What was filed

The complaint is Document 1 in No. 3:26-cv-13399, U.S. District Court for the Northern District of California, filed and dated November 6, 2026. It runs 36 pages. The plaintiffs are Eight Mile Style, LLC and Martin Affiliated, LLC, which the complaint describes as Michigan limited liability companies based in Ferndale, Michigan, and calls together "Eight Mile Style." It describes Eight Mile Style as an independent music publisher and copyright administration company that owns and administers 269 musical compositions by recording artist Marshall Mathers p/k/a Eminem, listed in Exhibit A, including "Lose Yourself," "Without Me," "Till I Collapse," "The Real Slim Shady," and "Stan." The complaint alleges each listed work is registered with the U.S. Copyright Office under the registration numbers in Exhibit A; Exhibit A is not available. The defendant is Suno, Inc., described as a Delaware corporation with its principal place of business in Cambridge, Massachusetts. 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 plaintiffs demand a jury trial under Federal Rule of Civil Procedure 38(b). The complaint says its allegations rest on the plaintiffs' personal knowledge as to themselves and on information and belief as to all other matters. (Compl. paras. 1 to 3, 17 to 21, 23; pp. 1, 31.)

What the complaint alleges about training

The complaint alleges that Suno has admitted to copying "essentially all music files of reasonable quality that are accessible on the open Internet" to train its AI music generator, and that publicly available sources show Suno accessed the works from licensed streaming services and paywalled platforms by scraping and circumventing technological access controls, in part through tools and services supplied by a third-party data-scraping vendor. It alleges that leaked Suno source code, as described in publicly available sources, contains lyrics and metadata for works including "Lose Yourself," "Without Me," and "Till I Collapse." It alleges, on information and belief, that Suno obtained copies of the works by accessing licensed platforms through automated scraping tools that bypassed login requirements, subscription gates and anti-bot defenses, and that Suno used stream-ripping tools known as YT-DL and YT-DLP to circumvent the "rolling cipher" encryption YouTube uses to control access to its video files. It says Eight Mile Style never authorized Suno to use the works for AI training or any other purpose. (Compl. paras. 3, 15 to 16, 33 to 38, 87.)

What the complaint alleges about outputs

The complaint alleges that Suno-generated outputs use the lyrics, often verbatim, and musical elements of works including "Lose Yourself," "Till I Collapse," "The Real Slim Shady," and "Houdini," and alleges, on information and belief, that there is infringing output for each of the works; it attaches examples as Collective Exhibit B. It contrasts those outputs with statements it attributes to a Suno motion to dismiss in No. 1:26-cv-14005 (D. Mass.). It alleges each infringing output violates the exclusive rights in 17 U.S.C. 106(1) through 106(5). (Compl. paras. 7 to 8, 90 to 93.)

Counts

  • Count I, direct copyright infringement (17 U.S.C. 106 and 501), alleging willful infringement at the training and output stages and seeking actual damages and profits under 17 U.S.C. 504(b) or statutory damages of up to $150,000 per work, which the complaint totals at $40,350,000 for 269 works.
  • Count II, circumvention of protection measures under 17 U.S.C. 1201(a)(1), alleging Suno circumvented, directly and through a third-party vendor's tools, measures such as logins, paywalls, CAPTCHA and bot detection on licensed platforms; the complaint cites statutory damages of up to $2,500 per violation under 17 U.S.C. 1203(c)(3)(A) and seeks a total of $672,500 for the 269 works.
  • Count III, removal or alteration of copyright management information under 17 U.S.C. 1202(b)(1), alleging, in part on information and belief, that Suno stripped title, songwriter and owner information in its data-cleaning pipeline; the complaint cites statutory damages of up to $25,000 per violation under 17 U.S.C. 1203(c)(3)(B) and seeks a total of $6,725,000 for the 269 works.

Relief requested

The prayer asks for declarations that Suno willfully infringed under 17 U.S.C. 106 and 501 and violated sections 1201 and 1202; a permanent injunction; impoundment or destruction of unauthorized copies, including copies in training datasets, internal repositories, model weights and server infrastructure, under 17 U.S.C. 503(b); an accounting of all training data, scraping activities and datasets involving the works; actual damages and profits or statutory damages; damages under 17 U.S.C. 1203(c); attorneys' fees and costs under 17 U.S.C. 505 and 1203(b)(4) to (5); pre-judgment and post-judgment interest; and other relief. (Compl. pp. 30 to 31.)

Docket

The docket shows the complaint (Dkt. 1) and a notice (Dkt. 2), both filed November 6, 2026.