie GrayDolly PartonDolly PartonDon GibsonDon GibsonDon GibsonDon GibsonDonny HathawayDonny OsmondDonovanDonovanI Say A Little PrayerWalk on By (#70)The 'In' CrowdJust Because I'm A WomanMule Skinner BluesFunny Familiar Forgotten FeelingsI Can't Stop Loving YouLonesome Number OneSweet DreamsThe GhettoSweet & InnocentAtlantisBarabajagalDonovanHurdy Gurdy ManDonovanDoorsSunshine SupermanBack Door ManDoorsBreak On ThroughDoorsHello, I Love YouDoorsDoorsLight My Fire (#35)DoorsLove Me Two TimesMaggie M'GillDoorsDoorsDoorsLove Her MadlyPeople Are StrangeQueen Of The HighwayRoadhouse BluesDoorsDoorsThe End (#336)DoorsTouch MeDoorsWaiting for the SunDoorsDoris DayYes, The River KnowsA Guy Is A GuyDoris DayI Only Have Eyes For YouDoris DayDoris DayLove SomebodySomeone Like YouDoris TroyDottie WestJust One LookHere Comes My BabyDottie WestPaper MansionsBristol StompDovells11 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistDoveIlsYou Can't Sit DownDriftersAdorableDriftersDriftersDriftersBip BarnDance With MeDriftersFools Fall In LoveHoney LoveDriftersMoney Honey (#254)DriftersDriftersOn BroadwaySaturday Night at the MoviesDriftersDriftersSave The Last Dance For Me (#184)There Goes My Baby (#196)DriftersDriftersUnder the Boardwalk (#489)Up on the Roof (#114)DriftersWhen My Little Girl Is SmilingDubsDuke EllingtonDon't Ask Me To Be LonelyDon't Get Around Much AnymoreDuke EllingtonPerdidoDusty SpringfieldDusty SpringfieldDusty SpringfieldDusty SpringfieldEaglesI Only Want To Be With YouSon of a Preacher Man (#242)Wishin and Hopin'You Don't Have To Say You Love MeWitchy WomanEddie CochranC'mon Everybody (#411)Eddie CochranJeanie, Jeanie, JeanieSomethin' ElseEddie CochranEddie CochranEddie FloydEddie HollandEdison LighthouseEdwin StarrSummertime Blues (#74)Knock on WoodLeaving HereLove Grows (Where My Rosemary Goes)WarElla FitzgeraldManhattanElla FitzgeraldStairway To The StarsElla Fitzgerald & Marty PaichElla Mae MorseYou Hit the SpotNo Love, No Nothin'Elton JohnTiny Dancer (#397)Elton JohnYour Song (#137)Elvis PresleyElvis PresleyAll Shook Up (#361)Baby Let's Play HouseElvis PresleyElvis PresleyBlue Suede Shoes (#430)Elvis PresleyElvis PresleyCan't Help Falling in Love (#403)Don't Be Cruel (#200)Don't Cry Daddy12 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleElvis PresleyGood Rockin' TonightElvis PresleyElvis PresleyHeartbreak Hotel (#45)His Latest FlameElvis PresleyElvis PresleyHound Dog (#19)I Got StungElvis PresleyIf I Can DreamElvis PresleyElvis PresleyIn the GhettoIt's Now or NeverElvis PresleyElvis PresleyJai!house Rock (#67)Elvis PresleyElvis PresleyElvis PresleyKentucky RainLove Me Tender (#444)Mystery Train (#77)Suspicious Minds (#91)Elvis PresleyElvis PresleyThat's All Right (#113)Eric Burdon & The AnimalsSan Franciscan NightsSky PilotWear My Ring Around Your NeckEric Burdon & The AnimalsEric ClaptonAfter MidnightEric ClaptonLet It RainErnie MarescaErroll GarnerShout! Shout! (Knock Yourself Out)MistyErskine HawkinsTuxedo JunctionEtta JamesTell MamaEverly BrothersEverly BrothersCathy's Clown (#150)Made To LoveEverly BrothersSo Sad (To Watch Good Love Go Bad)Everly BrothersWalk Right BackEydie GormeFabianBlame It on the Bossa NovaTurn Me LooseFats DominoFats DominoAin't That a Shame (#438)Fats DominoBlueberry Hill (#82)Bo WeevilFats DominoFats DominoFats DominoFats DominoFats DominoFats DominoFats DominoBe My GuestI Want to Walk You HomeI'm ReadyI'm Walkin'La LaShu RahFats DominoValley Of TearsWalking To New OrleansFats DominoFats WallerWhole Lotta Lovin'All My Life13 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistFever TreeFive SatinsFive StairstepsTitleSan Francisco Girls (Return Of The Native)In the Still of the Night (#90)0-o-h Child (#402)I Only Have Eyes for You (#158)FlamingosFleetwood MacTell Me All The Things You DoFlying MachineSmile A Little Smile For MeFontella BassFour PrepsRescue MeBig ManFour PrepsFour TopsDown by the Station (Early in the Morning)Four TopsAsk The LonelyBaby I Need Your Loving (#400)Four TopsFour TopsBernadetteI Can't Help Myself (#422)Four TopsFour TopsIt's All In The GameIt's the Same Old SongReach Out, I'll Be There (#209)Four TopsFour TopsShake Me, Wake Me (When It's Over)Four TopsStanding In The Shadows of Love (#470)Four TopsWalk Away ReneeFour TopsYou Keep