VMG Salsoul, LLC v. Ciccone
United States Court of Appeals for the Ninth Circuit
824 F.3d 871 (9th Cir. 2016)
Relevant factsFree
VMG Salsoul (plaintiff) owned copyrights in a song featuring distinctive horn-hit sounds repeated over 20 times. Madonna's later song 'Vogue' (defendant) used rhythmically similar horn hits at different notes and keys, altered electronically and layered with many other instruments, appearing only a few times in the song.
IssueFree
Whether a finding of copyright infringement requires more than de minimis copying.