AUDIO EXHIBIT: a) Zuma Dogg music excerpts; b) "Marvin Gaye"/Puth excerpts; c) Zuma Dogg follow-up excerpt
LINKS TO ABOVE-MENTIONED SONGS BY ZUMA DOGG
"New Sexual Healing" - "Time For Disco Dancing" - "Sexual Evening" - "This Holiday Season" [Lyrics printed below.]
PLAINTIFF: Zuma Dogg/Venice, CA 90291 Contact: ZD@ZumaDogg.com - ZumaDogg.com
DEFENDANTS: Writer(s): Charlie Puth, Nick Seeley, Jacob Luttrell, Julie Frost, Nick Production And Publishing, Charlie Puth Music Publishing, LSLX Music, Artist 101 Publishing Group, Totally Famous Music, W.B.M. Music Corp., EMI April Music Inc., Warner-Tamerlane Publishing Corp., Artist Publishing Group East.
[Use of the term, "Marvin Gaye themed lyrics," refers to lyrics that refer to songs of well-known, Motown recording artist, Marvin Gaye. When referring to the song, itself, by Puth/Trainor, the song will always appear in quotes ("Marvin Gaye").]
Zuma Dogg [DOGG] is a Los Angeles songwriter and recording artist. (See, "ABOUT ZUMA DOGG," below.)
In 2012, DOGG recorded vocal lyrics on an instrumental beat, called, "New Sexual Healing." DOGG describes it as a Marvin Gaye tribute song; and includes Marvin Gaye themed lyrics.
In 2013, DOGG recorded vocal lyrics on an instrumental beat, called, "Time For Disco Dancing." This song also includes Marvin Gaye themed lyrics, in tribute.
In 2014, DOGG recorded vocal lyrics on an instrumental beat, called, "Sexual Evening." This song also includes Marvin Gaye themed lyrics, in tribute.
In 2014, DOGG recorded vocal lyrics on an instrumental beat called, "This Holiday Season." The song does not contain any Marvin Gaye themed lyrics; but the music beat is very similar to the music beat used for, "Marvin Gaye."
Vocal lyrics contained within, "Marvin Gaye," by Puth/Trainor are similar to vocal lyrics contained within the songs, "New Sexual Healing," "Sexual Evening," and, "Time For Disco Dancing," by DOGG.
The music beat used for "Marvin Gaye," by Puth/Trainor is very similar to, "This Holiday Season," by DOGG. ("Marvin Gaye," is slower, but similarities are undeniable.)
Considering the lyrical similarities; and overall concept by Mr. Dogg -- of using an array of Marvin Gaye lyrics; in the way in which he did (for his Marvin Gaye themed, concept songs); and, when additionally considering the music beat similarities of, "This Holiday Season," and, "Marvin Gaye," it can only be concluded that the song, "Marvin Gaye," by Charlie Puth (featuring Meghan Trainor) could not have been conceived; written and produced -- without first hearing these songs by DOGG, and being fully aware that, "Marvin Gaye," was a, "rip off," of songs by Zuma Dogg. Then, moving forward with the recording/producing and sales/distribution of, "Marvin Gaye." Even the same lyric references are used; and, "Mavin Gaye," melody is similar to, DOGG's, "This Holiday Season."
All songs by DOGG, mentioned above, were posted on various platforms such as; ReverbNation, iTunes, Podomatic, Soundcloud -- and various other MP3 platforms, that syndicate these feeds, via Podomatic; including TuneIn (see this Google search).
Then, all songs were heavily promoted on social media, via platforms including multiple twitter, facebook and blogspot (blogger) accounts, operated by DOGG, using keywords and hashtags, #MarvinGayeTributeSong and/or "Tribute To Marvin Gaye," and related such keywords/tags. Any online search for Marvin Gaye songs, by any of the DEFENDANTS, could have easily highlighted these songs by DOGG near the top of any search-engine search, prior to their contribution on, "Marvin Gaye"; or, by coming across, "Legend/Icon/Superstar," Zuma Dogg, online. [See "About Zuma Dogg," below.]
ZUMA DOGG LYRICS OF SONGS MENTIONED ABOVE:
"MARVIN GAYE"/PUTH LYRICS:
"Like Marvin Gaye, got something to say, let's get it on. Cause I'm hot. Hot like an oven. A sexual evening on a Saturday Night. Like Marvin Gaye, a sexual feeling. Throughout the night, a sexual evening. More than just sexual healing. Marvin Gaye, more than a feeling. More than just sexual healing. Baby, this song is like Marvin, 'Sexual healing. 'This track reminds me of, 'Sexual Healing.' Let's get it on, Let's get it on, the sexual healing...let's get it on. Gotta give it up. Gotta give it up. What's going on. Let's Marvin Gaye get it on. Get your back up off the wall."