Running AwayFrank Zappa & The Mothers OfInventionMother PeopleFrank Zappa & The Mothers OfInventionMotherly LoveFrankie Lymon & The TeenagersI Want You to Be My GirlFrankie Lymon & The TeenagersI'm Not A Juvenile DelinquentFrankie Lymon & The TeenagersFrankie ValliWhy Do Fools Fall in Love (#314)Frankie Valli & The Four SeasonsCan't Take My Eyes Off YouBeggin'Frankie Valli & The Four SeasonsBig Girls Don't CryFrankie Valli & The Four SeasonsBig Man in TownFrankie Valli & The Four SeasonsCandy GirlFrankie Valli & The Four SeasonsFrankie Valli & The Four SeasonsDawn (Go Away)Frankie Valli & The Four SeasonsOpus 17 (Don't You Worry 'Bout Me)Rag DollSherryFrankie Valli & The Four SeasonsFrankie Valli & The Four SeasonsFrankie Valli & The Four SeasonsFrankie Valli & The Four SeasonsFred AstaireFred AstaireFred Astaire w/ Leo ReismanLet's Hang OnWill You Love Me TomorrowWorking My Way Back To YouA Fine RomanceAfter You, Who?Night And Day14 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleFreeFriend & LoverAll Right NowReach Out of the DarknessGantsGary Lewis & The Playboys(You Can't Blow) Smoke RingsCount Me InGary Lewis & The PlayboysGary Lewis & The PlayboysEverybody Loves a ClownGary Lewis & The PlayboysGary Lewis & The PlayboysGary Puckett & The Union GapGary Puckett & The Union GapGary Puckett & The Union GapGary Puckett & The Union GapGary Puckett & The Union GapGene AutryGene KrupaGene KrupaShe's Just My StyleSure Gonna Miss HerThis Diamond RingLady WillpowerOver YouThis Girl Is a Woman NowWoman, WomanYoung GirlBack In The Saddle AgainDrum BoogieDrummin' ManGene KrupaGene KrupaHow High the MoonKnock Me A KissGene KrupaOpus OneGene McDanielsGene McDanielsA Hundred Pounds Of ClayChip ChipGene McDanielsGene VincentTower Of StrengthSay MamaGene Vincent and His Blue CapsBe-Bop-A-Lula (#103)George HarrisonGeorge HarrisonMy Sweet Lord (#460)What Is LifeGeorge JonesA Girl I Used To KnowGerry & The PacemakersFerry Cross the MerseyGerry & The PacemakersGirl on a SwingI Like ItGerry & The PacemakersGladys Knight & The PipsGladys Knight & The PipsFriendship TrainGladys Knight & The PipsIf I Were Your WomanGlen CampbellGlen CampbellBy the Time I Get to PhoenixDreams of the Everyday HousewifeI Heard It Through the GrapevineGlen CampbellGalvestonGlen CampbellGentle On My MindWichita Lineman (#195)Glen CampbellGlenn MillerGlenn MillerGlenn MillerA Nightingale Sang in Berkeley SquareA String of PearlsBugle Call RagGlenn MillerElmer's Tune15 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistGlenn MillerGlenn MillerGlenn MillerGlenn MillerTitl eImaginationIt's a Blue WorldJuke Box Saturday NightGlenn MillerMoonlight SerenadePoincianaGlenn MillerSerenade In BlueGlenn MillerGlenn MillerSong Of The Volga BoatmenGlenn MillerGlenn MillerGuess WhoGuess WhoGuess WhoGuess WhoSt. Louis Blues MarchSunrise SerenadeTuxedo JunctionAmerican WomanLaughingThese EyesUndunGuy MitchellHeartaches By The NumberHank WilliamsHonky Tonk BluesHank WilliamsHank WilliamsHonky Tonkin'Hank WilliamsI Just Don't Like This Kind Of LivingI'm A Long Gone DaddyHank WilliamsHank WilliamsI'm So Lonesome I Could Cry (#112)Lost HighwayHank WilliamsHank WilliamsMoanin' The BluesHank WilliamsThey'll Never Take Her Love From MeHank WilliamsYour Cheatin' Heart (#217)Harpers BizarreThe 59th St. Bridge SongHarry James v/Kitty KallenI'm Beginning To See The LightIt's Been A Long, Long TimeHarry James v/Kitty KallenHarry NilssonMove It On OverEverybody's Talkin'Harry NilssonHarry NilssonI Guess the Lord Must Be in New York CityJump Into The FireHelen Forrest & Harry JamesI Don't Want To Walk Without YouHelen Forrest & Harry JamesI Remember YouI've Heard That Song BeforeHelen Forrest & Harry JamesHerman's HermitsA Must to AvoidHerman's HermitsCan't You Hear My HeartbeatHerman's HermitsI'm into Something GoodHerman's HermitsHerman's HermitsMrs. Brown, You've Got a Lovely DaughterThere's a Kind of HushHerman's HermitsNowlin' WolfWonderful WorldI'm Leavin' YouNowlin' WolfSmokestack Lightning (#291)16 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistNowlin' WolfHugo Montenegro & His OrchestraTitleSpoonful (#221)The Good, the Bad, and the UglyHugo Winterhalter v/Johnny ParkerHugo Winterhalter/Eddie HeywoodA Kiss To Build A Dream OnCanadian SunsetIke & Tina TurnerProud