Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 1 of 34

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

UMG RECORDINGS, INC., CAPITOL Case No.:

RECORDS, LLC, SONY MUSIC
ENTERTAINMENT, ATLANTIC COMPLAINT
RECORDING CORPORATION, ATLANTIC
RECORDS GROUP LLC, RHINO DEMAND FOR JURY TRIAL
ENTERTAINMENT LLC, THE ALL
BLACKS U.S.A., INC., WARNER MUSIC
INTERNATIONAL SERVICES LIMITED,
and WARNER RECORDS INC.,

Plaintiffs,

v.

SUNO, INC. and JOHN DOES 1-10,

Defendant.

Plaintiffs UMG Recordings, Inc. (“UMG”) and Capitol Records, LLC (“Capitol,” and

collectively with UMG, “Universal”); Sony Music Entertainment (“Sony”); Atlantic Recording

Corporation (“Atlantic”), Atlantic Records Group LLC (“ARG”), Rhino Entertainment LLC

(“Rhino”), The All Blacks U.S.A., Inc. (“The All Blacks”), Warner Music International Services

Limited (“WMISL”), and Warner Records Inc. (collectively with Atlantic, ARG, Rhino, The All

Blacks, and WMISL, “Warner,” and together with Universal and Sony, “Plaintiffs”), by and

through their undersigned counsel, file this Complaint against Suno, Inc. (“Suno”) and allege as

follows:

NATURE OF THE ACTION

1. From the invention of the phonograph record, through the eras of vinyl, cassette

tapes, CDs, and now streaming and social media, the recorded music industry has been at the

forefront of technological advancement. Artificial intelligence (“AI”) and machine learning are

the next frontier of technological development, poised to push boundaries and expand commercial
 Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 2 of 34

opportunity. But with AI’s enormous capabilities comes an equally enormous potential for abuse,

making it critical that AI technology be implemented responsibly, ethically, and legally.

2. Most fundamentally, AI companies, like all other enterprises, must abide by the

laws that protect human creativity and ingenuity. There is nothing that exempts AI technology

from copyright law or that excuses AI companies from playing by the rules. This lawsuit seeks to

enforce these basic principles.

3. Perhaps more so than with many other technologies, there is both promise and peril

with AI. As more powerful and sophisticated AI tools emerge, the ability for AI to weave itself

into the processes of music creation, production, and distribution grows. If developed with the

permission and participation of copyright owners, generative AI tools will be able to assist humans

in creating and producing new and innovative music. But if developed irresponsibly, without

regard for fundamental copyright protections, those same tools threaten enduring and irreparable

harm to recording artists, record labels, and the music industry, inevitably reducing the quality of

new music available to consumers and diminishing our shared culture.

4. This case concerns a generative AI service, which allows users to generate digital

music files that sound like genuine human sound recordings in response to basic inputs. The

capacity for a generative AI service to produce convincing imitations of genuine sound recordings

starts with copying a vast range of sound recordings. When those who develop such a service steal

copyrighted sound recordings, the service’s synthetic musical outputs could saturate the market
with machine-generated content that will directly compete with, cheapen, and ultimately drown

out the genuine sound recordings on which the service is built.

5. Foundational principles of copyright law dictate that copying protected sound

recordings for the purpose of developing an AI product requires permission from rightsholders.

Otherwise, such AI offerings will erode the value of the artistic works that comprise the essential

raw materials that allow them to function in the first place. If left unmoored from existing and

longstanding legal constraints, such products could supplant, rather than support, genuine human

creativity.

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6. Plaintiffs are record companies or recorded music businesses that, together, own or

exclusively control copyrights in a great majority of the most commercially valuable sound

recordings in the world. They have developed their enviable catalogs by discovering, developing,

and promoting human recording artists, whose artistic contributions are the bedrock of the

recorded music industry and the music we listen to today. These artists range from promising

newcomers to the most famous musicians and performers in the world to myriad other artists who

may not fill stadiums but who nevertheless shape culture. Plaintiffs have a track record of

embracing innovation and have entered into voluntary free-market licensing deals that authorize

the use of their protected sound recordings in emerging technologies. Such deals include full-

catalog licenses with streaming music services and user-generated content platforms, and other

licenses with innovative businesses associated with social media, fitness, gaming, the metaverse,

and more.

7. Defendant Suno, Inc. is the company behind Suno AI, or simply Suno, a generative

AI service that creates digital music files within seconds of receiving a user’s prompts. Building

and operating a service like Suno’s requires at the outset copying and ingesting massive amounts

of data to “train” a software “model” to generate outputs. For Suno specifically, this process

involved copying decades worth of the world’s most popular sound recordings and then ingesting

those copies into Suno’s AI model so it can generate outputs that imitate the qualities of genuine

human sound recordings. Suno charges many of its users monthly fees to use its product and
produce digital music files, which are designed to entertain, evoke emotion, and stoke passion just

like the genuine sound recordings Suno copied.

8. Given that the foundation of its business has been to exploit copyrighted sound

recordings without permission, Suno has been deliberately evasive about what exactly it has

copied. This is unsurprising. After all, to answer that question honestly would be to admit willful

copyright infringement on an almost unimaginable scale. Suno’s executives instead speak publicly

in exceedingly general terms. For example, one of Suno’s co-founders posted online that Suno’s

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service trains on a “mix of proprietary and public data,” 1 while another co-founder stated that

Suno’s training practices are “fairly in line with what other people are doing.” 2 Piercing the veil

of secrecy, an early investor admitted that “if [Suno] had deals with labels when this company got

started, I probably wouldn’t have invested in it. I think that they needed to make this product

without the constraints.” 3

9. Of course, it is obvious what Suno’s service is trained on. Suno copied Plaintiffs’

copyrighted sound recordings en masse and ingested them into its AI model. Suno’s product can

only work the way it does by copying vast quantities of sound recordings from artists across every

genre, style, and era. The copyrights in many of those sound recordings are owned or exclusively

controlled by Plaintiffs. In other words, if Suno had taken efforts to avoid copying Plaintiffs’

sound recordings and ingesting them into its AI model, Suno’s service would not be able to

reproduce the convincing imitations of such a vast range of human musical expression at the

quality that Suno touts. Suno’s service trains on the expressive features of these copyrighted sound

recordings for the ultimate purpose of poaching the listeners, fans, and potential licensees of the

sound recordings it copied.

10. If there were any doubt regarding Suno’s unauthorized copying, Suno dispelled it

by effectively conceding in pre-litigation correspondence that it copied Plaintiffs’ copyrighted

sound recordings. When Plaintiffs directly accused Suno of copying Plaintiffs’ sound recordings

to train its model, Suno did not deny or proffer any facts to undermine those allegations. It would

have been simple for Suno to say that it used other, legally acquired recordings, if that were the

case. Instead, Suno deflected and disingenuously asserted that its training data is “confidential

business information.” Suno also claimed that its large-scale copying of sound recordings is “fair

1
@georg, Discord, Suno-General (Aug. 3, 2023).
2
Rachel Metz, The AI Music Era Is Here. Not Everyone Is a Fan, Bloomberg (May 6, 2024),
https://www.bloomberg.com/news/articles/2024-05-06/suno-udio-and-more-the-ai-music-era-is-here-not-everyone-
is-a-fan.
3
Brian Hiatt, A ChatGPT for Music is Here. Inside Suno, the Startup Changing Everything, Rolling Stone (Mar. 17,
2024), https://www.rollingstone.com/music/music-features/suno-ai-chatgpt-for-music-1234982307/.

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use,” which was telling because fair use only arises as a defense to an otherwise unauthorized use

of a copyrighted work. When Plaintiffs confronted Suno with these concessions, Suno did not

respond.

11. Plaintiffs could have proceeded with this action based solely on eliciting that

reasonable inference of copying. Nevertheless, Plaintiffs’ claims are based on much more. In

particular, Plaintiffs tested Suno’s product and generated outputs using a series of prompts that

pinpoint a particular sound recording by referencing specific subject matter, genre, artist,

instruments, vocal style, and the like. Suno’s service repeatedly generated outputs that closely

matched the targeted copyrighted sound recording, which means that Suno copied those

copyrighted sound recordings to include in its training data. In addition, the public has observed

(and Plaintiffs have confirmed) that even less targeted prompts can cause Suno’s product to

generate outputs that resemble specific recording artists and specific copyrighted recordings. Such

outputs are clear evidence that Suno trained its model on Plaintiffs’ copyrighted sound recordings.

12. Suno is not exempt from the copyright laws that protect human authorship. Like

any other market participant, Suno cannot reproduce copyrighted works for a commercial purpose

without permission. Heedless of this basic principle, Suno’s unauthorized copying erodes the

value and integrity of Plaintiffs’ copyrighted sound recordings with rapid and devastating impact.

Suno’s service generates music with such speed and scale that it risks overrunning the market with

AI-generated music and generally devaluing and substituting for human-created work. Suno
already has over 10,000,000 users generating music files using its product, with some outputs

amassing upwards of 2,000,000 streams. These digital music files have been released to the

public—some already finding their way onto the major streaming services—and compete with the

copyrighted sound recordings that enabled their creation; yet Suno sought no permission from and

gives no credit or compensation to the human artists or other rightsholders whose works fueled

their creation.

13. Suno also profits substantially from its infringement of Plaintiffs’ copyrighted

sound recordings. Suno’s latest funding round raised $125 million, valuing the company at

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approximately $500 million. Suno further touts a roster of high-profile backers and has monetized

its service, charging users up to $24 per month for its highest subscription tier. None of that would

be possible without the vast troves of copyrighted sound recordings that Suno copied to train its

AI model.

14. Suno cannot avoid liability for its willful copyright infringement by claiming fair

use. The doctrine of fair use promotes human expression by permitting the unlicensed use of

copyrighted works in certain, limited circumstances, but Suno offers imitative machine-generated

music—not human creativity or expression. Moreover, the Copyright Act enumerates four factors

to assess whether an unauthorized use is fair, none of which favors Suno’s product. These factors

are: (1) the purpose and character of the use; (2) the nature of the copyrighted work; (3) the amount

and substantiality of the portion used in relation to the copyrighted work as a whole; and (4) the

effect of the use upon the potential market for or value of the copyrighted work. In these

circumstances, the purpose of Suno’s use of Plaintiffs’ copyrighted sound recordings is

quintessentially commercial and creates directly competitive digital music files that serve the same

purpose as the recorded music Plaintiffs create and substitute for genuine recordings by humans;

Suno copies the key expressive features of Plaintiffs’ copyrighted sound recordings; those

copyrighted sound recordings are at the core of copyright protection; and Suno’s infringement

undermines both existing and potential commercial markets for selling, licensing, and distributing

sound recordings. If left unchecked, Suno risks upending whole segments of the legitimate music
industry.

15. At its core, this case is about ensuring that copyright continues to incentivize human

invention and imagination, as it has for centuries. Achieving this end does not require stunting

technological innovation, but it does require that Suno adhere to copyright law and respect the

creators whose works allow it to function in the first place.

16. Plaintiffs bring this action seeking an injunction and damages commensurate with

the scope of Suno’s massive and ongoing infringement.

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THE PARTIES

17. Plaintiffs comprise the world’s foremost record companies and recorded music

businesses, engaged in the business of producing, manufacturing, distributing, selling, licensing,

and otherwise commercializing sound recordings in the United States and the world through

various media. Plaintiffs have made substantial investments in the development and promotion of

some of the most prolific and well-known recording artists in the world. Plaintiffs’ investments

extend further to lesser-known artists as well, with an eye toward sustaining the music industry

and discovering and supporting new generations of recording artists across all genres and styles.

Pursuant to their relationships with artists, Plaintiffs own or exercise exclusive control over rights

in millions of sound recordings of enormous cultural significance, artistic merit, and economic

value.

18. Plaintiff UMG Recordings, Inc. is a Delaware corporation with its principal place

of business at 2220 Colorado Avenue, Santa Monica, California 90404. UMG owns or exercises

exclusive control over the copyrights for the sound recordings within its catalog.

19. Plaintiff Capitol Records, LLC is a Delaware limited liability company with its

principal place of business at 2220 Colorado Avenue, Santa Monica, California 90404. Capitol

owns or exercises exclusive control over the copyrights for the sound recordings within its catalog.

A non-exhaustive list of specific sound recordings owned or exclusively controlled by Universal

that Suno has infringed is attached as Exhibit A (the “Universal Works”).

20. Plaintiff Sony Music Entertainment is a Delaware general partnership, the partners

of which are citizens of New York and Delaware. Sony’s headquarters and principal place of

business are located at 25 Madison Avenue, New York, New York 10010. Sony owns or exercises

exclusive control over the copyrights for the sound recordings within its catalog. A non-exhaustive

list of specific sound recordings owned or exclusively controlled by Sony that Suno has infringed

is attached as Exhibit A (the “Sony Works”).

21. Plaintiff Atlantic Recording Corporation is a Delaware corporation with its

principal place of business at 1633 Broadway, New York, New York 10019. Atlantic owns or

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exercises exclusive control over the copyrights for the sound recordings within its catalog.

22. Plaintiff Atlantic Records Group LLC is a Delaware limited liability company with

its principal place of business at 1633 Broadway, New York, New York 10019. ARG owns or

exercises exclusive control over the copyrights for the sound recordings within its catalog.

23. Plaintiff Rhino Entertainment LLC is a Delaware limited liability company with its

principal place of business at 777 S. Santa Fe Avenue, Los Angeles, California 90021. Rhino

owns or exercises exclusive control over the copyrights for the sound recordings within its catalog.

24. Plaintiff The All Blacks U.S.A., Inc. is a Delaware corporation with its principal

place of business at 1633 Broadway, New York, New York 10019. The All Blacks owns or

exercises exclusive control over the copyrights for the sound recordings within its catalog.

25. Plaintiff Warner Music International Services Limited is a limited liability

company organized and existing under the laws of England and Wales with its principal place of

business at 27 Wrights Lane, London, England. WMISL owns or exercises exclusive control over

the copyrights for the sound recordings within its catalog.

26. Plaintiff Warner Records Inc. is a Delaware corporation with its principal place of

business at 777 S. Santa Fe Avenue, Los Angeles, California 90021. Warner Records Inc. owns

or exercises exclusive control over the copyrights for the sound recordings within its catalog. A

non-exhaustive list of specific sound recordings owned or exclusively controlled by Warner that

Suno has infringed is attached as Exhibit A (the “Warner Works”).

27. A non-exhaustive, illustrative sampling of Plaintiffs’ federally copyrighted sound

recordings that Suno has illegally reproduced is attached hereto as Exhibit A. Plaintiffs currently

commercially exploit, and at all relevant times have commercially exploited, all the sound

recordings listed in Exhibit A. Plaintiffs intend to amend the Complaint at an appropriate time to

provide an expanded list of works that Suno has infringed.

28. Defendant Suno, Inc. is a Delaware corporation with its principal place of business

at 17 Dunster Street, Cambridge, Massachusetts 02138.

