Copyright for “Happy Birthday” Song Ruled Invalid in US

In Rupa Marya v Warner/Chappell Music, Inc, the United States District Court for the Central District of California (the Court) granted a motion for summary judgment against the defendants, declaring that the copyright claimed by the defendants for the Happy Birthday to You song lyrics is invalid.  The Court held that, because the defendants’ predecessor-in-title to the claimed copyright had not acquired the rights to the lyrics of the song, the defendants did not hold a valid copyright for the song.

The plaintiffs argued that the defendants did not own copyright in the lyrics of Happy Birthday to You, and that the defendants should be ordered to return the “millions of dollars of unlawful licensing fees” collected from wrongfully asserting copyright ownership.  The defendants, on the other hand, argued that, while they were unable to point to conclusive evidence that the copyright to the lyrics of the song had been registered and transferred through a series of agreements with the predecessors-in-title, a reasonable inference was that the rights to the lyrics had been transferred to the defendants.

Notwithstanding the presumption of validity the defendants enjoyed for their registered copyright, the Court concluded that the defendants’ assertions had no support in the record.  The Court found that the defendants had rights to the melody and to certain piano arrangements based on the melody, but never had any rights to the lyrics.  The plaintiffs’ motion for summary judgment was therefore granted.