MaryRiver Deep — Mountain High (#33)Ike & Tina TurnerInk SpotsDon't Get Around Much AnymoreInk SpotsInk SpotsI Don't Want To Set The World on FireJava JiveIsley BrothersIsley BrothersIt's Your Thing (#428)Love The One You're WithIvory Joe HunterJ. Geils BandSince I Met You BabyJackson 5ABCJackson 5I Want You Back (#121)Jackson 5I'll Be ThereMama's PearlJackson 5Jackson 5Jackson 5Jackson BrowneJames BrownJames BrownJames BrownJames BrownLooking for a LoveNever Can Say GoodbyeSugar DaddyDoctor My EyesGet On Up, Get Into It, Get InvolvedGet Up (I Feel Like Being a) Sex Machine (#334)Hot Pants Pt. 1I Got The Feelin'James BrownI Got You (I Feel Good) (#78)James BrownIt's a Man's Man's Man's World (#124)James BrownPapa's Got a Brand New Bag (#71)James BrownJames BrownPlease, Please, Please (#143)Say it Loud — I'm Black and I'm Proud (#312)James BrownSuper BadJames BrownJames GangThere Was A TimeFunk #49James GangWalk AwayJames TaylorFire And Rain (#227)James TaylorJan & DeanThe Little Old Lady From PasadenaJan BradleyYou've Got A FriendJanis IanMama Didn't LieSociety's Child (Baby I've Been Thinking)Janis JoplinJanis JoplinHalf MoonMe And Bobby McGee (#148)Janis JoplinJay & The AmericansMercedes BenzOnly In America17 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistJay & The AmericansJeff Beck GroupThis Magic MomentThe Hangman's KneeJefferson AirplaneJefferson AirplaneIt's No SecretSomebody To Love (#279)Jefferson AirplaneJefferson AirplaneWar MovieWhite Rabbit (#483)Jerry ButlerOnly the Strong SurviveJerry Lee LewisJerry Lee LewisAnother Place, Another TimeOnce More With FeelingJerry Lee LewisShe Still Comes Around (To Love What's Left of Me)Jerry Lee LewisTo Make Love Sweeter For YouWhat's Made Milwaukee Famous (Has Made a Loser Out ofJerry Lee LewisMe)Jerry Lee LewisWould You Take Another Chance On MeAqualungJethro TullJethro TullJethro TullCross-Eyed MaryJethro TullUp The 'PoolUp To MeJethro TullLiving In The PastJim LoweJimi Hendrix ExperienceThe Green DoorJimi Hendrix ExperienceJinni Hendrix ExperienceCan You See MeCome On (Let The Good Times Roll)Jimi Hendrix ExperienceCrosstown TrafficJimi Hendrix ExperienceFoxey Lady (#153)Hey Joe (#201)Jimi Hendrix ExperienceJimi Hendrix ExperienceAll Along The Watchtower (#47)Little Wing (#366)Jimi Hendrix ExperiencePurple Haze (#17)Jimi Hendrix ExperienceThe Wind Cries Mary (#379)Jimi Hendrix ExperienceVoodoo Child (Slight Return) (#102)Jimmie RodgersAre You Really MineJimmie RodgersJimmy CliffHoneycombMany Rivers to Cross (#325)Jimmy DeanJimmy JonesBig Bad JohnGood Timin'Jimmy JonesHandy ManJimmy RuffinJo StaffordWhat Becomes Of The Broken HeartedJo StaffordJo Stafford w/ Paul WestonJoe CockerJoe CockerIt Could Happen To YouOn the Sunny Side Of The StreetSmoke DreamsFeeling AlrightWith A Little Help From My Friends18 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraT itleArtistJoe SouthJoey Dee & The StarlitersJohn LennonJohnny BurnetteGames People PlayPeppermint TwistImagine (#3)Little Boy SadJohnny BurnetteYou're SixteenJohnny CashDaddy Sang BassI Still Miss SomeoneJohnny CashJohnny CashRing of Fire (#87)Johnny CashJohnny CashTennessee Flat Top BoxUnderstand Your ManJohnny CashJohnny MathisWhat Is TruthChances AreJohnny MercerAc-Cent-Tchu-Ate The PositiveG.I. JiveJohnny MercerJohnny MercerOn The Atchison, Topeka and the Santa FeJohnny MercerPersonalityJohnny PaycheckShe's All I GotJohnny PrestonJohnny PrestonCradle of LoveJohnny RiversJohnny RiversRunning BearMaybellineJohnny RiversMidnight SpecialMountain of LoveJohnny RiversPoor Side Of TownJohnny RiversJohnny RiversSecret Agent ManJohnny RiversSeventh SonSummer RainJohnny RiversThe Tracks of My TearsJoni MitchellBoth Sides Now (#171)Joni MitchellJr. Walker & The All StarsNight In The CityShotgunJudy CollinsJudy CollinsBoth Sides NowJudy GarlandSomeday SoonOver The RainbowKay KyserLet's Get LostKay KyserPraise The Lord And Pass The AmmunitionThe Old LamplighterKay Kyser v/Mike DouglasKay StarrKeithKenny Rogers & The First EditionKingston TrioKingston TrioRock And Roll Waltz98.6Just Dropped In (To See What Condition My Condition Was In)Greenback DollarM.T.A.19 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistLarry Clinton v/Bea WainLarry Clinton v/Bea WainLarry Clinton v/Bea WainLarry Clinton