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Bridgeport Music, Inc. v. Dimension Films (2005)

The 6th Circuit precedent establishing that any physical sampling of a master sound recording, no matter how brief, constitutes automatic copyright infringement.

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Reader answer checklist

This guide is structured to answer the practical questions a reader should resolve before relying on the topic.

Direct answer
Bridgeport is a Sixth Circuit precedent rejecting a de minimis defense for unauthorized copying of a sound recording, so sampling should be cleared or replaced in the relevant jurisdiction.
Who this is for
Artists, producers, labels, and sample-clearance teams evaluating a recording that contains a recognizable or hidden sample.
Practical example
A producer who copies a small piece of a master should not assume that its brevity makes the use safe; the team should seek a license or create a new recording.
Limits and exceptions
Bridgeport is a circuit decision, composition rights are separate, and other jurisdictions may apply different rules such as the Ninth Circuit approach.
What to do next
Identify whether the use copies the master, the composition, or both, then obtain clearance or legal advice before release.

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Editorial record

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Last edited
2026-07-17
Reviewed
2026-08-07
Reviewer
Michael Ruiz

Reviewed by Michael Ruiz on 2026-08-07. Recheck date-sensitive rules and contract terms for a specific matter. See the editorial policy for the review process.

Bridgeport Music, Inc. v. Dimension Films, 410 F.3d 792 (6th Cir. 2005)

This case represents one of the most famous and controversial decisions in digital music copyright history, establishing the absolute boundary of sampling.

The Infringement Details

The dispute arose over a two-second guitar arpeggio sample from Funkadelic's song "Get Off Your Ass and Jam." The hip-hop group N.W.A. lowered the pitch, looped it, and placed it as background audio in the movie *I Got the Hook Up*. Bridgeport Music (the publisher of Funkadelic's composition) and Westbound Records (the owner of the sound recording master) sued Dimension Films for infringement.

The 6th Circuit Ruling

The 6th Circuit Court of Appeals ruled that there is no de minimis defense for sampling sound recordings. The court rejected the argument that the sample was too brief or altered to be recognizable.

Under Section 114, the court held that any physical copying of a sound recording constitutes automatic copyright infringement: > *"Get a license or do not sample. We do not think this is an heroic requirement."*

Real-World Impact

This ruling established a strict, zero-tolerance licensing requirement for the hip-hop and electronic music industries within the 6th Circuit (which includes Nashville). It forced labels and distributors to implement strict, exhaustive master clearance checklists.

Timeline diagram of Bridgeport Music v. Dimension Films. A two-second Funkadelic guitar sample was pitched, looped, and used in a film without a license. Bridgeport Music and Westbound Records sued, and the 6th Circuit ruled there is no de minimis defense for sampling master recordings, establishing the standard: get a license or do not sample.Timeline diagram of Bridgeport Music v. Dimension Films. A two-second Funkadelic guitar sample was pitched, looped, and used in a film without a license. Bridgeport Music and Westbound Records sued, and the 6th Circuit ruled there is no de minimis defense for sampling master recordings, establishing the standard: get a license or do not sample.2-Second Funkadelic Guitar SamplePitched, Looped, Used in Film Without LicenseBridgeport Music + Westbound Records Sue6th Circuit: No De Minimis Defense for Masters“Get a License or Do Not Sample”
The 6th Circuit's rule has no exceptions for length or alteration — any physical copy of a master recording needs a license, full stop.

Educational Disclaimer: This document is provided for educational and informational purposes only and does not constitute legal or financial advice.