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65-406: Wide Angle is the debut studio album by Welsh breakbeat group Hybrid . It was released to critical acclaim, described by The Times as "one of the most moving pieces of electronic music ever". The album was re-released in 2000 as a double-CD edition entitled Wider Angle . The core Hybrid duo of Mike Truman and Chris Healings cooperated with Lee Mullin to create the dance music backbone of

130-590: A chill through the industry that is still felt". In the Washington Post , Chris Richards wrote in 2018 that no case had exerted more influence on pop music, likening it to banning a musical instrument. Some have accused the law of restricting creativity, while others argue that it forces producers to innovate. Since the O'Sullivan lawsuit, samples on commercial recordings have typically been taken either from obscure recordings or cleared, an often expensive option only available to successful acts. According to

195-549: A commodity, and yet sampling has never been more risky". Sampling can help popularize the sampled work. For example, the Desiigner track " Panda " (2015) reached number one on the Billboard Hot 100 after Kanye West sampled it on " Father Stretch My Hands, Pt. 2 " (2016). Some record labels and other music licensing companies have simplified their clearance processes by "pre-clearing" their records. For example,

260-496: A few seconds in length, but this increased with improved memory . In 1988, Akai released the first MPC sampler, which allowed users to assign samples to pads and trigger them independently, similarly to playing a keyboard or drum kit. It was followed by competing samplers from companies including Korg , Roland and Casio . Today, most samples are recorded and edited using digital audio workstations (DAWs) such as Pro Tools and Ableton Live . As technology has improved,

325-412: A long build-up section that leads to a breakdown and a climax, often having numerous sonic elements being added or subtracted from the track at various intervals in order to increase its intensity. Progressive breaks artists include Hybrid , BT , Way Out West , Digital Witchcraft , Momu , Wrecked Angle, Burufunk, Under This and Fretwell. Sampling (music) In sound and music , sampling

390-496: A mainstream audience by the BBC Radiophonic Workshop , which used the techniques to produce soundtracks for shows including Doctor Who . In the 1960s, Jamaican dub reggae producers such as King Tubby and Lee "Scratch" Perry began using recordings of reggae rhythms to produce riddim tracks, which were then deejayed over. Jamaican immigrants introduced the techniques to American hip hop music in

455-470: A piano by playing the recording back at different pitches. The result better resembled a real piano than sounds generated by synthesizers. Compared to later samplers, the Fairlight was limited; it allowed control over pitch and envelope , and could only record a few seconds of sound. However, the sampling function became its most popular feature. Though the concept of reusing recordings in other recordings

520-424: A row, using drum breaks from jazz-funk tracks such as James Brown 's " Funky Drummer " and The Winstons ' " Amen, Brother ", to form the rhythmic base for hip hop songs. DJ Kool Herc's breaks style involved playing the same record on two turntables and playing the break repeatedly, alternating between the two records. Grandmaster Flash perfected this idea with what he called the "quick-mix theory": he would mark

585-475: A wide range of different genres in their sets. This has led to breakbeats being used in many hip hop , jungle / drum & bass and hardcore tracks. They can also be heard in other music, anywhere from popular music to background music in car and clothing commercials on radio or TV. The Amen break, a drum break from The Winstons ' song "Amen, Brother" is widely regarded as one of the most widely used and sampled breaks among music using breakbeats. This break

650-623: A work, and gave the example of two artists both demanding more than 50%, a mathematical impossibility. He instead advocated for a process of clearing samples on a musicological basis, by identifying how much of the composition the sample comprises. According to Fact , early hip hop sampling was governed by "unspoken" rules forbidding the sampling of recent records, reissues, other hip hop records or non-vinyl sources, among other restrictions. These rules were relaxed as younger producers took over and sampling became ubiquitous. In 2017, DJ Shadow said that he felt that "music has never been worth less as

715-501: Is a creative act. In the 1940s, the French composer Pierre Schaeffer developed musique concrète , an experimental form of music created by recording sounds to tape , splicing them, and manipulating them to create sound collages . He used sounds from the human body, locomotives, and kitchen utensils. The method also involved tape loops , splicing lengths of tape end to end so a sound could be played indefinitely. Schaeffer developed