v/Ford LearyLaVern BakerLaVern BakerLed ZeppelinTitleHeart and SoulMy Heart Belongs To DaddyYou Go To My HeadJeepers CreepersJim Dandy (#352)Tweedlee DeeBlack Dog (#300)Led ZeppelinLed ZeppelinCommunication BreakdownDazed and ConfusedLed ZeppelinGoing To CaliforniaGood Times Bad TimesLed ZeppelinLed ZeppelinHeartbreaker (#328)Led ZeppelinHey Hey What Can I DoLed ZeppelinLed ZeppelinHow Many More TimesLed ZeppelinI Can't Quit You BabyImmigrant SongLed ZeppelinLed ZeppelinMisty Mountain HopRamble On (#440)Led ZeppelinRock and RollLed ZeppelinLed ZeppelinStairway To Heaven (#31)Traveling Riverside BluesLed ZeppelinWhole Lotta Love (#75)Lee DorseyWorking in the Coal MineLee DorseyLeft BankeYa YaLeft BankePretty BallerinaWalk Away Renee (#222)Len BarryLenny WelchSince I Fell For YouLeroy Van DykeLes Brown and Doris DayThe AuctioneerAmapolaLes Brown v/Miriam ShawDon't Worry 'Bout MeLes ElgartIn The Still Of The NightLesley GoreLesley GoreCalifornia NightsIt's My PartyLettermenThe Way You Look TonightLionel HamptonLionel HamptonLittle Anthony & The ImperialsLittle Eva1, 2, 3Hamp's Boogie WoogieWizzin' The WizzHurt So BadKeep Your Hands off My BabyLittle EvaLittle EvaLet's Turkey TrotThe Loco-Motion (#359)Little Jack LittleI'm in the Mood for Love20 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistLittle Joe & The ThrillersLittle Peggy MarchLittle Peggy MarchLittle WalterLloyd PriceTitlePeanutsI Will Follow HimI Wish I Were a PrincessMellow Down EasyI'm Gonna Get MarriedLloyd PriceStagger LeeLoretta LynnBlue Kentucky GirlLoretta LynnLoretta LynnDon't Come Home A Drinkin'Fist CityLoretta LynnLoretta LynnIf You're Not Gone Too LongYou Ain't Woman EnoughLoretta LynnYou're Lookin' At CountryLos BravosLou ChristieBlack Is BlackLightnin' StrikesLou ChristieLou ChristieRhapsody in the RainLou RawlsLou RawlsTwo Faces Have IDead End StreetLove Is a Hurtin' ThingLou RawlsYour Good Thing (Is About To End)Louis ArmstrongLouis ArmstrongA Kiss to Build a Dream OnJeepers CreepersLouis ArmstrongWhat A Wonderful WorldLouis PrimaLouis Prima & Keely SmithJust a Gigolo-I Ain't Got NobodyLoveNo Matter What You DoTo Sir With LoveLuluMac & Katie KissoonMajor LanceMajor LanceJump Jive An' WailChirpy Chirpy Cheep CheepThe Monkey TimeMamas & The PapasUrn Urn Urn Urn Urn UrnCalifornia Dreamin' (#89)Mamas & The PapasDedicated To The One I LoveMamas & The PapasMamas & The PapasDream a Little Dream of MeMamas & The PapasMonday, MondayWords of LoveMamas & The PapasMarcelsMarcelsMarcelsMarianne Faithful!Mark LindsayMartha & The VandellasMartha & The VandellasI Saw Her AgainBlue MoonHeartachesSummertimeAs Tears Go ByArizonaDancing in the Street (#40)Heat Wave21 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistMartha & The VandellasMartha Reeves & The VandellasCome and Get These MemoriesMartha Reeves & The VandellasMartha Reeves & The VandellasHoney ChileJimmy MackMartha Reeves & The VandellasMarty RobbinsQuicksandDevil WomanMarty RobbinsEl PasoMarty RobbinsMarty RobbinsMy Woman My Woman My WifeRibbon Of DarknessMarty RobbinsRuby AnnMarty RobbinsMary JohnsonTonight CarmenNowhere to Run (#367)(You've Got To) Move Two MountainsI Love The Way You LoveMary JohnsonMarvin GayeAin't That PeculiarMarvin GayeChainedMarvin GayeI Heard It Through the Grapevine (#81)Inner City Blues (Make Me Wanna Holler)Marvin GayeMarvin GayeMercy Mercy Me (The Ecology)Marvin GayeTry It BabyMarvin GayeMarvin Gaye & Tammi TerrellWhat's Going On (#4)Ain't No Mountain High EnoughMarvin Gaye & Tammi TerrellAin't Nothing Like The Real ThingYour Precious LoveMarvin Gaye & Tammi TerrellMary HopkinMary WellsMason WilliamsMcCoysMel CarterMerle HaggardThose Were the DaysMy GuyClassical GasHang On SloppyHold Me Thrill Me Kiss MeDaddy FrankMerle HaggardMama TriedMerle HaggardSwinging DoorsMerle HaggardMerle HaggardThe Fightin' Side of MeWorkin Man BluesMerrilee Rush & TurnaboutsAngel of the MorningMickey & SylviaLove Is StrangeMitch Ryder & The Detroit WheelsMoby GrapeJenny Take a RideMoby GrapeMoby GrapeMonotonesMoody BluesMoody BluesMurder In My Heart For The JudgeOmahaSitting By The WindowLegend Of Sleepy HollowGo NowQuestion22 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistMoody BluesMoody BluesThe Story In Your EyesMott The HoopleMott The HoopleAll The Way From MemphisAll