Michael Lowe learned a harsh hip-hop lesson this week when an appeals court handed him a stiff penalty for filing a copyright lawsuit against Xzibit. The lesson? If you hand someone a beat for free and say you just want to get it to Dr. Dre, don't sue them later and expect to win.

Upholding a lower court's order, the Third Circuit Court of Appeals in Philadelphia deemed aspiring Philly songwriter Lowe's suit against Xzibit, Dr. Dre and several record companies to be frivolous and ordered him to pay Dre's $35,000 in legal fees, according to the Associated Press.

According to the suit, Lowe claimed he created a beat for the song "X," from Xzibit's 2000 album, Restless, and gave it to producer Scott Storch, who he hoped would pass it along to Dre (see [article id="1450958"]"Dre, Xzibit Sued By Songwriter Claiming They Bit His Beat For 'X' "[/article]). Lowe admitted in a deposition that he didn't expect to get paid for the beat. The song credits X, Dre and El-Man as the songwriters, and Storch has said all along that Lowe was not involved in the song's creation.