Sun Trading Distributing Co. v. Evidence Music, Inc.
Plaintiff Sun Trading Distributing Co., doing business as Muse Records and Landmark Records, filed a lawsuit against Evidence Music, Inc. and Kenwood Electronics Corp. alleging unfair competition under Section 43(a) of the Lanham Act and New York State common law. The core of the complaint revolved around the defendants' alleged unauthorized exploitation of sound recordings by jazz artists John Hicks, Edward “Sonny” Stitt, and Antoine Roney. Sun Trading claimed false designation of origin (reverse passing off) for the Stitt recording and false advertising for the Roney recording, leading to consumer confusion. The court granted the defendants' motion for summary judgment on the Lanham Act claims, finding insufficient evidence of actual or likelihood of consumer confusion. Consequently, the court declined to exercise supplemental jurisdiction over the state law claims, dismissing them without prejudice, and denied the plaintiff's cross-motion to amend the complaint.