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GRADSTEIN & MARZANO, P.C.
I{ENRY GRADSTEIN (State
Bar No. 89747)
Telephone: 323 -7 7 6-3100
Facsimile: 323 -931 -4990
Attomeys for Plaintiff
QUINCYJONES
QUINCY
JONES, an individual and d/b/a
QUTNCY
JONES PRODUCTIONS,
MJJ PRODUCTIONS,INC., a Califomia
corporation; SONY MUSIC
ENTERTAINMENT, a
Delaware general
parhenhip; and DOES 1 through 50,
Defendants.
0).**SlL"fiP.,.""..
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heradstein@qradstein.com
MARYANN R. MARZANO (State BarNo. 96867V\v
mmarzano@cradstein.com r , {l/
6JT0San nregtva,Suitesto
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Los Angeles, Califomia 90048
ocl
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Case No.
BCSeSB0s
COMPLAINTF'OR:
(1) BREACHOFCONTRACTDATED
AS OF NOVEMBER 1, 1978;
(2)
BREACIIOFCONTRACTDATED
AS OF DECEMBER 1' l9E5; end
(3) ACCOUNTING.
DEMAND FORJTJRY TRIAL
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STJPERIORCOURT OF TTIE STATE OF CALIFORNIA
COI]NTY OF LOS ANGELES

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PlaintitrQLJINCY JONES, individually and d/b/a
QUINCY
JONES PRODUCTIONS,
hereby alleges against Defendants, as follows:
PARTIES
l. PlaintitrQUINCY JONES ("Jones"), individually and d/b/a
QUINCY
JONES PRODUCTIONS
C'QJP),
is an individual who, at all relevant times, has resided
in the State of Califomi4 County of Los Angeles.
2. Jones is informed and believes, and based thereon alleges, that MJJ
PRODUCTIONS, INC.
C'MJJ)
is a Califomia corporation with its principal place of
business in North Hollywood, Califomia-
3. Jones is informed and believes, and based thereon alleges, that SONY
MUSIC ENTERTAINMENT ("Sony') is a Delaware general partnership with a
principal place of business at 9830 Wilshire Blvd., Beverly Hills, Califomi4 and that
Sony was fomrerly known as CBS RECORDS, INC.
4- The true names and capacities ofthe Defendants named in this action as
DOES I through 50 are unknown to Jones, who therefore sues them by such fictitious
names. Jones alleges, upon information and belief, that such Doe Defendants
participated in the actions ofor conspired with Defendants to commit the wrongfirl acts
herei4 and to the extent that Jones identifies Doe Defendants involved in the transactions
alleged herein, he will amend this Complaint to set forth their tue names and capacities.
FACTS COMMON TO ALL CAUSES OT ACTION
5. Jones is considered one ofthe preeminent supentar producers in the
music industy, with a reputation for producing the highest quality master recordings and
some ofthe best-selling records in history. His career spans over six decades in the
entertairment industry, arecord,19 Grammy Award nominations, and 27 Gramrny
Awards, including a Grarnmy Legend Award in I 99 1 . Jones had provided services as a
producer, arranger and musician for artists such as Frank Sinatr4 Ella Fitzgerald, Dinah
Washington and many others. Jones utilizes
QJP
to perform his production,
entertrainment and/or other services and to own and exploit certain entertainment assets.
COMPLAINT

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6. MJJ is a music record label founded by Michael Jackson (..Jacksod').
Jackson was one ofthe most prominent
recording artists ofhis generation,
with a long
back record of some of the best-selling records in history. Jackson's career started in or
about 1964 with the band "The
Jackson Brothers," which shortly thereafter became
known as "The Jackson 5." The group has sold over 100 million albums.
7. In or about 1978, Jackson staned in the motion picture adaptation ofthe
musical entitled
"The Wiz." Jones was one of the composers of the music for The Wiz,
and built a relationship with Jackson during the production
of this motion picture.
Jackson and Jones were excited to work together. MJJ (as
successor in interest to The
Jackson Five, Inc.), fumishing the services of Jackson, entered into an agreement wittl
Jones d/b/a
QJP
dated as ofNovember l, 1978 (the
..1978
Agreement,,, a true and conect
redacted copy of which is attached hereto as Exhibit A, and incorporated herein by
reference) for Jones to produce
all of the master recordings to be embodied on Jackson's
upcoming fifth studio album (the
"OTW Masters") to be released by Sony, which
became the 1979 album entitled "Off The Wall" (the.,OTW
Album"). Sony has sold
approximately 20 rnillion copies of the OTW Album.
8. Pursuant
to the terrrs ofthe 1978 Agreemen! Jones had the option to
produce
all ofthe master recordings to be embodied on the next studio album after the
orw Album feah'ing Jackson's perforrrances,
and Jones tirnely exercised such option
on October 25, 1979. Jones produced
all of the master recordings on Jackson,s next
album (the
"Thriller Masters'), Jackson's sixth studio album entitled
"Thrillef,
(the
"Thriller Album"), which sony commercially released in 19g2. The Thriller Album has
been cited to have sold in excess of66 million albums worldwioe, purportedly
the
highest selling album ofall time.
9. After the tremendous success of both the OffThe Wall Album and the
Thriller Album, Jackson and Jones wanted to continue their incredibly successfirl
partnenhip.
MJJ, fumistring the services of Jackson, entered into an agreement with
Jones d/b/a
QJP
dated as ofDecember l, l9g5 (the
"19g5 Agreement
" a true and corrcct
COMPLAINT

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redacted copy of which is attached hereto as Exhibit B, and incorporated herein by
reference) to
produce
all ofthe master recordings to be embodied on Jackson's seventh
studio album (the'Bad Masters") entitled'Bad" (the "Bad Album,) for its release by
Sony. Sony commercially released the Bad Album in 1987 and sold approximately 30
million albums worldwide. The Bad Album is cited as one of the 20 best-selling albruns
of all time.
10. The 1978 Agreement and the 1985 Agreement are individually and
collectively referred to as the "Agreements." The OTW Master, Tbriller Masters and
Bad Masters arc sometimes individually and collectively refened to as the
.Masters."
The OTW Album, Thriller Album and Bad Album are individuallv and collectivelv
referred to as the "Original Al$ums."
I 1. In order to protect and safeguard his reputation, Jones required in each of
the Agreements the following: (a) thar
he be given the fust opporhrnity to re-edit and/or
re-mix any of the Masters;
ft)
that for singles, the coupling of Masters with other master
recordings required Jones' prior written coDsnt; and (c)
that he be
given producer
credit
for each ofthe Masters. Furtherrnore, the restriction on re-ediring and/or re-mixing the
Masters constituted additional compensation to Jones under each ofthe Agreements: If
IU.JJ wanted one (l) or more of the Masters re-edited or re-mixed, MJJ would have had to
pay Jones for such services at his fair market rate, which would have included both an
upfront payment
and a so-called
"backend," consisting ofa percentage
ofthe receipts
derived from the exploitation ofthe audio and/or audio-visual works embodying such re-
edited and/or re-mixed Masters (the
"Re-Mixing Fees").
12. The Ageements also provide,
among other things, that MJJ shall: (a)
pusuant to paragraph 4 of each ofthe Agreements, pay to Jones royalties for the
commercial exploitation of the Masten in records, including, without limitatioq
phonorecords; (b) punuant to paragraph
5 ofeach of the.Agreemetrts,
cause Sony to
account directly to Jones under Jackson's recording agreement with Sony for the
royalties set forth in paragraph
4 ofthe applicable Agreement; (c) pursuant to paragraph
CQMPLAINT