The Young Dudes (#256)MountainMississippi QueenGot My Mojo Working (#368)Muddy WatersMuddy WatersMuddy WatersMuddy WatersMuddy WatersTuesday Afternoon (Forever Afternoon)Hoochie Coochie Man (#226)I'm ReadyMannish Boy (#230)Rollin' Stone (#465)Music ExplosionLittle Bit 0' SoulNappy BrownNat King ColeLittle By Little(I Love You) For Sentimental ReasonsNat King ColeNat King ColeOrange Colored SkyStraighten up and Fly RightNeil DiamondBrother Love's Traveling SalvationNeil DiamondNeil SedakaShiloBreaking Up Is Hard to DoNeil SedakaHappy Birthday, Sweet SixteenNeil SedakaNeil SedakaNext Door To An AngelNeil SedakaStairway to HeavenNeil YoungNeil YoungAfter The Gold RushHeart Of Gold (#303)Neil YoungNeil YoungSouthern ManNeon PhilharmonicMorning GirlNew Christy MinstrelsGreen GreenThings I'd Like To SayNew Colony SixNew SeekersNew Vaudeville BandNina SimoneOhio ExpressOhio ExpressLittle DevilOld ManI'd Like To Teach The World to SingWinchester CathedralTo Be Young, Gifted, And BlackChewy, ChewyOliverYummy Yummy YummyGood Morning StarshineOrionsNot MeOrionsOtis ReddingThe Wah WatusiOtis ReddingOtis ReddingOtis ReddingOtis Redding(Sittin' On) The Dock of the Bay (#26)I've Been Loving You Too Long (#111)Mr. PitifulRespectSatisfaction23 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraOtis ReddingPartridge FamilyTitleTry a Little Tenderness (#207)Doesn't Somebody Want to Be WantedPat BoonePat BooneApril LoveBernardinePat BoonePat BooneDon't Forbid MeLove Letters in the SandPatsy ClineAlwaysPatsy ClinePatsy ClineBack In Baby's ArmsCrazy (#85)Patsy ClinePatsy ClineHalf as MuchArtistPatsy ClineHeartachesI Fall To Pieces (#241)Patsy ClinePatsy ClineSan Antonio RosePatsy ClineShoesSouth of the Border (Down Mexico Way)Patsy ClinePatsy ClinePatti DrewPaul & PaulaPaul AnkaPaul Butterfield Blues BandPaul Butterfield Blues BandPaul MauriatSeven Lonely DaysSweet Dreams (Of You)Tell HimHey PaulaPut Your Head On My ShoulderGet Out Of My Life, WomanLove DiseaseLove Is BluePaul Revere & The RaidersHim Or MePaul Revere & The RaidersPaul Revere & The RaidersHungryKicksPaul SimonMe And Julio Down By The SchoolyardPaul SimonRun That Body DownClose Your EyesPeaches & HerbPercy FaithTheme From A Summer PlacePercy SledgeIt Tears Me UpPercy SledgeWhen A Man Loves A Woman (#53)Perez PradoPatriciaPerry ComoI'm Gonna Love That GalPerry Como w/ Mitchell AyresPeter, Paul & MaryPapa Loves MamboQuestion Mark & The MysteriansR.B. GreavesI Dig Rock & Roll Music96 Tears (#213)RaidersTake a Letter, MariaIndian ReservationRandy & The RainbowsRare EarthDeniseGet ReadyRay Bryant & His ComboThe Madison Time24 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraRay CharlesRay CharlesTitle(Night Time Is) The Right TimeI Got A Woman (#239)Ray CharlesRay CharlesRoll With My BabyWhat'd I Say (#10)Ray PriceDon't You Ever Get Tired (Of Hurting Me)Ray PriceRay PriceFor The Good TimesHeartaches By The NumberRay PriceI Won't Mention It AgainRay PriceRay PriceInvitation To The BluesMake The World Go AwayRay PriceRay PriceMy Shoes Keep Walking Back To YouArtistRay PriceRichard HarrisPrideThe Other Woman (In My Life)Ricky NelsonMacArthur ParkA Wonder Like YouRicky NelsonBelieve What You SayRicky NelsonRicky NelsonHello Mary LouI Got A FeelingRicky NelsonIt's LateRicky NelsonRicky NelsonIt's Up To YouRicky NelsonMy Bucket's Got A Hole In ItRicky NelsonNever Be Anyone Else But YouThe Very Thought of YouRicky NelsonLonesome TownRicky NelsonRingo StarrYoung EmotionsRitchie ValensCome on, Let's GoDonnaRitchie ValensRitchie ValensRobert KnightRoberta Flack & Donny HathawayRobin LukeIt Don't Come EasyLa Bamba (#354)Everlasting LoveWhere Is The LoveSusie Darlin'Robin McNamaraLay A Little Lovin' On MeRod StewartDirty Old TownEvery Picture Tells A StoryRod StewartRod StewartRod StewartRod StewartRoger MillerRolf HarrisRolling StonesRolling StonesGasoline AlleyI Wouldn't Ever Change A ThingMaggie May (#131)King Of The RoadTie Me Kangaroo Down, Sport(I Can't Get No) Satisfaction (#2)19th Nervous Breakdown25 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleRolling StonesRolling StonesAs Tears Go ByBrown Sugar (#495)Rolling StonesRolling StonesConnectionRolling StonesRolling StonesRolling StonesCountry HonkDon't Lie To MeFlight 505Rolling StonesGimme Shelter (#38)Heart