> 1.Wixen brings this action against Spotify for willfully infringing the copyrights in the musical compositions listed in Exhibit A (each a “Work” and collecti

> 1.Wixen brings this action against Spotify for willfully infringing the copyrights in the musical compositions listed in Exhibit A (each a “Work” and collectively the “Works”). Wixen is an independent music publisher and exclusive licensee of the Works, all of which have either been registered or are pending registration with the United States Copyright Office. Spotify is the world’s most dominant music streaming and limited downloading service. As Spotify has publicly admitted, and as recent lawsuits and settlements confirm, Spotify has repeatedly failed to obtain necessary statutory, or “mechanical,” licenses to reproduce and/or distribute musical compositions on its service. Consequently, while Spotify has become a multibillion dollar company, songwriters and their publishers, such as Wixen, have not been able to fairly and rightfully share in Spotify’s success, as Spotify has in many cases used their music without a license and without compensation. 2.A recent proposed settlement involving rights holders and Spotify inthe class action lawsuit Ferricket al. v. Spotify USA Inc. et al.,No. 1:16-cv-8412(AJN) (S.D.N.Y.)(Dkt. # 167-3 (“Proposed Settlement”))does not adequately compensate Wixen or the songwriters it represents. Wixen has and, to the extent not yet effected, will opt out the Works from the Proposed Settlement. From the actual lawsuit. https://www.scribd.com/document/368281292/Wixen-Music-Publishing-Inc-v-Spotify-USA-Inc-Copyright-Infringement#from_embed https://www.scribd.com/document/368281292/Wixen-Music-Publis...