29. Defendants John Does 1-10 are unknown parties who directly copied Plaintiffs’

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federally copyrighted sound recordings, worked with Suno to copy Plaintiffs’ federally

copyrighted sound recordings, or have knowledge of Suno’s direct infringement of the copyrighted

sound recordings and intentionally induced and materially contributed to the infringement by

assisting Suno’s compiling, scraping, and/or copying of the copyrighted sound recordings for

Suno’s training data, intentionally promoted or encouraged Suno’s infringing conduct by

providing necessary tools and resources, and/or supervised and financially benefited from Suno’s

infringement.

JURISDICTION AND VENUE

30. This is a civil action seeking damages and injunctive relief for infringement under

the Copyright Act, 17 U.S.C. §§ 101, et seq., and the Music Modernization Act, 17 U.S.C. § 1401.

As such, this Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331

and 1338(a), based on federal question jurisdiction.

31. This Court has personal jurisdiction over Defendant Suno because its principal

place of business, listed as 17 Dunster Street, Cambridge, Massachusetts 02138, is in this district.

32. Venue lies in this judicial district pursuant to 28 U.S.C. § 1391(b)(1) because

Defendant Suno resides in this district.

FACTUAL BACKGROUND

Sound Recordings at Issue

33. Plaintiffs own or exercise exclusive control over copyrights and/or exclusive rights

under federal law in and to numerous valuable sound recordings. Exhibit A, attached hereto and

incorporated herein by reference, contains a non-exhaustive, representative list of copyrighted

sound recordings owned or exclusively controlled by Plaintiffs that Suno has directly infringed

(the “Copyrighted Recordings”). Plaintiffs or their predecessors in interest have obtained

Certificates of Copyright Registration for each of the post-1972 Copyrighted Recordings identified

in Exhibit A.

34. Plaintiffs own or exercise exclusive control over copyrights and/or exclusive rights

in and to numerous valuable sound recordings first “fixed” before February 15, 1972, which are

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protected under the Music Modernization Act (“MMA”), 17 U.S.C. § 1401 et seq. In enacting the

MMA, Congress directed the U.S. Copyright Office to create a process for rightsholders to submit

schedules of pre-1972 sound recordings so that the Copyright Office can publicly index the

recordings. 17 U.S.C. § 1401(f)(5)(A)(ii). Once the Copyright Office indexes a work, a

rightsholder who sues for infringement of that work can recover statutory damages and attorneys’

fees just like any other copyright owner, pursuant to 17 U.S.C. §§ 504 and 505. For each of the

pre-1972 Copyrighted Recordings listed in Exhibit A, Plaintiffs have filed with the Copyright

Office schedules containing all information specified in 17 U.S.C. § 1401.

Suno Launches in 2023

35. In July 2023, a group of individuals who collaborated at Kensho Technologies, an

AI solutions business, launched a “beta” version of Suno’s AI music generation service. Suno’s

stated vision is to “build[ ] a future where anyone can make great music. Whether you’re a shower

singer or a charting artist, [Suno] break[s] barriers between you and the song you dream of

making.” 4

36. Suno initially engaged users to generate AI music files through its channel on the

social media website Discord, and later rolled out a web interface to expand the reach of its music

generation product. In December 2023, Suno announced a strategic partnership with Microsoft by

which Suno’s service would be integrated into Microsoft’s AI chatbot Copilot. 5

37. Whether using Suno’s website interface or Microsoft’s Copilot, Suno’s product

allows users to enter text prompts to generate digital music files. Users can prompt Suno’s service

with a description of the music they want to generate, which can include specifying the genre,

lyrics, story direction, and themes to serve as inspiration. Within seconds, Suno’s service

processes the user’s prompt and generates a digital music file (Suno’s website generates two files

per prompt, whereas Copilot’s Suno plug-in generates one). Suno’s customization options then

4
Suno, About, https://suno.com/about.
5
Microsoft, Turn Your Ideas into Songs with Suno on Microsoft Copilot (Dec. 19, 2023),
https://www.microsoft.com/en-us/microsoft-copilot/blog/2023/12/19/turn-your-ideas-into-songs-with-suno-on-
microsoft-copilot/.

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allow users to adjust elements of the files, including tempo, mood, and genre.

38. Suno offers both free and paid versions of its product. Under the free plan, users

are given 50 credits per day, equivalent to 10 music files. According to Suno’s terms of service,

free users cannot use the files they generate for commercial purposes. 6 Users can subscribe to the

Pro and Premier plans for monthly fees of $8 and $24, respectively. The Pro plan gives users

2,500 credits per day, enough for 500 music files, while the Premier plan comes with 10,000 credits

per day, enough for 2,000 music files. Under either paid subscription, Suno allows users to utilize

their digital music files for commercial purposes, such as by uploading them to YouTube or music

streaming services like Spotify or Apple Music. With this model, Suno earns revenue by

encouraging users to generate digital music files and exploit them commercially. Put simply, the

more digital music files Suno’s service produces for its users, the more Suno charges.

39. On March 21, 2024, Suno launched a new version of its service, dubbed “v3,”

which it describes as its “first model capable of producing radio-quality music.” 7 v3 enables all
users, free or paid, to generate digital music files up to two minutes in length virtually

instantaneously.

40. On May 30, 2024, Suno launched yet another version of its service, named “v3.5,”

which it describes as an updated version of v3. 8 v3.5 enables all users, free or paid, to generate

digital music files up to four minutes in length virtually instantaneously. Suno has announced that

its next version, “v4,” is already in development and promises to continue “improving along the

axes of quality, control, and speed.” 9

Suno Trains its AI Using Copyrighted Recordings

41. AI models are developed to flexibly perform tasks that are typically expected to

require human intelligence to achieve. “Generative AI” is a kind of AI aimed at producing content

6
Suno Blog, Terms of Service (Jan. 27, 2024), https://suno.com/terms.
7
Suno Blog, Introducing v3 (Mar. 21, 2024), https://suno.com/blog/v3.
8
@suno_ai_, X (May 24, 2024), https://x.com/suno_ai_/status/1794145852723777559.
9
@suno_ai_, X (Mar. 21, 2024), https://x.com/suno_ai_/status/1770857568274911449.

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such as text, images, or (in Suno’s case) audio. The generative AI models rapidly advancing today,

including Suno’s, are based on machine learning models. These models do not employ preset rules

for generating outputs, but rather deduce patterns from a large corpus of training content. They

store these patterns as billions of numerical parameters. In aggregate, these parameters constitute

the model. The training process adjusts the parameters so that the model produces content that is

based on the content on which the model is trained.

42. Upon information and belief, and consistent with the basic facts of how generative

AI works, the content Suno used to “train” its AI model includes reams of Copyrighted Recordings

that Suno reproduced without permission from Plaintiffs. Suno could not have built a model

capable of producing audio so similar to the Copyrighted Recordings without the initial act of

copying those recordings. This explains why one of Suno’s investors has publicly recognized that

Suno’s service is likely to spawn litigation and that defending lawsuits from music labels is “the

risk we had to underwrite when we invested in the company.” 10

43. On information and belief, similar to other generative AI audio models, Suno trains

its AI model to produce audio output by generally taking the following steps:

a. Suno first copies massive numbers of sound recordings, including by

“scraping” (i.e., copying or downloading) them from digital sources. This vast

collection of information forms the input, or “corpus,” upon which the Suno AI

model is trained.

b. Suno then “cleans” the copied recordings to remove any material, whether

technical or substantive, that it does not wish to include in its AI model (for

instance, duplicate or low-quality data). This step may also involve copying the

recordings to convert them into a common digital audio format.

c. Suno then processes this corpus of previously copied recordings to establish

the values of the parameters that form its AI model. This step includes additional

10
Hiatt, supra n.3.

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copying of the recordings, including into computer memory, as they are further

converted and divided into units, and as those units are processed.

d. Suno next processes the data further to “finetune” its AI model, which may

require additional copying of the collected sound recordings.

44. After undergoing this training process, Suno’s service gains the capacity to generate

audio output based on Suno’s model, which, as just described, is a product of the corpus of sound

recordings on which it is trained. When a user prompts Suno’s service with a text input (e.g., make

a jazz song about New York), the service generates an audio output by making generalizations

about what the audio output should sound like based on the prompt and the corpus of sound

recordings on which it was trained. Certain features of the outputs from Suno’s model betray that

it was trained on particular data—in this case, the Copyrighted Recordings. In particular, Suno’s

product frequently generates outputs with strong resemblance to the Copyrighted Recordings, a

telltale sign that such recordings were included in its training data.

45. In technical terms, by generating outputs that mimic sound recordings in its training

corpus, Suno’s model reflects the machine-learning phenomenon known as “overfitting.” An AI

model is “overfitted” when it is too closely adapted to the data on which it was trained, making it

difficult for the model to generalize to new data sets. One symptom of overfitting is a model that

replicates portions of its training data. To take a simplified example, if a user inputs the prompt

“a jazz song about New York” into an overfitted AI model, the model may output a file that closely
resembles one of the jazz tracks on which it trained. As the myriad examples discussed below

reflect, Suno’s model obviously was trained on the Copyrighted Recordings. This infringement

cannot be cured by simply loosening the model’s fit or by implementing technical guardrails that

make it less likely that outputs will match excerpts of the Copyrighted Recordings. In other words,

modifying Suno’s offering in a way that better conceals its training data would not alter the fact

that Suno infringed the Copyrighted Recordings the moment it copied them to create its model.

46. The basic point is that Suno’s model requires a vast corpus of sound recordings in

order to output synthetic music files that are convincing imitations of human music. Suno’s corpus

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includes the body of recorded music that people listen to in their everyday lives. Because of their

sheer popularity and exposure, the Copyrighted Recordings had to be included within Suno’s

training data for Suno’s model to be successful at creating the desired human-sounding outputs.

47. One of Suno’s earliest investors has all but admitted that Suno’s service trains on

Plaintiffs’ sound recordings. Antonio Rodriguez, a partner at the venture capital firm Matrix

Partners, explained that his firm invested in the company with full knowledge that Suno might get

sued by copyright owners, which he understood as “the risk we had to underwrite when we

invested in the company.” 11 Rodriguez pulled the curtain back further when he added that

“honestly, if we had deals with labels when this company got started, I probably wouldn’t have

invested in it. I think they needed to make this product without the constraints.” 12 By

“constraints,” Rodriguez was, of course, referring to the need to adhere to ordinary copyright rules

and seek permission from rightsholders to copy and use their works. Rodriguez’s message was

clear: he was willing to “underwrite” the costs of the lawsuits relating to Suno’s large-scale

intellectual property theft because he expected his investment in Suno to be accretive despite the

damages owed to copyright owners.

48. Suno’s unlawful copying of the Copyrighted Recordings into its training data has

not been lost on even casual users of Suno’s product. Indeed, many observers have drawn this

obvious conclusion, expressing alarm over the scope of Suno’s unauthorized copying. To provide

just a sample:

• “Though neither company will directly confirm or deny it, there is substantial

reason to believe that . . . Suno . . . w[as] trained on copyrighted music, without

permission[.]” Brian Hiatt, AI-Music Arms Race: Meet Udio, the Other ChatGPT

for Music, Rolling Stone (Apr. 10, 2024).

• “While details about the data that trained these AI tools are sparse, there is plenty

11
Id.
12
Id.

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of reason to believe that they are trained on copyrighted music.” Sharon Goldman,

AI Music May be Having a Moment, But Human Songwriters Would Like a Word,

Fortune (May 17, 2024).

• “Although Suno hasn’t revealed what music has been used to train its music-

generation models, it seems almost certain that the startup has used materials

without the explicit consent of their creators. For one thing, many of its musical

outputs are somewhat similar to popular songs.” Mike Wheatley, Generative AI

Music Maker Startup Suno Raises $125M in Funding, SiliconAngle (May 21,

2024).

• “To create music as convincing as some of the examples generated by Suno and

other platforms using AI algorithms means training those algorithms on existing

music, and lots of it. And that’s where copyright comes into play, because it’s

become plainly obvious that many AI models have been built by ingesting

enormous quantities of copyrighted material.” Daniel Tencer, Suno Could Get Sued

By The Record Business. Who’s Backing it With $125M?, Music Business

Worldwide (May 28, 2024).

49. When directly accused of using Plaintiffs’ sound recordings, Suno dodged and did

not even try to dispute Plaintiffs’ allegations. Beyond this effective concession, Suno obfuscated

and claimed that its training data is “confidential business information.”

Suno’s Outputs Confirm Copying and Ingestion of Plaintiffs’ Copyrighted Recordings

50. The fact that Suno’s product generates digital music files that mimic readily

identifiable features of the Copyrighted Recordings supports the conclusion that Suno is using the

Copyrighted Recordings in training its AI model. To be clear, Plaintiffs are not presently alleging

that these outputs themselves infringe the Copyrighted Recordings unless discovery reveals that

they directly or indirectly recapture portions of the Copyrighted Recordings. These outputs

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confirm as an evidentiary matter that Suno has copied specific Copyrighted Recordings into its

training data to build its service.

51. Plaintiffs designed a test that sometimes reveals the Copyrighted Recordings that

Suno copied into its training data. Plaintiffs found that certain patterns of prompts can cause

Suno’s product to generate digital music files that contain melodic and stylistic similarities to well-

known copyrighted sound recordings. As further explained below, those similarities betray that

the model was trained on the Copyrighted Recordings.

52. Specifically, Plaintiffs discovered that using targeted prompts that include the

characteristics of popular sound recordings—such as the decade the sound recording was released,

as well as the topic, genre, and descriptions of the artist—can cause Suno’s product to generate

music files that strongly resemble the Copyrighted Recordings related to the descriptions in the

prompt. In performing this test, Plaintiffs specified the lyrics for the output, so as to more easily

surface the underlying melodic or rhythmic similarities with specific Copyrighted Recordings.

This approach was designed to identify specific, copyrighted sound recordings that are likely in

Suno’s training data, since Suno has attempted to conceal the recordings on which it has trained.

The results confirm that Suno has copied for training purposes the Copyrighted Recordings,

because this degree of similarity in output would be impossible if Suno were not training on the

Copyrighted Recordings.

53. As described below, the outputs from Suno’s product share indisputable similarities
with the Copyrighted Recordings, which results from training on the Copyrighted Recordings.

One need only listen to hear the resemblance. 13

54. For instance, Suno’s service has generated 29 different outputs that contain the style

of Chuck Berry’s “Johnny B. Goode” (the copyright in which is owned by UMG). Using the

prompt, “1950s rock and roll, rhythm & blues, 12 bar blues, rockabilly, energetic male vocalist,

13
Accompanying this Complaint and designated as Exhibit C is a thumb drive that contains all the Suno outputs
referenced herein and in Exhibit B. In the event Suno seeks to remove this evidence of its infringing conduct from
public view, the examples cited herein are preserved on this medium.

