Case 2:15-cv-03462-RGK-AGR Document 139 Filed 03/25/16 Page 1 of 16 Page ID #:3511

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Peter J. Anderson, Esq., Cal. Bar No. 88891

E-Mail: pja@pjanderson.com
LAW OFFICES OF PETER J. ANDERSON
A Professional Corporation
100 Wilshire Boulevard, Suite 2010
Santa Monica, CA 90401
Tel: (310) 260-6030
Fax: (310) 260-6040
Attorneys for Defendants
JAMES PATRICK PAGE, ROBERT ANTHONY
PLANT, JOHN PAUL JONES, WARNER/CHAPPELL
MUSIC, INC., SUPER HYPE PUBLISHING, INC.,
ATLANTIC RECORDING CORP., RHINO
ENTERTAINMENT COMPANY and WARNER
MUSIC GROUP CORP.
Helene Freeman, Esq., admitted pro hac vice
E-Mail: hfreeman@phillipsnizer.com
PHILIPS NIZER LLP
666 Fifth Avenue
New York, NY 10103-0084
Tel: (212) 977-9700
Fax: (212) 262-5152
Attorneys for Defendants
JAMES PATRICK PAGE, ROBERT ANTHONY
PLANT and JOHN PAUL JONES

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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MICHAEL SKIDMORE, etc.,

Plaintiff,

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vs.
LED ZEPPELIN, et al.,
Defendants.

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Case No. 2:15-cv-03462 RGK

(AGRx)
DEFENDANTS NOTICE OF
MOTION AND MOTION IN
LIMINE NO. 6 AND DAUBERT
MOTION TO EXCLUDE SOMACH;
MEMORANDUM OF POINTS AND
AUTHORITIES AND
DECLARATION IN SUPPORT
Date: May 10, 2016
Time: 9:00 a.m.
Courtroom of the Honorable
R. Gary Klausner
United States District Judge

Case 2:15-cv-03462-RGK-AGR Document 139 Filed 03/25/16 Page 2 of 16 Page ID #:3512

TO PLAINTIFF AND HIS ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that on May 10, 2016, at 9:00 a.m. or as soon

thereafter as the matter may be heard in Courtroom 850 of the above-entitled District

Court, located at 255 East Temple Street, Los Angeles, California, defendants James

Patrick Page, Robert Anthony Plant, John Paul Jones, Warner/Chappell Music, Inc.,

Super Hype Publishing, Inc., Atlantic Recording Corporation, Rhino Entertainment

Company and Warner Music Group Inc., will move the above-entitled Court, the

Honorable R. Gary Klausner, United States District Judge presiding, for an Order

excluding the testimony of plaintiffs proffered expert Denny Somach.

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This Motion is brought on the grounds that, as stated more fully in the

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accompanying Memorandum of Points and Authorities, this claimed expert purports

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to opine as to matters that are not relevant, his testimony and opinions are not

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reliable, and his testimony and opinions will unfairly prejudice defendants, confuse

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the issues, mislead the jury, delay the trial and waste trial time.

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This Motion is based upon this Notice of Motion and Motion, the

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Memorandum of Points and Authorities filed with this Notice of Motion and

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Motion, the pleadings and papers on file in this action, the matters of which this

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Court may take judicial notice, and such additional matters and oral argument as

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may be offered in support of the Motion.

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The Motions are made following the conference with plaintiffs counsel

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pursuant to Local Rule 7-3, which took place on March 22, 2016.

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Dated: March 25, 2016

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/s/ Peter J. Anderson

Peter J. Anderson, Esq.
LAW OFFICES OF PETER J. ANDERSON
A Professional Corporation
Attorney for Defendants
JAMES PATRICK PAGE, ROBERT
ANTHONY PLANT, JOHN PAUL JONES,
WARNER/CHAPPELL MUSIC, INC.,
SUPER HYPE PUBLISHING, INC.,
ATLANTIC RECORDING CORP., RHINO
ENTERTAINMENT COMPANY and
WARNER MUSIC GROUP CORP.
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Helene M. Freeman, Esq.

PHILLIPS NIZER LLP
Attorney for Defendants
JAMES PATRICK PAGE,
ROBERT ANTHONY PLANT and
JOHN PAUL JONES

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MEMORANDUM OF POINTS AND AUTHORITIES

1.