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780-572: Is a subgenre of breaks that is essentially a fusion of breakbeat and progressive house . Much like progressive house, this subgenre is characterized by its " trancey " sound. Its defining traits include extended synthesizer pads and washes, melodic synth leads, heavy reverberation , and electronic breakbeats. However, unlike progressive house, very few progressive breaks tracks have vocals, with most tracks being entirely instrumental or using only electronically altered snippets of vocal samples for sonic effect. Typical progressive breaks tracks will often have

845-551: Is another important early work of sampling, incorporating samples of sources including Arabic singers , radio DJs and an exorcist . Musicians had used similar techniques before, but, according to the Guardian writer Dave Simpson, sampling had never before been used "to such cataclysmic effect". Eno felt the album's innovation was to make samples "the lead vocal". Big Audio Dynamite pioneered sampling in rock and pop with their 1985 album This Is Big Audio Dynamite . Sampling

910-404: Is composed almost entirely of samples, most of which were cleared "easily and affordably"; the clearance process would be much more expensive today. The Washington Post described the modern use of well known samples, such as on records by Kanye West , as an act of conspicuous consumption similar to flaunting cars or jewelry. West has been sued several times over his use of samples. In 2000,

975-632: Is one of the foundations of hip hop , which emerged in the 1980s. Hip hop sampling has been likened to the origins of blues and rock , which were created by repurposing existing music. The Guardian journalist David McNamee wrote that "two record decks and your dad's old funk collection was once the working-class black answer to punk ". Before the rise of sampling, DJs used turntables to loop breaks from records, which MCs would rap over. Compilation albums such as Ultimate Breaks and Beats compiled tracks with drum breaks and solos intended for sampling, aimed at DJs and hip hop producers . In 1986,

1040-702: Is permitted. In Grand Upright Music, Ltd. v. Warner Bros. Records Inc (1991) and Bridgeport Music, Inc. v. Dimension Films (2005), American courts ruled that unlicensed sampling, however minimal, constitutes copyright infringement. However, VMG Salsoul v Ciccone (2016) found that unlicensed samples constituted de minimis copying, and did not infringe copyright. In 2019, the European Court of Justice ruled that modified, unrecognizable samples could be used without authorization. Though some artists sampled by others have complained of plagiarism or lack of creativity, many commentators have argued that sampling

1105-466: Is protected under American fair use laws, which grant "limited use of copyrighted material without permission from the rights holder". The American musician Richard Lewis Spencer , who owned the copyright for the widely sampled Amen break , never received royalties for its use as the statute of limitations for copyright infringement had passed by the time he learnt of the situation. The journalist Simon Reynolds likened it to "the man who goes to

1170-642: Is the reuse of a portion (or sample ) of a sound recording in another recording. Samples may comprise elements such as rhythm, melody, speech, or sound effects. A sample can be brief and only incorporate a single musical note (as is the case with sample-based synthesis ), or it can consist of longer portions of music (such as a drumbeat or complete melody), and may be layered, equalized , sped up or slowed down, repitched, looped , or otherwise manipulated. They are usually integrated using electronic music instruments ( samplers ) or software such as digital audio workstations . A process similar to sampling originated in

1235-629: The E-mu Emulator , Akai S950 and Akai MPC . Sampling is a foundation of hip hop music , which emerged when producers in the 1980s began sampling funk and soul records, particularly drum breaks . It has influenced many other genres of music, particularly electronic music and pop . Samples such as the Amen break , the " Funky Drummer " drum break and the orchestra hit have been used in thousands of recordings, and James Brown , Loleatta Holloway , Fab Five Freddy and Led Zeppelin are among

1300-577: The Florida breaks subgenre followed during the early-to-mid 1990s and had a unique sound that was soon internationally popular among producers, DJs, and club-goers. In 1994, the influential techno act Autechre released the Anti EP in response to the Criminal Justice and Public Order Act 1994 , deliberately using advanced algorithmic programming to generate non-repetitive breakbeats for

1365-501: The Guardian , "Sampling became risky business and a rich man's game, with record labels regularly checking if their musical property had been tea-leafed." For less successful artists, the legal implications of using samples pose obstacles; according to Fact , "For a bedroom producer, clearing a sample can be nearly impossible, both financially and in terms of administration." By comparison, the 1989 Beastie Boys album Paul's Boutique

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1430-457: The Phonogene , which played loops at 12 different pitches triggered by a keyboard. Composers including John Cage , Edgar Varèse , Karheinz Stockhausen and Iannis Xenakis experimented with musique concrète, and Bebe and Louis Barron used it to create the first totally electronic film soundtrack, for the 1956 science fiction film Forbidden Planet . Musique concrète was brought to

