The problem is this: Genius isn’t the copyright holder for these lyrics, it just licenses them itself.

Its allegations against Google, Judge Margo Brodie of the Eastern District of New York determined, amount to copyright violations, in nature if not in name, and copyright is outside Brodie’s jurisdiction.

Plaintiff’s allegations that Defendants “scraped” and used their lyrics for profit amount to allegations that Defendants made unauthorized reproductions of Plaintiff’s lyric transcriptions and profited off of those unauthorized reproductions, which is behavior that falls under federal copyright law.

Instead, Plaintiff’s claims are precisely the type of misappropriation claims that courts have consistently held are preempted by the Copyright Act.

Given that the Court finds that all of Plaintiff’s state law claims are preempted by the Copyright Act, and Plaintiff has not asserted any federal law claims, the Court dismisses the Complaint for failure to state a claim.