INTRODUCTION

Denny Somach, who wrote an unauthorized Led Zeppelin biography, claims

to be a historian and archivist of Led Zeppelin, and purports to opine as to the

historical importance of Stairway to Heaven and that apparent similarities between

other Led Zeppelin recordings and other songs have been noted by some. His

testimony is properly excluded.

First, Somachs Report is not signed by him and does not contain the required

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disclosures. For that reason alone, he is properly excluded.

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In addition, the historical importance of Stairway to Heaven to Led Zeppelin

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is irrelevant because plaintiffs claim is limited to alleged infringements within three

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years preceding his filing of this action. Testimony as to Stairway to Heaven prior

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success and implicitly, prior revenues that are beyond the reach of plaintiffs

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claims will only confuse issues and mislead the jury, all to defendants prejudice.

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Further, testimony as to prior and theoretical claims as to compositions other

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than Taurus, here in the guise of a historical experts testimony, are irrelevant,

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unreliable no attempt is made to prove the validity of the claims and unduly

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prejudicial.

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Somach should be excluded.

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SOMACH SHOULD BE EXCLUDED

Somachs Report Fails to Comply with FRCP 26(a)(2)(B)

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(a)

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Somach purports to be a historian and archivist of Led Zeppelin . . . .

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Anderson Decl. at 10, 3, & Exh. 1. But, (1) he does not disclose his claimed

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qualifications, (2) he does not include copies of the materials he cites, (3) aside from

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referring to an unauthorized biography he wrote, he does not list all publications he

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authored in the previous ten years and (4) does not identify other cases in which he

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has testified as an expert in the preceding four years. Fed. R. Civ. P. 26(a)(2)(B)-

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Case 2:15-cv-03462-RGK-AGR Document 139 Filed 03/25/16 Page 5 of 16 Page ID #:3515

(iii)-(v). Neither did he sign his Report as required by Rule 26(a)(2)(B), and instead

plaintiffs counsel merely typed /s/ and Somachs name.

These are not trivial matters. Initial expert disclosures were due February 10,

2016, and defendants were entitled to know then Somachs qualifications, his

publications, the materials he relied upon and his prior experience, or the lack

thereof, as an expert. Also, his actual signature is required by Rule 26 for a reason:

to confirm Somach, rather than plaintiffs counsel, prepared his Report and Somach

approved it.

For these reasons alone, Somach should be excluded.

The Standards Applicable to Plaintiffs Claimed Expert

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(b)

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Federal Rule of Evidence 702 permits a qualified witness to to testify in the

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form of an opinion or otherwise if: (a) the expert's scientific, technical, or other

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specialized knowledge will help the trier of fact to understand the evidence or to

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determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the

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testimony is the product of reliable principles and methods; and (d) the expert has

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reliably applied the principles and methods to the facts of the case.

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In addition, the Court must ensure that any and all scientific testimony or

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evidence admitted is not only relevant, but reliable. Daubert v. Merrell Dow

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Pharm., Inc., 509 U.S. 579, 589 (1985). In its role as gatekeeper, the district court

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determines the relevance and reliability of expert testimony and its subsequent

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admission or exclusion. Barabin v. AstenJohnson, Inc., 700 F.3d 428, 431 (9th Cir.

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2012) on rehg en banc sub nom. Estate of Barabin v. AstenJohnson, Inc., 740 F.3d

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457 (9th Cir. 2014).

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scientific testimony [but] to all expert testimony. Kumho Tire Co. v. Carmichael,

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526 U.S. 137, 147 (1999).

This basic gatekeeping obligation applies [not] only to

The party offering the expert bears the burden of establishing that Rule 702

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is satisfied. In re ConAgra Foods, Inc., 302 F.R.D. 537, 549 (C.D. Cal. 2014).

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(c)

Somachs Testimony and Opinions as to the Historical Popularity

of Stairway to Heaven to Led Zeppelin

(1)

The Historical Popularity of Stairway to Heaven Is Not

Relevant

The historical popularity of Stairway to Heaven to the band Led Zeppelin,

and . . . the public at large is not relevant to plaintiffs claim that Stairway to

Heaven copies from the musical composition Taurus.

Plainly, the historical popularity of Stairway to Heaven is not relevant to the

liability issue of whether it copies Taurus. As to remedies, plaintiff seeks profits

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attributable to the alleged copying of Taurus.

