A Manatt team led by entertainment litigation partner John Gatti successfully secured a $450,000 judgment on behalf of iconic songwriter and recording artist Tracy Chapman in her copyright infringement suit against well-known rapper Nicki Minaj. On January 15, 2021, Judge Phillips of the United States District Court entered judgment in favor of plaintiff Tracy Chapman and against defendant Nicki Minaj on Chapman’s copyright infringement claims.
The suit (Chapman v. Maraj) was based on Minaj’s unauthorized use of Chapman’s musical composition and lyrics “Baby Can I Hold You” in Minaj’s recording (featuring Nas) “Sorry.” Through her representatives, Minaj sought Chapman’s permission to use the song after Minaj’s song had been recorded, but Chapman denied the request. Notwithstanding Chapman’s request denial, Chapman asserted that Minaj improperly distributed the infringing work in violation of copyright law. The action was necessary to redress Minaj’s disregard and willful infringement of Chapman’s intellectual property rights under the Copyright Act and to protect Tracy Chapman’s and all artists’ creative rights.
The Manatt team representing Chapman also included senior partner Lee Phillips and associate Lauren Fried.
This case and its judgment in favor of Tracy Chapman has received significant media coverage due to its potential impact on artists and how they can use sampled compositions. Publications that covered this case include: The Hollywood Reporter, The Wrap, The Independent, Bloomberg Law, Pitchfork, Blavity, Law360, Rolling Stone and NBC New York, among others.