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7 of each of the Agreements, account to Jones for such royalties if Sony does not do so;
(c) pursuant
to paragraph
9 of each of the Agreements, grant to Jones the right to approve
Jones' likeness and biographical material in connection with the exploitation ofthe
Masters; and (d) pursrunt to paragmph
12 ofthe 1985 Agreenent, pay to Jones royalties
for the commercial exploitation of the Masters in audio-visual works.
13. Jones is informed and believes, and based thereon alleges, that Jackson
entered into various exclusive recording agreements with Epic Records, a subsidiary of
Sony (formerly known as CBS Records, Inc.), dated, among others, May 28, 1975,
February 25, 1981, June 20, 1985, June 16, 1992 and April l, 1994, as such agreements
may have been amended or othenvise modified (individually
and collectively, the
"Recording Ageements").
14. Jones is infonned and believes, and based thereon alleges, that the
Recording Agreements provide,
among other things, the following (the
,.producer
Terms"): (a)
Sony shall regularly account and make payments
ofproducer royalties to
the producers of the master recordings subject to the Recording Agreernents (the
"Producers');
@)
Sony shall accord credit to the Producers on record labels, album
jackets
and liner notes, cassette packaging
and in all advertising, billboard, print media
and television advertising; and (c) Sony shall grant the Producers designated by Jackson
the right to approve such Producers' likeness and biographical material.
15. Jones is informed and believes, and based thereon alteges, that Sony at
least partially complied with the Producer Terms in connection with the Masten
produced by Jones by (a) regularly accounting and making payments
ofproducer
royalties to Jones for the Masten as embodied on each of the Original Atbums; (b)
according Jones oedit as the producer
of the Masters on physical
copies of each ofthe
Original Album's albw
jackeq
liner notes and cassefte packaging;
and (c) granting
Jones the right to approve his likeness and biographical material used in connection with
the commercial exploitation of each of the Original Albums.
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COMPLAINT

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16. Pursuant to Califomia Civil Code
$
1559 and Califomia case law, Jones,
as one ofthe Producrs, is an intended third party beneficiary of the Recording
Agreements, notwithstan<ling any boilerplate language in the Recording Agreements to
the contary: The terms of the Recording Agreements necessarily r4uire that Sony
confer benefits to the producers
ofthe master recordings subject to the Recording
Agreements. Additionally, Sony's performance
of the hoducer Terms (obligations Sony
had agreed to perform on behalf of tvlJJ) discharges legal obligations MJJ has to
producrs, including Jones, under producr
agreements, includhg the Agreements.
17. Jackson died on June 25, 2009. Unfortunately, after Jackson's deat\
those in charge ofJackson's entities, including MJJ, began comnercially releasing new
audio and audio-visual works without regard to the tenns of either ofthe Agroements.
18. On or about October 28,2009, AEG Live and The Michael Jackson
Company, LLC, through their distributor Columbia Pictures, commercially released
worldwide a motion picture entitled
"This Is It" (the
"Film '). The Filrn has been cited as
currently being the highest grossing
concert movie and documentary in the history of
cinema. The Fikn has been disnibuted to theaters, home video renters and retailers,
premium cable television services, and digital distibutors, including over the lntemet
and via smartphone or other mobile devices.
19. On or about October 26,2009,WJ commercially released a soundhack
album to the Film, which was distributed worldwide by Sony (the
..Film
Soundtrack
Album"). The Fihn soundtrack Album has been commercially disnibuted physically
to
retail stores and online retailers such as Amazon.com,
and digitally to on_line retailers
such as Apple iTunes and Amazon Mp3.
20. On or about October 2, 201 I, Cirque du Soleil premiered
the traveling
theatrical audio-visual production
entitted
"Mchael Jackson: The lnmortal world
Tour" (the
"Immortal Production'). Jones is informed anid believes, and based tlereon
alleges that the Immortal Production is a worldwide tour that is cunently scheduled to
perfomr
approximately
336 shows tbrough 2014, at venues such as The Staples center in
COMPLAINT

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to over 2
million audience members and is cited as the highest gossing
tour in the Unitd States in
2012.
21. On or about November 18, 2011, MJJ conmercially released a soundEack
album to the Immortal Production embodying the knmortal Masters, which album was
distributed worldwide
by Sony (the
"Immortal Soundtack Album"). The Lnmoral
Soundtrack Album has been commercially
distibuted physically
to retail stores and
online retailen such as Amazon.com, and digitally to online retailers such as Apple
iTunes and Amazon MP3.
22, On or about May 23, 2013, Cirque Du Soleil premiered
the theatrical
audio-visual production
entitled "Michael Jackson: one" at the Mandalay Bay casino
and Resort in Las Vegas (the
..One
production').
23. Jones is infonned
and believes, and based thereon
alleges, that with MU,
Jackson or an affiliate or related entity of MJJ aod/or Jackson (individually
and
collectively, the 'Tackson
party')
secretry entered into a venture agreement with sony (or
its entities or affrliates) (the
"sony-Jackson venture Agreement'), pursuant
to which
Sony would distribute
the Jackson Party's
record label (the..Jackson
Label,'), and Sony
and the Jackson Label would share the profits
from master recordings
commercially
released
by such Jackson
laber. Jones is informed and believes, and based thereon
alleges, that the rights in and to the Masters reverted fiom Sony to MJJ, subsequent
to
which MJJ caused
the albums featuring
the perfomrances
of Jackson
to be distributed
by
the Jackson Label, instead of Sony, including albums embodying
one or more of the
Masters. Jones is informed
and believes,
and based thereon alleges, that the Sony_
Jackson Venture Agreement
diverts revenues
to MJJ in corurection
with the reproduction,
use or other exploitation
ofthe Masters, disguised such diverted revenues
as
,lrofits"
instead of"royalties" (the
..Disguised
Royalties").
By removing
such Disguised
Royalties from the pool
of revenues
upon which Jones, royalties
are calculated,
MJJ
purposely
reduces
the royalties (and
of
.Net
Receipts,, as defined in subparagraph
COMPLAINT

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12[a][ii] ofthe 1985 Agreement) payable to Jones under both ofthe Agreements.
24. Jones is inforrred and believes, and based thereon alleges, that Sony (or
its entities or affiliates) secretly entered into an agreement with the producers
ofthe Film
in connection with the masters used in the Filrn (including, without limitation, the OTW
Filn Masters, Thriller Filrn Masten and Bad Filn Masters
[individually
and collectively,
the "Film Masters"l) (the
"Sony-Film Agrcement').
Jones is informed and believes, and
based thereon alleges, that although the only rights licensed to ths Fihn producers
under
the sony-Fitn Agleement were the rights to use certain master recordings owned and/or
controlled by Sony in the Film (including,
without lirnitation, the Film Masters), the
Sony-Fikn Agreement
divides the compensation payable
to Sony into one portion
designated for the master use ricenses (the
"Master use License Fees,) and another
portion paid directty to MJJ (the
"Additional Fees,').
Jones is informed
and believes, and
based thereon alleges, that: (a)
alr ofthe compensation
under trre sony-Film
Agreemen!
including
both the Master Use License Fees and the Additional
Fees, represent
the
compensation payable
to Sony for the right to use the master recordings (including
the
Film Masten) in the Fikn; (b)
the Master use LicBnse Fees do not represent
the fair
market value, negotiated
in good
faitll to license the masters used in the Filrn (including
the Film
Mashn) in the Film and F'm
soundtrack
Album; and (c) the designation
and
payment
of Additional
Fees purposery
reduce the computation
ofroyalties (and
of
.Net
Receipts"
as defiaed in subparagraph
l2[a][ii]
ofthe 1gg5 Agreement) payabre
to Jones
under the Agreements.
25. The Sony-Jackson
Venture
Agreemenr
and the Sony-Filn
Ageement
are
sometimes
individually
and co ectively referred
to as the
.,crandestine
Agreements.,,
FIRSTCAUSE
OFACTION
@reach of Written
Contrecrt
dated as of November
l, 197g
Against
MJJ and Does l-25)
26. Jones repeats
and realleges,
and incorporates
herein
by reference,
the
allegations
set forth in paragaphs
r tt'ough
25 above, as thouh
fi-rlly set forth herein.
COMPLAINT

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27. The 1978 Agreement is a valid, enforceable contact betwen Jones d/b/a
QJP
and MJJ (as successor-in-interest
to The Jackson Five, Inc.), which provides
the
following:
(a).
Paragraph
2 states, in pertinent part:
"We shall provide
rhat EPIC
[Sony]
shall not have any other
person
re-mix or re_edit any MaSers produced
by you
[Jones]
hereunder
without first providing
you
lJonesl
with a reasonable
oppornrity
to perfomr
such re-mixing and/or re-editing
as EpIC
[Sony]
shall require."
(b).
Additionally,subparagraph4(a)(iii)states:
"lheroyalties payable
to you
[ones]
hereunder
shall othenuise
be
calculated, prorated
and reduced
I
in the same manner as the
royalties payable
to Artist with respect
to such sales are so pro-
rated,
calculated
and.reducgd,
We shall provide you ponesl
with
the applicable
provisions
of.the Recording
Agreement
regarding
these matrers. Nolwi
],standing
the forgotgjf
any Uaster
hereunder
is embodi-ed
on a single rvitl-othJi
m^t". recordings
(whic-h
cou-pling
shall.require
your pones,l
prior
written.o
ZnO,
you pones]
shall receive
the otherwise
applicable
royaty rate
hereunder,
which
shall not be reduced
by such oth"r masrc,
recordings."
(c).
Thirdty, paragraph
g
provides:
"We shall cause EpIC
[Sony]
to insure that you
[Jones]
receive
appropriate
production-credit
on record labeis, altum jackets
and
liner notes
and in all advertising,
including
tade advertising,
billboards,
television
and print
media . . .;
28. Jones has performed
all or substantially
a[ ofhis contactual
obligations
under the 1978 Agreement,
or was prevented
or excused
therefrom
by the actions of
Defendants.
29.
MJJ has breached
the lg7g Agreement
in connection
with the Film, the
Film Soundtrack
Album, the Immorfal
production,
the
'nmortal
Soundback
Album, the
One koduction,
the Sony-Jackson
Venh'e
Agreement
and the Sony-Fi'n
Agreement,
as
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COMPLAINT

