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His third studio album I Need a Haircut was released on August 27, 1991, on Cold Chillin '/ Warner Bros. Records and was produced by Biz Markie and his cousin Cool V. Sales of the album were already low when Markie was served a lawsuit by Gilbert O ' Sullivan, who claimed that the album's Alone Again featured an unauthorized sample from his hit " Alone Again ( Naturally )".
O ' Sullivan's claim was upheld in a landmark ruling, Grand Upright Music, Ltd. v. Warner Bros. Records, Inc., that altered the landscape of hip-hop, finding that all samples must be cleared with the original artist before being used.
In accordance with the ruling, Warner Bros., the parent company of Cold Chillin ', had to pull I Need a Haircut from circulation, and all companies had to clear samples with the samples ' creators before releasing the records.
This development reflected the increasing popularity of hip-hop and the financial stakes over which releases were set.
Biz responded in 1993 with the mischievously titled All Samples Cleared !, but his career had been hurt by the publicity emanating from the lawsuit, and the record suffered accordingly.

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