Eight Mile Style, LLC v. Meta Platforms, Inc.

District court denies Meta’s motion to dismiss direct copyright infringement claim brought by publishers of 243 musical compositions recorded by Eminem, holding that plaintiffs plausibly alleged Meta reproduced and stored unauthorized copies of their works in music libraries of social media platforms, but grants motion as to all secondary-liability claims for inducement, contributory infringement and vicarious infringement.

Plaintiffs Eight Mile Style LLC and Martin Affiliated LLC, which own and administer 243 copyrighted musical compositions, many recorded by Marshall Mathers (Eminem), brought suit against Meta Platforms Inc., Instagram LLC, and WhatsApp LLC for direct and secondary copyright infringement. Plaintiffs alleged that Meta Platforms Inc. and its subsidiaries Instagram LLC and WhatsApp LLC made the works available without a license, through curated, searchable music libraries on Facebook, Instagram and WhatsApp—libraries that featured algorithmically recommended categories such as “For You” and “Trending”—and through content-creation tools including Stories, Reels, direct-message music stickers, Original Audio and Reels Remix. Plaintiffs asserted claims for direct infringement, inducement of infringement, contributory infringement and vicarious infringement, seeking statutory damages and injunctive relief. Meta moved to dismiss all four counts.

First, the court denied Meta’s motion as to the direct infringement claim. Meta argued the complaint was insufficiently specific because it identified only two of the 243 compositions by name and failed to allege the “who, what, when, where and how” of the infringement. The court rejected this argument, holding that no heightened pleading standard applies to copyright claims in the Sixth Circuit, and that the complaint’s core allegations—that Meta reproduced and stored unauthorized copies of all 243 compositions in the music libraries of its three platforms—were sufficient to put Meta on notice of the alleged conduct at issue. Accepting those allegations as true, the court concluded that unauthorized storage of the works in Meta’s libraries could plausibly constitute reproduction in violation of the Copyright Act.

Turning to the secondary-liability claims, the court dismissed the inducement claim, concluding that inducement is not a stand-alone cause of action. Relying on the U.S. Supreme Court’s recent decision in Cox Communications, Inc. v. Sony Music Entertainment (read our summary of the decision here), the court held that the two recognized categories of secondary copyright liability are contributory and vicarious infringement, and that inducement functions only as a theory for establishing the intent element of contributory infringement, rather than as an independent claim.

Next, the court dismissed the contributory infringement claim, holding that the complaint did not plausibly allege that any user directly infringed the Eight Mile compositions through Meta’s platform tools. In addition, the court held that, even construing the allegations favorably, the complaint did not support an inference that Meta affirmatively encouraged or induced users to infringe. The court emphasized that encouraging users to employ platform features capable of substantial non-infringing uses is not equivalent to encouraging infringement, and that under Cox, mere knowledge that a service may be used to infringe is insufficient to establish the requisite intent.

Finally, the court dismissed the vicarious infringement claim. The court found that plaintiffs adequately alleged the first element—the right and ability to supervise the infringing conduct—because the complaint stated Meta had the power to “stop or limit” the infringement. Plaintiffs failed to plead the second element—a direct financial interest in the infringement—however, because Eight Mile’s allegations that Meta derived a direct financial benefit through advertising revenue, sponsored posts and subscription fees were conclusory. The court held that the complaint did not establish a plausible nexus between the presence of the Eight Mile compositions specifically and any financial benefit to Meta. Rather, the court noted, advertising and subscription revenue could derive from a number of other sources.

Meta was ordered to answer the only remaining claim for direct infringement by July 7, 2026.

Summary prepared by Safia Gray Hussain and Chloe Gordils