X-Nico

2 unusual facts about Grand Upright Music, Ltd. v. Warner Bros. Records Inc.


All Samples Cleared!

The title was a reference to the court battle over an illegal sample Biz used on his 1991 song "Alone Again."

I Need a Haircut

The resulting case was Grand Upright Music, Ltd. v. Warner Bros. Records Inc., in which the court granted an injunction against the defendants to prevent further copyright infringement of the plaintiff's song by sampling and referred them for criminal prosecution.


Grand Upright Music, Ltd. v. Warner Bros. Records Inc.

As early as 1989, Dr. Dre's production was styled around fewer samples per track, studio instrumentation, and heavy sampling from artists – Parliament-Funkadelic most notably in Dre's case – who were amenable to having their music sampled by hip hop producers.

Biz Markie, a rapper signed to Warner Bros. Records, had sampled a portion of the music from the song "Alone Again (Naturally)" by singer/songwriter Gilbert O'Sullivan, for use in "Alone Again", a track from Markie's third album, I Need a Haircut.

Records such as those produced by The Bomb Squad for Public Enemy, filled with literally dozens of samples, were no longer possible: each and every sample had to be cleared to avoid legal action.

Hilary Estey McLoughlin

From 2006-2013, she served as President of Warner Bros. Television's syndication production house Telepictures Productions.


see also