“Volitional Conduct” Doctrine Helps DistroKid Defeat Copyright Infringement Claim–White v. DistroKid
Eric Goldman
FEBRUARY 13, 2025
White created “beats” and got copyright registrations for them. He orally licensed the beats to Rivers for a 50% royalty and a promise to keep booking live performances for White. Rivers incorporated the beats into her album. White alleges that Rivers stopped booking live performances and thereby abrogated the beats license. White, with Rivers’ consent, had uploaded her album to DistroKid, which describes itself as “a service for musicians that puts your music into online
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