A US federal judge has dismissed a lawsuit filed by Grammy-winning rap duo Salt-N-Pepa against Universal Music Group, ruling that the artists never owned the copyrights to their sound recordings and therefore cannot reclaim them.
Judge Denise Cote of the US District Court for the Southern District of New York issued an opinion and order on Thursday (January 8) granting UMG’s motion to dismiss both claims in the case, which you can read in full here.
Cheryl James and Sandra Denton, professionally known as Salt-N-Pepa, filed the lawsuit in May 2025 seeking to regain their copyrights and physical master recordings. You can read the complaint in full here.
The duo attempted to exercise their termination rights under Section 203 of the Copyright Act, which allows artists to reclaim copyright ownership 35 years after an initial transfer.
Salt-N-Pepa served their Notice of Termination on UMG in March 2022, with the earliest termination date listed as May 15, 2024.
However, Judge Cote ruled that the 1986 agreements on which Salt-N-Pepa based their claim “do not indicate that Plaintiffs ever owned the copyrights to the sound recordings or that they granted a transfer of those rights to anyone else.”
In other words, because Salt-N-Pepa never owned the copyrights in the first place, they cannot use Section 203 of the Copyright Act to reclaim them. The termination provision only applies to artists who previously owned and then transferred their copyrights.
The judge’s decision centered on three agreements executed on May 15, 1986. Salt-N-Pepa signed a recording agreement with Noise In The Attic Productions, Inc. (NITA), a company owned by their producer Hurby Azor. That same day, Azor entered into a distribution agreement with Next Plateau Records, and Salt-N-Pepa signed an inducement letter addressed to Next Plateau Records.
The 1986 NITA Recording Agreement stated that NITA “shall be the sole and exclusive owner of any and all rights, title and/or interest in and to master recordings recorded hereunder, including but not limited to the worldwide sound copyrights therein.”
The 1986 agreement between Azor and Next Plateau Records then transferred those rights, stating that Azor “hereby sells, transfers and assigns to Company [Next Plateau Records]… all aforesaid right, title and interest in and to such Sides including without limitation the sound recording copyright.”
Judge Cote wrote: “It was only Azor and NITA that granted a transfer of rights in 1986 to Next Plateau Records.”
Salt-N-Pepa had argued that their inducement letter constituted a direct grant of their rights to Next Plateau Records.
However, Judge Cote rejected this interpretation, noting that in the letter, Salt-N-Pepa agreed to the representations in the distribution agreement, which included NITA’s representation that it was “the sole and exclusive owner” of the copyrights.
“The statutory text in § 203 is clear: Plaintiffs can only terminate copyright transfers that they executed,” Judge Cote wrote. “They cannot terminate a copyright grant executed by NITA.”
The judge also dismissed Salt-N-Pepa’s conversion claim, which alleged that UMG “intentionally and substantially interfered with Plaintiffs’ possession of their Master Tapes.”
Judge Cote ruled that Salt-N-Pepa failed to plausibly allege their ownership of the Master Tapes.
Thursday’s memorandum noted that UMG is the “successor-in-interest” to both Next Plateau Records and London Records. On May 15, 2024, UMG removed dozens of Salt-N-Pepa’s sound recordings from streaming platforms.
“Even with the court’s complete rejection of their claims, we remain open and willing to find a resolution to the matter and turn the page so we can focus our efforts on working together to amplify Salt-N-Pepa’s legacy for generations to come.”
UMG spokesperson
A Universal Music Group spokesperson told MBW: “While we are gratified that the court dismissed this baseless lawsuit, it should never have been brought in the first place. Prior to this suit—and without any legal obligation to do so—we made multiple attempts to resolve the matter amicably, improve the artists’ compensation, and ensure that Salt-N-Pepa’s fans had access to their music.
“Even with the court’s complete rejection of their claims, we remain open and willing to find a resolution to the matter and turn the page so we can focus our efforts on working together to amplify Salt-N-Pepa’s legacy for generations to come.”
Music Business Worldwide
