“In the early 2000s, popular culture was adequately suffused with the concepts of players and haters to render the phrases ‘playas… gonna play’ or ‘haters… gonna hate,’ standing on their own, no more creative than ‘runners gonna run’; ‘drummers gonna drum’; or ‘swimmers gonna swim,’” he wrote. “The concept of actors acting in accordance with their essential nature is not at all creative; it is banal....”
Not only is the concept not creative and banal, he wrote, the lyrics themselves “lack the modicum of originality and creativity required for copyright protection.” Dancing in the hiss of the sizzle, he concluded that they are “too brief, unoriginal, and uncreative to warrant protection under the Copyright Act.”
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