Of StoneRolling StonesRolling StonesHonky Tonk Women (#116)I'm A King BeeRolling StonesRolling StonesJumpin' Jack Flash (#125)Rolling StonesLet's Spend The Night TogetherMother's Little HelperRolling StonesRolling StonesOut Of TimeRolling StonesRolling StonesRuby Tuesday (#310)Salt of the EarthPaint It Black (#176)Rolling StonesShe's A RainbowRolling StonesRolling StonesStreet Fighting Man (#301)Rolling StonesRolling StonesRolling StonesSympathy For The Devil (#32)The Last TimeThinkUnder My ThumbRolling StonesWild Horses (#343)Rolling StonesRoy HamiltonRoy OrbisonYou Can't Always Get What You Want (#101)You Can Have HerBlue AngelRoy OrbisonCrying (#69)Roy OrbisonDream Baby (How Long Must I Dream)Roy OrbisonRoy OrbisonIn Dreams (#319)LeahRoy OrbisonOh Pretty Woman (#224)Roy OrbisonOnly the Lonely (#234)Running ScaredRoy OrbisonRuby & The RomanticsRufus ThomasRuth BrownSam & DaveSam & DaveSam & DaveOur Day Will ComeWalking The Dog(Mama) He Treats Your Daughter MeanHold On, I'm Comin'I Thank YouSoul Man (#463)Sam & DaveWhen Something Is Wrong With My BabySam & DaveYou Don't Know Like I Know26 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleSam CookeSam Cooke(Ain't That) Good NewsSam CookeSam CookeA Change Is Gonna Come (#12)Another Saturday NightBring It on Home to MeSam CookeSam Cooke(What A) Wonderful World (#382)Cupid (#458)Sam CookeEverybody Loves To Cha Cha ChaSam CookeSam CookeFrankie and JohnnyLittle Red RoosterSam CookeSam CookeMeet Me at Mary's PlaceSam CookeSam CookeSam CookeSam CookeSam the Sham & The PharaohsSantanaSantanaSantanaSantanaSanto & JohnnySarah VaughanScott McKenzieScreamin' Jay HawkinsSergio Mendes & Brasil '66Nothing Can Change This LoveSoothe MeTwistin' the Night AwayWin Your Love For MeYou Send Me (#115)Wooly BullyBlack Magic Woman/Gypsy QueenEverybody's EverythingEvil WaysOye Como VaSleep WalkBroken Hearted MelodySan Francisco (Be Sure to Wear Flowers in Your Hair)I Put a Spell on You (#320)Sergio Mendes & Brasil '66Shadows of KnightThe Fool On The HillScarborough FairGloriaShadows of KnightGospel ZoneShadows of KnightShadows of KnightSomeone Like MeOh Yeah!Shangri-LasLeader Of The Pack (#454)Shangri-LasOut in the StreetsShangri-LasRemember (Walking In The Sand) (#404)The Dum Dum DittyJohnny AngelShangri-LasShelley FabaresShirley & LeeSil AustinLet the Good Times RollSimon & GarfunkelSlow WalkA Hazy Shade of WinterSimon & GarfunkelAmericaSimon & GarfunkelSimon & GarfunkelApril Come She WillAt The ZooSimon & GarfunkelBlessed27 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistSimon & GarfunkelSimon & GarfunkelTitl eBridge Over Troubled Water (#48)Homeward BoundSimon & GarfunkelSimon & GarfunkelI Am A RockMrs. RobinsonSimon & GarfunkelThe Boxer (#106)Simon & GarfunkelThe Sound Of Silence (#157)Skeeter DavisSkeeter DavisSkeeter DavisI Can't Stay Mad At YouSkylinersSlim HarpoSly & The Family StoneSly & The Family StoneSly & The Family StoneMy Last Date with YouThe End of the WorldPennies From HeavenI'm A King BeeDance To The Music (#225)Everybody Is A StarSly & The Family StoneEveryday People (#146)Family Affair (#139)Sly & The Family StoneSly & The Family StoneHot Fun in the Summertime (#250)I Want To Take You HigherSly & The Family StoneStand! (#244)Sly & The Family StoneThank You (#410)Smiley LewisShame, Shame, ShameSmokey Robinson & The MiraclesSmokey Robinson & The MiraclesBaby, Baby Don't CryGoing To A Go-GoSmokey Robinson & The MiraclesI Second That EmotionSmokey Robinson & The MiraclesIf You Can WantSmokey Robinson & The MiraclesSmokey Robinson & The MiraclesOoo Baby Baby (#266)Shop Around (#500)Smokey Robinson & The MiraclesThe Tears Of A ClownSmokey Robinson & The MiraclesThe Tracks on My Tears (#50)Solomon BurkeSolomon BurkeCry To MeSolomon BurkeGot To Get You Off My MindSonny & CherSonny & CherSonny JamesBaby Don't GoI Got You Babe (#451)Young LoveSpanky & Our GangLazy DaySpanky & Our GangSunday Will Never Be The SameSpencer Davis GroupSpencer Davis GroupGimme Some Lovin' (#247)I'm A ManSpiral StarecaseSpringfieldsEverybody Needs Somebody to Love (#436)More Today Than YesterdayStampedersSilver Threads And Golden NeedlesSweet City WomanStan KentonArtistry Jumps28 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistStan KentonJump For JoeStan Kenton v/June ChristyStan