ATLANTA (CN) – The statute of limitations bars some claims a music producer hoped to press over its recording agreement with rapper Yung Joc, a federal judge ruled.
Yung Joc, born Jasiel Robinson, signed an artist development and exclusive recording agreement with Atlanta-based independent music producer Master Mind Music in 2005.
The agreement gave Master Mind exclusive rights to all master recordings Yung Joc created during the term of the agreement. This included the right for Master Mind to copyright Yung Joc’s recordings in its name, and co-ownership of the compositions.
Master Mind could collect 50 percent of revenues generated by Yung Joc’s music while the agreement was in effect.
“It’s Goin’ Down,” the first single on Yung Joc’s debut hip-hop album, which Master Mind allegedly supported, attracted the attention of music distributors like Block Enterprises and Sean Combs’s Bad Boy Records, Master Mind says.
Master Mind then signed an agreement with Block, which obligated Block to secure distribution for Yung Joc’s recordings in exchange for 50 percent of any revenue generated by that agreement.
Block had the authority to negotiate a distribution agreement, but did not receive rights to Yung Joc’s exclusive recording services or to his compositions.
Nevertheless, Master Mind claimed that Block later transferred the exclusive recording rights and copyright interests in all of Yung Joc’s recordings to Bad Boy Records and Atlantic Recording Corp., without including Master Mind in the negotiations.
Yung Joc agreed to the terms of the distribution agreement, Master Mind said.
Bad Boy and Atlantic released Yung Joc’s debut album, “New Joc City,” in June 2006, and sold more than 1 million copies. The following year, they released Yung Joc’s second album, “Hustlenomics.”
Master Mind claimed Bad Boy and Atlantic gave Block recording funds for the two albums, but failed to pay Master Mind under their agreement and failed to disclose information about the revenue the albums generated.
After a state court dismissed its two previous lawsuits against Block, Master Mind filed a January 2012 federal complaint against Block and the distributors.
Master Mind, who registered copyrights to Yung Joc’s albums the same month, alleged copyright infringement, conversion, fraud and other claims.
Block, Bad Boy and Atlantic asked the court to dismiss Master Mind’s claims as time-barred under Georgia law.
U.S. District Judge Richard Story agreed that Master Mind had waited too long to assert most of its claims.
Master Mind’s ownership of the copyrights, which is fundamental to its infringement claim, is disputed, Story found, noting that Bad Boy had registered its copyrights to the albums in 2006 and 2008.
Story found that the statute of limitations bars Master Mind’s copyright infringement claim against Block, as well as claims for tortious interference with contract, fraudulent misrepresentation and fraud.
Master Mind knew about its supposed injuries as early as 2006, when the defendants released Robinson’s first album without crediting Master Mind as co-producer or copyright owner, and without paying it, the judge found. Yet it failed to file its federal lawsuit before the statutes of limitations expired, according to the 27-page ruling.
What’s more, Master Mind cannot assert a conversion claim based on “funds of an unknown amount from advances, royalties, revenue or profits,” the ruling states.
Story denied Master Mind’s request for an accounting, finding it unlikely that such relief will reveal an amount of money to which Master Mind is entitled.
Master Mind may still pursue its breach of contract, accounting and punitive damages claims against Block, according to the ruling.
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