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6th Circuit Finds 'Bow Wow' Belongs to Clinton

On April 23, 2008, Judges Daughtrey, Cook and Farris of the 6th U.S. Circuit Court of Appeals in Nashville donned their robes and heard oral argument in the matter of Bridgeport Music, Inv. v. UMG Recordings, Inc. Last week, the 6th Circuit delivered its considered judgment in the case: The phrase "bow wow wow, yippie yo, yippie yea" belongs exclusively to funk legend George Clinton, who used it in his song, "Atomic Dog."

In a 2006 interview with NPR, Clinton admits he ad-libbed most of the lyrics in the seminal 1982 funk track.

I just had the word 'dog,'" Clinton says. "That's all I had in my mind. I had to ad lib a lot of it. The track was atomic. It's a futurist track... I don't still hear no tracks like that one.

Bits and pieces of the song have been sampled dozens of times by hip-hop artists, perhaps most famously by Snoop Dogg in "Who Am I? (What's My Name?)." But the 6th Circuit affirmed the lower court's jury instructions concerning the defendant's alleged misuse "and repetition of the word 'dog' in a low tone of voice at regular intervals and the sound of rhythmic panting" in Public Announcement's allegedly infringing song, “D.O.G. in Me.” Among other things, the court cited the testimony of an expert musicologist, who said that "the Bow Wow refrain 'is one of the most memorable parts of the song.'" In terms of iconology, the Court explained, the Bow Wow refrain was "perhaps the functional equivalent of 'E.T., phone home.'”

Refresh your memory of "Atomic Dog," "bow wow wow, yippie yo, yippie yea," and the "repetition of the word 'dog" in a low tone of voice at regular intervals and the sound of rhythmic panting" below.

Posted by Bruce Carton on November 13, 2009 at 03:45 PM | Permalink | Comments (0)


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