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30. Jones is infonned and believes, and based thereon alleges, that the
following Masten from the OTW Album, which were subject to the terms of paragraph 2
ofthe 1978 Agreemenl were re-edited and te-mixed, and, as subsequenfly modified are
embodied in the Film anrVor the Film Soundtack Album (the
'OTW Film Masters"): (a)
"Don't Stop 'Til You Get Enough;" and
@)
"She's Out Of My Life."
31. Jones is informed and belibves, and based thereon alleges, that the
following Masters from the Thriller Album, which were subject to the trms of paragraph
2 ofthe 1978 Agreement, were re-edited and re-mixed, and, as subsequently modified,
are embodied in the Fikn and/or the Fibn Soundhack Album (the "Thriller Film
Masten'): (a)
"Wanna Be Sudin' Somethin'i'
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"Thriller;" (c)
"Beat Iri' and (d)
' Billie Jean."
32. Jones is informed and believEs, and based thereon alleges, that the OTW
Film Master entitled
"Don't Stop
'Til You Get Enough" was re-mixed and re-edited for
the Film and/or the Filn Soundtrack Album by:
(a)
sampling and combining this OTW
Film Master as part of the master recordhg entitled "Shake Your Body
@own
To The
Ground}" (b) removing the vocal tacks and performing this OTW FiLn Master as an
instrumental work mixed with backing vocalists singing the choruq and (c)
other
alterations that will be proven at tial.
33. Jones is informed and believes, and based thereon alleges, that the Thriller
Film Master entitled "Wanna Be Startin' Something" was re-mixed and/or re+dited for
the Filrt and/or the Filn Soundtack Album by:
(a)
editing out the third verse; (b)
making a new recording bfthe first verse; (c) adding new lyrics from a different song by
Jackson in a transposed key; (d) removing the vocal tracks and adding live vocals; and
(e)
other alterations that will be proven
at trid.
34. Jones is infonned and believes, and based thereon alleges, that the Thriller
Fikn Master entitled "Thriller" was re-mixed and/or re-edited for the Fitm and/or the
Fihn Soundtack Album by: (a) embodying samples from other master recordings; (b)
COMPLAINT
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removing the into ftom the Master; (c)
removing one or more of the Vincent Price rap
verses; (d) removing the vocal hacks and adding dubbed vocals; and (e)
other alterations
that will be proven
at trial.
35. Jones is informed and believes, and based thereon alleges, that the Thriller
Film Master entitled "Beat It" was re-mixed and/or re-edited for the Film and,/or the Film
Soundfiack Album by: (a) editing out various parts ofthe Master, including, without
lirnitatio4 the second verse; (b) removing the vocal tacks and adding live vocals; and (c)
other altemtions that will be proven at trial.
36. Jones is informed and believes, and based thereon alleges, that the Thdller
Film Master entitled "Billie Jean" was re-mixed and/or re+dited for the Fikn and/or the
Filrn Soundtrack Album by: (a) removing the vocal tacks and adding both dubbed
vocals from other demo versions ofthis Master and live vocals; and (b)
other alterations
that will be proven at hial.
37. Jones is informed and believes, and based thereon alleges, that the Tbriller
Fikn Ma*er entitled "Smooth Criminal" was re-mixed and/or re-edited for the Film
and/or the Film Soundtrack Album by: (a) editing out the fint and third verse; (b)
making a new recording ofthe fust vene; (c) adding new lyrics from a different song by
Jackson in a tansposed key; and (d) other allerations that will be proven at trial.
38. IvIJJ materially breached its obligations under the 1978 Agreement by
permitting each of the OTW Fihn Masters and Thriller Filn Masters to be re-mixed
and/or re-edited by third parties for commercial release and exploitation in connection
with the Film without first providing a reasonable opportunity to Jones to perform such
re-mixes and/or re-edits.
39. MJJ materially breached its obligations under the 1978 Agreement by
permitting each of the OTW Filrn Masters and Thriller Film Masters to be re-rnixed
and/or re-edited by third parties for commercial release and exploitation in connection
with the Film Soundtack Album without first providing
a reasonable opportunity to
Jones to perform
such re-mixes and/or re-edits.
l0
COMPLAINT

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40. Jones is informed and believes, and based rhereon alleges, that MJJ
materially breached the 1978 Agreement by failing to accord Jones producer
credit as
required pursuant
to the 1978 Agreement for each of the OTW Film Masters and Thriller
Filn Masters in connection with the exploitation of the Film.
41. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1978 Agreement by failing to account and pay to Jones all
royalties otherwise payable
under the 1978 Agreement for each ofthe OTW FiLrn
Masters and Thriller Film Masters in connection with the Film.
42. Jones is informed and believcs, and based thereon alleges, that MJJ
materially breached tlre 1978 Agreement by failing to account and pay to Jones all
royalties otherwise payable
under the 1978 Agreement for each ofthe OTW FiLn
Masters and Thriller Filn Masters in connection with the Fikn Soundnack Album.
Michael Jackson: The Immortal World Tour
43. The following Masters from the OTW Albu& which were subject to the
terms ofparagraph 2 of the 1978 Agreement, were re-edited and re-mixed, and, as
subsequently modified, are embodied in the Immortal Production and./or the Imnortal
Soundtrack Album (the
"OTW Irnrnonal Masten"): (a)
"Get On The Floor;" (b)
.,Rock
With You;" (c) "Bum The Disco Out;" (d)
"Workin' Day and Night;" and (e)
,Don't
Stop 'Til You Get Enough."
44. The following Masten from the Tbriller Album, which were subject to the
terms ofparagraph 2 ofthe 1978 Agreement, were re-edited and re-mixed, and, as
subsequently modifid are embodied in the Immortal hoduction and/or the Imrnortal
Soundtrack Album (the
"Thriller knmortal Masters'): (a)
'P.Y.T.
(Pretty Yormg
Thing)";" (b)
"Baby Be Mine;" (c)
"Warura Be Startin' Somethin'i' (d) "Human
Naturei' (e)
"Thriller;" (f1
"Beat Iti' and (g)
"Billie Jean."
45. Jones is informed and believes, and based thereon alleges, that each ofthe
OTW Inunortal Masters and Thriller Irnmortal Masters was re-mixed and/or re-edited to'
qeate
new pre-recorded music to accompany the Immortal Production (most
of which
COMPLAINT

I
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are also embodied in the Immortal Soundtrack Album) by, among other things: (a)
overlaying multiple songs together and editing them in a way as to connect them for
medley sequences; (b)
changing tempo; (c)
changing pitch; (d)
adding or removing
verses; (e) adding additional musical elements; and (f) other alterations that will be
proven at trial. The OTW Immortal Masters and Thriller Immortal Masters were re-
edited and,/or re-mixed without Jones' consent.
46. MJJ commercially teleased each of the OTW Immortal Masters and
ThLriller Immortal Masters embodied on the knmortal Soundhack Alburn as a single,
available for purchase
as a single through various digital distibution retailers, including,
without limitation, Apple iTunes.
47. Notwithstanding the tenns of subparagraph 4(a)(iii) ofthe 1978
Agreement, MJJ commercially released as a single the Tbriller Immortal Master entitled
"Human Nature" coupled with the maser recording entitled
"Speechless." MJJ never
asked for nor obtained the prior written consent of Jones for the coupling of the "Human
Nature" Thriller Immortal Master with the master recording entifled "Speechless."
Additionally, notwithstanding the terms of subparagraph 4(a)(iii) ofthe 1978 Agreemen!
Jones' royalty rate for such Ttriller Immortal Master was reduced by the coupling with
the other master recording.
48. Notwithstanding the terms ofsubparagraph 4(a)(iii) ofthe l97S
Agrcement, MJJ commercially released as a single the Thriller lmmortal Master entitled
"Beat It" coupled with the master recording entitled "State ofShock" and the Bad
Lnmortal Master entitled
"Bad." MJJ never asked for nor obtained the prior written
corisent of Jones for the coupling of the "Beat It" Thriller Immortal Master with either
the master recording entitled "State of Shock" or the Bad Lnrnortal Master entitled
"Bad." Additionally, noturithstanding the terms of subparagraph 4(a)(iii) ofthe 1978
Ageement, Jones' royalty rate for such Thriller Immortal Master was reduced by the
coupling with the other master recordings.
COMPLAINT
-l

