Viren Bhatia
Robinson Cano v. Roc Nation and Jay-Z
Counsel for Roc Nation and Jay-Z (defendants): argue why the court should grant
Roc Nation and Jay Z’s motion to dismiss Cano’s complaint for a declaratory judgment
and breach of contract.
Claim for Breach of Contract elements
1. The existence of a contract between the parties
2. The material performance of their contractual obligations
3. The other party to the contract failed to materially perform their commitments
under the contract
4. damages resulting from the other party not upholding their obligations under
the contract
Cano claims breach of contract for Jay-Z’s failure to give him the bag with $200,000 cash
from Adidas
● This would breach element three of the list above
○ The other party to the contract failed to materially perform their commitments
under the contract
In order to counter this claim evidence has to be shown that Jay-Z/Roc Nation made
reasonable efforts to perform their commitments under contract.
●
●
●
●
Converse was called under Cano’s request, they were not interested in a deal
Jay-Z got him an endorsement deal with Adidas for a 1 million dollars with 200
thousand dollars under the table
Jay-Z’s 50 thousand dollars (If the multibillion dollar company is profitable) is a
very minor amount compared to the 1.2 million dollars Cano was being paid
○ To be clear Adidas is a 38.5 billion dollar company - one deal worth 1
million dollars will not affect whether or not Jay-Z gets paid
His contract was negotiated in good faith and Jay-Z followed through with their
deal and negotiated the contract as promised
○ The payment schedule does not change the fact that Jay-Z did his job,
therefore he is entitled to compensation for that.
Precedent for this case:
● Lee v. Raymond Brothers
○ Precedent for third parties ability to determine breach of contract is discussed
■ They cannot determine breach of contract
○ Cano used the fact that another worker at Roc Nation only had one phone call
with converse as the reason as to why he was not paying Jay-Z his money he
was owed
■ You cannot use a third party as a reason to not fulfill your contract
■ Using this case as precedent, Cano owes the remaining 25% to Jay-Z
and Roc Nation
● Zinn v. Parrish
○ In this case Zinn, Parrish’s agent, sued Parrish for not paying him what he was
owed and won the case
■ The precedent was set regarding reasonable effort in fulfilling your duty
as an agent
○ Jay-Z was told to negotiate the contract and “required to provide services
such as negotiating endorsement agreements and sponsorship deals”
■
○
There was no specification of what exactly this meant, and which
companies he was allowed to make deals with
Jay-Z used what most would consider to be reasonable efforts to get Cano a
payday
Script:
● Introduce myself
● I’m going to be discussing why the court should grant Roc Nation and Jay Z’s motion to
dismiss Cano’s complaint for a declaratory judgment and breach of contract.
● Facts
○ Jay Z got Cano a 10 year 240 mil contract - still owes last 25% of his commission
- doesn’t want to pay
○ Cano wanted converse - got adidas - mad over that
● To start, lets discuss the precedent for this case
○ Zinn V Parrish 1977
■ Discussed reasonable effort
■ In this scenario Jay Z provided reasonable effort in getting Cano an
endorsement deal
■ Jay-Z was told to negotiate the contract and “required to provide services
such as negotiating endorsement agreements and sponsorship deals”
■ No specifics
○ Lee vs Raymond brothers
■ That third parties cannot be the reason you do not fulfill your contract
● Cano used an employee to argue why he should be allowed out of
his contract, however this employee is a third party, as Jay Z
negotiated his contract in good faith.
● Using this case as precedent, Cano owes the remaining 25% to
the defense
● Now when discussing the elements of breach of contract, there is one specific element
that the plaintiff’s will likely use in their arguments,
■ They will likely argue that the defense failed to materially perform their
commitments under the contract because they did not deliver the 200
thousand dollars duffel bag
In order to counter this claim: I will be providing evidence that the defense made reasonable
effort to perform to the guidelines in the contract - prove me otherwise
● Converse was called under Cano’s request, they were not interested in a deal
● Jay-Z got him an endorsement deal with Adidas for a 1 million dollars with 200 thousand
dollars under the table
● Jay-Z’s 50 thousand dollars (If the multibillion dollar company is profitable) is a very
minor amount compared to the 1.2 million dollars Cano was being paid
○ To be clear Adidas is a 38.5 billion dollar company - one deal worth 1 million
dollars will not affect whether or not Jay-Z gets paid
● His contract was negotiated in good faith and Jay-Z followed through with their deal and
negotiated the contract as promised
○ The payment schedule does not change the fact that Jay-Z did his job, therefore
he is entitled to compensation for that.
● End argument - this is why Jay Z and Roc nation should be granted their motion to
dismiss Cano’s complaint for declaratory judgment and breach of contract - thank
you your honor
Sources:
https://www.romanolaw.com/business-disputes/breach-of-contract/