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 Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 17 of 34

singer guitarist” and the lyrics from the original, one output titled “Deep down in Louisiana close

to New Orle” replicates the highly distinctive rhythm of the original’s chorus, and uses the same

melodic shape on the phrases “go Johnny, go, go.” These similarities are further reflected in the

side-by-side transcriptions of the musical scores for the Suno file and the original recording. 14

These similarities are only possible because Suno copied the Copyrighted Recordings that contain

these musical elements.

Score: Deep down in Louisiana close to New Orle (Suno)

14
Plaintiffs include the transcriptions of select Suno outputs and the Copyrighted Recordings they resemble to
illustrate the technical, musical similarities between the two. To facilitate comparison of Suno’s output and the
original Copyrighted Recording, each copyrighted song transcription has been transposed into the key and/or vocal
register of the relevant Suno output. Red markings in the transcriptions indicate notes that are the same as the original
in both pitch and rhythm, where orange markings indicate notes that use either the pitch or the rhythm of the original,
but not both. Notes in Suno’s output that use the same scale degree as the corresponding note in the original
copyrighted song but where the modality is changed from major to minor or vice versa (e.g., a major third becoming
a minor third) are represented as the same pitch in the transcriptions.

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 Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 18 of 34

Score: Johnny B. Goode (Chuck Berry)

55. Another output also titled “Deep down in Louisiana close to New Orle” uses a

melody on the first two lines that is virtually identical to the original, the only differences being a

change in modality and two slight rhythmic changes. The 27 other outputs (included in Exhibit

B) also include melodies in the verse and/or chorus that exhibit similarities with the original.

Score: Deep down in Louisiana close to New Orle (Suno)

Score: Johnny B. Goode (Chuck Berry)

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56. Similarly, Suno’s service has generated 10 different outputs that resemble Bill

Haley & His Comets’ “Rock Around the Clock” (the copyright in which is owned by UMG). To

illustrate, one of these recordings, titled “One, Two, Three O’Clock, Four O’Clock, r,” was

generated using Suno’s service with the prompt “1954 rock and roll bill haley comets” and lyrics

from the original. As the audio and transcriptions reflect, the output contains four lines at the

beginning that are very similar to the original, with identical pitches and rhythm in many places.

It also uses a melody later in the output on the phrase “we’re gonna rock around the clock tonight,”

which is virtually identical to the melody of the original.

Score: One, Two, Three O’Clock, Four O’Clock, r (Suno)

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 Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 20 of 34

Score: Rock Around the Clock (Bill Haley & His Comets)

57. The nine other outputs (included in Exhibit B) also include clear stylistic and

melodic elements of the original sound recording.

58. As another example, Suno’s product generated an output that replicates the style

and melody of James Brown’s “I Got You (I Feel Good)” (the copyright in which is owned by

UMG). In the Suno output titled “Wow! I feel good, I knew that I would no,” the phrase “I knew

that I would now” uses the same melody as the original.

Score: Wow! I feel good, I knew that I would no (Suno)

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Score: I Got You (I Feel Good) (James Brown)

59. Suno’s product has also generated 10 different outputs that contain a melody similar

to one found in Jerry Lee Lewis’ “Great Balls of Fire” (the copyright in which is owned by UMG).

One example, titled “You shake my nerves and you rattle my br,” was created with the original

lyrics and the prompt “1950s rock and roll, jerry lee lewis, sun studio.” The output includes the

well-known, characteristic large vocal leap up to the word “great” in the line “Goodness gracious,

great balls of fire.” This line also replicates the rhythm of the original and follows a similar

melodic shape. The nine other outputs contain a similar large vocal leap up to the word “great.”

Score: You shake my nerves and you rattle my br (Suno)

Score: Great Balls of Fire (Jerry Lee Lewis)

60. Suno’s service has also generated six different outputs that contain portions of B.B.

King’s “The Thrill is Gone” (the copyright in which is owned by UMG). One example, also titled

“The Thrill is Gone,” was generated with the prompt “slow minor blues, west coast blues, 12-bar

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 Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 22 of 34

blues, king of the blues, electric guitar, gritty confident voice, 1969” and the original lyrics. The

first phrase in the output, “the thrill is gone,” uses identical pitches to those used in the third

occurrence of this phrase in the original sound recording. The second phrase, “the thrill has gone

away,” is also very similar to the same phrase in the original.

Score: The Thrill is Gone (Suno)

Score: The Thrill is Gone (B.B. King)

61. As yet another example, Suno’s product generated a digital music file with portions

that have striking resemblance to Michael Bublé’s hit “Sway” (the copyright in which is owned

by Warner Records Inc.). Using the prompt “canadian smooth male singer 2004 jazz pop buble

sway latin mambo minor key” as well as lyrics from the original, Suno’s service created “When

marimba rhythms start to play,” a file that contains an identical version of the distinctive opening

on the words “when marimba rhythms,” virtually identical rhythm throughout, and repeated

instances of the original’s characteristic three-note descending figure. Suno’s service generated

11 additional files that resemble “Sway,” which are listed in Exhibit B.

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Score: When marimba rhythms start to play (Suno)

Score: Sway (Michael Bublé)

62. Suno’s service has also generated audio outputs that contain vocals that are

instantly recognizable due to their resemblance to those of famous recording artists. For example,

even the biggest ABBA fan would have trouble distinguishing between sound recordings created

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by the real band and the vocals in the Suno outputs “Prancing Queen” and “Dancing in the

Moonlight.” Suno’s service generated the former using the prompt, “70s pop” and the latter via

the prompt “disco abba pop.”

63. Further evidencing Suno’s unauthorized copying of specific Copyrighted

Recordings, Suno’s product has generated outputs that include recognizable producer tags. A

producer tag is a short, distinctive sound that certain artists or producers include in their sound

recordings to identify their affiliation with a particular recording. Producer tags are designed to

be unique and instantly recognizable by fans. That certain Suno outputs replicate recognizable

producer tags strongly suggests that Suno’s service trained on the protected sound recordings of a

given producer.

64. For instance, the Suno output “Rains of Castamere” begins with the
“CashMoneyAP” producer tag, even though the prompt used to generate this digital music file in

no way referenced this producer. This output indicates a high likelihood that Suno’s service trained

on sound recordings affiliated with the music producer CashMoneyAP, whose producer tag can

be heard in the Copyrighted Recordings by artists such as Da Baby and Pop Smoke.

65. The artist Jason Derulo is known for singing his own name at the beginning of his

sound recordings. 15 Suno has also replicated this tag. For example, Jason Derulo’s name is

repeated at the beginning of the Suno-generated digital music file aptly titled “Jason Derulo,” in a

manner exceedingly similar to how Jason Derulo tags his recordings. Again, Suno’s reproduction

of this tag strongly suggests that Suno included Copyrighted Recordings by Jason Derulo in its

training data.

66. These similarities between outputs of Suno’s product and the Copyrighted

Recordings are not a coincidence. In fact, Suno co-founder Mikey Shulman admitted that Suno

already has the ability to produce outputs that replicate real artists’ vocals and genuine sound

15
G. Garner, Jason Derulo Reveals Why He Started Singing His Name at the Beginning of His Songs Again: ‘I Had
to Bring That Back’, Daily Mail (Oct. 16, 2020), https://www.dailymail.co.uk/tvshowbiz/article-8849659/Jason-
Derulo-reveals-started-singing-songs-bring-back.html.

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recordings, but Suno is holding back from allowing users to generate such replicas until “the

licensing . . . climate is a little less uncertain.” 16 Suno’s capacity to replicate the vocals of human

recording artists and other aspects of genuine sound recordings is only possible if Suno copied and

trained its model using these artists’ copyrighted sound recordings. 17

67. Additional outputs of Suno’s product that resemble the Copyrighted Recordings

and specific recording artists can be found in Exhibit B.

Suno Cannot Claim Fair Use

68. When Plaintiffs raised these issues with Suno in written correspondence, Suno

attempted to justify its pervasive illegal copying of Plaintiffs’ sound recordings by claiming fair

use. This, itself, is a tacit admission of Suno’s illegal copying, as fair use only comes into play

when an unauthorized use of a copyrighted work needs to be justified.

69. The fair use doctrine has been coined an “equitable rule of reason” that balances

various contextual factors to determine whether an unauthorized use of a copyrighted work is

“fair.” Sony Corp. v. Universal City Studios, Inc., 464 U.S. 417, 448 (1984). But Suno cannot

launder its conscious stealing of the Copyrighted Recordings for commercial gain with an appeal

to equitable principles. Suno understands that what it is doing is wrong and inequitable, which

explains why it refused to even acknowledge the extent of its unauthorized use of Plaintiffs’ sound

recordings, and why it tries to cover its tracks when users publicize outputs that clearly reflect

training on their recordings.

70. Suno’s conduct violates the very purposes of the copyright law and runs contrary

to the purpose animating the fair use doctrine. The Copyright Act codifies the common-law

16
@mignano, X at 43:55-44:53 (Mar. 8, 2024), https://x.com/mignano/status/1766151562299163030.
17
See Joe Coscarelli, An A.I. Hit of Fake ‘Drake’ and ‘The Weeknd’ Rattles the Music World, N.Y. Times (Apr. 19,
2023), https://www.nytimes.com/2023/04/19/arts/music/ai-drake-the-weeknd-fake.html (explaining that “A.I.
imitations of brand-name artists” have been created “using tools that had ‘learned’ from existing music and produced
a similar effect.”); Jem Aswad, What Would It Take for an AI-Generated Song to Qualify for a Grammy?, Variety
(Oct. 17, 2023), https://variety.com/2023/music/news/grammys-ai-drake-weeknd-awards-1235758275/ (“Ghostwriter
used generative AI to create Drake and Weeknd lyrics and melodies with no conscious input from those artists. He
was able to do this by loading multiple copyrighted songs by those artists into a computer — ingesting data for machine
learning, in technical terms — which is where the legal issues come in.”).

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doctrine of fair use in 17 U.S.C. § 107, which identifies examples of the types of uses that may

qualify as fair, including “criticism, comment, news reporting, teaching . . . scholarship, or

research.” These paradigmatic fair uses reflect the policy of ensuring public availability of

“literature, music, and other arts” so that other humans can draw on those works to create new

ones. Suno’s wholesale copying of countless recordings serves none of these purposes. Suno’s

service does not offer “commentary” or “scholarship” or promote human authorship. Rather,

Suno’s service copies and ingests copyrighted works to create computer-generated imitations of

human expression that do not merit copyright protection. Suno’s motive is brazenly commercial

and threatens to displace the genuine human artistry that is at the heart of copyright protection.

71. Moreover, applying the statutory fair use factors set forth in § 107 demonstrates

that Suno’s conduct fails to qualify as fair use. These factors are: “(1) the purpose and character

of the use, including whether such use is of a commercial nature or is for nonprofit educational

purposes; (2) the nature of the copyrighted work; (3) the amount and substantiality of the portion

used in relation to the copyrighted work as a whole; and (4) the effect of the use upon the potential

market for or value of the copyrighted work.” 17 U.S.C. § 107.

72. The first fair use factor focuses on “the problem of substitution—copyright’s bête

noire.” Andy Warhol Found. for the Visual Arts, Inc. v. Goldsmith, 598 U.S. 508, 528 (2023).

“The use of an original work to achieve a purpose that is the same as, or highly similar to, that of

the original work is more likely to substitute for . . . the work,” and thus is less likely to constitute
fair use. Id.

73. Suno claims its product can produce “radio-quality music,” 18 and encourages paid

users to post their outputs to “platforms expressly designed to commercialize music.” 19 In

furtherance of this objective, Suno copies Plaintiffs’ catalogs of sound recordings and generates

digital music files that are designed to entertain, evoke emotion, and stoke passion, just like the

18
Suno Blog, Introducing v3 (Mar. 21, 2024), https://suno.com/blog/v3.
19
@keenan, Discord (Oct. 1, 2023).

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genuine sound recordings on which Suno was trained. Suno feeds the Copyrighted Recordings

into its AI model not merely to deconstruct their expressive content, but with the explicit aim of

imitating these expressive features in digital music files that could serve as substitutes for and

compete with the original recordings.

74. The use here is far from transformative, as there is no functional purpose for Suno’s

AI model to ingest the Copyrighted Recordings other than to spit out new, competing music files.

That Suno is copying the Copyrighted Recordings for a commercial purpose, and is deriving

revenue directly proportional to the number of music files it generates, further tilts the first fair use

factor against it. See id. at 532–33 (“If an original work and a secondary use share the same or

highly similar purposes, and the secondary use is of a commercial nature, the first factor is likely

to weigh against fair use, absent some other justification for copying.”).

75. The second fair use factor also favors Plaintiffs. This factor recognizes that “certain

‘works are closer to the core of intended copyright protection than others, with the consequence

that fair use is more difficult to establish when the former works are copied.’” TCA TV Corp. v.

McCollum, 839 F.3d 168, 184 (2d Cir. 2016) (quoting Campbell v. Acuff-Rose Music, Inc., 510

U.S. 569, 586 (1994)). There is no doubt that the Copyrighted Recordings are the type of “creative

expression for public dissemination [that] falls within the core of the copyright’s protective

purposes.” Hachette Book Grp., Inc. v. Internet Archive, 664 F. Supp. 3d 370, 387 (S.D.N.Y.

2023) (quoting Campbell, 510 U.S. at 586).

76. So too does the third fair use factor weigh against fair use. “A finding of fair use

is more likely when small amounts . . . are copied than when the copying is extensive, or

encompasses the most important parts of the original.” Authors Guild v. Google, Inc., 804 F.3d

202, 221 (2d Cir. 2015). It is abundantly clear that Suno copies (at least) the most important parts

of the protected sound recordings it sweeps into its training data, as demonstrated by its ability to

recreate, for instance, some of the most recognizable musical phrases, hooks, and choruses in

popular music history. Suno then uses these copies of key elements of protectable expression to

generate audio outputs that resemble the Copyrighted Recordings it ingests.

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77. Turning to the fourth factor, Suno’s use of Copyrighted Recordings poses a

significant threat to the market for and value of the Copyrighted Recordings. Licensing is at the

core of Plaintiffs’ businesses, and Plaintiffs license the Copyrighted Recordings for myriad

purposes, including for use in emerging technologies such as streaming services, user-generated

content platforms, and other innovative technologies. Suno’s unauthorized use of the Copyrighted

Recordings threatens to eliminate the existing market for licensing sound recordings, as well as

the future market for licensing sound recordings to generative AI companies. Rather than license

copyrighted recordings, potential licensees interested in licensing copyrighted recordings for their

own purposes could generate an AI-soundalike at virtually no cost. This is an especially aberrant

result when the replacement audio file is generated using an AI music service, like Suno’s, that

produced the soundalike by infringing the copyrighted recording that would otherwise have been

licensed.

78. Moreover, Suno’s product has the potential to generate directly competing digital

music files at such speed that it risks overrunning the market for human-made sound recordings,

including the Copyrighted Recordings on which it was trained. This competition is ramping up at

a breathtaking pace. Suno has claimed that over 10,000,000 people have already created digital

music files using its service. 20 Suno’s Terms of Service authorize the use of outputs generated on

the platform by users who have subscribed to the paid tier for commercial purposes. 21 Users have

taken this cue by publishing Suno-generated outputs on music streaming services, where they will

compete for plays against real, copyrighted sound recordings.