Kenton v/June ChristyShoo Fly Pie And Apple Pan DowdyTampicoStatler BrothersStatler BrothersFlowers On The WallSteamStephen StillsSteppenwolfBed Of Rose'sNa Na Hey Hey Kiss Him GoodbyeLove The One You're WithBorn to Be Wild (#130)SteppenwolfSteppenwolfGod Fearing ManMagic Carpet RideSteppenwolfSteppenwolfRock MeYour Wall's Too HighSteve LawrenceGo Away Little GirlStevie WonderFingertips, Pt. 2Stevie WonderStevie WonderIf You Really Love MeStevie WonderSigned, Sealed, Delivered I'm YoursUptight (Everything's Alright)Stevie WonderYester-Me, Yester-You, YesterdayStone PoneysStrawberry Alarm ClockDifferent DrumSupremesSupremesIncense and PeppermintsBaby Love (#332)Back in My Arms AgainSupremesCome See About MeSuprennesSupremesI Hear a SymphonySupremesMy World Is Empty Without YouStoned LoveSupremesSupremesSupremesSupremesSupremesSurfarisT. RexLove Is Here and Now You're GoneStop! In The Name Of LoveThe HappeningWhere Did Our Love Go (#475)You Keep Me Hangin' On (#348)Wipe OutBang A Gong (Get It On)T. RexJeepsterTaj MahalKeep Your Hands Off HerD-I-V-O-R-C-ETammy WynetteTammy WynetteTeddy WilsonStand By Your ManTen Years AfterThe 5th DimensionI'd Love To Change The WorldAquarius / Let the Sunshine InThe 5th DimensionGo Where You Wanna GoStoned Soul PicnicThe 5th DimensionWhen You're Smiling29 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistThe 5th DimensionThe 5th DimensionUp, Up and AwayWedding Bell BluesThe American BreedThe AssociationBend Me Shape MeAlong Comes MaryThe AssociationCherishThe AssociationThe AssociationThe BandThe BandThe BandThe BandThe Beau BrummelsThe Beau BrummelsThe Box TopsNever My LoveWindyShoot Out In ChinatownThe Night They Drove Old Dixie Down (#249)The Weight (#41)Up On Cripple CreekJust A LittleLaugh, LaughThe Box TopsCry Like a BabyThe Letter (#372)The BuckinghamsDon't You CareThe BuckinghannsThe CapitolsCool JerkThe CaravellesYou Don't Have To Be A Baby to CryThe CasinosThe ChiffonsThen You Can Tell Me GoodbyeHe's So FineThe CleftonesFor Sentimental ReasonsThe CoastersThe CoastersSearchin'Young Blood (#421)The CoastersZing Went the Strings of My HeartThe ContoursDo You Love MeThe CowsillsHairKind of a DragThe CowsillsRain, Park & Other ThingsThe CowsillsThe CrystalsWe Can FlyDa Doo Ron Ron (When He Walked Me Home)The CrystalsThe CrystalsHe's A Rebel (#267)The CrystalsThe CrystalsThe CyrkleThe CyrkleHe's Sure The Boy I LoveThen He Kissed MeThere's No Other (Like My Baby)Red Rubber BallTurn-Down DayThe DanleersThe DellsOne Summer NightThe Electric PrunesThe ElegantsI Had Too Much to DreamLittle StarThe EssexThe EssexA Walkin' MiracleEasier Said Than DoneOh, What A Night (#263)30 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleThe Five BlobsThe BlobThe Five SatinsThe FleetwoodsTo The AisleThe FortunesThe Four LoversThe GentrysThe Grass RootsThe Grass RootsThe Grass RootsMr. BlueYou've Got Your TroublesYou're the Apple of My EyeKeep on DancingHeaven KnowsLet's Live for TodayMidnight ConfessionsThe HappeningsThe Hi-Lo'sSee You in SeptemberThe HolliesThe HolliesBus StopCarrie AnneThe HolliesThe HolliesHe Ain't Heavy He's My BrotherOf Thee I SingThe HolliesKing Midas in ReverseOn A CarouselThe HolliesStop, Stop, StopThe ImpressionsThe JarrnelsPeople Get Ready (#24)The Lemon PipersThe Lovin' SpoonfulThe Lovin' SpoonfulThe Lovin SpoonfulThe Lovin' SpoonfulThe Lovin' SpoonfulThe Lovin' SpoonfulA Little Bit of SoapGreen TambourineDarling Be Home SoonDaydreamDid You Ever Have To Make Up Your MindDo You Believe in Magic? (#218)She Is Still a MysteryThe MarkettsSummer in the City (#401)Batman ThemeThe MarkettsOut Of LimitsThe MarvelettesBeechwood 4-5789The MarvelettesThe MarvelettesDanger Heartbreak Dead AheadThe MarvelettesThe Hunter Gets Captured by the GameWhen You're Young And In LoveThe MarvelettesThe Mello-KingsPlease Mr. PostmanTonite ToniteThe Mind bendersA Groovy Kind of LoveThe Monkees(I'm Not Your) Steppin' StoneThe MonkeesThe Monkees(Theme From) The MonkeesDaydream BelieverI'm a BelieverThe Mon keesThe Mon keesThe MonkeesThe Mon keesLaughPleasant Valley SundayShe31 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleThe Mon keesYou Told MeThe MysticsThe O'KaysionsHushabyeThe OutsidersThe PenguinsThe PlattersThe PlattersGirl WatcherTime Won't Let MeEarth Angel (#152)He's