1495-507: The drum loops that were sampled occurred during a " break " in the music - for example the Amen break (a drum solo from " Amen, Brother " by The Winstons ) or the Think Break (from " Think (About It) " by Lyn Collins ). Beginning in 1973 and continuing through the late 1970s and early 1980s, hip hop turntablists such as DJ Kool Herc began using several funk breaks in

1560-590: The 1940s with musique concrète , experimental music created by splicing and looping tape . The mid-20th century saw the introduction of keyboard instruments that played sounds recorded on tape, such as the Mellotron . The term sampling was coined in the late 1970s by the creators of the Fairlight CMI , a synthesizer with the ability to record and playback short sounds. As technology improved, cheaper standalone samplers with more memory emerged, such as

1625-411: The 1969 track "Amen, Brother", known as the Amen break , became popular with American hip hop producers and then British jungle producers in the early 1990s. It has been used in thousands of recordings, including songs by rock bands such as Oasis and theme tunes for television shows such as Futurama , and is among the most sampled tracks in music history. Other widely sampled drum breaks came from

1690-635: The 1970 James Brown song " Funky Drummer "; the Think break , sampled from the 1972 Lyn Collins song " Think (About It) ", written by Brown; and Led Zeppelin 's 1971 recording of " When the Levee Breaks ", played by John Bonham and sampled by artists including the Beastie Boys , Dr. Dre , Eminem and Massive Attack . In 2018, the Smithsonian cited the most sampled track as " Change

1755-515: The 1970s. Holger Czukay of the experimental German band Can spliced tape recordings into his music before the advent of digital sampling. The Guardian described the Chamberlin as the first sampler, developed by the English engineer Harry Chamberlin in the 1940s. The Chamberlin used a keyboard to trigger a series of tape decks, each containing eight seconds of sound. Similar technology

1820-549: The 1980s, samples were incorporated into synthesizers and music workstations , such as the bestselling Korg M1 , released in 1988. The Akai MPC , released in 1988, had a major influence on electronic and hip hop music, allowing artists to create elaborate tracks without other instruments, a studio or formal music knowledge. Its designer, Roger Linn , anticipated that users would sample short sounds, such as individual notes or drum hits, to use as building blocks for compositions; however, users sampled longer passages of music. In

1885-823: The American producer Frank Dukes , has been used by artists including Drake , Kanye West , Kendrick Lamar , and J. Cole . In 2020, the US Library of Congress created an open-source web application that allows users to sample its copyright-free audio collection. Instead of sampling, artists may recreate a recording, a process known as interpolation. This requires only the musical content owner's permission, and creates more freedom to alter constituent components such as separate guitar and drum tracks. Sampling has influenced many genres of music, particularly pop, hip hop and electronic music. The Guardian journalist David McNamee likened its importance in these genres to

1950-465: The Beat " by Fab Five Freddy , which appears in more than 1,150 tracks. According to WhoSampled , a user-edited website that catalogs samples, James Brown appears in more than 3000 tracks, more than any other artist. The Independent named Loleatta Holloway as the most sampled female singer in popular music. Her vocals were sampled in house and dance tracks such as " Ride on Time " by Black Box ,

2015-678: The Bridgeport judgement was decided in an American Federal court of appeal , lower courts ruling on similar issues are bound to abide by it. However, in the 2016 case VMG Salsoul v Ciccone , the United States Court of Appeals for the Ninth Circuit ruled that Madonna did not require a license for a short horn sample in her 1990 song " Vogue ". The judge Susan Graber wrote that she did not see why sampling law should be an exception to standard de minimis law. In 2019,

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2080-530: The Los Angeles record label Now-Again Records has cleared songs produced for West and Pusha T in a matter of hours. The owner of sampled material may not always be traceable, and such knowledge is commonly mislaid through corporate mergers, closures and buyouts. For example, Eddie Johns, the author of a song sampled in the 2000 Daft Punk track " One More Time ", has never been located. As of 2021, he

2145-530: The Secret Life of Plants may have been the first album to make extensive use of samples. The Japanese electronic band Yellow Magic Orchestra were pioneers in sampling, constructing music by cutting fragments of sounds and looping them. Their album Technodelic (1981) is an early example of an album consisting mostly of samples. My Life in the Bush of Ghosts (1981) by David Byrne and Brian Eno

