Mariah Carey has won a lawsuit that claimed the perennial hit All I Want For Christmas Is You infringed the copyright on another song with the same name.
The court also slapped sanctions on the lawyers who brought the case against Carey, saying they had filed “frivolous” and “unsupported” claims in the case in “to cause unnecessary delay and needlessly increase the costs of litigation.”
Songwriter Andy Stone, who performs as Vince Vance and the Valiants, along with co-writer Troy Powers, filed a complaint in November 2023, alleging that Carey’s 1994 classic Christmas song ripped off their own song called All I Want For Christmas Is You, which was released in 1989 and “became a country music hit” after “extensive seasonal airplay in 1993,” according to their complaint.
The complaint, which also named Sony Music Entertainment as a defendant, alleged that Carey’s song copies the “compositional structure of an extended comparison between a loved one and trappings of seasonal luxury.”
It also claimed that Carey’s hit “includes several of [Stone’s] lyrical phrases”.
Stone and Powers asked the court for at least $20 million in damages.
Carey’s All I Want For Christmas Is You is among the most lucrative songs of recent years, routinely rocketing up the charts every year around Christmas.
Last year, Manatt, Phelps & Phillips, a law firm that specializes in the music industry, estimated the song generates $3.4 million a year and has made around $103 million over the past three decades.
Last year, the plaintiffs and defendants in the case agreed to limit the court battle to “extrinsic tests” of the two songs, meaning an objective investigation into the similarities between them.
In her ruling issued on Wednesday (March 19), which can be read in full here, Judge Monica Ramirez Almadani of the US District Court for the Central District of California rejected the testimony of the experts brought in by Stone and Powers, and accepted the testimony of experts brought in by Carey and the other defendants.
One of those experts for the defendants, Dr. Lawrence Ferrara – a musicologist, professor of music and director emeritus of music studies at New York University – concluded that despite the songs having the same title, the lyrical similarities between them are “fragmentary, used with different lyrical phrases, arranged differently, and… in common use.” Elements of music that are “in common use” are not subject to copyright protection.
Ferrara also concluded that the main expressive idea behind the two songs – that the narrator wishes for a certain “you” in lieu of other gifts for Christmas – is “normally associated with Christmas.”
“Ferrara found at least 19 songs predating [the Stone/Powers 1989 song] that incorporated the lyrical idea behind the title phrase All I Want for Christmas Is You,” Judge Ramirez Almadani wrote in her ruling. “Several incorporate the exact or near identical title phrase.”
The judge rejected the reports filed by the experts brought in by Stone and Powers, on the grounds that their reports didn’t show they had carried out a complete analysis, and didn’t show the methodology used to carry out their analyses.
“Plaintiffs’ counsel… is at fault for this non-compliance.”
US District Court Judge Monica Ramirez Almadani
The judge also granted Carey and the other defendants’ request for sanctions on the lawyers who brought the case, on the grounds that they had violated the court order to limit the case to the “extrinsic” examination of the songs’ similarities, and made other “irrelevant” arguments in their court filings.
“The court ordered the parties to conduct discovery and file motions for summary judgment as to the extrinsic test only,” Judge Ramirez Almadani wrote.
“Despite the parties’ agreement and the court’s clear instructions, Plaintiffs, by and through their counsel, inexplicably moved for summary judgment on other elements of their copyright claim, i.e., ownership, copying, and access.”
The judge concluded that “plaintiffs’ counsel… is at fault for this non-compliance. Instead of timely remedying this misconduct, plaintiffs’ counsel delayed and needlessly caused defendants to oppose irrelevant factual and legal issues that are not properly before the court.”
The judge decreed that Stone and Powers are to pay “some or all” of the legal costs that Carey and the other defendants incurred in responding to the plaintiffs’ motion for summary judgment. She gave the defendants’ lawyers 14 days to submit a “reasonable” estimate of the costs involved.Music Business Worldwide
