The filing states that the song presents, as an “unambiguous matter of fact,” that Drake is a “certified ped*phile,” and alleges that UMG “relentlessly” promoted the track in a misleading way that caused him serious harm. It also argues that the allegation has a “precise” meaning that is “capable of being proven true or false.”The brief also claims the ruling creates a “dangerous categorical rule” by treating rap diss tracks as non-actionable opinion:“The court effectively created an unprecedented and overbroad categorical rule that statements in rap diss tracks can never constitute statements of fact.”
