CASSANDRA SPANGLER, ESQ. 276 Fifth Avenue, Suite 704 New York, New York 10001 (917)300-9557 cass.spangler@gmail.com January 26, 2016 Digital Music News 1158 26th Street, Suite 206 Santa Monica, California 90403 RE: Coast 2 Coast Mixtapes Dear Digital Music News: I write on behalf of my client, Lil Fats, Inc. (d/b/a Coast 2 Coast Mixtapes) (“Coast 2 Coast”), with regard to a posting on your website, www.digitalmusicnews.com, dated January 21, 2016 and entitled 5 Music Industry Schemes That Still Exploit Artists” (the “Post”), a copy of which is attached hereto. The Post includes screenshots of what appear to be Coast 2 Coast's social media pages and website and refers to Coast 2 Coast as “scummy” and its business model as a “scheme”, and it is my client's position that this posting is defamatory to the Coast 2 Coast name, constituting libel under New York law. According, I write to demand that all references to Coast 2 Coast be removed from this Post immediately, including, but not limited to, images referring to Coast 2 Coast. The elements of a cause of action for libel in the State of New York are: (1) a false and defamatory statement of fact; (2) regarding the plaintiff; (3) which is published to a third party; and (4) results in injury to the plaintiff. See, e.g., Intellect Art Multimedia, Inc. v. Milewski, 899 N.Y.S.2d 60 (Sup. Ct, N.Y. Co. 2009). Moreover, where the defendant, among other situations, states a false fact that tends to injure the plaintiff in his businesstrade or profession, such conduct constitutes libel per se, and the plaintiff is not even required to allege damages. See, e.g., Liberman v. Gelstein, 80 N.Y.2d 429 (N.Y. 1992). The Post makes false statements about Coast 2 Coast and has been published on the internet for public viewing, and these false statements have resulted in significant injury to Coast 2 Coast's business reputation and professional relationships. See Liberman, 80 N.Y.2d 429; Milewski, 899 N.Y.S.2d 60, Accordingly, the Post constitutes not only libel, but libel per se, by Digital Music News against Coast 2 Coast! Given the above, this correspondence shalll serve as notice for Digital Music News to remove the libelous references to Coast 2 Coast immediately, including, but not limited to, screenshots of the Coast 2 Coast website and social media accounts, and to refrain from making any additional defamatory statements regarding Coast 2 Coast. In the event that Digital Music News fails to remove all references to Coast 2 Coast within five (8) days following the date of this correspondence, Coast 2 Coast intends to explore and pursue any and all remedies available to it by law, including, among others, the possible filing of a lawsuit against Digital Music News seeking monetary damages and an injunction? ‘Thank you for your immediate attention to this matter and for your every anticipated cooperation. You and/or your counsel may contact me directly should you have any questions or concerns about this correspondence or the content set forth herein. Your internet domain registrar has been copied on this correspondence. Siferel. i fassandra Spangler, Esq. CSjst u Encl. Via USPS Priority Mail del. conf. no. ce: Namesecure.com (via Email Onh Abuse@web.com) ' Moreover, itis noted that even if Digital Music News were to attempt to claim “media publisher or broadcaster” status in this context, the Post nonetheless constitutes libel as Digital Music News does not appear to have consulted any “authoritative source” in publishing the alleged information about Coast 2 Coast in Post. See Chapadeau 2. Utica Obersereer Dispatch, 38 N.Y.2d 196, 199-200 (N.Y. 1975). > Any and all statements contained herein have been made in an effort to settle this matter without resorting to litigation; however, in the event thatthe parties are unable to do so, none of the statements or content set forth herein shall be admissible against Coast 2 Coast in a court of lav, nor shall this correspondence be construed as a waiver of any of Coast 2 Coast legal rights with regard to this matter, each and every one of which is expressly reserved. See N.Y.CP.LR. § 4547.PVH |g Minune eNO am op (9/72 52.85 23trenvehwwlcalveyI Bhp? cparamex2_bannarde208_soneid=29__cona68109600_cadestnpi3AMOFUOFDUNRZF 18674) (& Dicitai Music News” [Boro nee tcebookcomtiimisnens) | (hse comiitalnscn) |) (ip Meets eeu combigtamuscnes) HOME) JOBS /JOBS/1 CONFERENCES C/CONFERENCES/) CHARTS (HTTP://WWW DIGTALMUSICNEWS.COM/CHARTS/) ADVERTISE (HTTP.//WWU.DIGITALMUSICNEWS.COM ADVERTISE) ABOUT (TTP.