79. Enticed by the prospect of exponential growth, Suno continues to circumvent the

ordinary rules and steal vast amounts of copyrighted recordings to train its AI model. Suno’s

efforts are “directly aimed at replacing the work of human artists with massive quantities of AI-

created ‘sounds’ . . . that substantially dilute the royalty pools that are paid out to artists.” 22

20
Mikey Shulman, Suno Has Raised $125 Million to Build a Future Where Anyone Can Make Music, Suno Blog (May
21, 2024), https://suno.com/blog/fundraising-announcement-may-2024.
21
Suno, Terms of Service, https://suno.com/terms.
22
Artist Rights Alliance, 200+ Artists Urge Tech Platforms: Stop Devaluing Music, Medium (Apr. 1, 2024),

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80. The harm Suno is causing goes far beyond these immediate economic

consequences. Suno’s wholesale theft of the Copyrighted Recordings threatens the entire music

ecosystem and the numerous people it employs. It also degrades the rights of artists to control

their works, determine whether future uses of their works align with their aesthetic and personal

values, and decide the products or services with which they wish to be associated. And it

propagates the destructive theory that copyrighted music is free for the taking whenever a new

technology claims that seeking and obtaining permission is just too cumbersome. In other words,

Suno’s conduct is a frontal attack on the very purpose of copyright law to reward authors and

promote their incentives to continue creating copyrighted works.

81. There is room for AI and human creators to forge a sustainable, complementary

relationship that promotes human creativity and facilitates the human creations that shape culture,

excite the public, and resonate with consumers. This can and should be achieved through the well-

established mechanism of free-market licensing that ensures proper respect for copyright owners.

Like the other AI technologies that have struck licensing deals with copyright owners, copyright

law mandates that Suno do the same if it wishes to build a business using the Copyrighted

Recordings.

82. Since the day it launched, Suno has flouted the rights of copyright owners in the

music industry as part of a mad dash to become the dominant AI music generation service. Neither

Suno, nor any other generative AI company, can be allowed to advance toward this goal by
trampling the rights of copyright owners.

CLAIMS FOR RELIEF

FIRST CAUSE OF ACTION

(Direct Copyright Infringement of Post-1972 Copyrighted Recordings)

83. Plaintiffs repeat, reallege, and incorporate the allegations in paragraphs 1–82 as if

fully set forth herein.

https://artistrightsnow.medium.com/200-artists-urge-tech-platforms-stop-devaluing-music-559fb109bbac.

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84. Plaintiffs UMG and Capitol own or exercise exclusive control over rights in the

Universal Works, which are an illustrative and non-exhaustive list of some of Universal’s works

infringed by Defendant through its development of Suno’s service. Universal has duly registered

each of the Universal Works.

85. Plaintiff Sony owns or exercises exclusive control over rights in the Sony Works,

which are an illustrative and non-exhaustive list of some of Sony’s works infringed by Defendant

through its development of Suno’s service. Sony has duly registered each of the Sony Works.

86. Plaintiffs Atlantic, ARG, Rhino, The All Blacks, WMISL, and Warner Records Inc.

own or exercise exclusive control over rights in the Warner Works, which are an illustrative and

non-exhaustive list of some of Warner’s works infringed by Defendant through its development

of Suno’s service. Warner has duly registered each of the Warner Works.

87. Suno has knowingly infringed Plaintiffs’ exclusive rights in copyrighted sound

recordings, including but not limited to the Universal Works, the Sony Works, and the Warner

Works, by reproducing them in violation of 17 U.S.C. § 106(1).

88. Suno does not have authorization, permission, license, or consent to reproduce or

otherwise use the Universal Works, the Sony Works, or the Warner Works.

89. Upon information and belief, Suno used the reproductions of the Universal Works,

the Sony Works, and the Warner Works to train its generative AI model.

90. Each of Suno’s acts of infringement of the Universal Works, the Sony Works, and
the Warner Works is a willful violation of 17 U.S.C. § 106.

91. As a direct and proximate result of Suno’s infringement of Plaintiffs’ exclusive

rights, Suno has caused and will continue to cause irreparable injury to Plaintiffs for which

Plaintiffs have no adequate remedy at law. Plaintiffs are therefore entitled to injunctive relief and

to either actual damages and Suno’s profits or statutory damages pursuant to 17 U.S.C. § 504(c),

together with Plaintiffs’ costs and reasonable attorneys’ fees pursuant to 17 U.S.C. § 505.

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 Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 31 of 34

SECOND CAUSE OF ACTION

(Direct Copyright Infringement of Pre-1972 Copyrighted Recordings)

92. Plaintiffs repeat, reallege, and incorporate the allegations in paragraphs 1–82 as if

fully set forth herein.

93. Plaintiffs UMG and Capitol own or exercise exclusive control over rights in the

Universal Works, which are an illustrative and non-exhaustive list of some of Universal’s works

infringed by Defendant through its development of Suno’s service. All of the pre-1972 Universal

Works have been submitted to and publicly indexed by the U.S. Copyright Office pursuant to 17

U.S.C. § 1401.

94. Plaintiff Sony owns or exercises exclusive control over rights in the Sony Works,

which are an illustrative and non-exhaustive list of some of Sony’s works infringed by Defendant

through its development of Suno’s service. All of the pre-1972 Sony Works have been submitted

to and publicly indexed by the U.S. Copyright Office pursuant to 17 U.S.C. § 1401.

95. Plaintiffs Atlantic, ARG, Rhino, The All Blacks, WMISL, and Warner Records Inc.

own or exercise exclusive control over rights in the Warner Works, which are an illustrative and

non-exhaustive list of some of Warner’s works infringed by Defendant through its development

of Suno’s service. All of the pre-1972 Warner Works have been submitted to and publicly indexed

by the U.S. Copyright Office pursuant to 17 U.S.C. § 1401.

96. Suno has knowingly infringed Plaintiffs’ exclusive rights in copyrighted sound

recordings, including but not limited to the Universal Works, the Sony Works, and the Warner

Works, by reproducing them in violation of 17 U.S.C. §§ 106(1) and 1401(a)(1).

97. Suno does not have authorization, permission, license, or consent to reproduce or

otherwise use the Universal Works, the Sony Works, or the Warner Works.

98. Upon information and belief, Suno used the reproductions of the Universal Works,

the Sony Works, and the Warner Works to train its generative AI model.

99. Each of Suno’s acts of infringement of the Universal Works, the Sony Works, and

the Warner Works is a willful violation of 17 U.S.C. § 106.

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 Case 1:24-cv-11611 Document 1 Filed 06/24/24 Page 32 of 34

100. As a direct and proximate result of Suno’s infringement of Plaintiffs’ exclusive

rights, Suno has caused and will continue to cause irreparable injury to Plaintiffs for which

Plaintiffs have no adequate remedy at law. Plaintiffs are therefore entitled to injunctive relief and

to either actual damages and Suno’s profits or statutory damages pursuant to 17 U.S.C. § 504(c),

together with Plaintiffs’ costs and reasonable attorneys’ fees pursuant to 17 U.S.C. § 505.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request a judgment in their favor and against Suno

as follows:
A. For a declaration that Suno has willfully infringed Plaintiffs’ protected sound

recordings, including the Universal Works, the Sony Works, and the Warner

Works.

B. For such equitable relief under Title 17, Title 28, and/or the Court’s inherent

authority as is necessary to prevent or restrain infringement of Plaintiffs’ protected

sound recordings, including a preliminary and permanent injunction requiring that

Suno and its officers, agents, servants, employees, attorneys, directors, successors,

assigns, licensees, and all others in active concert or participation with any of them,

cease infringing, or causing, aiding, enabling, facilitating, encouraging, promoting,

inducing, or materially contributing to or participating in the infringement of any

of Plaintiffs’ exclusive rights under federal law, including without limitation in the

sound recordings in Exhibit A;

C. For statutory damages pursuant to 17 U.S.C. § 504(c), in an amount up to the

maximum provided by law, arising from Suno’s willful violations of Plaintiffs’

rights, including in an amount up to $150,000 per work infringed; or, in the

alternative, at Plaintiffs’ election, Plaintiffs’ actual damages and/or Suno’s profits

from infringement pursuant to 17 U.S.C. § 504(b), in an amount to be proven at

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trial;

D. For an award of Plaintiffs’ costs and disbursements in this action, including

reasonable attorneys’ fees, pursuant to 17 U.S.C. § 505;

E. For an award of pre-judgment and post-judgment interest, to the fullest extent

available, on any monetary award made part of the judgment against Suno; and

F. For such other and further relief as the Court may deem just and proper.

JURY DEMAND
Plaintiffs demand a trial by jury on all claims for which trial by jury is proper.

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Dated: June 24, 2024 HUESTON HENNIGAN LLP

By: Moez M. Kaba (to be admitted pro hac vice)

Mariah N. Rivera (to be admitted pro hac vice)
Alexander R. Perry (to be admitted pro hac vice)
HUESTON HENNIGAN LLP
1 Little West 12th Street
New York, New York 10014
Telephone: (646) 930-4046
Facsimile: (888) 775-0898
[email protected]
[email protected]
[email protected]

Robert N. Klieger (to be admitted pro hac vice)

HUESTON HENNIGAN LLP
523 West 6th Street, Suite 400
Los Angeles, California 90014
Telephone: (213) 788-4340
Facsimile: (888) 775-0898
[email protected]

Daniel J. Cloherty (BBO #565772)

CLOHERTY & STEINBERG LLP
One Financial Center, Suite 1120
Boston, Massachusetts 02110
Telephone: (617) 481-0160
Facsimile: (617) 848-0830
[email protected]

Attorneys for Plaintiffs

UMG Recordings, Inc., Capitol Records,
LLC, Sony Music Entertainment, Atlantic
Recording Corporation, Atlantic Records
Group LLC, Rhino Entertainment LLC, The
All Blacks U.S.A., Inc., Warner Music
International Services Limited, and Warner
Records Inc.

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JS 44 (Rev. 10/20) CIVIL
Case 1:24-cv-11611 COVER
Document 1-1 SHEET
Filed 06/24/24 Page 1 of 1
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
UMG Recordings, Inc., Capitol Recordings, LLC, Sony
Suno, Inc.
Music Entertainment, Atlantic Recording Corporation,
Atlantic
(b) County Records
of Residence Group
of First LLC,
Listed RhinoLos
Plaintiff Entertainment LLC, CA
Angeles County, County of Residence of First Listed Defendant Middlesex County, MA
The ALL Blacks U.S.A.,
(EXCEPT Inc.,
IN U.S. Warner
PLAINTIFF Music International
CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
Services Limited, and Warner Records Inc. THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

Moez M. Kaba, Hueston Hennigan LLP, 1 Little West Andrew Gass, Latham & Watkins LLP, 505 Montgomery
12th St., 2nd Fl., New York, NY 10014, Tele: (646) St., Suite 2000, San Francisco, CA 94111; Tele: (415)
II. BASIS OF JURISDICTION (Place an “X” in One Box Only)
930-4046 III. CITIZENSHIP
391-0600OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S.Daniel J. Cloherty,✖ BBO
Government #565772,
3 Federal Question Cloherty & Steinberg PTF DEF PTF DEF
LLP, One Financial Center,
Plaintiff Suite 112,
(U.S. Government Not aBoston,
Party) MA Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
02111, Tel. 617-481-0160
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ✖ 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
✖ 1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
17 U.S.C. 101, et. seq, 17 U.S.C. 1401
VI. CAUSE OF ACTION Brief description of cause:
Infringement of protected sound recordings.
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ✖ Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
June 24, 2024 /s/ Daniel J. Cloherty (BBO #565772)
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 1 of 27

EXHIBIT A

Sound Recordings at Issue

# Artist Title Reg. No. Rights Owner

Atlantic Recording
1. Jason Derulo Acapulco SR0000909583
Corporation
(Sittin' On) the Dock of Atlantic Recording
2. Otis Redding Pre-1972 Sound Recording
the Bay Corporation
Atlantic Recording
3. Otis Redding A Change Is Gonna Come Pre-1972 Sound Recording
Corporation
Atlantic Recording
4. Otis Redding Cigarettes and Coffee Pre-1972 Sound Recording
Corporation
Atlantic Recording
5. Otis Redding For Your Precious Love Pre-1972 Sound Recording
Corporation
Atlantic Recording
6. Otis Redding Hard to Handle Pre-1972 Sound Recording
Corporation
I've Been Loving You Too Atlantic Recording
7. Otis Redding Pre-1972 Sound Recording
Long Corporation
I've Got Dreams to Atlantic Recording
8. Otis Redding Pre-1972 Sound Recording
Remember Corporation
Atlantic Recording
9. Otis Redding Love Man Pre-1972 Sound Recording
Corporation
Atlantic Recording
10. Otis Redding Merry Christmas Baby Pre-1972 Sound Recording
Corporation
Atlantic Recording
11. Otis Redding My Girl Pre-1972 Sound Recording
Corporation
Atlantic Recording
12. Otis Redding Pain in My Heart Pre-1972 Sound Recording
Corporation
Atlantic Recording
13. Otis Redding Shake Pre-1972 Sound Recording
Corporation
Atlantic Recording
14. Otis Redding Stand by Me Pre-1972 Sound Recording
Corporation
That's How Strong My Atlantic Recording
15. Otis Redding Pre-1972 Sound Recording
Love Is Corporation
Atlantic Recording
16. Otis Redding These Arms of Mine Pre-1972 Sound Recording
Corporation
Atlantic Recording
17. Otis Redding Try a Little Tenderness Pre-1972 Sound Recording
Corporation
Atlantic Recording
18. Otis Redding White Christmas Pre-1972 Sound Recording
Corporation
Atlantic Recording
19. Otis Redding Wonderful World Pre-1972 Sound Recording
Corporation
Atlantic Recording
20. Otis Redding You Send Me Pre-1972 Sound Recording
Corporation
Otis Redding
Atlantic Recording
21. & Carla Tramp Pre-1972 Sound Recording
Corporation
Thomas
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 2 of 27

