Producer Jake Angel Beats sues Empire Distribution and two individuals over his Red Dead beat in Make It Out Alive

The complaint

Jacob Angel Higgins p/k/a "Jake Angel Beats" v. Herbert Lamont Clemons, Levi Bloom, Empire Distribution, Inc., and Does 1-10, No. 2:26-cv-11102 (C.D. Cal.), was filed September 25, 2026 (10 pages). Higgins is a music producer in Nashville, Tennessee. The complaint describes Clemons as Bloom's manager, alleges, on information and belief, that Bloom is an author of Make It Out Alive and owns or controls rights in it, and alleges, on information and belief, that Empire, a California corporation, distributes or administers the sound recording. Higgins demands a jury trial. (Compl. caption; paras. 4 to 9.)

What it alleges

The complaint alleges Higgins created and owns the instrumental Red Dead, first published on August 3, 2025 and registered with the Copyright Office. It alleges that on or about January 4, 2026 Clemons bought a nonexclusive license to use Red Dead in one new song in exchange for fifty percent of master royalties and sound recording income, with Higgins keeping fifty percent of the writers' share, and that Clemons later sought an exclusive license, the two did not agree, and Clemons repudiated the royalty split. It alleges Bloom released Make It Out Alive on or about January 8, 2026 with Red Dead as its primary instrumental track, that Higgins sent a notice of breach on or about June 22, 2026, that the license terminated on June 29, 2026 under its terms, and that the defendants have exploited the song since then without a license and paid no royalties. (Compl. paras. 12 to 26.)

The counts and relief

The first claim pleads copyright infringement against all defendants, the second vicarious copyright infringement against all defendants based on streaming services' public performance of the song, and the third breach of contract against Clemons. Higgins alleges, on information and belief, that the infringement was willful. The prayer asks for a constructive trust, an accounting, the defendants' profits and his losses, statutory damages, actual damages and lost profits, interest, and fees and costs. (Compl. paras. 27 to 52; Prayer a to h.)