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relationship between profits and the importance of Stairway to Heaven to Led

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Zeppelin, as opposed to, e.g., the relative popularity of Stairway to Heaven and other

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recordings on the album Led Zeppelin IV, or the importance of Led Zeppelins

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popularity and the performances and skill of its members, to sales of Stairway to

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Heaven (subjects on which Somach does not opine).

However, there is no logical

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Further, the Copyright Acts three year statute of limitations strictly limits any

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potential profit award to profits from the exploitation of Stairway to Heaven after

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May 31, 2011. See, e.g., Jt. R. 26(f) Report (Doc. 75) at 4, 6; 17 U.S.C. 507(b);

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Petrella v. Metro-Goldwyn-Mayer, Inc., 134 S. Ct. 1962, 1969 (2014) (Under the

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Acts three-year provision, an infringement is actionable within three years, and only

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three years, of its occurrence). The historical popularity of Stairway to Heaven also

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is not relevant because defendants are insulated from liability for earlier [alleged]

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infringements of the Taurus musical composition. Id.

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Thus, Somachs assertions that Stairway to Heaven was played at Led

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Zeppelin concerts in the 1970s, that it was the most requested song on radio thirty to

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forty years ago, that the press estimated it to have generated $562 million since

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1971 and that 40 million copies of the album Led Zeppelin IV have been sold since

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Case 2:15-cv-03462-RGK-AGR Document 139 Filed 03/25/16 Page 7 of 16 Page ID #:3517

1971, are not only unsubstantiated but irrelevant because plaintiff is strictly limited

to exploitation after May 31, 2011.

(2)

Somachs Opinions as to Historical Popularity Are Not

Reliable

Neither are Somachs opinions reliable. He fails to provide a resume or

otherwise disclose his supposed qualifications to testify as an expert. Instead, he

merely labels himself a historian and archivist of Led Zeppelin with extensive

experience that he fails to describe or include in his Report.

methodology, if it can be called that, is to quote from articles and books, doing no

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more than serving as a mouthpiece for plaintiff to get before the jury articles and

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books that are themselves inadmissible. See, e.g., Exh. 1 at 2.

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Somach merely parrots hearsay and inadmissible assertions cherry-picked by

plaintiff. That is not reliable expert testimony and Somach should be excluded.

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(3)

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Somachs Opinions as to Historical Popularity Are Unduly

Prejudicial

Somachs testimony is also properly excluded under Federal Rule of Evidence

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Further, his

403.

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There is no probative value in Somachs testimony and opinions.

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example, his testimony that Stairway to Heaven has generated $562 million since

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1971 is based on an article in a magazines website, which is hearsay, lacks

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foundation and not probative of what Stairway to Heaven has earned since May 31,

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2011, the only revenues in issue. As another example, Somachs testimony and

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opinions as to the historical importance of Stairway to Heaven to Led Zeppelin and

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the public is not only speculative but not probative of revenues since May 31, 2011.

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For

Balanced against the lack of any probative value, is the undeniable prejudice

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if Somachs testimony were allowed.

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importance or earnings in the past will only confuse the issues and mislead the jury,

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which can only award relief, if at all, as to profits from alleged infringements within

Assertions as to Stairway to Heaven

Case 2:15-cv-03462-RGK-AGR Document 139 Filed 03/25/16 Page 8 of 16 Page ID #:3518

three years preceding the filing of this case, and in doing so unfairly prejudice

defendants, as well as waste time and delay the trial.

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Somachs testimony and opinions are properly excluded under Federal Rule of
Evidence 403.
(d)

Somachs Opinion that People Have Suggested Other Led

Zeppelin Songs Are Copied from Other Works

(1)

Testimony and Opinions as to Other Claims or Theoretical

Claims Is Not Relevant

Somach provides a litany of Led Zeppelin recordings other than Stairway to

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Heaven that he claims people have suggested may be copied from other works, none

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of which are protected by the one copyright plaintiff sues upon.

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eschews any personal knowledge or view as to the truth of those suggestions, merely

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repeating them as gossip. Exh. 1 at 3 (It is not my place in this report to comment

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on the veracity of those claims).

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plaintiffs attempts to prejudice the jury by parading unproven and even unasserted

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claims, this time again in the guise of a supposed expert.

Somach also

Instead, he is simply another example of

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Prior claims, actual or imagined by others, are irrelevant. United States v.

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Bailey, 696 F.3d 794, 801 (9th Cir. 2012); see, Def. Motions in Limine No. 5 at 3-4.

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Accordingly, Somachs testimony and opinions are not relevant.

