When Robert Smith (aka Bigg Robb) recorded his song Looking for a Country Girl, he probably was not looking for a legal battle, too. But Bernard Thomas (aka Bishop Bullwinkle) copied the beat from Smith’s song to make a new one—called Hell 2 Da Naw Naw—and suddenly became famous. Understandably upset at his work being copied, Smith informed Thomas of the issue and attempted to negotiate a resolution. When that failed, he sued and won. On appeal, Thomas seeks to vacate Smith’s damages award based on an overly-proceduralized interpretation of the Copyright Act. We reject Thomas’s interpretation and affirm Smith’s award.
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