MineI'm SorryMy PrayerThe PlattersThe PlattersThe PlattersSmoke Gets in Your EyesThe Great Pretender (#360)The PlattersTwilight TimeThe PlattersThe RascalsYou've Got the Magic TouchA Beautiful MorningThe RascalsGood Lovin' (#333)The RascalsHow Can I Be SureThe RascalsI've Been Lonely Too LongPeople Got To Be FreeThe RascalsThe RascalsThe Righteous BrothersThe Righteous BrothersThe Righteous BrothersThe RobinsThe Rock-A-TeensYou Better RunSoul and InspirationUnchained Melody (#374)You've Lost That Lovin' Feelin' (#34)Smokey Joe's CafeThe RonettesWoo HooBe My Baby (#22)The RonettesDo I Love You?The RonettesThe SensationsWalking in the Rain (#269)The ShireIlesI Met Him on a SundayIt's A ShameThe SpinnersThe Syndicate of SoundThe TamsThe TemptationsLet Me InLittle GirlWhat Kind of Fool (Do You Think I Am)(I Know) I'm Losing YouThe TemptationsBall Of ConfusionThe TemptationsThe TemptationsGet ReadyThe TemptationsThe TemptationsThe TemptationsThe TemptationsThe TemptationsThe TokensThe TokensJust My Imagination (#399)My BabyMy Girl (#88)Psychedelic ShackThe Way You Do The Things You DoYou're Not An Ordinary GirlThe Lion Sleeps TonightTonight I Fell in Love32 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTitleThe ToysA Lover's ConcertoThe TroggsThe TroggsI Want YouThe TroggsThe TroggsThe VenturesThe VenturesThe VenturesThe VoguesLove Is All AroundWild Thing (#261)With a Girl Like YouDiamond HeadPerfidiaWalk Don't RunNo, Not MuchThe WhoA Legal MatterThe WhoAnyway, Anyhow, AnywhereThe WhoThe WhoBaba 0' Riley (#349)Barbara AnnThe WhoThe WhoDaddy Rolling StoneGetting In TuneThe WhoThe WhoGoing MobileThe WhoThe WhoThe WhoI Can See For Miles (#262)I Can't Explain (#380)My Generation (#11)The WhoOverturePinball WizardThe WhoSo Sad About UsThe WhoThe WhoSubstituteThe WhoThe WhoThe WhoThe WhoThe Good's GoneThe Kids Are AlrightThe Song Is OverTommy Can You Hear Me?The Yard birdsWon't Get Fooled Again (#134)For Your LoveThe YardbirdsHeart Full Of SoulThe YardbirdsShapes of ThingsThree Dog NightAn Old Fashioned Love SongEasy to Be HardThree Dog NightThree Dog NightThree Dog NightEli's ComingThree Dog NightJoy To The WorldOneThunderclap NewmanThurston HarrisTimi YuroSomething In The AirLittle Bitty Pretty OneHurtTodd RundgrenI Saw The LightTommy Boyce & Bobby HartAlice Long (You're Still My Favorite Girlfriend)Tommy Boyce & Bobby HartI Wonder What She's Doing33 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraArtistTommy Dorsey v/Frank SinatraTommy Dorsey v/Frank SinatraTommy Dorsey v/Jack LeonardTommy EdwardsTommy James & The ShondellsTommy James & The ShondellsTommy James & The ShondellsTommy James & The ShondellsTommy James & The ShondellsTommy RoeTommy RoeT itleI'll Never Smile AgainMarieIt's All in the GameCrimson & CloverHanky PankyI Think We're Alone NowMirageMony MonyHooray for HazelJam up and Jelly TightTommy RoeSweet PeaTommy SandsTony PastorTeenage CrushHey! MabelToots & The MaytalsPressure Drop (#453)TrafficTrafficEmpty PagesForty Thousand HeadmenTrafficGladTrafficTravis & BobHeaven Is in Your MindTrini LopezTell Him NoIf I Had A HammerTune WeaversHappy Happy Birthday BabyVan MorrisonVan MorrisonBrown Eyed Girl (#110)Van MorrisonMoondance (#231)Commodore ClipperVaughn MonroeVaughn Monroe.....DoloresInto the Mystic (#474)Vaughn MonroeI Wish I Didn't Love You SoMy DevotionVaughn MonroeVaughn MonroeSomeday (You'll Want Me to Want You)There! I've Said It AgainVelvet UndergroundHeroin (#455)Velvet UndergroundI'm Waiting For The Man (#161)Velvet UndergroundSweet Jane (#342)Walker BrothersThe Sun Ain't Gonna Shine AnymoreYours LoveGame of LoveWaylon JenningsWayne Fontana & The MindbendersWe FiveWebb PierceWill BradleyWillie DixonWilson PickettWilson PickettYou Were on My MindI Ain't NeverThere I Go29 Ways634-5789Don't Fight It34 of 35Schedule ARepresentative List of Plaintiffs' Pre-1972Sound Recordings Infringed by PandoraTitleArtistWilson PickettWilson PickettWilson PickettWilson PickettWilson PickettWilson PickettWoody HermanWoody HermanDon't Knock My Love - Pt. 1Don't Let The Green Grass Fool YouEngine Number 9In the Midnight Hour (#135)Mustang Sally (#441)Sugar SugarApple HoneyNorthwest PassageXavier CugatYesMy ShawlLong Distance RunaroundYesStarship TrooperYesYoungbloodsYours Is No DisgraceRide The Wind35 of 35