Two years ago, Tyler was indeed banned from visiting the UK for three to five years by the UK Home Office because his presence was “not conducive to the public good.” “Your albums Bastard, in 2009, and Goblin, in 2011, are based on the premise of your adopting a mentally unstable alter ego who describes violent physical abuse, rape and murder in graphic terms which appears to glamourise this behaviour,” a statement from the UK Home Office read. (Theresa May, the Home Secretary who headed up the Home Office at the time, is now the British Prime Minister.)

Also in 2015, Tyler claimed to have been banned from Australia, though he never was, officially. He did, however, cancel a tour after outcry over his lyrics and a campaign to deny his visa application.

Cooksey's complaint continues:

This is the reason Defendant did not include this homophobic Tyler the Creator on June 21, 2016, because it would expose Defendant as a hypocrite and fraud who dishonestly betrayed the LGBT fans base for Tyler the Creator, who has clearly demonstrated hate for the LGBT community. In so, to protect the financial success of Defendant's new album Blonde, the Defendant .... Just left the biggest homophobic in the music industries out of Defendant’s bogus June 12th 2016 Anti Homophobic — Tumblr Essay.

(The Tumblr post went up on June 21, not June 12. The date is referenced correctly elsewhere in the complaint.)

In addition, Cooksey accuses Ocean's mother, Katonya Breaux, of being a “hypocrite” for calling out Kim Burrell for her homophobia while not saying a word about Tyler.

Attached to the original complaint as an exhibit is a 2015 Rolling Stone article about Tyler being banned from the UK over his lyrics. The exhibit also includes a fan-made image of the deluxe-edition cover art for Tyler's 2011 album Goblin, which depicted Tyler with an upside-down cross on his forehead.

A spokesperson for Tyler declined to comment about the matter to Pitchfork. Pitchfork has also reached out to representatives for Frank Ocean for further comment.

According to another public document, a judge has sent Ocean and Cooksey to mediation in hopes of reaching an out-of-court settlement.