2210-416: The album until the song was removed. The journalist Dan Charnas criticized the ruling, saying it was difficult to apply conventional copyright laws to sampling and that the American legal system did not have "the cultural capacity to understand this culture and how kids relate to it". In 2005, the writer Nelson George described it as the "most damaging example of anti-hip hop vindictiveness", which "sent

2275-401: The album was re-released as a double CD package, labelled Wider Angle . The second CD, titled Live Angle , featured a live set with Alex Madge on drums and Jamie Griffiths on turntables , and several singles, including "Kid 2000" with Chrissie Hynde . The US version had 13 tracks and the tracks were mixed differently. Breakbeat The origin of the word "breakbeat" is the fact that

2340-626: The album, with a mix of progressive breakbeat , techno , trance and house . However, they were joined by a wide array of musical personnel for this expansive, symphonic album. Orchestral parts were performed by the Russian Federal Orchestra, conducted by Sacha Puttnam, who was also responsible for the orchestral arrangements. Julee Cruise , best known for the theme of Twin Peaks , supplied vocals on several songs, and Soon E MC added French rapping to "Sinequanon". In 2000,

2405-555: The artist's permission or even knowledge. "Acid breaks" or "chemical breaks" is acid house , but with a breakbeat instead of a house beat. One of the earliest synthesizers to be employed in acid music was the Roland TB-303 , which makes use of a resonant low-pass filter to emphasize the harmonics of the sound. The Asian breakbeat scene is a remix genre blending elements of Freestyle , electro , progressive trance melodies, Florida Breaks drums and Southern rap, Crunk . It

2470-494: The beat, and even to individual sounds by themselves. Individual instruments from within a breakbeat can be sampled and combined with others, thereby creating wholly new breakbeat patterns. With the rise in popularity of breakbeat music and the advent of digital audio samplers, companies started selling "breakbeat packages" for the express purpose of helping artists create breakbeats. A breakbeat kit CD would contain many breakbeat samples from different songs and artists, often without

2535-564: The bestselling single of 1989 in the UK. The orchestra hit originated as a sound on the Fairlight, sampled from Stravinsky's 1910 orchestral work Firebird Suite , and became a hip hop cliché. MusicRadar cited the Zero-G Datafiles sample libraries as a major influence on 90s dance music, becoming the "de facto source of breakbeats, bass and vocal samples". To legally use a sample, an artist must acquire legal permission from

2600-475: The break recorded on their original music release. With the advent of digital sampling and music editing on the computer, breakbeats have become much easier to create and use. Now, instead of cutting and splicing tape sections or constantly backspinning two records at the same time, a computer program can be used to cut, paste, and loop breakbeats endlessly. Digital effects such as filters , reverb , reversing, time stretching and pitch shifting can be added to

2665-401: The copyright holder, a potentially lengthy and complex process known as clearance. Sampling without permission can breach the copyright of the original sound recording, of the composition and lyrics, and of the performances, such as a rhythm or guitar riff. The moral rights of the original artist may also be breached if they are not credited or object to the sampling. In some cases, sampling

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2730-552: The first album created entirely from samples. The E-mu SP-1200 , released in 1987, had a ten-second sample length and a distinctive "gritty" sound, and was used extensively by East Coast producers during the golden age of hip hop of the late 1980s and early 90s. Commonly sampled elements include strings, basslines, drum loops, vocal hooks or entire bars of music, especially from soul records. Samples may be layered, equalized , sped up or slowed down, repitched, looped or otherwise manipulated. A seven-second drum break in

2795-455: The full duration of the tracks, in order to subvert the legal definitions within that legislation which specified in the section creating police powers to remove ravers from raves that "'music' includes sounds wholly or predominantly characterised by the emission of a succession of repetitive beats". In the late 1990s, another style of breakbeat emerged, funky breaks , a style that was incorporating elements of trance , hip hop and jungle . It

2860-464: The hip hop group N.W.A . were successfully sued for their use of a two-second sample of a Funkadelic song in the 1990 track " 100 Miles and Runnin' ". The United States Court of Appeals for the Sixth Circuit ruled that all samples, no matter how short, required a license. A judge wrote: "Get a license or do not sample. We do not see this as stifling creativity in any significant way." As