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6
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49. Notwithstanding the terms of subparagraph 4(a)(iii) ofthe l9?8
Agreement, MJJ commercially released the master recording entitled "lmmortal
Megamix" as a single, which coupled various master recordings together, including,
without limitation, the OTW Immortal Master entifled "Don't Stop
.Til
You Get
Enough" and the Thriller Immortal Master entitled "Billie Jean." MJJ never asked for
nor obtained the prior written consent ofJones for the coupling ofeither the
,.Don,t
Stop
'Til You Get Enough" OTW Imnortal Master or the
*Billie
Jean" Thriller Immortal
Master as part of the master recording entitled "Immortal Megamix." Additionally,
notwithstanding the terms of subparagraph 4(a)(iii) of the I 978 Agreement, Jones'
royalty rates for both such OTW hnmortal Master and Thriller Immortal Master were
reduced by the coupling with the other master recording.
50. MJJ materially breached its obligations under the 1978 Agreement by
pennitting
the OTW Immortal Masten and the Thriller Irnmortal Masters to be re-mixed
and/or re-edited by third parties for cornmercial rlease and exploitation in connection
with the Immoral Production without fust providing a reasonable opportunity to Jones to
perform
such re-mixes and/or re-edits.
5 I . MJJ materially breached its obligations under the I 978 Agreement by
permitting the OTW Immortal Masters and the Thriller Masters to be coupled with other
master recordings as part of commercially released singles.
52. MJJ materially breached its obligations under the 1978 Agreement by
reducing Jones' royalties on Masters coupled with other master recordings.
53. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1978 Agreement by failing to accord Jones producer credit as
required pursuant to the 1978 Agreement for each of the OTW Immortal Masters and
I
Thriller Immortal Masten in connection with the exploitation of the Lnmortal
Production.
54. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1978 Agreement by failing to account and pay
to Jones all
COMPI.AINT

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royalties otherwise payable
under the 1978 Agreement for each ofthe OTW Immortal
Masters and Thriller Immortal Masters in connection with the Immortal Production.
55. Jones is infomed and believes, and based thereon alleges, that MJJ
materially breached the 1978 Agreement by failing to account and pay to Jones all
royalties otherwise payable
under the 1978 Agreement for each of the OTW Irnmortal
Masters and Thriller Irnmortal Masters in connection with the Lnmortal SoundEack
Album.
Michrel Jackson: One
56. The following OTW Masters, which were subject ro paragraph 2 ofthe
1978 Agreemen! were re-edited and re-mixed, and, as subsequently modified, are
embodied in the One Production (the
"OTW One Masters,,): (a)
,,Workin'
Day and
Night;" and (b)
"Don't Stop
'Til
you
Get Enough.',
.
57. The following Thriller Masters, which were subject to paragraph
2 ofthe
1978 Agreement, were re-edited and re-mixd and as subsequently modifie4 are
embodied in the One Production (the
"Thriller One Maste6"): (a)
..Beat
lti'
O)
..Human
Nanre;" (c)
"Wanna Be Startin' Somethin';" (d)
'Billie Jean;" and (e)
.,Thriller."
58. MJJ materially breached its obligations under the l9Z8 Agreement by
pennitting each of the OTW One Masters and Thriller One Masters to be re-mixed
and/or re-edited by third parties
for commercial exploitation in connection with the One
Production without first providing a reasonable opportunity to Jones to perform
such re-
mixes and/or re-edits.
59. Jones is informed and believes, and based thereon alleges, that MJJ
materially bieached the 1978 Agreement by failing to accord Jones producer
credit as
required pursuant to the 1978 Ageement for each of the OTW One Masters and Tbriller
One Masters in connection with the exploitation of the One Production.
60. Jones is informcd and believes, and based thereon alleges, that MJJ
materially breached the 1978 Agreement by failing to account and pay to Jones all
royalties otherwise payable
under the 1978 Agreement for each of the OTW One Masters
14
COMPLAINT

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26
27
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and Thriller One Masters in connection with the One
production.
Clandesthe Agrements
61. Jones is informed and believes, and based thereon alleges, that MU has
materially brcached the 1978 Agreement and violated the covenant ofgood faith and fair
dealing implied in all contacts by means ofthe Sony-Jackson Venture Agrcement.
Specifically, through the Sony-Jackson Venhre Agreement, Jones is informed and
believes, and based thereon alleges, that MJJ disguised
.toyalties,'as .,profits,,,
and
diverted the Disguised Royalties to itself, which Disguised Royalties should have been
included in the pool
ofrevenues upon which Jones' royalties under the 1978 Agreement
were based. Jones is informed and believes, and based thereon alleges, that MJJ diverted
such Disguised Royalties for its own garq for the purpose ofreducing the computation
ofroyalties payable to Jones under the 1978 Agreement.
62. Jones is informed and believes, and based thereon alleges, that MJJ has
niaterially breached the 1 978 Agreement and violatsd the covenant of good faith and fair
dealing implied in all contracts by means of the Sony-Film Agreement. Jones is
informed and believes, and based thereon alleges, that MJJ is a third party
beneficiary of
the Sony-Filn Agrement. Specifrcaily, through the Sony-Film Agreement Jones is
informed and believes; and based thereon alleges, that MJJ caused Sony to divert the
Additional Fees to MJJ, which Additional Fees should have been included in the pool of
revenues upon which Jones' royalties under the 1978 Agrment were based. Jones is
informed and believes, and based thereon alleges, that MJJ caused Sony to divert the
Additional Fees for MJJ's own gain,
for the purpose of reducing the computation of
royalties payable
to Jones under the 1978 Agreement.
63. As a direct and proximate
result ofall of the foregoing, Jones has been
damaged in an amount that is Dot as yet fully ascertaine4 but which Jones believes
exceeds $ I 0,000,000, according to proof at trial, including, without limitation, for the
following:
COMPLAINT

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(a)
All ofthe unpaid royalties to which Jones is entitled under the
1978 Agreement fiom the exploitation of the OTW Filn Masters and Thriller
Film Masters in the Fihn and/or the Film Soundtrack Alburn, without deduction
of any kind, including, without limitation, for re-mixen or for coupled master
rccordings, and including, without limitatiorl Jones' share ofthe Disguised
Royalties under the Sony-Jackson Venture Agreement and the Additional Fees
under lhe Sony-Film Agreement;
O)
Re-mixing Fees that would otherwise have been paid to Jones had
Jones been engaged to re-edit and/or re-mix the OTW Filrn Masters and Thriller
Filn Masters as rquired under the 1978 Agreement;
(c)
Loss ofthe value ofcredit Jones would have received had Jones
re-edited and/or re-mixed the OTW Film Masters and Thriller Film Masters in the
Film;
(d)
All of the unpaid royalties Jones is entitled under the 1978
Agreement from the exploitation of the OTW knmortal Masten and Tbriller
hnmortal Masters in the Immortal Production and/or the Immortal Soundtack
Album, without deduction of any kind including, without limitation, for re-
mixen or for coupled master recordings, and including without limitation, Jones'
share ofthe Disguised Royalties under the Sony-Jackson Venture Agreement;
(e)
Re-mixing Fees that would otherwise have been paid to Jones had
Jones been engaged to re-edit and/or re-mix the OTW Immortal Masters and
Tbriller Immortal Masters as required under the 1978 Agreement;
(D
Loss ofthe value of credit Jones would have received had Jones
re-edited and/or re-mixed the OTW linmortal Masters and Thriller lrnmortal
Masters;
(g) All ofthe unpaid royalties Jones is entitled under 1978 Agreement
from the exploitation of the OTW One Masters and Thriller One Masters in the
One Production, without deduction of any kind, including, without lirnitation, for
COMPI.AINT

