Bridgeport Music, Inc. v. Dimension Films is a very significant case in the field of copyright law for recorded music. Focusing on the relationship between the digital sampling of copyrighted music and copyright infringement, this case centers on two different songs: Hip Hop group N.W.A.'s "1000 miles and Runnin" and Funkadelic's "Get Off Your Ass and Jam." N.W.A. sampled a two-second guitar chord from Funkadelic's song, lowered the pitch of that chord, and used the sample five times in their "1000 miles and Runnin." Bridgeport Music, Inc., which owns the copyright to Funkadelic's music, had not given N.W.A. permission to sample the tune, and since no compensation was paid to Bridgeport, they filed charges and brought the issue to district court.
This case can be viewed in essentially two parts-the case was first heard in district court, and following that decision, an appeal was made and the case was revisited in appellate court. The district court case will be examined in this post.
In response to charges of copyright infringement, the defense did not deny that their song contained the alleged infringing sample- rather they claimed the copying was 'de minimis' and as a result, not legally significant.In reference to this case, de minimis refers to the defense that the alleged copyright infringer sampled such a small part of the tune that it is insignificant.
Ralph B. Guy, circuit Judge who gave the opinion in the appellate court, reflected on the district court's view of the defense:
"In granting summary judgment to defendant, the district court looked to general de minimis principles and emphasized the paucity of case law on the issue of whether digital sampling amounts to copyright infringement. Drawing on both the quantitative/qualitative and "fragmented literal similarity" approaches, the district court found the de minimis analysis was a derivation of the substantial similarity element when a defendant claims that the literal copying of a small and insignificant portion of the copyrighted work should be allowed."
Citing de minimis, along with the facts that the sampled song sounded entirely different from the original and the qualitative differences between the songs were so great, the district court dismissed Bridgeport's claim of copyright infringement on September, 7 2004.
The ruling of the district court doesn’t hold significant legal ramifications as the judge was merely following precedent by citing de minimis. The real significance of this case arises from the appellate court’s decision, which came after Bridgeport appealed the decision of the district court.
Sources:
http://cip.law.ucla.edu/cases/case_bridgeportmusicstillnthewaterpublishing.html
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