2925-525: The importance of the guitar in rock. In August 2022, the Guardian noted that half of the singles in the UK Top 10 that week used samples. Sampling is a fundamental element of remix culture . Using the Fairlight, the "first truly world-changing sampler", the English producer Trevor Horn became the "key architect" in incorporating sampling into pop music in the 1980s. Other users of the Fairlight included Kate Bush , Peter Gabriel and Thomas Dolby . In

2990-509: The jazz flautist James Newton filed a claim against the Beastie Boys' 1992 single " Pass the Mic ", which samples his composition "Choir". The judge found that the sample, comprising six seconds and three notes, was de minimis (small enough to be trivial) and did not require clearance. Newton lost appeals in 2003 and 2004. In the 2005 case Bridgeport Music, Inc. v. Dimension Films ,

3055-413: The late 1970s, breakbeats had attained a large presence in hip hop. In the 1980s, the evolution of technology began to make sampling breaks easier and more affordable for DJs and producers, which helped nurture the commercialization of hip hop. Through early techniques such as pausing tapes and then recording the break, by the 1980s, technology allowed anybody with a tape recorder to find the breakbeat. In

3120-492: The late-1980s, breakbeat became an essential feature of many genres of breaks music which became popular within the global dance music scene, including acid breaks , electro-funk , and Miami bass , and a decade later big beat and nu skool breaks . In the early 1990s, acid house artists and producers started using breakbeat samples in their music to create breakbeat hardcore . The hardcore scene then diverged into subgenres like jungle and drum and bass , which generally

3185-438: The most sampled artists. The first album created entirely from samples, Endtroducing by DJ Shadow , was released in 1996. Sampling without permission can infringe copyright or may be fair use . Clearance , the process of acquiring permission to use a sample, can be complex and costly; samples from well-known sources may be prohibitively expensive. Courts have taken different positions on whether sampling without permission

3250-451: The points on the record where the break began and ended with a crayon, so that he could easily replay the break by spinning the record and not touching the tone arm. This style was copied and improved upon by early hip hop DJs Afrika Bambaataa and Grand Wizard Theodore . This style was extremely popular in clubs and dancehalls because the extended breaks compositions provided breakers with more opportunities to showcase their skills. In

3315-482: The possibilities for manipulation have grown. Samples are distributed in sample libraries, also known as sample packs. In the 1990s, sample libraries from companies such as Zero-G and Spectrasonics had a major influence on contemporary music. In the 2000s, Apple introduced "Jam Packs" sample libraries for its DAW GarageBand . In the 2010s, producers began releasing sample packs on online platforms such as Splice . The Kingsway Music Library, created in 2015 by

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3380-400: The program "Mundo Evassion" was broadcast» or «Evassion Planet» which was presented by Dani Moreno. Artists to highlight: Digital Base , Dj Nitro , Jordi Slate, Man, Wally, Kultur, Jan B, Anuschka, Ale Baquero. The breakbeat of Andalusia has been forming its own style, based on a simple structure of "Pre breaks" + "Pre drop" + "Drop". All this repeated a second time with some variations in

3445-513: The song. With this structure, the tracks are mixed when one has passed the drop, until the pre drop of the next one arrives. Respecting the melodies without breaks. Andalusian breakbeat has once again become a mass industry, with festivals almost exclusively dedicated to this genre, such as the Winter Festival, Summer festival, Floridance, Retro fest, or Olibass. Progressive breaks or prog breaks , also known as atmospheric breaks ,

3510-456: The sperm bank and unknowingly sires hundreds of children". Clyde Stubblefield , the performer of the widely sampled drum break from " Funky Drummer ", also received no royalties. DJ Shadow said that artists tended to either see sampling as a mark of respect and a means to introduce their music to new audiences, or to be protective of their legacy and see no benefit. He described the difficulty of arranging compensation for each artist sampled in

3575-476: The tracks " South Bronx ", " Eric B. is President " and " It's a Demo " sampled the funk and soul tracks of James Brown , particularly a drum break from " Funky Drummer " (1970), helping popularize the technique. The advent of affordable samplers such as the Akai MPC (1988) made looping easier. Guinness World Records cites DJ Shadow 's acclaimed hip hop album Endtroducing (1996), made on an MPC60, as