Atlantic Recording
22. Ray Charles A Fool for You Pre-1972 Sound Recording
Corporation
Atlantic Recording
23. Ray Charles Ain't That Love Pre-1972 Sound Recording
Corporation
Atlantic Recording
24. Ray Charles Come Back Baby Pre-1972 Sound Recording
Corporation
Come Rain or Come Atlantic Recording
25. Ray Charles Pre-1972 Sound Recording
Shine Corporation
Atlantic Recording
26. Ray Charles Don't You Know Pre-1972 Sound Recording
Corporation
Atlantic Recording
27. Ray Charles Drown in My Own Tears Pre-1972 Sound Recording
Corporation
Atlantic Recording
28. Ray Charles Hallelujah, I Love Her So Pre-1972 Sound Recording
Corporation
Hard Times (No One Atlantic Recording
29. Ray Charles Pre-1972 Sound Recording
Knows Better Than I) Corporation
Atlantic Recording
30. Ray Charles I Believe to My Soul Pre-1972 Sound Recording
Corporation
Atlantic Recording
31. Ray Charles It Had to Be You Pre-1972 Sound Recording
Corporation
Atlantic Recording
32. Ray Charles I’ve Got A Woman Pre-1972 Sound Recording
Corporation
Atlantic Recording
33. Ray Charles Leave My Woman Alone Pre-1972 Sound Recording
Corporation
Atlantic Recording
34. Ray Charles Let the Good Times Roll Pre-1972 Sound Recording
Corporation
Atlantic Recording
35. Ray Charles Lonely Avenue Pre-1972 Sound Recording
Corporation
Atlantic Recording
36. Ray Charles Mary Ann Pre-1972 Sound Recording
Corporation
Atlantic Recording
37. Ray Charles Mess Around Pre-1972 Sound Recording
Corporation
Atlantic Recording
38. Ray Charles Sinner’s Prayer Pre-1972 Sound Recording
Corporation
What Would I Do Without Atlantic Recording
39. Ray Charles Pre-1972 Sound Recording
You Corporation
Atlantic Recording
40. Ray Charles What'd I Say, Pt. 1 & 2 Pre-1972 Sound Recording
Corporation
Atlantic Recording
41. Ray Charles You Won't Let Me Go Pre-1972 Sound Recording
Corporation
Atlantic Records
42. Jason Derulo Take You Dancing SR0000886298
Group LLC
The Beach Capitol filed 2019-03-25 - Capitol Records,
43. 409
Boys USCA20001612 LLC
The Beach Capitol filed 2019-03-25 - Capitol Records,
44. All I Wanna Do
Boys USGJP1300033 LLC
The Beach Capitol filed 2019-03-25 - Capitol Records,
45. All Summer Long
Boys USCA20001636 LLC
The Beach Capitol filed 2019-03-25 - Capitol Records,
46. Barbara Ann
Boys GBCBR0100608 LLC

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 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 3 of 27

The Beach Be True To Your School Capitol filed 3.22.2019 - Capitol Records,
47.
Boys (Single Version) GBCBR0100593 LLC
The Beach Capitol Records,
48. California Dreamin' SR0000902518
Boys LLC
The Beach Capitol filed CALIFORNIA Capitol Records,
49. California Girls
Boys GIRLS 3.22.2019 LLC
The Beach Capitol Records,
50. Caroline, No Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 Catch A Capitol Records,
51. Catch A Wave
Boys Wave LLC
The Beach Capitol Records,
52. Dance, Dance, Dance Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
53. Darlin' Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
54. Do It Again Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
55. Do You Wanna Dance? Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 Don't Capitol Records,
56. Don't Back Down
Boys Back Down LLC
The Beach Capitol Records,
57. Don't Go Near The Water Capitol filed 2019-03-25
Boys LLC
The Beach Don't Hurt My Little Capitol Records,
58. Capitol filed 2019-03-25
Boys Sister LLC
The Beach Don't Talk (Put Your Head Capitol Records,
59. Capitol filed 2019-03-25
Boys On My Shoulder) LLC
The Beach Capitol filed 3.22.2019 Don't Capitol Records,
60. Don't Worry Baby
Boys Worry Baby LLC
The Beach Capitol Records,
61. Drive-In Capitol filed 2019-03-25
Boys LLC
The Beach Fall Breaks And Back To Capitol Records,
62. Capitol filed 2019-03-25
Boys Winter LLC
The Beach Capitol filed 3.22.2019 Farmer's Capitol Records,
63. Farmer's Daughter
Boys Daughter LLC
The Beach Capitol Records,
64. Feel Flows Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
65. Finders Keepers Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
66. Forever Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed FRIENDS Capitol Records,
67. Friends
Boys 3.22.2019 LLC
The Beach Capitol Records,
68. Frosty The Snowman Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 Fun, Fun, Capitol Records,
69. Fun, Fun, Fun
Boys Fun LLC
The Beach Capitol Records,
70. Getting Hungry Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
71. Girl Don't Tell Me Capitol filed 2019-03-25
Boys LLC

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The Beach Capitol filed 3.22.2019 Girls On Capitol Records,

72. Girls On The Beach
Boys The Beach LLC
The Beach Capitol filed GOD ONLY Capitol Records,
73. God Only Knows
Boys KNOWS 3.22.2019 LLC
The Beach Capitol Records,
74. Good To My Baby Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
75. Good Vibrations Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
76. Got To Know The Woman Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
77. Graduation Day Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
78. Hang On To Your Ego Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
79. Hawaii Capitol filed 2019-03-25
Boys LLC
The Beach Heads You Win, Tails I Capitol filed 3.22.2019 Heads Capitol Records,
80.
Boys Lose You Win, Tails I Lose LLC
The Beach Capitol filed 3.22.2019 Help Me, Capitol Records,
81. Help Me, Rhonda
Boys Rhonda LLC
The Beach Capitol Records,
82. Here Comes The Night Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
83. Here Today Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
84. Heroes And Villains Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
85. Honky Tonk Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
86. How She Boogalooed It Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
87. Hully Gully Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
88. Hushabye Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
89. I Can Hear Music Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
90. I Do Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 I Get Capitol Records,
91. I Get Around
Boys Around LLC
The Beach I Get Around/Little Deuce Capitol Records,
92. Capitol filed 2019-03-25
Boys Coupe LLC
The Beach I Just Wasn't Made For Capitol Records,
93. Capitol filed 2019-03-25
Boys These Times LLC
The Beach I Know There's An Capitol Records,
94. Capitol filed 2019-03-25
Boys Answer LLC
The Beach Capitol Records,
95. I Was Made To Love Her Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
96. I Went To Sleep Capitol filed 2019-03-25
Boys LLC

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 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 5 of 27

The Beach I'd Love Just Once To See Capitol Records,

97. Capitol filed 2019-03-25
Boys You LLC
The Beach I'll Be Home For Capitol Records,
98. Capitol filed 2019-03-25
Boys Christmas LLC
The Beach I'm Bugged At My Ol' Capitol Records,
99. Capitol filed 2019-03-25
Boys Man LLC
The Beach Capitol Records,
100. I'm So Young Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
101. I'm Waiting For The Day Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
102. In My Room Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
103. In The Back Of My Mind Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 In The Capitol Records,
104. In The Parkin' Lot
Boys Parkin' Lot LLC
The Beach Capitol Records,
105. It's About Time Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
106. Johnny B. Goode Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
107. Keep An Eye On Summer Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed KISS ME, BABY Capitol Records,
108. Kiss Me, Baby
Boys 3.22.2019 LLC
The Beach Capitol Records,
109. Lana Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
110. Land Ahoy Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed LET HIM RUN Capitol Records,
111. Let Him Run Wild
Boys WILD 3.22.2019 LLC
The Beach Capitol Records,
112. Let The Wind Blow Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
113. Let's Go Away For Awhile Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
114. Let's Go Trippin' Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
115. Little Bird Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 - Little Capitol Records,
116. Little Deuce Coupe
Boys Deuce Coupe LLC
The Beach Little Girl (You're My Capitol filed 3.22.2019 Little Capitol Records,
117.
Boys Miss America) Girl (You're My Miss America) LLC
The Beach Capitol Records,
118. Little Honda Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
119. Little Pad Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
120. Little Saint Nick Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
121. Lonely Sea Capitol filed 2019-03-25
Boys LLC

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 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 6 of 27

The Beach Capitol Records,

122. Long Promised Road Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
123. Long Tall Texan Capitol filed 2019-03-25
Boys LLC
The Beach Lookin' At Tomorrow (A Capitol Records,
124. Capitol filed 2019-03-25
Boys Welfare Song) LLC
The Beach Capitol Records,
125. Louie Louie Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
126. Mama Says Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
127. Meant For You Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
128. Merry Christmas, Baby Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
129. Misirlou Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
130. Monster Mash Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 Moon Capitol Records,
131. Moon Dawg
Boys Dawg LLC
The Beach Capitol Records,
132. Mountain Of Love Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
133. Never Learn Not To Love Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
134. Noble Surfer Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 No-Go Capitol Records,
135. No-Go Showboat
Boys Showboat LLC
The Beach Old Folks At Home / Ol' Capitol Records,
136. Capitol filed 2019-03-25
Boys Man River LLC
The Beach Capitol Records,
137. Our Car Club Capitol filed 2019-03-25
Boys LLC
The Beach Our Favorite Recording Capitol Records,
138. Capitol filed 2019-03-25
Boys Sessions LLC
The Beach Capitol Records,
139. Our Prayer Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
140. Our Sweet Love Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
141. Papa-Oom-Mow-Mow Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
142. Passing By Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
143. Pet Sounds Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
144. Please Let Me Wonder Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 Pom Capitol Records,
145. Pom Pom Play Girl
Boys Pom Play Girl LLC
The Beach Capitol filed 3.22.2019 Rocking Capitol Records,
146. Rocking Surfer
Boys Surfer LLC

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The Beach Capitol filed SALT LAKE CITY Capitol Records,

147. Salt Lake City
Boys 3.22.2019 LLC
The Beach Capitol Records,
148. Santa's Beard Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed SHE KNOWS ME Capitol Records,
149. She Knows Me Too Well
Boys TOO WELL 3.22.2019 LLC
The Beach Capitol Records,
150. Shut Down Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
151. Shut Down, Part II Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed SLOOP JOHN B Capitol Records,
152. Sloop John B
Boys 3.22.2019 LLC
The Beach Capitol filed 3.22.2019 South Capitol Records,
153. South Bay Surfer
Boys Bay Surfer LLC
The Beach Capitol filed 3.22.2019 Spirit Of Capitol Records,
154. Spirit Of America
Boys America LLC
The Beach Capitol Records,
155. Stoked Capitol filed 2019-03-25
Boys LLC
The Beach Student Demonstration Capitol Records,
156. Capitol filed 2019-03-25
Boys Time LLC
The Beach Capitol Records,
157. Summer Means New Love Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
158. Summertime Blues Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
159. Surf Jam Capitol filed 3.22.2019 Surf Jam
Boys LLC
The Beach Capitol filed 3.22.2019 Surfer Capitol Records,
160. Surfer Girl
Boys Girl LLC
The Beach Capitol filed 3.22.2019 Surfer's Capitol Records,
161. Surfer's Rule
Boys Rule LLC
The Beach Capitol Records,
162. Surfin' Capitol filed 3.22.2019 Surfin'
Boys LLC
The Beach Capitol filed 3.22.2019 Surfin' Capitol Records,
163. Surfin' Safari
Boys Safari LLC
The Beach Capitol Records,
164. Surfin U.S.A. Capitol filed 3.22.2019
Boys LLC
The Beach Take A Load Off Your Capitol Records,
165. Capitol filed 2019-03-25
Boys Feet LLC
The Beach Capitol Records,
166. Tears In The Morning Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
167. Ten Little Indians Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
168. That's Not Me Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
169. The Baker Man Capitol filed 2019-03-25
Boys LLC
The Beach The Girl From New York Capitol Records,
170. Capitol filed 2019-03-25
Boys City LLC
The Beach The Little Girl I Once Capitol Records,
171. Capitol filed 2019-03-25
Boys Knew LLC

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 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 8 of 27

The Beach The Little Old Lady From Capitol Records,

172. Capitol filed 2019-03-25
Boys Pasadena LLC
The Beach The Man With All The Capitol Records,
173. Capitol filed 2019-03-25
Boys Toys LLC
The Beach The Nearest Faraway Capitol Records,
174. Capitol filed 2019-03-25
Boys Place LLC
The Beach Capitol Records,
175. The Shift Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
176. The Surfer Moon Capitol filed 2019-03-25
Boys LLC
The Beach The Times They Are A- Capitol Records,
177. Capitol filed 2019-03-25
Boys Changin' LLC
The Beach Capitol Records,
178. The Wanderer Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
179. The Warmth Of The Sun Capitol filed 2019-03-25
Boys LLC
The Beach Their Hearts Were Full Of Capitol Records,
180. Capitol filed 2019-03-25
Boys Spring LLC
The Beach Capitol Records,
181. Then I Kissed Her Capitol filed 2019-03-25
Boys LLC
The Beach There's No Other (Like Capitol Records,
182. Capitol filed 2019-03-25
Boys My Baby) LLC
The Beach Capitol filed 3.22.2019 This Car Capitol Records,
183. This Car Of Mine
Boys Of Mine LLC
The Beach Capitol Records,
184. This Whole World Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
185. 'Til I Die Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
186. Time To Get Alone Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
187. Transcendental Meditation Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
188. Trombone Dixie Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
189. Vegetables Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
190. Wake The World Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
191. Walk On By Capitol filed 2019-03-25
Boys LLC
The Beach We Three Kings Of Orient Capitol Records,
192. Capitol filed 2019-03-25
Boys Are LLC
The Beach Capitol filed 3.22.2019 We'll Capitol Records,
193. We'll Run Away
Boys Run Away LLC
The Beach Capitol Records,
194. Wendy Capitol filed 3.22.2019 Wendy
Boys LLC
The Beach Capitol Records,
195. We're Together Again Capitol filed 2019-03-25
Boys LLC
The Beach When A Man Needs A Capitol Records,
196. Capitol filed 2019-03-25
Boys Woman LLC

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The Beach When I Grow Up (To Be Capitol filed 3.22.2019 When I Capitol Records,
197.
Boys A Man) Grow Up (To Be A Man) LLC
The Beach Capitol Records,
198. Whistle In Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
199. White Christmas Capitol filed 2019-03-25
Boys LLC
The Beach Why Do Fools Fall In Capitol filed 3.22.2019 Why Do Capitol Records,
200.
Boys Love Fools Fall In Love LLC
The Beach Capitol Records,
201. Wild Honey Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
202. Wind Chimes Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
203. With Me Tonight Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
204. Wonderful Capitol filed 2019-03-25
Boys LLC
The Beach Capitol Records,
205. Wouldn't It Be Nice Capitol filed 3.22.2019 - 5
Boys LLC
The Beach Capitol Records,
206. You Still Believe In Me Capitol filed 2019-03-25
Boys LLC
The Beach Capitol filed 3.22.2019 Your Capitol Records,
207. Your Summer Dream
Boys Summer Dream LLC
The Beach Capitol filed YOU'RE SO Capitol Records,
208. You're So Good to Me
Boys GOOD TO ME 3.22.2019 LLC
The Beach You're So Good To Me Capitol Records,
209. Capitol filed 2019-03-25
Boys (Instrumental) LLC
The Beach Capitol Records,
210. You're Welcome Capitol filed 2019-03-25
Boys LLC
Capitol filed A DAY IN THE Capitol Records,
211. The Beatles A Day In The Life
LIFE 3.13.2019 LLC
Capitol filed A HARD DAY'S Capitol Records,
212. The Beatles A Hard Day's Night
NIGHT 3.13.2019 LLC
Capitol filed A TASTE OF Capitol Records,
213. The Beatles A Taste of Honey
HONEY 3.13.2019 LLC
Capitol filed ACROSS THE Capitol Records,
214. The Beatles Across The Universe
UNIVERSE 3.13.2019 LLC
Capitol filed ACT NATURALLY Capitol Records,
215. The Beatles Act Naturally
3.13.2019 LLC
Capitol filed ALL I'VE GOT TO Capitol Records,
216. The Beatles All I've Got To Do
DO 3.13.2019 LLC
Capitol filed ALL MY LOVING Capitol Records,
217. The Beatles All My Loving
3.13.2019 LLC
Capitol filed ALL TOGETHER Capitol Records,
218. The Beatles All Together Now
NOW 3.13.2019 LLC
Capitol filed ALL YOU NEED Capitol Records,
219. The Beatles All You Need Is Love
IS LOVE 3.13.2019 LLC
Capitol filed AND I LOVE HER Capitol Records,
220. The Beatles And I Love Her
3.13.2019 LLC
Capitol filed AND YOUR BIRD Capitol Records,
221. The Beatles And Your Bird Can Sing
CAN SING 3.13.2019 LLC