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(2)

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Somachs Testimony and Opinions as to Other and

Theoretical Claims Is Not Reliable

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Neither are Somachs testimony and opinion that people have claimed to

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hear similarities between other Led Zeppelin recordings and other works the result

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of reliable scientific or other expert analysis.

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background or even familiarity with the other songs, and does not claim to have

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conducted the analytical dissection required to opine. Instead, he merely purports to

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repeat gossip and innuendo. That is not reliable testimony and he is properly

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excluded.
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He claims no musicological

Case 2:15-cv-03462-RGK-AGR Document 139 Filed 03/25/16 Page 9 of 16 Page ID #:3519

(3)

Somachs Testimony and Opinions as to Other and

Theoretical Claims Is Unduly Prejudicial

That some people have suggested other Led Zeppelin recordings borrowed

from other songs is, as a matter of law, not proof there was copying here. Bailey,

696 F.3d at 800-01.

probative.

As a result, Somachs tallying of such assertions is not

On the other hand, plaintiffs use of Somach and other claimed experts to get

those unproven assertions before the jury would be irremediably prejudicial to

defendants. Testimony of other unsubstantiated claims will confuse the issue, which

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is whether Stairway to Heaven copies protectable expression in the copyrighted

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Taurus musical composition. Testimony of other unsubstantiated claims will also

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mislead the jury, which will assume the Court allows the testimony because it is to

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be taken into account. And once that testimony is heard, the damage cannot be

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undone. Also, testimony as to irrelevant and unproven claims will waste trial time

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and delay the case.

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Somach and this testimony are properly excluded under Federal Rule of

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Evidence 403.

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3.

CONCLUSION

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Somach is another example of plaintiffs attempt to avoid the merits or lack

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thereof of his claims and prejudice the jury, this time with unsubstantiated and

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inadmissible assertions as to exploitation and revenues outside the three-year statute

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of limitations, as well as unsubstantiated and inadmissible accusations of copying in

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other instances. Defendants respectfully submit that in its role as gate-keeper, the

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Case 2:15-cv-03462-RGK-AGR Document 139 Filed 03/25/16 Page 10 of 16 Page ID

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Court should prohibit plaintiffs attempt to misuse a claim of expertise to get in, by

the back door, irrelevant, unreliable and prejudicial testimony.

Dated: March 25, 2016

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/s/ Peter J. Anderson

Peter J. Anderson, Esq.
LAW OFFICES OF PETER J. ANDERSON
A Professional Corporation
Attorney for Defendants
JAMES PATRICK PAGE, ROBERT
ANTHONY PLANT, JOHN PAUL JONES,
WARNER/CHAPPELL MUSIC, INC.,
SUPER HYPE PUBLISHING, INC.,
ATLANTIC RECORDING CORP., RHINO
ENTERTAINMENT COMPANY and
WARNER MUSIC GROUP CORP.
Helene M. Freeman, Esq.
PHILLIPS NIZER LLP
Attorney for Defendants
JAMES PATRICK PAGE,
ROBERT ANTHONY PLANT and
JOHN PAUL JONES

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DECLARATION OF PETER J. ANDERSON

I, Peter J. Anderson, declare and state:

1.

I am an attorney admitted to practice before this Court and all Courts of

the State of California. I have personal knowledge of the following facts and could

competently testify to these facts if called upon to do so.

2.

I represent defendants Warner/Chappell Music, Inc., Super Hype

Publishing, Inc., Atlantic Recording Corp., Rhino Entertainment Company, James

Patrick Page, Robert Plant and John Paul Jones in this action. This Reply

Declaration is submitted in support of their foregoing Motion in limine.

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3.

Attached to this Declaration as Exhibit 1 is a true and correct copy of

Denny Somachs Report in this action.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 25, 2016.