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re-mixers or for coupled master recordings, and including, without limitation,
Jones' share ofthe Disguised Royalties under the Sony-Jackson Venture
Agreement;
(h)
Re-mixing Fees that would otherwise have been paid to Jones had
Jones been engaged to re-edit and/or re-mix the OTW One Masters and Thriller
One Masters as required under the 1978 Agreement; and
(t Loss ofthe value ofcredit Jones would have received
had
Jones
re-edited and/or re-mixed the OTW One Masrcrs and Thriller One Masters.
SECOND CAUSE OF'ACTION
@reach
of Written Contract as of December 1, l9g5
Against MJJ and Ddes 1_25)
64. Jones repeats and
realleges,
and incorporates herein by reference, the
allegations set forth in paragraphs
I through 25 above, as thougl firlly set fo(h herein.
65. The 1985 Agreement is a valid, enforceable con&act between Jones d/b/a
QJP
and MJJ, which provides
the following:
(a).
Subparagraph 2(a) states in pertinent part:
"We
[MJ{
shall not and shall not permir
CBS to have any person
other than you
[ones]
re-mix or re-edit any Masters produced
by
you
[Jones]
hereunder without fint providing you ponesl
with a
reasonable opportunity to perforrn
such re-mixing and/or re-editing
a:
lve
IMJI
or CBS shall require. ln connection with your
[Jonesf
rights as set forth in the irnmediately preceding
sentence (and
as a
means of effechrating your
such rights), we
[MJ[
shall require
CBS Records (hereinafter
referred to as
,.CBS,)
to compty wittr tle
relevant provisions
ofthe recording agreement betweerCBS and
us
[MJJI
regarding the recording sewices of Artist (the
,.Recording
Agreement'), which provisions grant us
[MJJ]
the aforesaid right.;
O).
Additionally, subparagraph a(axiii) stares the following:
"The royalties payable
to you ponesl
hereunder shall otherwise be
calculated, pro.rated and reduced
[]
in the same manner as the
royalties payable to Artist with respect to such sales are so pro-
rated, calculated and reduced. We
[MJJI
shall provide you
[Jones]
with the applicable provisions
ofthe Recording Agreement
regarding these matters . . . . Notwithstanding the forgoing, if any
Master hereunder is embodied on a single with other master
t7
COMPLAINT

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rccoldings (which
coupling shall require your
pones,l
prior
written consent), you ponesl
shall receive the otherwise applicable
royalty rate hereunder,
which shall not be reduced by such other
master recordings; provided,
however, that if CBS shall couple
master recordings without your
[ones,]
consent as provided
in the
forgoing portion
of this sentence, such coupling shall not constitute
a,breach hereof (and you
[Jones]
shatl
in 6ay sygnl receive your
[Jones']
applicable royalty thereon as set forth herein)."
(c).
Thirdly, paragraph
8 provides:
'We
|MJI
shall require CBS to comply with the provisions
of the
Recording Agreement relating to credit to be accorded to
producers
such that you
[Jones]
receive appropriate production
[]
credit on record labels, album
jackets
and linei notes, cassette
packaging
and in all-advertising,
billboards, print medi4 and (only
. to the same extn! if any, as you
pones]
received credit in
television
advertising, ifany, for the album entitled
"Thdller,,)
television advertising. . ."
66. Jones has performed
all or substantially an ofhis connactuar obrigations
under the 1985 Agreement,
or was prevented
or excused therefrom by the actions of
Defendants.
67. MJJ has breached the l9g5 Agreement
in connestion with the F m. the
Film
soundtrack Album, the Bad 25 Album, the Bad 25 Single, the Immortal
production
the Lnmodal Soundfrack Album, the One
production,
the Sony_Jackson Venture
Agreement and the Sony-Fitm
Agreement
as follows:
This Is It
68. Jones is informed
and believes, and based thereon alleges, that the
following
Masten from the Bad Album, which were subject to the terms of subparagraph
2(a) of the 1985 Agreemen! wer re-edited
and re-mixed and as subsequently
modified,
are embodied in the Film and/or the Film soundtack Album (the
"Bad Fihn Masters"):
(a)
"Smooth Criminal;"
O)
"The Way
you
Make Me Feel;" (c)
.,I
Just Can,t Stop
f'.j
Lj:
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|-.
t--,
ir,l
Loving You;" and (d)..Man
in The Mirror."
69. Jones is informed
and believes, and based thereon alleges, that the Bad
Fihn Master entitled
"The way
you
Make Me Feer" was re-mixed and/or re-edited for
the Film and/or the Fikn Soundrack
Album by: (a)
slowing down the intoduction; (b)
COMPLAINT

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moving the fust verse to be performed
after the intro; (c) removing the second verse; (d)
adding new and lower pitched
vocals; (e)
adding new souod elements; and (0
other
alterations that will be proven
at trial.
70. Jones is informed and believes, and based thereon alleges, that the Bad
Filn Master entitled
"I Just can't stop Loving
you"
was re-mixed and/or rc-edited for
the Fikn and/or the Film soundtack Album by: (a) containing an a cappella portion
of
the Spanish version
"Todo Mi Amor Eres Tuf'ft) including vocals from Judith Hill, a
backup vocalist; and (c) other alterations that will be proven
at trial.
71. Jones is informed and believes, and based thereon alleges, that the Bad
Film Master entitled 'Man In The Mirror" was re-mixed and/or re-edited for the Film
and./or the Film Soundtack
Album by: (a)
displaying a sripped down version with
dubbed vocals (i.e.,
newly recorded
backing vocats); and (b)
other alterations that will be
proven at tial.
72. MJJ materially breached its obligations under the l9g5 Agreement by
permitting each of the Bad Film Masters to be re-mixed and/or re-edited by third parties
for commercial release and exploitation in connection wirh the Filn without first
providing
a reasonable opportunity to Jones to perform such re-mixes and/or re-edits.
73. MJJ malerially breached its obligations under the l9g5 Agreement by
permitting
each of the Bad Fikn Masters to be re-mixed and,/or re-edited by third parties
for commercial release and exploitation in connection with the Filrn soundtack Album
without first providing
a reasonable
opportunity to Jones to perfonn
such re-mixes and/or
re-edits.
?4. Jones is informed and believes, and based 0rereon alleges, that MJJ
materially breached the 1985 Agreement by failing to accord Jones producer
credit as
required pursuant
to the 1985 Agreement for each ofthe Bad Fikn Masters in connection
with the exploitation of the Film.
75. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1985 Agreement by failing to account and pay to Jones all
COMPLAINT

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royalties and'Net Receips" otherwise payable under the 1985 Agreement for each of
ilre Bad Filrn Masters in connection with 0re Film.
76. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1985 Agreement
by failing to account and pay to Jones all
royalties and'Net Receipts
' otherwise payable
under the l9g5 Agreement for each of
the Bad Film Masters in connection with the Film soundnack Album
Bed 25 Album
77. On or about Septernber
14,2012, MJJ commercially released the album
entitred
"Bad
(25s
Anniversary
Edition)" (the'.Bad
25 Arbum"), which album was
distributed worldwide
by Sony.
78. The Bad 25 Album was sold in various packaging,
but each had at least
one set of the original Masters from the Bad Album and one set of
,Bonus
Materials."
Included in the "Bonus Materiars"
of the Bad 25 Album are the following master
recordings (the
"Bad 25 Masten'): (a)
"Todo Mi Amor Eres Tu" (a
Spanish re_mix of
the Master entitled
"I Just can't stop Loving
you
);
(b) '.Je Ne vuex
pas
La Fin De
Nous" (a
French re-mix of the Master entitled
..I
Just Can,t Stop Loving
you,);
(c)
2
different re-mixes
ofthe Master entitred
"Bad" (one
by the producer
Aaojack featruing
Pitbull entitled
"Bad
[Afiojack
Re-mix/DJ
Buddha Edit]- and one by the producer
A*ojack
entitled
,.Bad
[Afrojack
Club Mix]"); and (d) a re_mix by the producer
Nero of
the Master entitled
.,Speed
Demon.',
79. The Bad 25 Master entitled
.Bad
feahring
pitbull
[Afrojack
Re_mix
@J
)<
26
27
28
i::l
r,j
Ltl
l'j
Buddha
Edit)1" was commcrcially
released
on or aboul August 4, 2012 as a digital single
prior
to the release
of the Bad 25 Album.
80. Around the same time of the Bad 25 Album,s commercial
release,
MJJ
commercially
rereased
as a singre the Bad Master entitred
.,I
Just can,t stop Lovrng
You" coupled with the yet
unreleased
master recording
entitled
.
Don't Be Messin,
Round" (the
'tsad 25 Single').
81. MJJ materially
breached
its obligations under the l9g5 Agreement
by
COMPLAINT

