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In Campbell, the Supreme Court distinguished between parody, which makes humorous use of a prior work for the purpose of commenting on that prior work, and satire, which makes use of a prior work to make fun of, or comment on, something other than the prior work. In Gordy, the court determined that the lyric “everyday I’m shufflin'” was not a parody of the Ross lyric because it does not subject the latter to criticism or ridicule, but rather, uses Ross’s lyric as a way to “avoid the drudgery in working up something fresh,” citing the Supreme Court’s canonical fair use ruling, Campbell v. Parody, which is a work that mocks or criticizes the original work through humor, is a form of commentary that typically is considered a favored type of use under the first fair use factor. In determining whether a particular unlicensed use is privileged as fair use, the courts consider four, non-exclusive factors: (1) the purpose and character of the use (2) the nature of the copyrighted work (3) the amount and substantiality of the portion of the work used and (4) the effect of the use on the potential market for or value of the work. The fair use doctrine creates a limited privilege for users of copyrighted works to use copyrighted material without the owner’s consent. The electronic dance duo argued that the song’s use of the lyric “everyday I’m shufflin” was meant to be a “humorous parody of, and comment on, the drug dealing, daily hustle, and lifestyle of criminal activity described by Rick Ross in Hustlin’”, which features the line “everyday I’m hustlin'.” is also listed as a defendant in the lawsuit, because of its use of the track in a popular television commercial featuring dancing hamsters. LMFAO’s single “Party Rock Anthem” was released in early 2011 and was the most successful song of their career. Williams held that the band’s use of the lyric “everyday I’m shufflin'” was not a parodic use of rapper Rick Ross’s lyric “every day I’m hustlin’”. In a recent ruling denying LMFAO’s bid for summary judgment, US District Judge Kathleen M.