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/s/ Peter J. Anderson

PETER J. ANDERSON

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EXHIBIT 1

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Expert Report of Denny Somach

Qualitative Importance of Stairway to Heaven to Led Zeppelin
and History of Led Zeppelin
Introduction
I have been retained as an expert in this case to provide an opinion of the qualitative
value of Stairway to Heaven to the band Led Zeppelin, and also the public at large. As a historian
and archivist of Led Zeppelin I have extensive experience to address this subject matter.
The song Stairway to Heaven occupies a unique spot in the history Led Zeppelin. It is
widely acknowledged as one of, if not the, greatest rock songs ever written. Its importance to the
band and the history of rock and roll cannot be understated.
Qualifications
I am a published author (Get the Led Out: How Led Zeppelin Became the Biggest Band
in the World-Sterling Books), radio producer, syndicator, archivist, and recognized rock
historian. In addition, I have appeared on the Today Show, CBS Morning Show, Larry King,
CNN, the Michael Smerconish Program, the Howard Stern Show and others to discuss Led
Zeppelins history. I have dedicated a good portion of my life to chronicling Led Zeppelin, their
music, and its significance. My book, Get the Led Out, contains 26 interviews with notable
musicians of the time period, record executives, insiders, and the band members themselves.
Materials Reviewed
I reviewed the following materials:

Get the Led Out: How Led Zeppelin Became the Biggest Band in the World by Denny
Somach
Led Zeppelins Catalogue of Songs
Various Songs Compared to Led Zeppelins Song, such as Dazed and Confused by Jake
Holmes, Babe Im Gonna Leave You by Anne Bredon, etc.
Wisdom from the Gods, John Bonham: Interview with Chris Welch, The Paul Green
School of Rock Magazine, Fall 2006, originally in Melody Maker, John and Jason
Bonham Issue, 1992.
Todd Brabec, American Society of Composers, Authors, and Publishers;
Cameron Crowe, The Durable Led Zeppelin, Rolling Stone, March 1975;
Led Zeppelin: The Complete Guide to Their Music, by Dave Lewis;
Nielsen Broadcast Data Systems and SoundScan;
Recording Industry Association of America;
Danny Strick, president, Sony/ATV Music Publishing;
Alan Wallis, executive director of valuation and business modeling, Ernst & Young
The case docket and filings

EXHIBIT 1
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Qualitative Importance of Stairway to Heaven to Led Zeppelin

From my work and extensive experience as a historian, I can say that Stairway to Heaven
is one of the defining songs of rock and roll and that it is also Led Zeppelins signature song. Led
Zeppelin released a total of 87 songs, but each song obviously holds different weight in the
Zeppelin catalogue. The proportional weight of Stairway to Heaven is far more than most, if not
all, of the rest of Led Zeppelins catalogue. It was the most popular song on Led Zeppelins most
popular album, Led Zeppelin IV.
By almost any conceivable measure, Stairway to Heaven ranks as Led Zeppelins most
important song. Stairway to Heaven was played at every Led Zeppelin show as the groups
centerpiece, main-set grand finale, or encore. Despite never being released as a single, it went on
to become the most requested song on American radio in history and is also widely regarded as
the best-selling piece of sheet music in history. Phil Carson, an executive at Atlantic Records
stated in an interview that Stairway to Heaven was the most played song in the history of rock
radio. Get the Led Out, page 129. He also stated that he was absolutely riveted the first time he
heard Jimmy Page playing the introductory notes to Stairway on the front lawn of Pages house.
Get the Led Out, page 129. Upon being asked, How do audiences react when you play wellknown Zeppelin songs?, John Bonham commented before his death:
I dont know what would happen if we didnt play Stairway to Heaven,
because its become one of the biggest things weve ever done. When
Jimmy plays the first chord in the States, its like instant bedlam, until
Robert comes in with the first line.
Wisdom from the Gods, John Bonham: Interview with Chris Welch, The Paul Green School of
Rock Magazine, Fall 2006, originally in Melody Maker, John and Jason Bonham Issue, 1992.
Jimmy Page told Rolling Stone in 1975 that Stairway to Heaven was total brilliance and that:
To me, I thought "Stairway" crystallized the essence of the band. It had everything there and
showed the band at its best ... as a band, as a unit. Not talking about solos or anything, it had
everything there. We were careful never to release it as a single. It was a milestone for us. Every
musician wants to do something of lasting quality, something which will hold up for a long time
and I guess we did it with Stairway. Cameron Crowe, The Durable Led Zeppelin, Rolling
Stone, March 1975.
Bonham was merely acknowledging the obvious, Stairway to Heaven occupies a
unique place in minds of rock and roll fans across the world. Famed rocker Alice Cooper told
me, in an interview in Get the Led Out, when I asked him what Led Zeppelins best song was:
Well, I think people will always say Stairway to Heaven is the song theyre known for more
than anything else . . . . Get the Led Out, page 188. As many have likewise noted, it has become
far more than just a song in popular culture. In terms of value over time, Stairway to Heaven has
generated over half a billion dollars, with a Conde Nast Portfolio analyzing the value of the song
at $562 million.
In terms of awards and achievements, Stairway to Heaven routinely ranks near the top of
rock song lists across the world. For instance, Rolling Stone stated it was the 8th best guitar song
of all time, while VH1 listed it as the 3rd best rock song ever. Radio stations routinely rank it as
the number 1 Classic Rock song of all time. RIAA ranked it as the 53rd best song of the 20th
Century. The significance of this piece of music, and the iconic introductory notes, are hard to
overstate. Led Zeppelin also recognizes Stairway to Heavens iconic status, as it is one of the
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EXHIBIT 1
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most protected pieces of music in history having never to my knowledge been licensed for
commercial use or having appeared in a commercial, movie, or television show.
The popularity of Stairway to Heaven propelled Led Zeppelin IV to sell almost 40
million albums, and, according to the RIAA website, it is the fourth best-selling album of all
time, and has gone platinum 23 times.

