Rock River Communications, Inc. v. Universal Music Group, Inc.

This case concerns the licensing rights for several early musical recordings by reggae legends Bob Marley and the Waal-ers. When the music was initially recorded in Jamaica in the 1960s, record keeping was not a primary concern. The absence of legal documentation has led to confusion in the marketplace as to which entities own licensing rights for these recordings.

Defendants Universal Music Group, Inc., UMG Recordings, Inc. and Universal Music Group International, Ltd. (collectively, UMG) successfully invoked this lack of documentation in the district court to obtain summary judgment on plaintiff Rock River Communications, Inc.’s (Rock River) claim for intentional interference with prospective economic advantage. Rock River’s lawsuit alleged that UMG inappropriately blocked Rock River from distributing its album of Marley remixes by wrongfully threatening to sue Rock River’s distributors. UMG persuaded the district court that unless Rock River had proof that its chain of licensing rights was valid'—dating all the way back to the initial musicians and producers—then UMG could not be liable, because there is no liability for interference with an invalid business…