The complaint was filed on 18 September 2026 in the US District Court for the District of Massachusetts by UMG Recordings and Capitol Records (together "Universal"), and by Sony Music Entertainment with Alamo Records, Arista Music, Arista Records, LaFace Records, Records Label LLC, Sony Music Entertainment US Latin, Ultra Records, Volcano Entertainment III and Zomba Recording (together "Sony"), against Suno, Inc. and John Does 1–10. Counsel are Hueston Hennigan LLP, with Cloherty & Steinberg LLP as local counsel; the filing attorney is Alexandra Arnold. It runs to 130 numbered paragraphs and demands a jury trial. For the docket and procedural posture see UMG Recordings v. Suno (2026 — the v6 models).
Why a second action
The complaint describes itself as "the second action brought by two record companies and their affiliates to vindicate their rights." It explains that in the original action of June 2024 (No. 1:24-cv-11611) the plaintiffs "identified a minuscule, illustrative fraction of the recordings Suno had actually copied" because "Suno concealed the contents of its training data," and states that even the 60,202 recordings asserted here "remain only a small portion of Plaintiffs' works that Suno infringed."
The procedural route is set out in paragraph 6. The plaintiffs moved for leave to amend the original complaint to assert more than 61,000 additional works identified through forensic analysis of Suno's training corpus; Suno opposed; and on 18 August 2026 the court denied the motion without prejudice "on the primary basis that the amendment would impact the existing case schedule." The complaint quotes the court: "Plaintiffs are of course entitled to pursue valid claims for copyright infringement, and the magnitude of the alleged infringement is not a defense," and says the court concluded "that proceeding in parallel cases best balances Plaintiffs' interests in enforcing their rights with judicial economy."
It also recites admissions from the original action: that Suno "constructed" its models "by showing the program tens of millions of instances of different kinds of recordings" and that those recordings "presumably included recordings whose rights are owned by the Plaintiffs in this case," while refusing to identify the specific recordings — which the plaintiffs say forced the forensic analysis that found "millions" of their works in the corpus.
The v6 theory
Suno launched v6 on 9 September 2026 as a suite of three models — v6, v6 Wild and v6 Mini — presented as built in partnership with the music industry on catalogs licensed from Warner Music Group, BMG and Believe. Paragraphs 47 and 48 advance three independent routes by which the complaint says infringement carries into v6.
Retained copies. "On information and belief, Suno developed v6 using Plaintiffs' copyrighted recordings, unauthorized copies of which Suno retains to this day." Paragraph 63 adds that in announcing v6 and the retirement of the prior models, Suno did not say it had deleted the earlier corpus, and alleges Suno "continues to use them to develop, evaluate, fine-tune, and improve its products, including v6."
Outputs and preference data. Suno stated that it trained v6 on user "interactions." The complaint characterizes these as the outputs of, and preference data derived from, the earlier unlicensed models, quoting CEO Michael "Mikey" Shulman on the mechanism: Suno "give[s] users two songs and they will implicitly tell [Suno] one of those is better than the other," then "take[s] that signal and learn[s] from it what makes a song particularly catchy, particularly good." The argument is that "these 'signals' that represent user preferences among paired outputs cannot be divorced from the outputs themselves," and that the outputs include user-uploaded audio altered by the earlier models.
Knowledge distillation. Paragraph 48 alleges v6 was also developed "using knowledge distillation and related model-transfer techniques, whereby a new 'student' model is trained to reproduce the learned behavior of a predecessor 'teacher' model." Here "the 'teachers' are Suno's prior models, and the capabilities they transmit — how to compose, arrange, and render convincing imitations of human-created music across genres and styles — were derived from the unlicensed recordings on which those models trained."
The two framings the coverage carried are the complaint's own: "training a new model on the outputs of an infringing model does not eliminate the infringement; it launders it," and "v6 is not a fresh start; it is the fruit of the same poisoned tree." The complaint concludes that "every model Suno has ever released — from its earliest versions through v6 — is the product" of the unlicensed corpus.
