What was filed
The complaint is Document 1 in ABG EPE IP LLC v. Anthropic PBC, No. 5:26-cv-12473 (N.D. Cal.), filed and dated October 23, 2026. It runs 28 pages, and Exhibit A lists 274 musical compositions, which the complaint calls the Works, with their composers and Copyright Office registration numbers. The plaintiffs are ABG EPE IP LLC; The Luigi Creatore Trust and Claire Creatore and Stephen Chapman as trustees; The Susan T. Aberbach Revocable Trust and Susan T. Aberbach as trustee; The Decedents Exempt Trust Created Under The Anne-Rachel Aberbach Family Trust and Steven Lee as trustee; Jason Simeon Aberbach; Abilene Music LLC; and Raleigh Music Publishing LLC, which the complaint calls together "The Elvis Plaintiffs." It describes them as independent music and entertainment companies, trusts, and individuals that own or control, in whole and in part, exclusive rights in compositions recorded by Elvis Presley, pursuant to their contracts with songwriters, artists, and other rights holders, and says ABG EPE IP LLC is a Tennessee limited liability company and Raleigh Music Publishing LLC a New York limited liability company, each with its principal place of business in New York, New York. The defendant is Anthropic PBC, described as a Delaware public benefit corporation with its principal place of business in San Francisco, California, that develops the Claude family of large language models. (Compl. paras. 1, 10 to 18; Ex. A.)
The complaint is signed by Richard S. Busch of Adams & Reese, LLP in Nashville, Tennessee, and also lists Skaggs Faucette LLP of San Francisco, California. Jurisdiction is pleaded under 28 U.S.C. 1331 and 1338(a), and venue under 28 U.S.C. 1391(b) and/or 1400. The complaint lists related copyright actions against Anthropic pending in the district, two brought by Concord Music Group, Inc. and one by BMG Rights Management (US) LLC. The plaintiffs demand a jury trial under Federal Rule of Civil Procedure 38(b). The docket shows the case assigned to Judge William H. Orrick on October 26, 2026. (Compl. paras. 20, 22; pp. 26 to 27.)
What the complaint alleges about training
The complaint alleges, on information and belief, that the plaintiffs' lyrics for each of the Works were included in text Anthropic collected from the internet and in pre-assembled datasets it used to train Claude, naming Common Crawl, "Book3," and The Pile, including a YouTube Subtitles subset that it says publicly available sources show includes "Can't Help Falling in Love" and "Don't Be Cruel." It quotes a response it says Anthropic gave to requests for admission in Bartz v. Anthropic PBC, No. 4:24-cv-05417 (N.D. Cal.), that at least one commercially released Claude model "was trained on certain data derived from YouTube subtitles found in a public dataset that Anthropic understands to be a version of The Pile, or components thereof." Citing the July 17, 2025 decision in Bartz, it alleges Anthropic used BitTorrent to download millions of copyrighted books from Library Genesis and other pirate libraries, including hundreds or more books that contain the Works' lyrics, and alleges, on information and belief, that torrenting also distributed copies of the Works. It alleges that each new Claude model, including Opus 5, Sonnet 5, Fable 5, and Mythos 5, which it dates between June 9 and July 24, 2026, is another infringing copy. (Compl. paras. 33 to 45.)
It alleges that Anthropic maintained, and on information and belief continues to maintain, an all-purpose internal repository in which the Works are kept indefinitely apart from any training run. It alleges, on information and belief, that Anthropic's data-cleaning pipeline deliberately removed copyright management information, including song titles, songwriter and composer credits, publisher names, and copyright-ownership attributions, and that Anthropic chose an extraction tool called Newspaper over alternatives that would have preserved that information. (Compl. paras. 47 to 54.)
What the complaint alleges about outputs
The complaint alleges that training on the Works' lyrics gave Claude the capacity to reproduce them in full or in substantial part when prompted, and alleges, on information and belief, that Claude has generated copies of and derivative works based on the Works when users ask for lyrics by title, for songs in the style of particular artists, or for original compositions. It points to examples it says appear in Anthropic's publicly released fine-tuning dataset, and says Anthropic added output filters after the first Concord suit was filed in October 2023, which it alleges, on information and belief, cover only a narrow subset of songs and are readily circumvented. It alleges that Claude Haiku 4.5 and Sonnet 5 decline to reproduce lyrics but still create derivative works, and quotes a Sonnet 5 response, which it calls an admission, given after Claude was asked to rewrite certain songs for a modern audience: "These renders keep landing very close to the originals: same structure, same hooks reused with light rewording, and full sets of verses/choruses/bridges. That's edging past 'inspired by' into reproducing the copyrighted song, even when the words are swapped out." It alleges, on information and belief, that Claude has created infringing output for all 274 Works. (Compl. paras. 4, 55 to 68.)
Fair use
Anticipating a fair use defense under 17 U.S.C. 107, the complaint relies on Bartz v. Anthropic PBC, 787 F. Supp. 3d 1007 (N.D. Cal. 2025), for the point that indefinite retention in a general-purpose archive is legally distinct from purchasing and scanning works solely to train a specific model, and characterizes Bartz as holding that the indefinite retention of unlicensed copies is not fair use. It also cites Harper & Row Publishers, Inc. v. Nation Enterprises, 471 U.S. 539 (1985), for the statement that fair use presupposes good faith and fair dealing. (Compl. paras. 76 to 79, 84.)
Counts and relief
All plaintiffs bring all three counts against Anthropic. Count I alleges willful direct copyright infringement under 17 U.S.C. 106(1) and 106(2) through acquisition, storage, data cleaning, and training, and through outputs that it says violate the rights in 17 U.S.C. 106(1) through 106(5). Count II alleges circumvention of technological measures that control access to the Works on licensed platforms, under 17 U.S.C. 1201(a)(1), citing measures including user authentication, paywalls, CAPTCHA and bot detection, IP-based rate limiting, and Terms of Service and robots.txt directives. Count III alleges intentional removal or alteration of copyright management information, as defined in 17 U.S.C. 1202(c), in violation of 17 U.S.C. 1202(b)(1). (Compl. paras. 81 to 100.)
The complaint seeks declarations under 17 U.S.C. 106, 501, 1201, and 1202, a permanent injunction, impoundment or destruction of copies under 17 U.S.C. 503(b), including copies in training datasets, internal repositories, model weights, and server infrastructure, an accounting of training data, scraping, and datasets involving the Works, actual damages and profits under 17 U.S.C. 504(b) or statutory damages under 17 U.S.C. 504(c), damages under 17 U.S.C. 1203(c), attorney's fees and costs under 17 U.S.C. 505 and 1203(b)(4) and (5), and interest. It totals the statutory damages it seeks at $41,100,000 for infringement, $685,000 under section 1203(c)(3)(A), and $6,850,000 under section 1203(c)(3)(B). (Compl. paras. 89, 94, 100; pp. 25 to 26.)
Registration records
Exhibit A lists renewal registration RE0000415237 for "Can't Help Falling in Love" and RE0000210743 and RE0000240941 for "Don't Be Cruel." The Copyright Office public catalog lists the claimants of RE0000415237, registered January 3, 1989, as songwriters George David Weiss and Luigi Creatore and three family members of co-writer Hugo Peretti, and lists a copyright assignment from George David Weiss to Abilene Music, Inc., effective October 21, 2009 and recorded October 26, 2009 as V3585D567, that covers "Can't Help Falling in Love" and cites RE0000415237. It lists Lisa Marie Presley as claimant of both RE0000210743 and RE0000240941, each registered June 20, 1984.