What was filed

The complaint is Document 1 in No. 3:26-cv-13398, U.S. District Court for the Northern District of California, filed and dated November 6, 2026. It runs 51 pages. The plaintiffs are Elvis Presley Enterprises, LLC; 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; Karen Zimmerman; Janice Macdowell; Helene Kaye; Karen Kaye Lee; Steven Baum; Melissa Ferrick; Lori Zimmerman; and Raleigh Music Publishing LLC. The complaint calls Elvis Presley Enterprises, ABG EPE IP LLC, the three trusts and their trustees, Jason Simeon Aberbach, Abilene Music LLC and Raleigh Music Publishing LLC together "The Elvis Plaintiffs," and calls the seven other individual plaintiffs, together with Raleigh on compositions that are not Elvis Presley works, "the Raleigh Plaintiffs." It alleges Elvis Presley Enterprises solely retains Elvis Presley's likeness rights, and that the plaintiffs own or control 859 compositions listed in Exhibit F, including "All Shook Up," "Can't Help Falling in Love," "If I Can Dream," and "Don't Be Cruel," and other artists' songs such as "Let's Twist Again." Exhibit F 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. 18 to 22, 57, 59; pp. 1, 49.)

What the complaint alleges

The complaint alleges that Suno outputs use Elvis Presley's voice and likeness and reproduce the plaintiffs' songs, and points to recorded examples in Exhibits A through E, including five examples it says use both Presley's likeness and the Elvis Plaintiffs' copyrighted works, 33 examples it says use his likeness, nine examples involving the Elvis Plaintiffs' works and three involving the Raleigh Plaintiffs' works. It alleges the voice examples are not recordings of Elvis Presley singing but synthetic, unlicensed uses of his voice and likeness. It contrasts those outputs with statements it attributes to a Suno motion to dismiss in No. 1:26-cv-14005 (D. Mass.). On the copyright side, it alleges Suno copied the works to train its models without authorization, in part by scraping licensed platforms and circumventing access controls, and removed copyright management information. 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 encryption YouTube uses to control access to its video files. (Compl. paras. 10 to 17, 79 to 84, 160 to 161, 171 to 172, 176 to 177.)

Counts

  • Count I, violations of the ELVIS Act, Tenn. Code § 47-25-1101 et seq. The complaint alleges that Suno, without authorization from Elvis Presley Enterprises, used Elvis Presley's name, image, voice and likeness for purposes of advertising products or services, in violation of T.C.A. 47-25-1105(a)(1); made his voice and likeness available to the public knowing the use was not authorized, in violation of section 47-25-1105(a)(2); and made available technology whose primary purpose or function is producing a particular, identifiable individual's voice or likeness, here Elvis Presley's, knowing that was not authorized, in violation of section 47-25-1105(a)(3). Elvis Presley Enterprises seeks actual damages and profits under T.C.A. 47-25-1106(d)(1) that the complaint says it believes exceed $50 million, and treble damages and attorney fees under section 47-25-1106(d)(2), which the complaint ties to Elvis Presley's service in the United States Army from about March 1958 to March 1960. (Compl. paras. 127 to 137.)
  • Count II, violations of the Tennessee common law right of publicity, in which Elvis Presley Enterprises seeks compensatory damages and profits the complaint says it believes exceed $50 million, punitive damages, and injunctive relief.
  • Count III, direct copyright infringement (17 U.S.C. 106 and 501), seeking actual damages and profits or statutory damages of up to $150,000 per work, which the complaint totals at $128,850,000 for 859 works.
  • Count IV, circumvention of protection measures under 17 U.S.C. 1201(a)(1), citing statutory damages of up to $2,500 per violation under 17 U.S.C. 1203(c)(3)(A) and seeking a total of $2,147,500 for the 859 works.
  • Count V, removal or alteration of copyright management information under 17 U.S.C. 1202(b)(1), citing statutory damages of up to $25,000 per violation under 17 U.S.C. 1203(c)(3)(B) and seeking a total of $21,475,000 for the 859 works.

The ELVIS Act

The ELVIS Act is Tennessee House Bill 2091 of the 113th General Assembly, signed by the Governor on March 21, 2024, assigned Public Chapter 588 on March 26, 2024, and effective July 1, 2024. As amended by House Amendment 1 before passage, it renamed the Personal Rights Protection Act of 1984 the "Ensuring Likeness, Voice, and Image Security Act of 2024," defined "voice" as a sound in a medium that is readily identifiable and attributable to a particular individual, whether it contains the individual's actual voice or a simulation of it, and rewrote section 47-25-1105(a). As rewritten, section 47-25-1105(a)(2) makes a person liable who publishes, performs, distributes, transmits or otherwise makes available to the public an individual's voice or likeness knowing the use was not authorized, and section 47-25-1105(a)(3) makes a person liable who distributes, transmits or otherwise makes available an algorithm, software, tool, or other technology, service, or device whose primary purpose or function is the production of a particular, identifiable individual's photograph, voice, or likeness, with knowledge that making it available was not authorized. For a deceased individual, authorization comes from the executor or administrator, heirs, or devisees.

Relief requested

The prayer asks for declarations that Suno's use of Elvis Presley's name, image and likeness violated the ELVIS Act and Tennessee common law, and that Suno willfully infringed the works and violated 17 U.S.C. 1201 and 1202; a permanent injunction, including against unauthorized use of Elvis Presley Enterprises' rights in Presley's name, image, voice and likeness; 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), and impoundment and destruction of materials made or used in violation of Elvis Presley Enterprises' rights; an accounting of training data, scraping activities and datasets; actual damages, profits and treble damages under T.C.A. 47-25-1106(d) and punitive damages; actual damages and profits or statutory damages under 17 U.S.C. 504; damages under 17 U.S.C. 1203(c); attorneys' fees and costs under 17 U.S.C. 505 and 1203(b)(4) to (5) and/or T.C.A. 47-25-1106(d)(2); interest; and other relief. (Compl. pp. 47 to 49.)

Docket

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