## Facts

- Music publishing and recording companies alleged ownership of copyrights in numerous musical compositions and sound recordings.
- Plaintiffs filed a single omnibus complaint alleging unauthorized “sampling” of their works across many later recordings and compositions.
- The complaint named more than 770 defendants (including publishers, labels, administrators, and clearance entities) and asserted nearly 500 infringement counts tied to different songs, defendants, and time periods.
- Plaintiffs claimed the alleged infringements were sufficiently related because they involved the same type of harm (sampling) and allegedly overlapping industry actors.
- Multiple defendants moved to sever for misjoinder under Federal Rule of Civil Procedure 20(a) and moved to dismiss under Rule 8(a), asserting the complaint was not a “short and plain statement.”

## Issues

1. Whether Rule 20(a) permitted joinder of hundreds of defendants where the infringement claims concerned many different songs and alleged sampling events.
2. Whether the length and complexity of the omnibus pleading failed Rule 8(a)’s “short and plain statement” requirement.

## Decision

- The court held that joinder was improper under Rule 20(a) because the claims did not arise from the same transaction, occurrence, or series of transactions or occurrences.
- The court granted the motions to sever, requiring the alleged infringements to proceed as separate actions organized around distinct songs/sampling events.
- The court denied the motions to dismiss as moot in light of severance and restructuring of the litigation.
- The court emphasized that the consolidated action was unmanageable and risked unfairness by forcing defendants to confront large volumes of unrelated material.

## Legal Principles

- Under Rule 20(a), multiple defendants may be joined only if the right to relief arises out of the same transaction, occurrence, or series of transactions or occurrences, and at least one common question of law or fact exists.
- Similarity in alleged wrongdoing (e.g., many instances of copyright infringement by sampling) does not, by itself, satisfy Rule 20(a)’s transactional relatedness requirement.
- Alleged overlap among some industry participants across different works does not convert separate alleged infringements into a single transaction or a sufficiently related series.
- Courts may order severance to address misjoinder, manageability, and prejudice, particularly where consolidated pleading would overwhelm parties and the court.
- Rule 8(a) requires a short and plain statement providing fair notice; severance may functionally address concerns created by sprawling, multi-party pleadings.

## Conclusion

The court ruled that the plaintiffs’ attempt to litigate hundreds of distinct sampling-based infringement claims against more than 770 defendants in one case violated Rule 20(a)’s transaction-or-occurrence requirement, ordered severance into separate actions, and treated the pending Rule 8(a) dismissal motions as moot after severance.


Bridgeport Music, Inc. v. 11C Music, 202 F.R.D. 229 (M.D. Tenn. 2001)