Claims and relief
| Count | Claim | Statute |
|---|---|---|
| I | Direct infringement of post-1972 sound recordings | 17 U.S.C. § 106(1); willfulness under § 106 |
| II | Direct infringement of pre-1972 sound recordings | 17 U.S.C. §§ 106(1) and 1401(a)(1), under the Music Modernization Act |
| III | Circumvention of technological measures | 17 U.S.C. § 1201(a) |
The pre-1972 count rests on the Music Modernization Act's indexing mechanism: once the Copyright Office indexes a pre-1972 recording, its owner may recover statutory damages and fees under §§ 504 and 505 as any other copyright owner, per § 1401(f)(5)(A)(ii).
The circumvention count alleges Suno obtained recordings by "stream ripping" them from YouTube, "employ[ing] code to access, extract, copy, and download" audio in circumvention of the measures YouTube uses to prevent unauthorized copying.
The prayer seeks a declaration of willful infringement; preliminary and permanent injunctive relief reaching Suno's officers, agents, employees, successors, assigns and licensees and requiring it to cease circumventing YouTube's measures; statutory damages up to $150,000 per work under § 504(c) or, at the plaintiffs' election, actual damages and profits under § 504(b); statutory damages up to $2,500 per act of circumvention under § 1203(c)(3)(A) or actual damages and profits under § 1203(c)(2); costs and fees under §§ 505 and 1203(b)(4)–(5); and pre- and post-judgment interest.
Market and licensing allegations
The complaint cites Deezer's report of 21 July 2026 that AI-generated tracks exceeded half of all daily new music deliveries to that platform for the first time, "amounting to roughly 90,000 machine-made tracks uploaded every day," and a Billboard report of November 2025 that Suno told investors its users generate "a Spotify catalog's worth of outputs every two weeks."
On fair use, the complaint argues that none of the four statutory factors favours Suno, that the use is "quintessentially commercial and non-transformative," and that "a product built by copying expressive works to produce audio files designed to occupy the same place in listeners' lives and in the marketplace as genuine human recordings is the antithesis of fair use."
On licensing, it argues the Warner, BMG and Believe agreements defeat Suno's position rather than supporting it: they "confirm that when Suno finally chose to 'sit down' with rightsholders, a license was possible, just as it was from the start." It quotes Shulman in January 2025 — "it just seems silly to throw a bunch of venture dollars at lawyers instead of sitting down and talking about how you could work together" — and an early Suno investor saying the company "needed to make this product without the constraints" of copyright law, and characterizes the sequence as "asking for forgiveness, rather than paying for permission." It further disputes Chief Product Officer Jack Brody's statement that the partners' revenue share is "not in exchange for training" and that the deals are "not really about the data," arguing that "Suno takes its partners' recordings as training inputs and pays the rightsholders who supply them. That is a functioning licensing market, whatever nomenclature Suno adopts for litigation purposes." It also points to Suno's own January 2024 Terms of Service, which required users to grant Suno a broad licence, as evidence Suno understood that training on recorded content requires a licence from the owner.
The complaint quotes Shulman on Suno's ambition — "[w]e didn't just want to build a company that makes the current crop of creators 10 percent faster … If you want to impact the way a billion people experience music you have to build something for a billion people" — and argues that "Suno was never conceived as a service to serve the artists whose recordings it copied."
Provenance
Captured on 19 September 2026 from the RECAP copy of docket entry 1 on CourtListener docket 74812464, whose docket text lists the same twelve plaintiffs, the same defendants, and Alexandra Arnold as filer. Variety's report of 18 September 2026 describes a 45-page complaint filed that day asserting 60,202 recordings and quotes both the "launders it" and "poisoned tree" passages, which appear in the fetched text (Source: variety.com). The capture covers the main document in full — caption, nature of the action, parties, jurisdiction and venue, factual allegations, claims, prayer A–G, jury demand and signature block. Exhibit A, the schedule of the 60,202 asserted works, together with the civil cover sheet, local category form and certificate of relatedness, was not captured. The complaint's caption leaves "Case No." blank as filed; the number 1:26-cv-14275 comes from the docket.
Relationships
- supports: UMG Recordings v. Suno (2026 — the v6 models) — the operative pleading.
- related: UMG Recordings v. Suno (AI music training data) — the 2024 original action before the same judge, whose denial of leave to amend produced this filing.
- related: Suno — the defendant, and the v6 launch the complaint targets.
- supports: AI Copyright, Training Data Walls — advances a theory that training on a prior model's outputs and preference data carries the prior model's infringement forward.
- related: Distillation — knowledge distillation pleaded as a route of transfer.