3640-408: The words of Greg Milner, author of Perfecting Sound Forever , musicians "didn't just want the sound of John Bonham's kick drum, they wanted to loop and repeat the whole of ' When the Levee Breaks '." Linn said: "It was a very pleasant surprise. After 60 years of recording, there are so many prerecorded examples to sample from. Why reinvent the wheel?" Stevie Wonder's 1979 album Journey Through

3705-420: Was faster and focused more on complex sampled drum patterns. An example of this is Goldie 's album Timeless . Josh Lawford of Ravescene prophesied that breakbeat was "the death-knell of rave" because the ever-changing drumbeat patterns of breakbeat music didn't allow for the same zoned out, trance-like state that the standard, steady 4/4 beats of house enabled. Incorporating many components of those genres,

3770-460: Was first used on "King of the Beats" by Mantronix , and has since been used in thousands of songs. Other popular breaks are from James Brown 's Funky Drummer (1970) and Give it Up or Turnit a Loose , The Incredible Bongo Band 's 1973 cover of The Shadows ' " Apache ", and Lyn Collins ' 1972 song " Think (About It) ". The Winstons have not received royalties for third-party use of samples of

3835-561: Was not new, the Fairlight's design and built-in sequencer simplified the process. The Fairlight inspired competition, improving sampling technology and driving down prices. Early competitors included the E-mu Emulator and the Akai S950 . Drum machines such as the Oberheim DMX and Linn LM-1 incorporated samples of drum kits and percussion rather than generating sounds from circuits. Early samplers could store samples of only

3900-968: Was originated and made popular by predominantly Vietnamese American and Southeast Asian DJs throughout the U.S. South (Louisiana, Texas, Mississippi, Missouri, North Carolina) during the 1990s and 2000s. Notable active DJs include New Orleans' Dj Babyboi, Tinman, and Loopy. Big beat is a term employed since the mid-1990s by the British music press to describe much of the music by artists such as The Prodigy , Cut La Roc , Fatboy Slim , The Chemical Brothers , The Crystal Method and Propellerheads typically driven by heavy breakbeats combined with four-on-the floor kick drums, synthesizer-generated loops and patterns in common with established forms of electronic dance music such as techno and acid house . Breakbeat combined with electro music, often using 80s synths, robotic sounds, vocals with vocoders or talkboxes , and infused with elements of funk . Electro breaks

3965-521: Was owed an estimated "six-to-seven-figure sum" based on streams. In 1989, the Turtles sued De La Soul for using an unlicensed sample on their album 3 Feet High and Rising . The Turtles singer Mark Volman told the Los Angeles Times : "Sampling is just a longer term for theft. Anybody who can honestly say sampling is some sort of creativity has never done anything creative." The case

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4030-536: Was pioneered by Afrika Bambaataa & The Soulsonic Force , Kraftwerk , Man Parrish , Cybotron , Newcleus and In Spain from the mid-1990s to early 2000s, breakbeat became a massive social movement, especially in the southern part of the country, Andalusia . Largely responsible for the spread of the "broken rhythm" in Andalusia, was the public radio station of the autonomous community: Canal Sur Radio and Canal Fiesta known at that time as "Fórmula 1", where

4095-543: Was pioneered by the Chemical Brothers and James Lavelle 's Mo'Wax Records imprint. The genre had commercial peak in 1997, when such music was topping in pop charts and often featured in commercials. The most notable artists of the sound were The Prodigy , Death in Vegas , The Crystal Method , Propellerheads . The tempo of breaks tracks, ranging from 110 to 150 beats per minute, allows DJs to mix breaks with

4160-496: Was popularised in the 60s with the Mellotron . In 1969, the English engineer Peter Zinovieff developed the first digital sampler, the EMS Musys . The term sample was coined by Kim Ryrie and Peter Vogel to describe a feature of their Fairlight CMI synthesizer, launched in 1979. While developing the Fairlight, Vogel recorded around a second of piano performance from a radio broadcast and discovered that he could imitate

4225-502: Was settled out of court and set a legal precedent that had a chilling effect on sampling in hip hop. In 1991, the songwriter Gilbert O'Sullivan sued the rapper Biz Markie after Markie sampled O'Sullivan's " Alone Again (Naturally) " on the album I Need a Haircut . In Grand Upright Music, Ltd. v. Warner Bros. Records Inc , the court ruled that sampling without permission infringed copyright. Instead of asking for royalties, O'Sullivan forced Markie's label Warner Bros . to recall

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