"MARVIN GAYE"/PUTH LYRICS:
"Let's Marvin Gaye and get it on. You got the healing that I want. Just like they say it in the song. Until the dawn, let's Marvin Gaye and get it on. Let's Marvin Gaye and get it on. You got the healing that I want. Just like they say it in the song. Until the dawn, let's Marvin Gaye and get it on, babe. You got to give it up..."
[LYRIC COMPARISONS: "Marvin Gaye," "healing," "let's get it on," "got to give it up": A lot of similar references, in once short verse. "Just like they say in the song," has a similar meaning to the phrase, "This song reminds me of Marvin." Even, "Until the dawn," is another way of saying, "throughout the night." And, the entire concept/theme is the same; including use of same words/references.]
Mr. Dogg seeks damages in the amount of $(XX) million dollars. (The song, "Marvin Gaye," is a huge international hit, now; and Mr. Dogg is left with nothing but a karaoke track, of a song by some teeny-bopper douchebag, with a nice hair do, for DOGG's holiday song, "This Holiday Season." And, DOGG's album of Marvin Gaye themed, tribute songs, mentioned above, is now obsolete.)
ABOUT ZUMA DOGG: As seen on ABC Nightline/Good Day L.A./Howard Stern -- and every TV news station in L.A. (KNBC, KCBS, KABC, FOX-11, KCAL, KCET-PBS). "Legend"/KABC. "A Treasure Of Venice"/L.A. Times. "An L.A. Superstar, Icon"/L.A. Weekly. "Everyone knows Zuma Dogg"/Reggie Miller (NBA All-Star). "Of course, I know Zuma Dogg!"/Arnold Schwarzenegger. "Malibu celebrity"/Malibu Times. (Malibu is home to biggest celebrities in the world. Their hometown newspaper calls Zuma Dogg, "celebrity." Think about the magnitude of awareness on Mr. Dogg.) In August 2014; singer/actor, Jamie Foxx approached Mr. Dogg, in public; to record a selfie video, together, as Mr. Dogg sang one of his songs, for Mr. Foxx & his party. Adam Sandler has been photographed wearing a Zuma Dogg T-Shirt. Stone Temple Pilots have shouted out, Mr. Dogg, on-stage, during their concert. Nearly 10,000 people voted for Zuma Dogg, for L.A. City Mayor in 2009. Run-DMC let Mr. Dogg backstage, at House of Blues show, without a backstage pass. (These are a few of countless examples.) NOT HARD to come across, "ZUMA DOGG." It's not unreasonable to think any of these, "Marvin Gaye," writers are fans of/aware of Zuma Dogg; and have listened to his music.
ABOUT ZUMA DOGG: As seen on ABC Nightline/Good Day L.A./Howard Stern -- and every TV news station in L.A. (KNBC, KCBS, KABC, FOX-11, KCAL, KCET-PBS). "Legend"/KABC. "A Treasure Of Venice"/L.A. Times. "An L.A. Superstar, Icon"/L.A. Weekly. "Everyone knows Zuma Dogg"/Reggie Miller (NBA All-Star). "Of course, I know Zuma Dogg!"/Arnold Schwarzenegger. "Malibu celebrity"/Malibu Times. (Malibu is home to biggest celebrities in the world. Their hometown newspaper calls Zuma Dogg, "celebrity." Think about the magnitude of awareness on Mr. Dogg.) In August 2014; singer/actor, Jamie Foxx approached Mr. Dogg, in public; to record a selfie video, together, as Mr. Dogg sang one of his songs, for Mr. Foxx & his party. Adam Sandler has been photographed wearing a Zuma Dogg T-Shirt. Stone Temple Pilots have shouted out, Mr. Dogg, on-stage, during their concert. Nearly 10,000 people voted for Zuma Dogg, for L.A. City Mayor in 2009. Run-DMC let Mr. Dogg backstage, at House of Blues show, without a backstage pass. (These are a few of countless examples.) NOT HARD to come across, "ZUMA DOGG." It's not unreasonable to think any of these, "Marvin Gaye," writers are fans of/aware of Zuma Dogg; and have listened to his music.
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