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In dual lawsuits filed on Feb. 7, 2022, the estates of Robin Williams and George Carlin accuse Pandora Media of willfully infringing the legendary comedians' registered copyrights in their "spoken word compositions" — their standup routines — by streaming the sound recordings that embody those routines without a license to use these works. Robin Williams Trust v. Pandora Media, No. 22-cv-815 (C.D. Cal. Feb. 7, 2022); Main Sequence, Ltd. v. Pandora Media, No. 22-cv-810 (C.D. Cal. Feb. 7, 2022).
The Williams complaint alleges that Pandora infringed 27 Robin Williams spoken word works (SWWs), which were included in the albums Reality … What a Concept and A Night at the Met. The 56 allegedly infringed George Carlin SWWs are contained on the albums An Evening With Wally Londo, Class Clown (including a performance of the famous — or infamous — "Seven Words You Can Never Say On Television" routine), Classic Gold, George Carlin on Comedy, On the Road, SOFA — Comedy Clips, The George Carlin Collection, Toledo Window Box, and You Are All Diseased.
Both complaints specify that the relevant sound recording copyrights are owned by major record labels, pursuant to recording contracts entered into by the labels with the respective comics, but that Williams and Carlin each retained all of their exclusive rights in their original SWWs. And both complaints allege that Pandora made the specified SWWs "available for dissemination to the public via their digital broadcast radio service knowing full well that it did not possess a valid license to publicly perform the [SWWs]," and that "[i]n addition to no license, it also made no royalty payments for the [SWWs]."
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