37. Kesha has repudiated the Gottwald Recording Agreement. In violation of the
terms of the Gottwald Recording Agreement, Kesha has refused to comply with her ongoing obligations to deliver sound recordings to Gottwald, or to allow Gottwald to produce her work.
38.
Because of Kesha's breach of contract, Gottwald and KMI are entitled to compensatory damages (including expectation damages and consequential damages) in an amount to be proven at trial, plus interest