In a case before Judge Mastroianni, Ronald Satish Emrit filed a pro se complaint against rapper Rick Ross, his record label Def Jam Group, Universal Music Group (which owns Def Jam), and the estate of Shakir Stewart, the A&R agent who signed Ross to Def Jam, accusing them of copyright infringement in connection with Ross’ song “Billionaire.” Emrit, performs as “Satish Dat Beast,” asserts that the Ross song utilizes the same backing track as his song “Dilemma.” Emrit says that “Dilemma” was distributed by Tunecore and Ditto Music, music distribution services that assist independent artists in selling their music through on-line retailers like iTunes, Tik Tok, Amazon Music and the like. “Billionaire” was released in 2008; the complaint does not allege dates on which “Dilemma” was recorded or released. In addition to the copyright claim, Emrit brings counts for conversion, which seems unlikely as the complaint does not allege that anything physical was taken, and tortious interference with business relations and with contracts, which also seem questionable as no particular business relations or contracts are identified as having been impaired. Further, it is entirely unclear why the complaint was filed in Massachusetts or why personal jurisdiction exists over the defendants – Emrit suggests that he might move to Massachusetts in the near future, but currently resides in Florida, and none of the defendants are alleged to reside in this state. In addition to damages, Emrit seeks an order mandating that Def Jam and/or Universal sign him to a recording deal.
Emrit is well-known to the federal court system – one federal judge stated that “other courts have taken note of Plaintiff’s extensive and abusive litigation practices” and noted that Emrit has been deemed a vexatious litigant in multiple district courts. Further, Emrit has already sued the same defendants in the Middle District of Florida, the Central District of California, and the Northern District of Iowa, all within the past month. I would note, however, that while the complaint does have issues with jurisdiction, lacks an express allegation that “Dilemma” pre-dates the accused song, and with the non-copyright counts, the backing tracks of the two songs do strike me as remarkably similar.