I
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J
I
5
6
7
8
9
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l3
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I
271
I
281
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o
permitting each ofthe Bad 25 Masren to be re-mixed and/or re-edited by third parties for
commercial release and exploitation in connection with the Bad 25 Album without first
providing
a reasonable opportunity to Jones to perform such re-mixes and./or re-edits.
82. IVIJJ materially breached its obligations under the l9g5 Agreement by
coupling the Master entitled
"I
Just can't Stop Loving
you"
with the master recording
entitled "Don't Be Messin' Round" on the Bad 25 singrg, withsrl Jones prior written
consnL
83. Jones is inforrned and believes, and based thereon alleges, that tv{JJ
materially breached the 1985 Agreement by failing to accord Jones producer
credit as
required pursuant
to the 1985 Agreement
for each of the Bad 25 Masters in connection
with the exploitation
of the Bad 25 Album.
84. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1985 Agreement
by failing to account and pay to Jones all
royalties otherwise payable
under the l9g5 Agreement for each ofthe Bad 25 Masten in
connection wilh the Bad 25 Album.
85. Jones is informed
and believes, and based thereon alleges, that MJJ
materially breached the 1985 Agreement by failing to account and pay
to Jones all
royalties
otherwise payable
under the l9g5 Agrcement for the applicable Bad 25 Master
in connection
with the Bad 25 Single.
Michael Jackson:
The Immortrl
World Tour
86. The following
Masten fiom ttre Bad Album, which were subject to the
tenns of subparagraph
2(a) ofthe 1985 Agreemen! were re_edited and re_mixed,
and, as
subsequently modified,
are embodied
in the lnmortal
production
and/or the Imnortal
Soundtack Album (the
"Bad Lnmortal
Masters"): (a)
,.Dirty
Diana;,, (b)
*The
Way
you
Make Me Feeli' (c)
"smooth Criminal;" (d)
..Another
part
of Me;', (e)
.Man
In The
Miror;" (f) "Speed
Demon;', and (g)
..Bad.',
87. Jones is infonned and believes, and based thereon aleges, that each ofthe
Bad Immortal Masters was re-mixed and/or re-edited to creale new pre-recorded
music
21
COMPLAINT

t
I
2
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4
5
6
7
8
9
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DsEF
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*
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24
25
26
27
28
to accompany the Immortal Production (most
of which are also embodied in the.
Immortal Soundtack Album) by, among other things: (a) overlaying multiple songs
together and editing them in a way as to connect them for medley sequences;
@)
changing tempo; (c)
changing pirch; (d) adding or removing verses; (e)
adding additional
musical elements; and (f)
other alterations
that will be proven
at trial. The Bad lmmortat
Masters were re-edited
and/or ie-mixed without Jones' coasent.
88. MJJ commercially
released
each of the Bad Immortal Masters embodied
on the Inmortal soundtack
Album as a single, ava able for purchase
as a single through
various digital dishibution
retailen, including, without rirnitatior\ AFple irunes.
89. Notwithstanding
the terms of subparagraph 4(a)(iii) ofthe l9g5
Agreemenl MJJ commerciany
released
the master recording entifled
,,The
Immortal
Into" as a single, which coupled various iraster recordings together,
including, without
limitation, the Bad Immortal
Masters entitled
,.Bad," ,.smooth
criminal,"
..Another
part
of Me" and "The way
you
Make Me Feel." IvIJJ never asked for nor obtained
the prior
u/ritten consent
ofJones for the coupling any ofthese Bad Immortal
Masters as part
of
the master recording
entitled "The
Immortar
Into.r' Additionally,
notwithstanding
the
temn of subparagraph
4(a)(iii)
of the lgg5 Agreement,
Jones' royalty rate for such Bad
Masters were reduced
by the coupling
with the other master rcording.
90. Notwithstanding
the terms of subparagraph
4(a)(iii) ofthe l9g5
Agreement,
MJJ commercially
released
the master recording
entitled
..The
Mime
Segment" as a single, which coupled various
master recordings
togettrer, including,
without limitation,
the Bad lnmortar
Master entitled "Another
part
of Me' and the Bad
Immortal Master entitled
"speed Demon."
MIJ never asked for nor obtained the prior
written consent
ofJones for the coupling ofeither these Bad Immcirtal
Masters as part
of
the master recording entitred
"Mime Segment." Additionally,
notwithstanding
the terms
of subparagraph 4(a)(iii)
ofthe l9g5 Agreemen!
Jones' royalty rate for such Bad
Masters werc reduced by the coupling with the other master recording.
9 I . Nonrithstanding
the terms of subparagraph 4(a)(iii)
of the I 9g5
22
COMPLAINT
I

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sHg9
3-q*E
lE ? I,.
sE.ifi
.6?:-ii
26ft7
H?
g
E
i{(,'<F
<;6
I
2
J
4
5
6
7
8
9
l0
ll
t2
l3
,14
l)
l6
t7
l8
l9
20
2l
22
23
24
25
26
27
28
l_/
qr
i'..\
u'l
f..l
Gj
p
,.i
Agreement, MJJ commercially released as a single the Bad Immortal Master entitled
..I
Just Can't Stop Loving You" coupled with the master recording entitled "You Are Not
Alone." MJJ never asked for nor obtained the prior written consent of Jones for the
coupling of the "I Just Can't Stop Irving You" Bad Lnmortal Master with the master
rcs61ding entitled
'You Are Not Alone." Additionally, notwithstanding the tenns of
subparagraph 4(a)(iii) ofthe 1985 Ageemen! Jones' royalty rate for such Bad Master
was reduced by the coupling $'ith the other master recording.
92. Notwithstanding the terrns of subparagraph 4(a)(iii) ofthe 1985
Agreement, MJJ cornmercially released as a single the Bad Immoftal MasGr entitled
"Bad" coupled with the master recording entitled "State of Shock" and the Thriller
Immortal Master entitled
"Beat
It." lvflJ never asked for nor obtained the prior written
consent of Jones for the coupling of the "Bad" Bad Irnmortal Master with either the
master recording entitled "State of Shock" or the Thriller lmmortal Master entitled
"Beat
It." Additionally, notwithstanding the temrs of subparaeraph a(axiii) ofthe 1985
Agreement, Jones' royalty rate for such Bad Master was rcduced by the coupling with
the other master recordings.
93. Notwithstanding the terms of subparagraph 4(a)(iii) of the 1985
Ageement, lvlJJ commercially released as a single the Bad Immortal Master entitled
"Bad" coupled with the master recording entitled "Remember The Time." MJJ never
asked for nor obtained the prior written consent of Jones for the coupling of the
"Bad"
Bad Inmortal Master with the master recording entitled "Remenber The Time."
Additionally, notwithstanding the terms of subparagraph 4(a)(iii) ofthe 1985 Agreemen!
Jones' royalty rate for such Bad Master was reduced by the coupling with the other
master recording,
94. MJJ materially breached its obligations under the 1985 Agreement by
permitting the Bad krunortal Masters to be re-mixed and/or re-edited by third parties for
comrnercial release and exploitation in connection with the Irnmortal Production without
COMPLAINT

