Circumstantial Evidence Does Not Create A Triable Issue Of Material Fact

The U.S. Court of Appeals for the Sixth Circuit upheld the district court's grant of summary judgment in favor of defendant-appellee Universal-MCA Music Publishing (Universal), agreeing that plaintiff-appellant Bridgeport Music, Inc. (Bridgeport) had failed to set forth specific facts showing a triable issue of material fact. Bridgeport Music, Inc., et al. v. WB Music Corp., et al., Case No. 06-5546 (6th Cir., Nov. 21, 2007) (Gibbons, J.).

The plaintiff, Bridgeport, owned the copyright to the P-Funk All Stars' song "Pumpin' It Up." A few years later, Calvin Broadus (a/k/a Snoop Dogg) collaborated with Priest Joseph Brooks and Lenton Hutton on the recording "Change Gone Come." In May 1999, Soul Town released the album Well Connected and in October 2000, D-3 Albums released the album Dead Man Walkin. Both albums contained the recording "Change Gone Come." Neither of these albums nor any recording