Reservoir Media sues Suno over AI music training on and outputs of 1,050 compositions, with anti-circumvention and CMI claims

What was filed

The complaint is Document 1 in No. 3:26-cv-12305, U.S. District Court for the Northern District of California, filed and dated October 21, 2026. It runs 28 pages, with a 23-page Exhibit A listing 1,050 musical compositions by title, composer, and Copyright Office registration number. The plaintiffs are Reservoir Media Management, Inc., which the complaint describes as a Delaware corporation with its principal place of business in New York, New York, and two private limited companies formed under the laws of England and Wales, Reservoir Media Management (UK) Limited and Shapiro, Bernstein & Co. Limited, which the complaint says are wholly owned within the Reservoir group. The complaint calls them together "Reservoir" and describes Reservoir as an independent music company. The defendant is Suno, Inc., described as a Delaware corporation with its principal place of business in Cambridge, Massachusetts, that operates a subscription generative AI music service. Counsel are Adams & Reese, LLP of Nashville, Tennessee, and Skaggs Faucette LLP of San Francisco, California, with pro hac vice admission listed as forthcoming for two attorneys. 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 case was assigned on October 22, 2026 to Magistrate Judge Nathanael M. Cousins. (Compl. paras. 2, 15 to 23; pp. 1, 26 to 27; Ex. A; Dkt. 3.)

For venue and personal jurisdiction, the complaint alleges, citing press reports, that Suno opened a San Francisco office in late March 2026, and alleges that it manages the training of its AI models from an office in the district, and that it uses cloud data servers located in the district that host the copies of the works at issue. (Compl. paras. 22 to 23.)

What the complaint alleges about training

The complaint quotes an answer it says Suno filed in UMG Recordings, Inc. v. Suno, Inc., No. 1:24-cv-11611-FDS (D. Mass.), stating that Suno's "training data includes essentially all music files of reasonable quality that are accessible on the open Internet, abiding by paywalls, password protections, and the like." It alleges, on information and belief, that Suno obtained copies of the works by scraping licensed streaming platforms with automated tools that bypassed login requirements, subscription gates, and anti-bot defenses, in part through tools and proxy services from a third-party data-scraping vendor. It also alleges, on information and belief, 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. (Compl. paras. 32 to 38, 40 to 42.)

The complaint alleges that leaked Suno source code, as described in publicly available sources, contains works on Exhibit A, including "Both Sides Now," "Ring of Fire," and "Jukin' City," along with song metadata for other listed works. It alleges, on information and belief, that all of the works exist in some form in Suno's code and training sets. It also alleges Suno stores copies in a permanent, all-purpose internal repository for future use, and says Suno never sought or obtained a license from Reservoir. (Compl. paras. 13 to 14, 45, 75.)

What the complaint alleges about outputs

The complaint alleges that Suno's guardrails against output resembling existing artists are easily circumvented, that its version 6 model, launched September 9, 2026, accepts artist-specific prompts and redirects them toward descriptive musical characteristics, and that Suno's terms grant it a perpetual, irrevocable license to train on user uploads. It points to outputs described in other complaints against Suno, including UMG Recordings, Inc. v. Suno, Inc. and two other Northern District of California cases, and alleges that each infringing output violates the exclusive rights in 17 U.S.C. 106(1) through 106(5). (Compl. paras. 31, 46 to 60, 78 to 82.)

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 of copies in a general-purpose archive is legally distinct from purchasing and scanning works solely to train a specific model, and says that under Bartz the indefinite retention of unlicensed copies is not fair use. It also relies on the Third Circuit's September 29, 2026 decision in Thomson Reuters Enter. Ctr. GmbH v. ROSS Intel. Inc., No. 25-2153, which it describes as holding that ROSS's use of Thomson Reuters materials to train its AI was not fair use. (Compl. paras. 68 to 72, 76.)

Counts and relief

Count I alleges willful direct copyright infringement under 17 U.S.C. 106 and 501, at both the training and output stages. Count II alleges circumvention of technological measures that control access to the works on licensed streaming and lyrics platforms, under 17 U.S.C. 1201(a)(1). 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). The complaint seeks declarations, a permanent injunction, impoundment or destruction of copies under 17 U.S.C. 503(b), including copies in training datasets and model weights, an accounting of training data, actual damages and profits under 17 U.S.C. 504(b) or statutory damages under 17 U.S.C. 504(c) that it totals at $157,500,000, statutory damages under 17 U.S.C. 1203(c)(3)(A) and (B) that it totals at $2,625,000 and $26,250,000, attorney's fees and costs under 17 U.S.C. 505 and 1203(b), and interest. (Compl. paras. 73 to 94; pp. 25 to 26.)