Comparisons of Led Zeppelins Work to Others

During my time chronicling Led Zeppelins history, an unavoidable aspect of Led
Zeppelin has been the comparison of prior artists music to many of Led Zeppelins songs which
purportedly borrow from the previous pieces. It is not my place in this report to comment on
the veracity of those claims, but it is common knowledge in music circles and among Led
Zeppelin aficionados that such comparisons have been made, including between Stairway to
Heaven and Taurus well before this lawsuit was filed on May 31, 2014.
For instance, in an interview with Led Zeppelin biographer Mick Wall, the use of other
artists music by Led Zeppelin came up as a topic of discussion. That interview is included in my
above-referenced book Get the Led Out. The similarities of Dazed and Confused, Whole
Lotta Love, Nobodys Fault but Mine, Bring it On Home, Gallows Pole, and even
Stairway to Heaven, to previous pieces by other artists are noted by Wall. I also appeared on
Howard Sterns radio show to discuss many of these apparent similarities.
Out of Led Zeppelins entire first album, I am aware of only one song, Good Times Bad
Times, to which comparisons have not been made between Led Zeppelins music and that of
previous, uncredited artists. The song Babe, Im Gonna Leave You, has been compared to
Babe Im Gonna Leave You by Anne Bredon--who was later credited on Led Zeppelins
version of the song. The song You Shook Me, has been compared to You Shook Me by
Willie Dixonan artist that Led Zeppelin was heavily influenced by. The song Dazed and
Confused, has been compared to Dazed and Confused by Jake Holmes, who now has an
inspired by credit on the Led Zeppelin song following a lawsuit. The song Your Time Is
Gonna Come, has been compared to Dear Mr. Fantasy by Traffic. The song Black Mountain
Side, has been compared to Black Waterside, by Bert Jansch. The song Communication
Breakdown, has been compared to Nervous Breakdown by Eddie Cochran. The song I Cant
Quit You Baby, has been compared to I Cant Quit You Baby by Willie Dixon. The song
How Many More Times has been compared to How Many More Years, by Howlin Wolf,
another artist upon which Led Zeppelin heavily relied. I incorporate by reference the audio clips
that are being submitted contemporaneous with the plaintiffs expert reports, or identified above.
To be clear, the notion that many Led Zeppelin songs can be compared to previous songs
and artists is not novel and is in fact well known in the music, rock, and the Led Zeppelin fan
communities.
Compensation:
My compensation in this matter is $125 per hour and $250 per hour for trial.

EXHIBIT 1
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Conclusion:
Stairway to Heaven occupies a far more important spot in Led Zeppelins catalogue than
simply just another song. It was a bona fide cultural phenomenon that propelled Led Zeppelin to
previously unreachable levels of fame in the rock and roll world, and which led the song itself to
become the most played song in history, valued at over half a billion dollars. Stairway to Heaven
qualitative importance to Led Zeppelin and the history of rock music is perhaps greater than any
song in history. I also note that many Led Zeppelin songs, including Stairway to Heaven, have
been compared to songs by previous artists. I make no judgment as to whether those claims are
correct, except to note that credit has been changed on several Led Zeppelin songs, such as
Dazed and Confused, and that those comparisons are well known in the music, rock, and Led
Zeppelin fan communities.
I told these opinions with a reasonable degree of historical and professional certainty. I
reserve the right to amend or supplement this report as needed.

February 10, 2016

/s/ Denny Somach__

Denny Somach

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