Hellerstein Denies Universal Music Group’s Fee Bid in Copyright Dispute

MANHATTAN (LN) — U.S. District Judge Alvin Hellerstein on Thursday denied a motion by Universal Music Group for attorneys’ fees in a copyright dispute, ruling that the pro se artist’s claims were not frivolous or objectively unreasonable despite being dismissed as time-barred.

The dispute began when plaintiff Timothy Regisford sued Lynn Lockamy over song copyrights in July 2023. Lockamy counterclaimed and later filed a third-party complaint against Universal Music Group and Tribe Records Limited, alleging they infringed her rights.

Hellerstein granted Universal’s motion to dismiss the third-party complaint on August 25, 2025, finding the claims were time-barred. The case between Regisford and Lockamy settled on February 9, 2026, and Hellerstein dismissed the action.

Universal then moved for attorneys’ fees under 17 U.S.C. § 505, arguing Lockamy’s litigation was motivated by opportunism and lacked legal merit.

Under the Copyright Act, courts may award fees to prevailing parties based on factors including frivolousness, motivation, and the need for deterrence, as outlined in Fogerty v. Fantasy, Inc.

Hellerstein found Lockamy’s arguments were not frivolous. She argued her claims were timely based on the 2021 release of "Make Me Feel Good" by Universal, a position Hellerstein deemed reasonable given the facts and governing law.

The judge also rejected Universal’s claim that Lockamy’s motivation was suspect. While Universal argued Lockamy waited for the song’s commercial success to sue, Hellerstein noted that pursuing litigation before such success would have been financially detrimental to the artist.

"To create a per se rule that litigants must pursue all potential infringement claims, even to their own financial detriment, would create an unworkable system that improperly benefits well-funded litigants," Hellerstein wrote.

Hellerstein concluded that awarding fees to large corporations of an individual artist seeking to protect her copyrights would not advance the purposes of the Copyright Act.

"The Copyright Act aims to 'encourage the production of original literary, artistic, and musical expression for the good of the public,'" Hellerstein wrote, citing Earth Flag Ltd. v. Alamo Flag Co.

Lockamy’s failure to pursue the claim earlier did not indicate ill intent, the judge said, noting that Universal’s arguments on that point were based on mere speculation.

Hellerstein denied the motion for attorneys’ fees and costs, ordering the clerk to terminate the fee motion.

The judge’s ruling underscores the high bar for fee awards in copyright cases, where prevailing status alone does not guarantee compensation for legal expenses.