Taylor Swift’s legal team has filed a second motion to dismiss the trademark infringement lawsuit brought by Las Vegas performer Maren Flagg over the branding of Swift’s album The Life of a Showgirl, calling the amended claims “absurd.”
The motion, filed on June 30 in the US District Court for the Central District of California, targets the First Amended Complaint that Flagg filed on June 16. It was filed on behalf of all four defendants — Swift, TAS Rights Management, UMG Recordings, and UMG’s merchandise arm Bravado International — by attorneys at Venable LLP.
“This lawsuit is merely Plaintiff’s latest attempt to generate publicity by associating herself with Ms. Swift,” the filing states.
The Legal Argument
Swift’s lawyers argue that the amended complaint “fares no better” than the original, which they first moved to dismiss in May. The new motion deploys a First Amendment defense as its threshold argument, invoking the Rogers v. Grimaldi test — a legal doctrine that shields expressive works from trademark claims unless the challenged title has no artistic relevance to the underlying work, or explicitly misleads consumers as to its source.
“Plaintiff does not — and cannot — allege that the Album title lacks artistic relevance to the underlying work,” the filing states. “Nor does she plausibly allege the title explicitly misleads (or misleads at all) as to source.”
The motion cites a December 2025 ruling in Lost International, LLC v. Germanotta, in which a judge in the same district denied an injunction sought against Lady Gaga over her use of “Mayhem” as an album title and on related merchandise. That ruling found that an album title and its associated promotional goods are expressive works protected by Rogers.
Likelihood of Confusion
On the question of likelihood of confusion, the defendants argue that Flagg’s cabaret show, book, podcast, and video content bear no resemblance to a musical album and its promotional merchandise.
“Plaintiff is a ‘comedian’ and cabaret performer who has never released any music,” the filing states. “In contrast, Ms. Swift has never offered a cabaret show (comedic or otherwise), or any live performance in connection with the Album.”
Jurisdiction Challenge
The motion also challenges the court’s personal jurisdiction over Swift and TAS Rights Management, arguing that neither is domiciled in California, and Flagg has not alleged forum-directed conduct giving rise to her claims. The filing states that Swift “does not own, operate, or control an office in California” and that her business is based in Tennessee.
All of TASRM’s work, including IP ownership, licensing, and commercialization, is directed from Tennessee, and all of Swift’s promotional appearances for the album occurred outside of California, according to the filing. Decisions concerning the album were made at Republic Records in New York, the motion states, despite UMG’s headquarters being located in California.
The Background
Flagg first sued Swift in March, alleging that the branding of Swift’s twelfth studio album threatened to “drown out” her Confessions of a Showgirl trademark, which she registered in 2015. The Life of a Showgirl was released in October 2025 and sold more than 4 million equivalent album units in its first week in the US.
The defendants seek dismissal with prejudice, meaning Flagg would not be permitted to amend her complaint a second time. A hearing on the motion is scheduled for October 7.
The Bottom Line
Taylor Swift’s legal team has filed a motion to dismiss the “Showgirl” trademark lawsuit in US federal court, arguing that the amended claims are “absurd” and that the album title is protected under the First Amendment. The motion also challenges the court’s jurisdiction over Swift and her company, stating they are based in Tennessee, not California. A hearing is set for October 7.
