Fifth Circuit: Beyoncé song does not infringe songwriter's copyright

In a decision last week, the Fifth Circuit affirmed a district court's grant of summary judgment of no copyright infringement.  A plaintiff brought suit against the singer Beyoncé Knowles and several parties with whom she is associated alleging that Beyoncé's song "Baby Boy" infringed the plaintiff's work.  The district court granted summary judgment of noninfringement based on a lack of substantial similarity.

The Fifth Circuit affirmed, but on the grounds that the plaintiff had not proven access to the copyrighted work.  The plaintiff's responses to Beyoncé's requests for admissions foreclosed most of her theories of access, and the remaining theories were too speculative to survive summary judgment.  As a result, the Fifth Circuit affirmed the summary judgment of noninfringement.

More detail of Armour v. Knowles after the jump.

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