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 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 10 of 27

Capitol filed ANNA (GO TO Capitol Records,

222. The Beatles Anna (Go To Him)
HIM) 3.13.2019 LLC
Capitol filed ANOTHER GIRL Capitol Records,
223. The Beatles Another Girl
3.13.2019 LLC
Capitol filed ANY TIME AT Capitol Records,
224. The Beatles Any Time At All
ALL 3.13.2019 LLC
Capitol filed ASK ME WHY Capitol Records,
225. The Beatles Ask Me Why
3.13.2019 LLC
Capitol filed BABY IT'S YOU Capitol Records,
226. The Beatles Baby It's You
3.13.2019 LLC
Capitol filed BABY YOU'RE A Capitol Records,
227. The Beatles Baby You're A Rich Man
RICH MAN 3.13.2019 LLC
Capitol filed BABY'S IN Capitol Records,
228. The Beatles Baby's In Black
BLACK 3.13.2019 LLC
Capitol filed BACK IN THE Capitol Records,
229. The Beatles Back In The U.S.S.R.
U.S.S.R 3.13.2019 LLC
Capitol filed BAD BOY Capitol Records,
230. The Beatles Bad Boy
3.13.2019 LLC
Capitol filed BECAUSE Capitol Records,
231. The Beatles Because of You
3.13.2019 LLC
Capitol filed BEING FOR THE
Being For The Benefit of Capitol Records,
232. The Beatles BENEFIT OF MR KITE!
Mr Kite! LLC
3.13.2019
Capitol Records,
233. The Beatles Birthday Capitol filed 3.13.2019
LLC
Capitol Records,
234. The Beatles Birthday 2009 Remaster Capitol filed Birthday 3.13.2019
LLC
Capitol filed BLACKBIRD Capitol Records,
235. The Beatles Blackbird
3.13.2019 LLC
Capitol filed BLUE JAY WAY Capitol Records,
236. The Beatles Blue Jay Way
3.13.2019 LLC
Capitol Records,
237. The Beatles Boys Capitol filed BOYS 3.13.2019
LLC
Capitol filed CAN'T BUY ME Capitol Records,
238. The Beatles Can't Buy Me Love
LOVE 3.13.2019 LLC
Capitol filed CARRY THAT Capitol Records,
239. The Beatles Carry That Weight
WEIGHT 3.13.2019 LLC
Capitol Records,
240. The Beatles Chains Capitol filed CHAINS 3.13.2019
LLC
Capitol filed COME Capitol Records,
241. The Beatles Come Together
TOGETHER 3.13.2019 LLC
Capitol filed CRY BABY CRY Capitol Records,
242. The Beatles Cry Baby Cry
3.13.2019 LLC
Capitol filed DAY TRIPPER Capitol Records,
243. The Beatles Day Tripper
3.13.2019 LLC
Capitol filed DEAR Capitol Records,
244. The Beatles Dear Prudence
PRUDENCE 3.13.2019 LLC
Capitol filed DEVIL IN HER Capitol Records,
245. The Beatles Devil In Her Heart
HEART 3.13.2019 LLC

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 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 11 of 27

Capitol Records,
246. The Beatles Dig It Capitol filed 3.13.2019
LLC
Capitol filed DIZZY MISS Capitol Records,
247. The Beatles Dizzy Miss Lizzy
LIZZY 3.13.2019 LLC
Capitol filed DO YOU WANT
Do You Want To Know A Capitol Records,
248. The Beatles TO KNOW A SECRET
Secret LLC
3.13.2019
Capitol filed DON'T BOTHER Capitol Records,
249. The Beatles Don't Bother Me
ME 3.13.2019 LLC
Capitol Records,
250. The Beatles Don't Let Me Down Capitol filed 3.13.2019
LLC
Capitol Records,
251. The Beatles Don't Pass Me By Capitol filed 3.13.2019
LLC
Capitol filed DRIVE MY CAR Capitol Records,
252. The Beatles Drive My Car
3.13.2019 LLC
Capitol filed EIGHT DAYS A Capitol Records,
253. The Beatles Eight Days A Week
WEEK 3.13.2019 LLC
Capitol filed 3.13.2019 - Eleanor Capitol Records,
254. The Beatles Eleanor Rigby
Rigby LLC
Capitol filed 3.13.2019 - Every Capitol Records,
255. The Beatles Every Little Thing
Little Thing LLC
Everybody's Got
Something To Hide Capitol Records,
256. The Beatles Capitol filed 3.13.2019
Except Me And My LLC
Monkey
Everybody's Trying To Be Capitol Records,
257. The Beatles Capitol filed 3.13.2019
My Baby LLC
Capitol Records,
258. The Beatles Fixing A Hole Capitol filed 3.13.2019
LLC
Capitol Records,
259. The Beatles Flying Capitol filed 3.13.2019 - Flying
LLC
Capitol filed FOR NO ONE Capitol Records,
260. The Beatles For No One
3.13.2019 LLC
Capitol Records,
261. The Beatles For You Blue Capitol filed 3.13.2019
LLC
Capitol filed From Me To You Capitol Records,
262. The Beatles From Me To You
3.13.2019 LLC
Capitol Records,
263. The Beatles Get Back Capitol filed Get Back 3.13.2019
LLC
Capitol filed Getting Better Capitol Records,
264. The Beatles Getting Better
3.13.2019 LLC
Capitol Records,
265. The Beatles Girl Capitol filed 3.13.2019 - Girl
LLC
Capitol filed GLASS ONION Capitol Records,
266. The Beatles Glass Onion
3.13.2019 LLC
Capitol filed Golden Slumbers Capitol Records,
267. The Beatles Golden Slumbers
3.13.2019 LLC
Capitol filed GOOD DAY Capitol Records,
268. The Beatles Good Day Sunshine
SUNSHINE 3.13.2019 LLC

- 11 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 12 of 27

Good Morning Good Capitol filed GOOD MORNING Capitol Records,

269. The Beatles
Morning GOOD MORNING 3.13.2019 LLC
Capitol filed GOOD NIGHT Capitol Records,
270. The Beatles Good Night
3.13.2019 LLC
Got To Get You Into My Capitol filed Got To Get You Capitol Records,
271. The Beatles
Life Into My Life 3.13.2019 LLC
Capitol filed HAPPINESS IS A Capitol Records,
272. The Beatles Happiness Is A Warm Gun
WARM GUN 3.13.2019 LLC
Capitol filed HELLO, Capitol Records,
273. The Beatles Hello, Goodbye
GOODBYE 3.13.2019 LLC
Capitol Records,
274. The Beatles Help! Capitol filed HELP! 3.13.2019
LLC
Capitol filed HELTER Capitol Records,
275. The Beatles Helter Skelter
SKELTER 3.13.2019 LLC
Capitol filed Her Majesty Capitol Records,
276. The Beatles Her Majesty
3.13.2019 LLC
Capitol filed HERE COMES Capitol Records,
277. The Beatles Here Comes The Sun
THE SUN 3.13.2019 LLC
Capitol filed HERE, THERE
Here, There And Capitol Records,
278. The Beatles AND EVERYWHERE
Everywhere LLC
3.13.2019
Capitol filed HEY BULLDOG Capitol Records,
279. The Beatles Hey Bulldog
3.13.2019 LLC
Capitol filed HEY JUDE Capitol Records,
280. The Beatles Hey Jude
3.13.2019 LLC
Capitol filed HOLD ME TIGHT Capitol Records,
281. The Beatles Hold Me Tight
3.13.2019 LLC
Capitol Records,
282. The Beatles Honey Don't Capitol filed 3.13.2019
LLC
Capitol filed Honey Pie Capitol Records,
283. The Beatles Honey Pie
3.13.2019 LLC
Capitol filed I Am The Walrus Capitol Records,
284. The Beatles I Am The Walrus
3.13.2019 LLC
Capitol Records,
285. The Beatles I Call Your Name Capitol filed 3.13.2019
LLC
I Don't Want To Spoil The Capitol Records,
286. The Beatles Capitol filed 3.13.2019
Party LLC
Capitol filed I Feel Fine Capitol Records,
287. The Beatles I Feel Fine
3.13.2019 LLC
Capitol filed I ME MINE Capitol Records,
288. The Beatles I Me Mine
3.13.2019 LLC
Capitol filed I Need You Capitol Records,
289. The Beatles I Need You
3.13.2019 LLC
Capitol filed I SAW HER Capitol Records,
290. The Beatles I Saw Her Standing There
STANDING THERE 3.13.2019 LLC
I Should Have Known Capitol filed I Should Have Capitol Records,
291. The Beatles
Better Known Better 3.13.2019 LLC
Capitol filed I Wanna Be Your Capitol Records,
292. The Beatles I Wanna Be Your Man
Man 3.13.2019 LLC

- 12 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 13 of 27

Capitol filed I WANT TO HOLD Capitol Records,

293. The Beatles I Want To Hold Your Hand
YOUR HAND 3.13.2019 LLC
Capitol filed I Want To Tell You Capitol Records,
294. The Beatles I Want To Tell You
3.13.2019 LLC
I Want You (She's So Capitol filed I WANT YOU Capitol Records,
295. The Beatles
Heavy) (SHE'S SO HEAVY) 3.13.2019 LLC
Capitol Records,
296. The Beatles I Will Capitol filed I WILL 3.13.2019
LLC
Capitol filed I'M HAPPY JUST
I’m Happy Just To Dance Capitol Records,
297. The Beatles TO DANCE WITH YOU
With You LLC
3.13.2019
Capitol Records,
298. The Beatles If I Fell Capitol filed If I Fell 3.13.2019
LLC
Capitol filed If I Needed Capitol Records,
299. The Beatles If I Needed Someone
Someone 3.13.2019 LLC
Capitol Records,
300. The Beatles I'll Be Back Capitol filed 3.13.2019
LLC
Capitol Records,
301. The Beatles I'll Cry Instead Capitol filed 3.13.2019
LLC
Capitol filed I'll Follow The Sun Capitol Records,
302. The Beatles I'll Follow The Sun
3.13.2019 LLC
Capitol filed I'll Get You Capitol Records,
303. The Beatles I'll Get You
3.13.2019 LLC
Capitol filed I'm A Loser Capitol Records,
304. The Beatles I'm A Loser
3.13.2019 LLC
Capitol filed I'm Down Capitol Records,
305. The Beatles I'm Down
3.13.2019 LLC
Capitol filed I'm Looking Capitol Records,
306. The Beatles I'm Looking Through You
Through You 3.13.2019 LLC
Capitol filed I'm Only Sleeping Capitol Records,
307. The Beatles I'm Only Sleeping
3.13.2019 LLC
Capitol filed I'm So Tired Capitol Records,
308. The Beatles I'm So Tired
3.13.2019 LLC
Capitol filed IN MY LIFE Capitol Records,
309. The Beatles In My Life
3.13.2019 LLC
Capitol filed It Won't Be Long Capitol Records,
310. The Beatles It Won't Be Long
3.13.2019 LLC
Capitol filed It's All Too Much Capitol Records,
311. The Beatles It's All Too Much
3.13.2019 LLC
Capitol filed It's Only Love Capitol Records,
312. The Beatles It's Only Love
3.13.2019 LLC
Capitol filed I've Got A Feeling Capitol Records,
313. The Beatles I've Got A Feeling
3.13.2019 LLC
Capitol filed I've Just Seen A Capitol Records,
314. The Beatles I'Ve Just Seen A Face
Face 3.13.2019 LLC
Capitol Records,
315. The Beatles Julia Capitol filed JULIA 3.13.2019
LLC
Kansas City / Hey-Hey- Capitol filed Kansas City/Hey- Capitol Records,
316. The Beatles
Hey-Hey Hey-Hey-Hey 3.13.2019 LLC

- 13 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 14 of 27

Komm Gib Mir Deine Capitol filed Komm, Gib Mir Capitol Records,
317. The Beatles
Hand Deine Hand 3.13.2019 LLC
Capitol Records,
318. The Beatles Lady Madonna Capitol filed 3.13.2019
LLC
Capitol filed LET IT BE Capitol Records,
319. The Beatles Let It Be
3.13.2019 LLC
Capitol Records,
320. The Beatles Little Child Capitol filed 3.13.2019
LLC
Capitol Records,
321. The Beatles Long Long Long Capitol filed 3.13.2019
LLC
Capitol Records,
322. The Beatles Long Tall Sally Capitol filed 3.13.2019
LLC
Capitol filed Long Long Long Capitol Records,
323. The Beatles Long, Long, Long
3.13.2019 LLC
Capitol filed LOVE ME DO Capitol Records,
324. The Beatles Love Me Do
3.13.2019 LLC
Capitol Records,
325. The Beatles Love You To Capitol filed 3.13.2019
LLC
Capitol filed Lovely Rita Capitol Records,
326. The Beatles Lovely Rita
3.13.2019 LLC
Lucy In The Sky With Capitol filed Lucy In The Sky Capitol Records,
327. The Beatles
Diamonds With Diamonds 3.13.2019 LLC
Capitol Records,
328. The Beatles Maggie Mae Capitol filed 3.13.2019
LLC
Captiol filed Magical Mystery Capitol Records,
329. The Beatles Magical Mystery Tour
Tour 3.13.2019 LLC
Capitol Records,
330. The Beatles March Of The Meanies Capitol filed 3.13.2019
LLC
Capitol filed Martha My Dear Capitol Records,
331. The Beatles Martha My Dear
3.13.2019 LLC
Capitol filed Matchbox Capitol Records,
332. The Beatles Matchbox
3.13.2019 LLC
Capitol filed MAXWELL'S Capitol Records,
333. The Beatles Maxwell's Silver Hammer
SILVER HAMMER 3.13.2019 LLC
Capitol Records,
334. The Beatles Mean Mr Mustard Capitol filed 3.13.2019
LLC
Capitol Records,
335. The Beatles Michelle Capitol filed Michelle 3.13.2019
LLC
Capitol Records,
336. The Beatles Misery Capitol filed Misery 3.13.2019
LLC
Money (That's What I Capitol Records,
337. The Beatles Capitol filed 3.13.2019
Want) LLC
Capitol filed MOTHER Capitol Records,
338. The Beatles Mother Nature's Son
NATURE'S SON 3.13.2019 LLC
Capitol filed MR MOONLIGHT Capitol Records,
339. The Beatles Mr Moonlight
3.13.2019 LLC
Capitol filed NO REPLY Capitol Records,
340. The Beatles No Reply
3.13.2019 LLC