//WWU-DIOITALMUSICNEWS.COM/ABOUT/3 5 Music Industry Schemes That Still iAAGNIFL Exploit Artists Never Miss a Cee peared Great Show (napa 52.81 250Re—Ne (hts: facebook.con/PRODUKTEX/ *ef=nt) Let me start by saying that this arti Is going to piss a ot of people off. If youte one ofthe millons (es millons) of independent artsts/prodicers out there trying to make something of youself, youre, {aing to love what I'm about to tell you. Tf youre one of the shady opportunist stil ying to “hustle” Your way into'a quick buck, you're going to hate me. I must be totaly unapologetic about this. T dont are ether, Why Do Schemes Exist?Lets start by examining wy these schemes work. Artists by nature are not good businesspeople, that's why they get business managers and layers to manage the non-reatve side of ther carer for them, However, is not very realistic for most Independent arts to have those types of resources ‘valabe, For Uat reason, sdiemers know they can expllt your hopes and dreams for ther own profits LUlumately, the cons exist because artists Keep falling for it. Artists keep falling frit because the schemes are svategically bul upon Toundatons that tap ito the EMOTIONAL sensory stimul for every person inthe World that Wants toe a star. What I mean by that, is they deceve you with false promises that will satisfy your emotional cravings. The Problem With Unsigned Artists Here's the most common problems wth most (tal) unsigned artists + They fall to realize that there are costs associated with every service. ‘They fall to accept that there are NO shortcuts to fame and fortune. “They think thelr alent is ata higher level than what actualy is ‘They think people wil help them for fee. They ae easly manipulated & decoWves. 2 They make erical decisions based off ele emotions and “energy” instead of facts, data, & Togial reasoning. Infact, there are many more that I could lst, but these are the main problems that Ihave seen throughout my years of experience inthe bu, not only as an artist myself but also as a producer, songwriter, engineer, and digital marketer. "Now that we know why the schemes et, let take look at feof hem shall we? The Classic: Pay to Perform Pe Coast 2 Coast Mixtapes Tag an #Indie #Rapper who can rock our stage! Artists sign up now for your chance to perform on tour! RAPPERS Perform for Celebrity Judges! | signup Including Trip emcees (tp: ww gtalmusicnews.com/wp-content/uploads/2016/01/scam.og?d84142) st Accounting Solsion Try iextooke™ Onine Fr FreeBefore 1 even get o why this company is so scummy, I want to point out the word SPONSORED atthe {top of thal AD._ Yes, this i in fact an AD. Td not ask fr this to bea part of my timeline, bat because Facebook targeted advertising aiows them to geotarget my location and interests, they have surely appeared my time, Was even more daguing, tat ewes. Look at he Mes and comments So lets get into the nuts and boks ofthe pay to perform scam. Ah, @ dassi, and one of my personal favorites. The old “perform for celebnity judges!” tick. Or even worse "ABR JOE BLOW FROM SONY ‘WILL BE IN THE BUILDING.” ‘What they don tll you, i that these ABRY'S ae paid to be there, Yes, 99% ofthese folks are only there because they are getting pid. Guess what? Your performance fee's paying thelr salary. Even it they di ke you these arent people that have any real decsion making power. The only Wey to ‘grab the attention of real deision maker sto creat 2 legit online buzz orgaically trough creative ‘Grassroots digtal marketng efforts. ‘Now the real part 1 ove i that they dont tll you upfront that there are submission fees and costs associated th performing. rom beaut ooking in Rounds real exting Goes But, here's the realty fos. | agree tothe for Coast 2 Coast Submissions, Coast 2 Coast LIVE Maling List Optin POLES AND CONDITIONS COAST 2 COAST PERFORMANCE OPPORTUNITIES 1. Allsong submissions wil be screened by the Management Team of Coast 2 Coast Mixtapes and listened to for consideration to perform at the selected event 2. Att wil be responsibe for applicable performance fee I selected. A daposit to lock in the performance sot wil be required (http ww ciitalmusicnes.com/wp-content/uploads/2016/01/scam2.jpg?A8412) performance schedule wih 20 sLIKE YOU xfinity exclusive offer exciave ter > ARTISTS GET BOOKED ON SHOWS! > > 3498 5599 7495 Fad Peete Peg Pry . i (itp cigtalmusionews.com/wp-content/upioads/2016/01/scam3.pog?d641d2) B “This scheme has been around for quite some time. ‘The danger vth this one is that there appears to be legtimacy attached tt because you'e getting the oppertuny to open fr a major ats 1 decided to include this company, Artist Auctions, into the atce after a close and very smart friend ‘of mine asked what I thought of The premise is that you svaight up pay them a fee of anywhere ‘rom $1,000 ~ $3,009, in exchange for stage time as an Opener for @ major arts. “There are so many things wrong with this scenario that I can even think of where to begin. ve ben booked to open for major acts before, and T have GOTTEN PAID for those shows not the ‘opposite. Pease understand that most ofthe audlence is there to see the headliner, not you. ‘ess tha, chances are that they wil be to drunk to even remember who you Were,4LOO0O0LO000Sd S'6XGZL'dO sioz Aine sipida SNIMINO S3IIddNs 3 .WWO9'SdSM1 LW Sf LISIA za \vIS TWLSOd Vs G3LINN WO1sno V 5 a z z 193 ‘OLLVNRINI GSN N3HAN VW * ALIMOLd CASSANDRA SPANGLER 276 STH AVE RM TOS 0006 NEW YORK NY 10001-1827 Zones) a. (COZ! Carrier ~ Leave if No Re SHIP To: DIGITAL MUSIC NEWS: {186 26TH ST STE 208 SANTA MONICA CA 90403-4698 USPS TRACKING # nN 9405 5036 9930 0247 9170 78 Electronic Rate Approved +#038555749 ll ae ‘WAS OL ATU SST aauinowy 39VLsOd AW ALISON