What was filed

The complaint is Document 1 in No. 2:26-cv-12115, U.S. District Court for the Central District of California, filed October 16, 2026. It runs nine pages. Exhibit 1, the sound recording, is being lodged separately, and the docket shows a notice of lodging filed the same day. Exhibit 2 is a copy of the registration certificate. The plaintiff is Aviel Calev Hirschfield of Portland, Oregon. Counsel is Kinsella Holley Iser Kump Steinsapir LLP of Los Angeles, California. Jurisdiction is pleaded under 28 U.S.C. 1331 and 1338(a), and venue under 28 U.S.C. 1391(b) and 1400(a). He demands a jury trial. (Compl. paras. 10 to 12, 18 to 19; pp. 1, 9.)

The complaint alleges, on information and belief, that Drake's primary residence is Toronto, Canada, and that he owns residences in Los Angeles County, California; that OVO Sound LLC is a California limited liability company with its principal place of business in Toronto; and that UMG Recordings, Inc., a Delaware corporation, and Universal Music Publishing, Inc., a California corporation, are each headquartered in Santa Monica, California. (Compl. paras. 13 to 16.)

What the complaint alleges

It alleges Hirschfield composed original lyrics and a vocal melody between December 2025 and January 2026, and on or about January 25, 2026 finished a recording of them in his home studio over an instrumental track that, on information and belief, was produced by a producing duo that had worked with Drake. It alleges he sent the recording to that duo and other producers who work with Drake and heard nothing back. It alleges Janice STFU was released on or about May 15, 2026, with that duo credited as producers and Drake as the sole credited artist, and that its chorus is "literally identical" to his work "in lyrics, melody, and cadence." It alleges, on information and belief, that Drake had access to the work through those producers, and that Janice STFU was released and distributed by OVO under exclusive license to Republic Records, a division of UMG, with UMG distributing it on streaming platforms and in physical copies and UMPG administering the publishing rights. (Compl. paras. 2 to 6, 17, 20 to 22.)

It alleges Hirschfield's representatives gave Drake's representatives a copy of the recording and the recording-software "stems," with metadata the complaint says shows the work was created months before Drake began working on Janice STFU; that the defendants have said Drake wrote the chorus lyrics and melody on his own; and that Drake's litigation counsel sent Hirschfield a cease-and-desist letter. It alleges the song debuted at number one on the Billboard Hot 100 and has more than 300 million streams on Spotify. The complaint says his damages are presently unknown and states no dollar amount. (Compl. paras. 7 to 8, 25, 31.)

Count and relief

The single claim, against all defendants, alleges copyright infringement: that each defendant copied, distributed, publicly performed, or monetized the composition, or authorized others to do so, through Janice STFU, without Hirschfield's consent, and that the infringement was willful. The prayer seeks actual and compensatory damages, disgorgement of the defendants' profits, or statutory damages including enhanced statutory damages for willful infringement (see 17 U.S.C. 504), plus pre-judgment and post-judgment interest, attorneys' fees (see 17 U.S.C. 505), and costs. (Compl. paras. 27 to 32; pp. 7 to 8.)

The complaint says the work, covering both the composition and his vocals from the recording, is registered as Registration No. SRu 1-646-991, effective July 21, 2026. The U.S. Copyright Office public catalog lists Registration No. SRu001646991, an unpublished sound recording and music work titled "audio 5 [2026-01-25 144441]," registered July 21, 2026, with Aviel Calev Hirschfield as author and claimant and the authorship stated as sound recording, lyrics and music. (Compl. paras. 19, 29.)