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 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 15 of 27

Capitol filed NORWEGIAN

Norwegian Wood (This Capitol Records,
341. The Beatles WOOD (THIS BIRD HAS
Bird Has Flown) LLC
FLOWN) 3.13.2019
Capitol Records,
342. The Beatles Not A Second Time Capitol filed 3.13.2019
LLC
Capitol filed NOWHERE MAN Capitol Records,
343. The Beatles Nowhere Man
3.13.2019 LLC
Capitol filed OB-LA-DI, OB- Capitol Records,
344. The Beatles Ob-La-Di, Ob-La-Da
LA-DA 3.13.2019 LLC
Capitol filed OCTOPUS'S Capitol Records,
345. The Beatles Octupus's Garden
GARDEN 3.13.2019 LLC
Capitol filed OH! DARLING Capitol Records,
346. The Beatles Oh! Darling
3.13.2019 LLC
Capitol filed Old Brown Shoe Capitol Records,
347. The Beatles Old Brown Shoe
3.13.2019 LLC
Capitol Records,
348. The Beatles One After 909 Capitol filed 3.13.2019
LLC
Capitol Records,
349. The Beatles Only A Northern Song Capitol filed 3.13.2019
LLC
Capitol filed P.S. I Love You Capitol Records,
350. The Beatles P.S. I Love You
3.13.2019 LLC
Capitol filed PAPERBACK Capitol Records,
351. The Beatles Paperback Writer
WRITER 3.13.2019 LLC
Capitol filed PENNY LANE Capitol Records,
352. The Beatles Penny Lane
3.13.2019 LLC
Capitol filed Pepperland Capitol Records,
353. The Beatles Pepperland
3.13.2019 LLC
Capitol Records,
354. The Beatles Pepperland Laid Waste Capitol filed 3.13.2019
LLC
Capitol Records,
355. The Beatles Piggies Capitol filed 3.13.2019
LLC
Capitol filed PLEASE MISTER Capitol Records,
356. The Beatles Please Mister Postman
POSTMAN 3.13.2019 LLC
Capitol filed PLEASE PLEASE Capitol Records,
357. The Beatles Please Please Me
ME 3.13.2019 LLC
Capitol filed POLYTHENE PAM Capitol Records,
358. The Beatles Polythene Pam
3.13.2019 LLC
Capitol Records,
359. The Beatles Rain Capitol filed RAIN 3.13.2019
LLC
Capitol filed REVOLUTION Capitol Records,
360. The Beatles Revolution
3.13.2019 LLC
Capitol filed Revolution 9 Capitol Records,
361. The Beatles Revolution 9
3.13.2019 LLC
Capitol Records,
362. The Beatles Rock And Roll Music Capitol filed 3.13.2019
LLC
Capitol filed ROCKY Capitol Records,
363. The Beatles Rocky Raccoon
RACCOON 3.13.2019 LLC
Capitol filed ROLL OVER Capitol Records,
364. The Beatles Roll Over Beethoven
BEETHOVEN 3.13.2019 LLC

- 15 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 16 of 27

Capitol filed RUN FOR YOUR Capitol Records,

365. The Beatles Run For Your Life
LIFE 3.13.2019 LLC
Capitol Records,
366. The Beatles Savoy Truffle Capitol filed 3.13.2019
LLC
Capitol filed Sea Of Holes Capitol Records,
367. The Beatles Sea Of Holes
3.13.2019 LLC
Capitol Records,
368. The Beatles Sea Of Monsters Capitol filed 3.13.2019
LLC
Capitol Records,
369. The Beatles Sea Of Time Capitol filed 3.13.2019
LLC
Capitol filed SEXY SADIE Capitol Records,
370. The Beatles Sexy Sadie
3.13.2019 LLC
Sgt Pepper'S Lonely Capitol filed Sgt Pepper's Lonely Capitol Records,
371. The Beatles
Hearts Club Band Hearts Club Band 3.13.2019 LLC
Sgt Pepper's Lonely
Capitol Records,
372. The Beatles Hearts Club Band Capitol filed 3.13.2019
LLC
(Reprise)
Capitol filed SHE CAME IN
She Came In Through The Capitol Records,
373. The Beatles THROUGH THE BATHROOM
Bathroom Window LLC
WINDOW 3.13.2019
Capitol filed She Loves You Capitol Records,
374. The Beatles She Loves You
3.13.2019 LLC
Capitol Records,
375. The Beatles She Said She Said Capitol filed 3.13.2019
LLC
Capitol Records,
376. The Beatles She's A Woman Capitol filed 3.13.2019
LLC
Capitol filed SHE'S LEAVING Capitol Records,
377. The Beatles She's Leaving Home
HOME 3.13.2019 LLC
Capitol filed SIE LIEBT DICH Capitol Records,
378. The Beatles Sie Liebt Dich
3.13.2019 LLC
Capitol filed SLOW DOWN Capitol Records,
379. The Beatles Slow Down
3.13.2019 LLC
Capitol filed SOMETHING Capitol Records,
380. The Beatles Something
3.13.2019 LLC
Capitol filed STRAWBERRY Capitol Records,
381. The Beatles Strawberry Fields Forever
FIELDS FOREVER 3.13.2019 LLC
Capitol filed SUN KING Capitol Records,
382. The Beatles Sun King
3.13.2019 LLC
Capitol filed TAXMAN Capitol Records,
383. The Beatles Taxman
3.13.2019 LLC
Capitol Records,
384. The Beatles Tell Me What You See Capitol filed 3.13.2019
LLC
Capitol filed TELL ME WHY Capitol Records,
385. The Beatles Tell Me Why
3.13.2019 LLC
Capitol Records,
386. The Beatles Thank You Girl Capitol filed 3.13.2019
LLC
The Ballad Of John And Capitol filed THE BALLAD OF Capitol Records,
387. The Beatles
Yoko JOHN AND YOKO 3.13.2019 LLC
The Continuing Story Of Capitol Records,
388. The Beatles Capitol filed 3.13.2019
Bungalow Bill LLC

- 16 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 17 of 27

Capitol filed THE END Capitol Records,

389. The Beatles The End
3.13.2019 LLC
Capitol filed THE FOOL ON Capitol Records,
390. The Beatles The Fool On The Hill
THE HILL 3.13.2019 LLC
Capitol Records,
391. The Beatles The Inner Light Capitol filed 3.13.2019
LLC
The Long And Winding Capitol Records,
392. The Beatles Capitol filed 3.13.2019
Road LLC
Capitol filed THE NIGHT Capitol Records,
393. The Beatles The Night Before
BEFORE 3.13.2019 LLC
Capitol filed THE WORD Capitol Records,
394. The Beatles The Word
3.13.2019 LLC
Capitol filed THERE'S A Capitol Records,
395. The Beatles There's A Place
PLACE 3.13.2019 LLC
Capitol filed THINGS WE SAID Capitol Records,
396. The Beatles Things We Said Today
TODAY 3.13.2019 LLC
Capitol Records,
397. The Beatles Think For Yourself Capitol filed 3.13.2019
LLC
Capitol filed THIS BOY Capitol Records,
398. The Beatles This Boy
3.13.2019 LLC
Capitol filed TICKET TO RIDE Capitol Records,
399. The Beatles Ticket To Ride
3.13.2019 LLC
Capitol filed TILL THERE WAS Capitol Records,
400. The Beatles Till There Was You
YOU 3.13.2019 LLC
Capitol filed TOMORROW Capitol Records,
401. The Beatles Tomorrow Never Knows
NEVER KNOWS 3.13.2019 LLC
Capitol filed TWIST AND Capitol Records,
402. The Beatles Twist And Shout
SHOUT 3.13.2019 LLC
Capitol filed Two Of Us Capitol Records,
403. The Beatles Two Of Us
3.13.2019 LLC
Capitol Records,
404. The Beatles Wait Capitol filed WAIT 3.13.2019
LLC
Capitol Records,
405. The Beatles We Can Work It Out Capitol filed 3.13.2019
LLC
Capitol Records,
406. The Beatles What Goes On Capitol filed 3.13.2019
LLC
Capitol Records,
407. The Beatles What You're Doing Capitol filed 3.13.2019
LLC
Capitol filed When I Get Home Capitol Records,
408. The Beatles When I Get Home
3.13.2019 LLC
Capitol Records,
409. The Beatles When I'm Sixty Four Capitol filed 3.13.2019
LLC
Capitol filed WHILE MY
While My Guitar Gently Capitol Records,
410. The Beatles GUITAR GENTLY WEEPS
Weeps LLC
3.13.2019
Why Don't We Do It In Capitol Records,
411. The Beatles Capitol filed 3.13.2019
The Road LLC
Capitol filed WILD HONEY PIE Capitol Records,
412. The Beatles Wild Honey Pie
3.13.2019 LLC

- 17 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 18 of 27

Capitol filed WITH A LITTLE

With A Little Help From Capitol Records,
413. The Beatles HELP FROM MY FRIENDS
My Friends LLC
3.13.2019
Capitol Records,
414. The Beatles Within You Without You Capitol filed 3.13.2019
LLC
Capitol Records,
415. The Beatles Words Of Love Capitol filed 3.13.2019
LLC
Capitol filed Yellow Submarine Capitol Records,
416. The Beatles Yellow Submarine
3.13.2019 LLC
Yellow Submarine In Capitol Records,
417. The Beatles Capitol filed 3.13.2019
Pepperland LLC
Capitol Records,
418. The Beatles Yer Blues Capitol filed 3.13.2019
LLC
Capitol filed YES IT IS Capitol Records,
419. The Beatles Yes It Is
3.13.2019 LLC
Capitol filed YESTERDAY Capitol Records,
420. The Beatles Yesterday
3.13.2019 LLC
Capitol Records,
421. The Beatles You Can't Do That Capitol filed 3.13.2019
LLC
Capitol Records,
422. The Beatles You Know My Name Capitol filed 3.13.2019
LLC
Capitol filed YOU LIKE ME Capitol Records,
423. The Beatles You Like Me Too Much
TOO MUCH 3.13.2019 LLC
You Never Give Me Your Capitol Records,
424. The Beatles Capitol filed 3.13.2019
Money LLC
Capitol filed YOU REALLY
You Really Got A Hold Capitol Records,
425. The Beatles GOT A HOLD ON ME
On Me LLC
3.13.2019
Capitol Records,
426. The Beatles You Won't See Me Capitol filed 3.13.2019
LLC
Your Mother Should Capitol filed YOUR MOTHER Capitol Records,
427. The Beatles
Know SHOULD KNOW 3.13.2019 LLC
Capitol filed YOU'RE GOING
You're Going To Lose Capitol Records,
428. The Beatles TO LOSE THAT GIRL
That Girl LLC
3.13.2019
Capitol filed YOU'VE GOT TO
You've Got To Hide Your Capitol Records,
429. The Beatles HIDE YOUR LOVE AWAY
Love Away LLC
3.13.2019
Rhino Entertainment
430. The Doors Roadhouse Blues Pre-1972 Sound Recording
LLC
Michael Sony Music
431. Billie Jean SR0000041965
Jackson Entertainment
Michael Sony Music
432. Beat It SR0000041965
Jackson Entertainment
Michael Sony Music
433. Thriller SR0000041965
Jackson Entertainment
Michael Sony Music
434. Rock With You SR0000011120
Jackson Entertainment
Michael Sony Music
435. Smooth Criminal SR0000084256
Jackson Entertainment

- 18 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 19 of 27

Michael Don't Stop 'Til You Get Sony Music

436. SR0000011105
Jackson Enough Entertainment
Michael P.Y.T. (Pretty Young Sony Music
437. SR0000041965
Jackson Thing) Entertainment
Michael The Way You Make Me Sony Music
438. SR0000084256
Jackson Feel Entertainment
Michael Sony Music
439. Man in the Mirror SR0000084256
Jackson Entertainment
Michael Sony Music
440. Remember the Time SR0000178165
Jackson Entertainment
Michael Sony Music
441. Bad SR0000084256
Jackson Entertainment
Michael Wanna Be Startin' Sony Music
442. SR0000041965
Jackson Somethin' Entertainment
Michael Sony Music
443. You Rock My World SR0000791010
Jackson Entertainment
Michael Sony Music
444. Chicago SR0000754292
Jackson Entertainment
Michael Sony Music
445. Black or White SR0000178165
Jackson Entertainment
Michael Sony Music
446. Human Nature SR0000041965
Jackson Entertainment
Michael Sony Music
447. Dirty Diana SR0000084256
Jackson Entertainment
Michael Sony Music
448. You Are Not Alone SR0000212660
Jackson Entertainment
Michael Sony Music
449. Off The Wall SR0000011120
Jackson Entertainment
Michael Sony Music
450. Heaven Can Wait SR0000304780
Jackson Entertainment
Michael Sony Music
451. They Don't Care About Us SR0000212660
Jackson Entertainment
Michael Sony Music
452. The Lady In My Life SR0000041965
Jackson Entertainment
Michael Sony Music
453. The Girl Is Mine SR0000041013/SR0000042782
Jackson Entertainment
Michael Sony Music
454. Butterflies SR0000304780
Jackson Entertainment
Michael Sony Music
455. Baby Be Mine SR0000041965
Jackson Entertainment
Michael Sony Music
456. Heal the World SR0000178165
Jackson Entertainment
Michael Sony Music
457. Earth Song SR0000212660
Jackson Entertainment
Michael Sony Music
458. I Can't Help It SR0000011120
Jackson Entertainment
Michael I Just Can't Stop Loving Sony Music
459. SR0000822650
Jackson You Entertainment
Michael Sony Music
460. Workin' Day and Night SR0000011120
Jackson Entertainment

- 19 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 20 of 27

Michael Sony Music

461. Leave Me Alone SR0000084255
Jackson Entertainment
Michael Sony Music
462. Will You Be There SR0000178165
Jackson Entertainment
Michael Beat It (2008 with Fergie Sony Music
463. SR0000613501
Jackson Remix) Entertainment
Michael Sony Music
464. Dangerous SR0000178165
Jackson Entertainment
Michael Sony Music
465. Jam SR0000178165
Jackson Entertainment
Michael Sony Music
466. Liberian Girl SR0000084256
Jackson Entertainment
Michael Sony Music
467. She's Out Of My Life SR0000011120
Jackson Entertainment
Michael Sony Music
468. In the Closet SR0000178165
Jackson Entertainment
Michael Sony Music
469. Another Part Of Me SR0000084256
Jackson Entertainment
Michael Sony Music
470. Love Never Felt So Good SR0000754292
Jackson Entertainment
Sony Music
471. Ray Charles Two Old Cats Like Us SR0000058443
Entertainment
This Old Heart (Is Gonna Sony Music
472. Ray Charles SR0000058443
Rise Again) Entertainment
Sony Music
473. Ray Charles We Didn't See a Thing SR0000058443
Entertainment
Sony Music
474. Ray Charles Who Cares SR0000058443
Entertainment
Sony Music
475. Ray Charles Rock and Roll Shoes SR0000057170
Entertainment
Sony Music
476. Ray Charles Friendship SR0000058443
Entertainment
It Ain't Gonna Worry My Sony Music
477. Ray Charles SR0000058443
Mind Entertainment
Sony Music
478. Ray Charles Little Hotel Room SR0000058443
Entertainment
Sony Music
479. Ray Charles Crazy Old Soldier SR0000058443
Entertainment
Sony Music
480. Ray Charles Seven Spanish Angels SR0000058443
Entertainment
The All Blacks
481. Slipknot (sic) SR0000301094
U.S.A., Inc.
The All Blacks
482. Slipknot Before I Forget SR0000358238
U.S.A., Inc.
The All Blacks
483. Slipknot Dead Memories SR0000656810
U.S.A., Inc.
The All Blacks
484. Slipknot Disasterpiece SR0000330440
U.S.A., Inc.
The All Blacks
485. Slipknot Duality SR0000358238
U.S.A., Inc.