O PE8
3.q;E
EIPF
sE.i*
2862
H;EE
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4
5
6
8
9
l0
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t2
IJ
t4
l5
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t7
l8
l9
20
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22
24
25
26
27
28
f'
i:
Fl
tJl
t'..!
'.:.'
l-.
t:
fust providing a reasonable opportunity to Jones to perform such re-mixes and/or re-
edits.
95. MJJ materially breached its obligations under the 1985 Agreement by
permitting the Bad lrunortal Masters to be re-mixed and,/or re-edited by third parties for
commercial release and exploitation in connection with the Immortal Soundtrack Album
without first providing a reasonable opportunity lo Jones to perform such re-mixes and/or
re-edits.
96. MJJ materially brcached its obligations under the 1985 Agreement by
pemitting
the Bad Immortal Masters to be coupled with other master recordings as part
of commercially released singlcs.
97 . MJJ materially breached its obligations under the 1978 Agreement by
reducing Jones' royalties on Masters coupled with other master recordings.
98. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1985 Agreement by failing to accord Jones producer credit as
required.pursuant to the 1985 Agreement for each of the Bad lmmortal Masters in
connection with the exploitation of the tnmortal Production.
99. Jones is informed and believes, and based thereon alleges, that IV{JJ
materially breached the 1985 Agreement by failing to account and pay to Jones all
royalties and 'Net Receipts" otherwise payable
under the 1985 Agreenent for each of
the Bad lmmortal Masters in connection with the Lnmortal Production.
100. Jones is informed and believes, and based thereon alleges, that MJJ
materially breached the 1985 Agreement by failing to account and pay to Jones all
royalties and
'Na Receipts" otherwise payable under the 1985 Agreement for each of
the Bad Immortal Masters in connection with the Immortal Soundtrack Album.
Michael Jackson: One
101. The following Bad Masters, which werc zubject to subparagraph 2(a) of
the 1985 Agreement, were re-edited and re-mixed, and, as subsequently modified, are
embodied in the One Production (the
'Bad One Masters"):
(a)
"Bad;"
(b)
"smooth
24
COMPLAINT

rll
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I
t
ll
ca-na;"
<"1
'Dirtv Dianai'(d)
"The way You Make Me Feeli'(e)
"r Just canl Stop
|
,ll Lovinc vou; and (f)
"Man In the Mirror.,,
|
3
ll
tr. Jones is informed
and believes, and based thereon alleges, that at least two
|
+
llof
the Bad one Masten,
"Bad" and "smooth Criminal," were used in so-caled
*Sneak
tlt
I
t
ll
Peek" videos
commercially
released
over the Lrtemet to promote
the one
producrion.
I
U
ll
t*. IVIJJ materially
breached its obligations
under the 1985 Agreernent
by
I 'llnennittins
eactr ofthe Bad one Masters to be re-mixed
and/or re-edited
by thtud parties
I
t
flfor
conunercial
release
and exploitation
in connection
with the one
production
without
i
n
ll
f'st
nrovidine
a reasonable
opportunityto
Jones to perfomr
such re-mixes
and/or
re-
I
tolleaits.
I ..
t t
ll
ro4'
Jones is informed
and believes,
and based thereon
a'eges,
rhat MJJ
I !: $g
12
llmateriailv
breached
the 1985
Agreement
bv failing to accord Jones producer
credit
as
I !;
g5
l3
f f
reluirea
nursuant
'o
the 1985
Agreement
for each
of the Bad
one Masters
in connection
t
E *o. i
l4
ll
with the exploitarion
ofthe
one
production.
Fgi. l: ll
105.
Jones
is informed
and berieves,
and based thereon
aleges,
that MJJ
r o
ll
materia'y
breached
the l9g5
Agreement
by fa'ing
to account
and pay
to Jones
a'
I ]l ll
royatties
and
'Net Receipts"
otherwise
payable
under
the 1985 Agreement
for each
of
i if ff
tne
raa one uasters
in connection
with
the one
production,
including,
without
'
]g ll
rimitation'
for the Bad
one Masters
used in the
,,Sneak
peak,,
videos
for the one
zu
lf
production.
,r
ll
Chndesrine
Asreements
r"-)
22
ll
106.
Jones is informed
and beti
i:.,
^^
ll
evuwr rD uutlruec
ano oetreves,
and based thereon
alleges,
tlnt MJJ bas
.
.
:: ll T:-
treached
the 1985
Agreement
and viorated
the covenant
of good
faith and fair
i
i;
:l ll"*tt
tmplied
in all conracts
by means
of the sony_Jackson
Ventune
Aseement.
i ,,
z:
ll
Snecificallf,
through
the
Sony_Jackson
Venhre
Agreernen!
Jones is infonned
and
i
;:
:: ll :t"*-
and based
thereon
alleses,
that MJJ disguised
.,royalties,,
as
..profi1s,,,6,,6
I i; :1 llo*"*o
*r Disguised
Rovalties
ro irserf,
which
Disguised
Rovalties
should
have
been
I
zu
ff
included
in the pool
ofrevenues
upon which
Jones,
royalties (and
..Net
Receipts,,
under
tll
I ll-2s
|"co

t4
l5
t6
1.7
L'
l8
l9
20
$EgF
s
E,i$
E;gE
E;s-
26
27
28
p
i:'l
r'.i
L.{
Ir.'
L:J
F.l
tj
2l
22
z5
ai
25
I
2
J
+
5
6
7
8
9
l0
l1
t2
l3
the 1985 Agreement) were based. Jones is informed and believes, and based thereon
alleges' that MJJ diverted such Disguised Royalties for its own gain, for the purpose
of
reducing the computation
ofroyalties and'Net Receipts ' otherwise payable
to Jones
under the 1985 Agreement.
107. Jones is informed
and believes, and based thereon alleges, that tvflJ has
materially
breached the 1985 Agreement
and viorated the covenant
of good
faith and fair
dealing implied in all contacts
by means ofthe Sony-Film Agreement.
Jones is
informed and believes'
and based thereon
a'eges, that MJJ is a third party
beneficiary
of
the Sony-Film
Agreement.
Specifically,
tbrough the Sony_Film
Agreement
Jones is
infonned
and believes,
and based thereon
alleges, that MJJ ca,sed
Sony to divert the
Additionar
Fees to MJJ, which
Additional
Fees should
have been included
in the pool
of
revenues
upon which Jones'
royalties
under the l
gg5
Agreement
were based.
Jones is
infonned
and berieves,
and based thereon
alleges,
that MJJ caused
sony to divert the
Additional
Fees for MJJ's own gaiq
for the purpose
of reducing
the computation
of
royalties payable
to Jones under the l9g5 Agreement.
108.
As a direct and proximale
result ofall ofthe foregoing,
Jones
has been
danaged
in an amount
that is not as yet
fully ascertained,
but which
Jones believes
exceeds
$10,000,000,
according
to proofat
trial, including,
without
lirnitation,
for the
following:
(a)
All ofthe unpaid
royalties
and unpaid.Net
Receipts,,
Jones is
entitred
under the 1gg5 Agreement
fiom the exploitation
of the Bad Fi'n
Masten
in the Film
and/or
the Fikn Soundtack
A.lbum,
without
deduction
ofany
kind,
including,
without limitation,
for re-mixers
or for coupled
master recordings,
and
including,
without
limitation,
Jones'
sharc of the Disguised
Royalties
und* the
Sony-Jackson
Venture
Agreemen
and the Additional
Fees under the Sony_Film
Agreement;
(b)
Re-mixing
Fees that would otherwise
have
been paid
to Jones
had
Jones
been engaged tolre-edit
and/or re-mix
the Bad F'm Masters as required
26
COMPLAINT

o.;g
^-uSo
y
=59
$:;es
< 6-q G;
Ec'iS
4'z--r,i
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ft
il
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.'
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under the 1985 Agreement;
(c)
Loss ofthe value of credit Jones would have received had
Jones
re-edited and/or re-mixed
the Bad Film Masters in the Fikn;
(d)
All ofthe unpaid royalties Jones is entitled under the l9g5
Agreement
from the exploitation
of the Bad 25 Masters in the Bad 25 Album
and/or the Bad 25 Single, without deduction
ofany kind including,
without
limitation,
for re-mixers
or for coupled master recordingg
and including,
without
limitation,
Jones' share ofthe Disguised
Royalties under the Sony_Jackson
Venhre
Agreement;
G)
Re-mixing
Fees that would
otherwise
bave been paid
to Jones had
Jones been engaged
to re-edit
and/or
re-mix
the Bad 25 Masters
as required
under
the 1985 Agreement;
(D
loss
ofthe value
ofcredit
Jones would have received
had Jones
.re-edited
and/or
re-mixed
the Bad 25 Masters;
(g)
All of the unpaid royalties
and unpaid
.Net
Receipts.
to which
Jones is entitled
under the I 9g5 Agreement
ftorr the exploitation
of the Bad
Lnmortal
Ma3ters
in the knmortal
production
and/or the Inmortal
Soundtrack
Alburu
without
deduction
of any kind, including
without
limitation,
for re_
mixers
or for coupled
master
recordings,
and including,
without
limitatioq
Jones,
share ofthe
Disguised
Royalties
under the Sony_Jackson
Venhle
Agreement;
(h)
Re-mixing
Fees
that would
otherwise
have been paid
to Jones had
Jones
been engaged
to re+dit
and/or re-mix
the Bad Immortal
Masters
as
required
under
the Agreement;
(t
Loss
ofthe value
ofcredit
Jones
would
have received
had Jones
re-edited
and/or
re-mixed
the Bad lnmortal
Masters;
(j)
All of the unpaid
royalties
and unpaid
.Net
Receipts,,
to which
Jones
is entitled
under the l9g5 Agreement
Aom the exploitation
of the Bad One
Masters in the One
production,
without
deduction
ofany
kind, including,
without
il
ll
'll
ll
.ll
'll
'll
'll
8ll
tl
nll
'o
ll
;ll
"ll
14ll
i:ll
r?
ll
"ll
,n
ll
,o
ll
"ll
nll
--
tl
"ll
'oll
"ll
26ll
"ll
28
tl
il-
COMPLAINT

