- Judge dismisses copyright case citing lack of substantial similarity
- Plaintiffs ordered to pay partial defense legal fees
- Carey's hit generates $3M+ annually in streaming revenue
- Case highlights challenges in protecting holiday song concepts
In a decisive ruling with implications for music copyright law, U.S. District Judge Mónica Ramírez Almadani determined Mariah Carey's 1994 holiday classic contains no actionable similarities to a 1989 country song sharing its title. The court found both tracks employ universal Christmas motifs like Santa Claus letters and materialistic disillusionment that predate either composition.
Legal experts note this decision continues a trend of courts requiring concrete melodic or lyrical copying rather than conceptual parallels. This ruling reinforces that copyright protects expression, not ideas,explains entertainment attorney Lauren Ballard. Seasonal songs face particular challenges given the limited pool of holiday imagery.
The plaintiffs' argument relied heavily on structural comparisons analyzed by musicologists. However, defense experts demonstrated 78% of disputed lyrical elements appear in pre-1989 Christmas standards. Notably, the court sanctioned the claimants for failing to verify their copying allegations through basic musical analysis.
Carey's chart-topper has evolved into a cultural phenomenon, with streaming platforms reporting 1.2 billion annual plays during December. Industry analysts attribute its resurgence to social media trends and Gen Z's nostalgia for 90s pop. A 2023 MIDiA Research study shows holiday streams grew 58% faster than overall music consumption last season.
This case mirrors a 2018 UK dispute over Slade's Merry Xmas Everybody,where courts similarly rejected claims based on generic Christmas themes. Legal scholars suggest such rulings may deter speculative copyright claims while encouraging artists to modernize traditional concepts.
The decision comes as streaming services face pressure to better compensate legacy artists. Spotify's recent Holiday Hits playlist generated $28M in ad revenue, yet Carey reportedly receives less than 15% of total song earnings. This financial context underscores why copyright clarity remains crucial for seasonal staples.
Judge Almadani's sanctions order specifically criticized the plaintiffs' legal team for ignoring streaming-era copyright precedents. Music attorneys now predict tighter scrutiny of musicology reports in future cases, particularly those involving public domain elements.
