Lion King Composer vs. Comedian Dispute Leads to ~$40K Attorney Fee Award Against Composer

From Morake v. Mwanyenyeka, decided Friday by Judge Josephine Staton (C.D. Cal.):

Plaintiff Lebohang Morake is the creator and original performer of “Nants’ingonyama bagithi Baba,” the opening chant from Disney’s The Lion King. Defendant Learnmore Mwanyenyeka is a comedian and content creator.

Defendant appeared on a podcast, where he asserted that “Nants’ingonyama bagithi Baba” means “Look, there’s a lion. Oh my god” in the Zulu language. The podcast was posted on YouTube and went viral. Defendant has been repeating this assertion at various comedy clubs. Plaintiff maintains that Defendant’s assertion is false, and that the true translation of “Nants’ingonyama bagithi Baba” is “All hail the king, we all bow in the presence of the king.”

On March 16, 2026, Plaintiff filed the instant action, bringing claims for (1) misleading representation in violation of the Lanham Act, 15 U.S.C. § 1125; (2) defamation per se; (3) trade libel; and (4) tortious interference with prospective economic advantage against Defendant, for Defendant’s “mischaracterization of the true meaning of ‘Nants’ingonyama bagithi Baba.’”

Defendant filed an anti-SLAPP motion to strike the state law claims, arguing that the case should be promptly dismissed because it’s meritless and because it’s based on speech on matters of public interest. (State anti-SLAPP motions can’t apply to federal claims, such as the Lanham Act claim.) Plaintiff then dropped the state claims, and refiled a First Amendment Complaint (FAC):

The FAC no longer contained allegations regarding Defendant’s purported mischaracterization of Plaintiff’s work. Rather, the FAC focused on Defendant’s enterprise and its relation to Plaintiff, including Defendant’s “online storefront marketing an ‘It’s a Lion’ line of apparel and goods derived from Plaintiff’s composition.” Plaintiff alleged that “Defendant’s commercial use of the association between Plaintiff and his signature work is likely to cause, and has caused consumers to be confused as to whether Plaintiff is affiliated with … Defendant’s merchandise, performances, and content.” Plaintiff brought claims for (1) false association/false endorsement in violation of the Lanham Act, 15 U.S.C. § 1125, and (2) false advertising in violation of the Lanham Act.

The court concluded that defendant prevailed on the anti-SLAPP motion, though no hearing took place:

Here, Defendant’s Anti-SLAPP Motion targeted the state law claims in Plaintiff’s complaint, arguing that they are barred by the First Amendment. Rather than opposing the Anti-SLAPP Motion, Plaintiff filed a FAC, which dropped all Plaintiff’s state law claims and asserted only two federal law claims. Plaintiff’s FAC no longer focused on Defendant’s “false statements of fact,” but instead alleged that Defendant uses “public association with Plaintiff to attract consumers and drive sales.”

It thus appears to the Court that Defendant’s Anti-SLAPP Motion successfully prompted Plaintiff to drop his state law claims and related allegations. Although Plaintiff could contest the success of the Anti-SLAPP Motion by “show[ing] [he] actually dismissed [the state law claims] because [he] had substantially achieved [his] goals through a settlement or other means, because the defendant was insolvent, or for other reasons unrelated to the probability of success on the merits,” he does not provide any such alternative explanations here.

Because of this, defendant was entitled to have plaintiff pay for the reasonable attorney fees incurred in filing the anti-SLAPP motion, which here amounted to $39,560.

Bryan M. Sullivan and Zachary Hansen (Early Sullivan Wright Gizer and McRae LLP) represent defendant.

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