o-69
r|!90
F;; r
s
-t.t
*
ztgZ
H;e$
E;s-
i)
u.1
i..,r
i_jj
l.j
j:";
t--.'
t
ll
limiation, for re-mixers
or for coupled master recordings,
and including, without
t
ll
firnitation'
Jones' share ofthe Disguised
Royalties under the sony-Jackson
3
ll
Venhue
Agreement;
O
ll
G)
Re-mixing
Fees that would orherwise have been paid ro Jones had
t
ll
Jones
been angaged
to re+dit and/or re-mix the Bad one Masters as required
6
ll
under the Agreement;
and
t
ll
0)
Loss ofthe value
of credit Jones would
have received
had Jones
8
ll
re-edited
and/or re-mixed
the Bad
One Masters.
9
TIIIRD
CAUSE
OF ACTION
t O
ll
(F,or
aa Accounring
againsr
MJJ, Sony and Does 2G50)
I I ll
I 09.
Jones repeats
and realeges
paragraphs
I through
109 above,
as though
l2
ll
they were
firily set forth
herein.
]l ll
I10. Jones
is infonned
and believes,
and based
thereon alleges,
thar
MJJ, Sony
I a
ff
and/or'their
other
entities
or assigns
have and are continuing
to receive
substantial
I s
f f
n"rr*tr from the reproduction,
use or other exploitation
of the Masters
embodied
in the
t 6
llFitn'
the Firm
Soundhack
Arbum,
the Bad 25 Atbum,
the Bad 25 Single,
the Immortal
l7
lf
froductio+
the Irnmortal
Soundtrack
Album
and the One
production.
I : ll
I I t. Jones
does not precisely
know
how much
money has been
eamed
by tvIJJ,
l9
ff
sonr or tneir
other entities
and assigns
through
the improper
use ofthe
Masters
and
:: ll
*Y
*
"lure
to account properly
to Jones
for a' of the royalties
and
.Net
Receipts,,
:l ll*
**"
t subparagraph
r2[a][ii]
of the 1985
Agreement)
owed
to Jooes pursuant
to
:i ll
*.
"O.".ents,
nor has he seen
all of the agreements
that may affect the amount
of such
23
lf
roralties
and
.Net
Receipts.,,
:rl
tl2.
Additionally,
Jones
does
not precisely
know how much
money
has been
1] ll:*
*
"JJ'
Sonv
or their
other
entities
and assigns
from rhe exploitarion
ofthe
Firm,
ZO
ll
the Fihn Soundtrack
Album,
the Bad 25 Album,
the Bad 25 Single,
the Immortal
27
ff
Productiou
rhe Immortar
soundhack
Album
and the one
production
in order to
28
ffcatculate
the amount
of the Re_Mixing
Fees that Jones
should
have
been paid
in
COMPLAINT

rll
ilol
tl
II
tl
ltl
I
t
ll
connection therewit[ since the Re-Mixing Fees would have been inclusive
ofa so-calle
|
2ll"uackend,"
consisting ofa percentage
ofthe receipts derived from the exploitation
ofthr
|
3
ll
audio and/or audio-visual
works embodying
such re-edited and/or re-mixed
Masters.
|
4
ll
I13. Jones is informed
and believes
and based thereon alleges,
that the
ttl
I
5
ll
clandestine
Aereements
were put
into place
suneptitiously
to reduce the royalties
and
I
u
lltm'r'r"t
n r"inrs" (as
defined in subparagraph
l2[a][ii]
of the 1985 Agreement) payabrt
| 'ffto
Jones under the AgremeDts.
An accounting
is necessary
in order to determine
the
I
t
ll
exact amount
ofall monies,
revenues, profits
and property
and the proceeds
thereof
I
n
llreceived
br Defendants
and owed to and owned
by Jones
by reason ofthe foregoing
acrs
I
t 0
ff
in breach ofsaid
Defendanrs'
conrachral,
equitable
and other obligations.
,
u"- llll
114.
Because
MJJ has materially
breached
the Agreements
by not providing
I ! ,g E
g
I 2
ll
anv infonnation
to Jones
as to anv agreements (other
than the Agreements)
related
to the
I E
5
C ;
l3
f l
Masters (including,
without
limitation,
the clandestine
Agements),
and in view
of
I * Eg". E
I a
lf
lclt
actions in appropriating
for iself
to rhe detriment
of Jones,
Jones is entifled to a
I
g g
6E
I 5
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firll'and
comnlete
accounting
from MJJ (and
any IVIIJ afrriates
or relared
entities)
as to
I
n
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l6
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at monies rereived
ftom the F'm, the Film soundtrack
Album,
the Bad 25 Album,
the
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t 7
llBad
25
gingle,
the Immortal
producrion,
the
rmmoftal
Soundhack
Album
and the One
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t 8
ll
Production'
and copies ofatl
agreements
entered into rhat relate
to any ofthis income.
I
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I15.
Because
Jones is a third party
beneficiary
ofthe
Recording
Agreements,
20
lf
as evident
br, without
rimitation,
Sony agreeing
and partially
performing
the
producer
:: ll ].-r,
with respect
to Jones,
Jones is entitled to a fir' and complere
accounting
from
:,
zz
ll
nony as to a, monies received
from the Firn, the Firn
soundtrack
Album,
the Bad 25
-:.
23
f f
amum'
ttre naa 25 single, the knmortar
production,
the Immonal
Soundrack
Atbum
I
I
24
lland
the one Production,
and copies
ofall agreements
entered
into that relate ro any of
|
.. 25
ll
this income.
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connection therewith,
since the Re-Mixing Fees would have been inclusive
ofa so-called
2
ll
"uackend'" consisting ofa percentage
ofthe receipts derived from the exploitation
ofthe
3
ll
audio and/or audio-visual
works embodying
such re-edited and/or re-mixed
\ifasters.
a
ll
I13. Jones is informed
and believes
and based thereon alleges,
that the
5
ll
clandestine
egreements
were put
into place
suneptitiously
to reduce the royalties
and
o
lltm'rrr"t
na"iprs" (as
defined in subparagraph
l2[a][ii]
ofthe 1985 Agreement) payable
7
ff
to Jones under the Agreemeuts.
An accounting
is necessary
in order to determine
the
8
ll
exact amount
ofall monies,
revenues, profits
and property
and rhe proceeds
thereof

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PRAYER
WHEREFORE
Plaintiffprays
for Judgment against Defendants, and each of them.
as follows:
l. For damages
according to proofbu!
in any event, in the amount ofat least
$10
million:
For damages
according
to proofbu!
in any event, in the amount ofat least
$10
million;
Decembcr l. 1985 asaipst MJJ end Does l_25:
50:
1. For a frrll and complete
accounting
by Defendants
ofall sums ofmoney
and
revenue
which Defendants
received
in corurcction
with the reproduction,
use or
other exploitation
of the Masten, including,
without limitation,
from the
exploitation
of the Filrn, the Film
Soundfack
Album,
the Bad 25 Album, the Bad
25 Single, the Lnmortal
production,
the Immortal
Soundhack
Album
or the One
Productio4
and what was done with such revenue.
2' For copies ofalr agreements
entered
into by any ofthe
Dfendants
that relate to
the reproductioq
use or other exploitation
ofthe Masten, including,
without
linitation,
in connection
with the Fil-rr, the FiLn Soundtrack
Album, the Bad 25
Album, the Bad 25 Single,
the lmmortal
production,
the Immortal
Soundtack
Album
or the one
production,
and what was done with such revenue.
a'.
i1r
ul
f,..1
t:'l
I'j
2l
22
z5
AA
z+
25
26
27
28
On All Causes
of Action:
i. For such fees and costs inctmed
herein as permitted
by law;
COMPLAINT