Dr. Lawrence Ferrara, Ph.D. prepares rebuttal report basically contending that Holla' back is unprotectable as it has been used in numerous pieces and that Holla'back and Young'n do not share any element of original musical expression. However, of over 50 songs presented by the Defense as evidence, none of them (except Young'n (Holla back) and Holla' back) share the numerous admitted similarities divulged during deposition questioning and testimony.

Since Defendants never proved that Boone copied her work from anyone (nor did anyone other than Boone and Defendants share all the similarities noted; thus no PRIOR ART existed for Boone to copy from) and it was proven that Boone's work was published PRIOR TO Defendants, the piece should have been deemed original (in accordance with copyright definition which is not new/novel..it must come from authors creative mind).

Yet, we allege and the court records will show that expert testimony was manipulated, despite regulations  not permitting its use in the analysis, to reach what we now know is the PRO DEFENDANT BIASED RESULTS THAT HAVE PLAGUED ARTISTS FOR CENTURIES; THE ILLEGAL, UNETHICAL, AND UNCONSTITUTIONAL SUMMARY JUDGMENT DISMISSAL of this and hundreds of other cases!

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