In the complaint, Cooper and Valentine accuse Brown, Drake and their "No Guidance" collaborators of stealing several elements from “I Love Your Dress,” including the lyrics from the hook -- “she got it; she got it” in “I Love Your Dress” versus “you got it, girl; you got it” in “No Guidance” -- as well as the primary scale degrees and a “distinctive sound effect,” described as “a pitch metronome-like click and a vocal effect through which portions of the primary vocal part appear to have been sped up to a high register and added to double/echo the primary vocal part." According to the complaint, the plaintiffs consulted with “highly regarded musicology experts” to determine similarities between the two tracks.
“To be sure, any comparative analysis of the beat, lyrics, hook, rhythmic structure, metrical placement, and narrative context demonstrates that ‘No Guidance’ was copied or principally derived from ‘I Love Your Dress,’” reads the lawsuit, which was filed by attorney Neil Solomon of McLaughlin & Stern in West Palm Beach, Florida. The complaint notes that "I Love Your Dress" first became available to the public on SoundCloud in July 2016, nearly three years prior to the release of "No Guidance." It was later included on Cooper's 2019 EP My Life in Black & White.
Cooper, Valentine and Signature SKillz Entertainment (the company behind “I Love Your Dress”) are seeking actual and punitive damages, 50% of publishing and revenues derived from “No Guidance,” a complete accounting of all defendants’ financial records related to the song, pre- and post-judgment interest and attorneys’ fees.
"No Guidance" also reached No. 1 on Billboard's R&B/Hip-Hop Airplay, U.S. Adult R&B Songs and U.S. Rhythmic charts and received a nomination for Best R&B Song at the 2020 Grammys. The song's official music video has garnered over 374 million YouTube views, while the complaint notes that its main hook and chorus have been used in advertisements for "various products and/or services."
In order to establish a more direct line between Cooper and Valentine and the “No Guidance” team, the lawsuit notes that in early March 2019, Mic Tee -- an A&R representative with close ties to Drake’s former label Cash Money Records and its associated artist management company, AMAG Collective -- contacted Cooper, allegedly “to discuss Cooper’s musical talents.”
Following that conversation, Cooper sent Tee an email through his marketing agents with a link to My Life in Black & White. Tee then allegedly asked Cooper if he had any unreleased music to send -- “presumably so that Mic Tee and/or his associates could use such music with minimal risk of subsequent infringement claims,” the complaint alleges. Though Cooper never sent any additional songs, he “became suspicious of the interaction” upon first hearing “No Guidance,” which was released in June 2019, several months later.
To further establish that the "No Guidance" team had access to "I Love Your Dress," the complaint adds that during the time that “No Guidance” was being written and recorded, Brown was “in regular and close contact” with Cash Money founder Bryan Williams (a.k.a. Birdman) in their work as co-producers and co-stars on the feature film She Ball.
“Additional social and business-related connections between and among Mic Tee, Cash Money Records, AMAG, Brown, and Drake abound,” the complaint continues, “and further discovery will likely support the assertion that Defendants had access to and actually heard the Work, then incorporated key elements of it when creating No Guidance.”
Later in the complaint, Cooper and Valentine say they notified the defendants of their alleged infringement and demanded monetary relief in a letter sent through their lawyers on Dec. 15, 2020, but claim the letter was ignored.
"The Complaint filed by our office speaks for itself, and we would encourage anyone who is interested to read the allegations set forth in the Complaint in their entirety," says McLaughlin & Stern attorney Chester Ostrowski, who is representing Cooper and Valentine in the case, in a statement sent to Billboard. "The thrust of the Complaint, however, is that Defendants copied Plaintiffs’ original song, I Love Your Dress, in various material respects. Plaintiffs’ song was recorded and published first. Defendants had access to it, and we believe the evidence will show that they knowingly and willfully copied and used significant portions of it, without consent, in creating the infringing song, No Guidance. In Plaintiffs’ view, when taken together, the similarities between the two songs cannot be a mere coincidence. Artists and producers should be properly credited with and compensated for the works that they create, in whole or in part; that is all Plaintiffs are looking for here, and they eagerly await their day in court."
Sony Music Entertainment, which distributed "No Guidance" and is also named as a defendant in the suit, declined to comment for the story.
The other defendants named in the suit are Brown’s production company Chris Brown Entertainment (a.k.a. Culture Beyond UR Experience), songwriter-producer Anderson Hernandez (a.k.a. Vinylz), songwriter-producer Joshua Louis Huizar (a.k.a. J-Louis), songwriter-producer Travis Darelle Walton (a.k.a. Teddy Walton), songwriter Nija Charles (a.k.a. Nija), songwriter Tyler Bryant (a.k.a. Velous), songwriter Michee Patrick Lebrun (a.k.a. Che Ecru) and songwriter-producer Noah Shebib (a.k.a. 40).
Also named are publishing companies Songs of Universal Inc., 1damentional Publishing, Mavor & Moses Publishing (d.b.a. Roncesvalles Music Publishing), Sony/ATV, Vinylz Music Group, JLouisMusic and Songs of Amnija; and Brown's record label RCA Records.