Case 1:18-cv-08791 document 1 filed 09/25/18 page 1 of 14

Defendant, sony music entertainment (“sony music” or “defendant”), is a ... sony music exercises total control over these subsidiaries to create substantial.
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1IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF NEW YORKCase No:______________THE RICK NELSON COMPANY, LLC,a Delaware limited liability company, on behalf ofitself and all others similarly situated,Plaintiff, CLASS ACTIONCOMPLAINTv.SONY MUSIC ENTERTAINMENT, aDelaware corporation,Defendant.Case 1:18-cv-08791 Document 1 Filed 09/25/18 Page 1 of 142Plaintiff, The Rick Nelson Company, LLC. (“Plaintiff” or “Nelson LLC”), on behalf ofitself and all others similarly situated, alleges as follows upon personal knowledge as toPlaintiff’s own conduct and on information and belief as to all other matters based on aninvestigation by counsel, such that each allegation has evidentiary support or is likely to haveevidentiary support upon further investigation and discovery:I. NATURE OF THE ACTION1. Defendant, Sony Music Entertainment (“Sony Music” or “Defendant”), is arecord label which obtained the rights to exploit the artistic works of Plaintiff and Class members(defined below) in ...