- 20 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 21 of 27

The All Blacks

486. Slipknot Eyeless SR0000301094
U.S.A., Inc.
The All Blacks
487. Slipknot Killpop SR0000768649
U.S.A., Inc.
The All Blacks
488. Slipknot Left Behind SR0000330440
U.S.A., Inc.
The All Blacks
489. Slipknot My Plague SR0000330440
U.S.A., Inc.
The All Blacks
490. Slipknot People = Shit SR0000330440
U.S.A., Inc.
The All Blacks
491. Slipknot Psychosocial SR0000656810
U.S.A., Inc.
The All Blacks
492. Slipknot Snuff SR0000656810
U.S.A., Inc.
The All Blacks
493. Slipknot Spit It Out SR0000301094
U.S.A., Inc.
The All Blacks
494. Slipknot Sulfur SR0000656810
U.S.A., Inc.
The All Blacks
495. Slipknot Surfacing SR0000301094
U.S.A., Inc.
The All Blacks
496. Slipknot The Blister Exists SR0000358238
U.S.A., Inc.
The All Blacks
497. Slipknot The Heretic Anthem SR0000330440
U.S.A., Inc.
The All Blacks
498. Slipknot Vermilion SR0000358238
U.S.A., Inc.
The All Blacks
499. Slipknot Vermilion, Pt. 2 SR0000358238
U.S.A., Inc.
The All Blacks
500. Slipknot Wait and Bleed SR0000301094
U.S.A., Inc.
UMG Recordings,
501. ABBA Andante, Andante SR0000024153
Inc.
UMG Recordings,
502. ABBA Angel Eyes SR0000010318
Inc.
UMG Recordings,
503. ABBA Chiquitita SR0000010318
Inc.
UMG Recordings,
504. ABBA Dame! Dame! Dame! SR0000025354
Inc.
UMG Recordings,
505. ABBA Dancing Queen SR0000303039
Inc.
UMG Recordings,
506. ABBA Does Your Mother Know SR0000009415
Inc.
UMG Recordings,
507. ABBA Eagle SR0000000071
Inc.
UMG Recordings,
508. ABBA Estoy Sonando SR0000025354
Inc.
UMG Recordings,
509. ABBA Fernando SR0000025354
Inc.
Gimme! Gimme! Gimme! UMG Recordings,
510. ABBA SR0000015044
(A Man After Midnight) Inc.

- 21 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 22 of 27

UMG Recordings,
511. ABBA Happy New Year SR0000024153
Inc.
UMG Recordings,
512. ABBA Head Over Heels SR0000031826
Inc.
UMG Recordings,
513. ABBA Honey, Honey N00000016810 / RE0000867304
Inc.
I Do, I Do, I Do, I Do, I UMG Recordings,
514. ABBA SR0000040286
Do Inc.
UMG Recordings,
515. ABBA I Have A Dream SR0000010318
Inc.
UMG Recordings,
516. ABBA If It Wasn't For The Nights SR0000010318
Inc.
UMG Recordings,
517. ABBA I've Been Waiting For You SR0000303039
Inc.
Knowing Me, Knowing UMG Recordings,
518. ABBA N000038737; SR0000814798
You Inc.
UMG Recordings,
519. ABBA Lay All Your Love On Me SR0000024153
Inc.
UMG Recordings,
520. ABBA Mamma Mia N00000026084
Inc.
UMG Recordings,
521. ABBA Money, Money, Money N000038737 / SR0000814798
Inc.
UMG Recordings,
522. ABBA My Love, My Life N000038737 / SR0000814798
Inc.
UMG Recordings,
523. ABBA On And On And On SR0000024153
Inc.
UMG Recordings,
524. ABBA One Of Us SR0000031826
Inc.
UMG Recordings,
525. ABBA Our Last Summer SR0000024153
Inc.
UMG Recordings,
526. ABBA Ring Ring SR0000040286 / SR0000303049
Inc.
UMG Recordings,
527. ABBA S.O.S. N00000024436
Inc.
Slipping Through My UMG Recordings,
528. ABBA SR0000031826
Fingers Inc.
UMG Recordings,
529. ABBA So Long SR0000040286
Inc.
UMG Recordings,
530. ABBA Summer Night City SR0000010318
Inc.
UMG Recordings,
531. ABBA Super Trouper SR0000024153
Inc.
UMG Recordings,
532. ABBA Take A Chance On Me SR0000000071
Inc.
UMG Recordings,
533. ABBA Thank You For The Music SR0000000071
Inc.
The Day Before You UMG Recordings,
534. ABBA SR0000039662
Came Inc.
UMG Recordings,
535. ABBA The Name Of The Game SR0000000071
Inc.

- 22 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 23 of 27

UMG Recordings,
536. ABBA The Winner Takes It All SR0000054688
Inc.
UMG Recordings,
537. ABBA Voulez-Vous SR0000010318
Inc.
UMG Recordings,
538. ABBA Waterloo N00000016810 / RE0000867304
Inc.
When All Is Said And UMG Recordings,
539. ABBA SR0000031826
Done Inc.
When I Kissed The UMG Recordings,
540. ABBA N000038737/ SR0000814798
Teacher Inc.
Why Did It Have To Be UMG Recordings,
541. ABBA N00000038737
Me? Inc.
Pre-1972 Sound Recording UMG Recordings,
542. B.B. King The Thrill is Gone
(ISRC - USUM70608474) Inc.
Bill Haley & (We're Gonna) Rock UMG Recordings,
543. 2021-04-08 - USMC15486163
His Comets Around The Clock Inc.
UMG Recordings,
544. Blink-182 A New Hope SR0000243969
Inc.
UMG Recordings,
545. Blink-182 Adam's Song SR0000279826
Inc.
UMG Recordings,
546. Blink-182 After Midnight SR0000685509
Inc.
UMG Recordings,
547. Blink-182 Aliens Exist SR0000279826
Inc.
UMG Recordings,
548. Blink-182 All Of This SR0000345359
Inc.
UMG Recordings,
549. Blink-182 All The Small Things SR0000279826
Inc.
UMG Recordings,
550. Blink-182 Always SR0000345359
Inc.
UMG Recordings,
551. Blink-182 Anthem SR0000279826
Inc.
UMG Recordings,
552. Blink-182 Anthem Pt. 2 SR0000301317
Inc.
UMG Recordings,
553. Blink-182 Apple Shampoo SR0000243969
Inc.
UMG Recordings,
554. Blink-182 Asthenia SR0000345359
Inc.
UMG Recordings,
555. Blink-182 Boring SR0000243969
Inc.
UMG Recordings,
556. Blink-182 Dammit SR0000243969
Inc.
UMG Recordings,
557. Blink-182 Degenerate SR0000243969
Inc.
UMG Recordings,
558. Blink-182 Dick Lips SR0000243969
Inc.
UMG Recordings,
559. Blink-182 Don't Leave Me SR0000279826
Inc.
UMG Recordings,
560. Blink-182 Down SR0000345359
Inc.

- 23 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 24 of 27

UMG Recordings,
561. Blink-182 Dumpweed SR0000279826
Inc.
UMG Recordings,
562. Blink-182 Dysentery Gary SR0000279826
Inc.
UMG Recordings,
563. Blink-182 Easy Target SR0000345359
Inc.
UMG Recordings,
564. Blink-182 Emo SR0000243969
Inc.
UMG Recordings,
565. Blink-182 Enthused SR0000243969
Inc.
UMG Recordings,
566. Blink-182 Even If She Falls SR0000685509
Inc.
Every Time I Look For UMG Recordings,
567. Blink-182 SR0000301317
You Inc.
UMG Recordings,
568. Blink-182 Feeling This SR0000345359
Inc.
UMG Recordings,
569. Blink-182 Fighting The Gravity SR0000685509
Inc.
UMG Recordings,
570. Blink-182 First Date SR0000301317
Inc.
Ghost On The Dance UMG Recordings,
571. Blink-182 SR0000685509
Floor Inc.
Give Me One Good UMG Recordings,
572. Blink-182 SR0000301317
Reason Inc.
UMG Recordings,
573. Blink-182 Go SR0000345359
Inc.
UMG Recordings,
574. Blink-182 Going Away To College SR0000279826
Inc.
Happy Holidays, You UMG Recordings,
575. Blink-182 SR0000301317
Bastard Inc.
UMG Recordings,
576. Blink-182 Heart's All Gone SR0000685509
Inc.
UMG Recordings,
577. Blink-182 Here's Your Letter SR0000345359
Inc.
UMG Recordings,
578. Blink-182 I Miss You SR0000345359
Inc.
I Won't Be Home For UMG Recordings,
579. Blink-182 SR0000303924
Christmas Inc.
UMG Recordings,
580. Blink-182 I'm Lost Without You SR0000345359
Inc.
UMG Recordings,
581. Blink-182 I'm Sorry SR0000243969
Inc.
UMG Recordings,
582. Blink-182 Josie SR0000243969
Inc.
UMG Recordings,
583. Blink-182 Kaleidoscope SR0000685509
Inc.
UMG Recordings,
584. Blink-182 Lemmings SR0000243969
Inc.
UMG Recordings,
585. Blink-182 Love Is Dangerous SR0000685509
Inc.

- 24 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 25 of 27

UMG Recordings,
586. Blink-182 Man Overboard SR0000214761
Inc.
UMG Recordings,
587. Blink-182 MH 4.18.2011 SR0000685509
Inc.
UMG Recordings,
588. Blink-182 Mutt SR0000279826
Inc.
UMG Recordings,
589. Blink-182 Natives SR0000685509
Inc.
UMG Recordings,
590. Blink-182 Obvious SR0000345359
Inc.
UMG Recordings,
591. Blink-182 Online Songs SR0000301317
Inc.
UMG Recordings,
592. Blink-182 Pathetic SR0000243969
Inc.
UMG Recordings,
593. Blink-182 Please Take Me Home SR0000301317
Inc.
UMG Recordings,
594. Blink-182 Reckless Abandon SR0000301317
Inc.
UMG Recordings,
595. Blink-182 Roller Coaster SR0000301317
Inc.
UMG Recordings,
596. Blink-182 Shut Up SR0000301317
Inc.
UMG Recordings,
597. Blink-182 Snake Charmer SR0000685509
Inc.
Stay Together For The UMG Recordings,
598. Blink-182 SR0000301317
Kids Inc.
UMG Recordings,
599. Blink-182 Stockholm Syndrome SR0000345359
Inc.
UMG Recordings,
600. Blink-182 Story Of A Lonely Guy SR0000301317
Inc.
UMG Recordings,
601. Blink-182 The Party Song SR0000279826
Inc.
UMG Recordings,
602. Blink-182 The Rock Show SR0000301317
Inc.
UMG Recordings,
603. Blink-182 This Is Home SR0000685509
Inc.
UMG Recordings,
604. Blink-182 Untitled SR0000243969
Inc.
UMG Recordings,
605. Blink-182 Up All Night SR0000685510
Inc.
UMG Recordings,
606. Blink-182 Violence SR0000345359
Inc.
UMG Recordings,
607. Blink-182 Voyeur SR0000243969
Inc.
UMG Recordings,
608. Blink-182 Waggy SR0000243969
Inc.
UMG Recordings,
609. Blink-182 Wendy Clear SR0000279826
Inc.
UMG Recordings,
610. Blink-182 What'S My Age Again? SR0000279826
Inc.

- 25 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 26 of 27

UMG Recordings,
611. Blink-182 Wishing Well SR0000685509
Inc.
Pre-1972 Recording (indexed UMG Recordings,
612. Chuck Berry Johnny B. Goode
2019-03-25) Inc.
Pop Star (feat. Kevin UMG Recordings,
613. DaBaby SR0000866566
Gates) Inc.
Enrique UMG Recordings,
614. Hero SR0000303794
Iglesias Inc.
UMG Recordings,
615. Frou Frou Let Go SR0000322873
Inc.
UMG Recordings,
616. Gloria Gaynor I Will Survive SR0000004986 / SR0000010931
Inc.
UMG Recordings,
617. James Brown I Got You (I Feel Good) 2019-11-26 - USPR36809924
Inc.
James Brown
2019-11-26 - USPR36807121; UMG Recordings,
618. & The Famous I Got You (I Feel Good)
USF066825010; USF066625050 Inc.
Flames
Jerry Lee Pre-1972 Recording (indexed UMG Recordings,
619. Great Balls Of Fire
Lewis 2022-07-12 - USIR20400813) Inc.
For The Night (feat. Lil UMG Recordings,
620. Pop Smoke SR0000886562
Baby & DaBaby) Inc.
2020-03-26 - USMO16500449;
Smokey
USMO16500499; UMG Recordings,
621. Robinson & The Tracks of My Tears
USMO16572026; Inc.
The Miracles
USWWW0142397
UMG Recordings,
622. Stevie Wonder Superstition N00000003886; RE0000852322
Inc.
The UMG filed 6.10.2019 - UMG Recordings,
623. My Girl
Temptations USMO16490001 Inc.
Warner Music
624. Ed Sheeran Shape of You SR0000804886 International
Services Limited
Colors (Coca-Cola®
625. Jason Derulo Anthem, 2018 FIFA World SR0000939790 Warner Records Inc.
CupTM)
626. Jason Derulo Don't Wanna Go Home SR0000693162 Warner Records Inc.
627. Jason Derulo Get Ugly SR0000774211 Warner Records Inc.
628. Jason Derulo If It Ain't Love SR0000775353 Warner Records Inc.
629. Jason Derulo In My Head SR0000685175 Warner Records Inc.
630. Jason Derulo It Girl SR0000693162 Warner Records Inc.
631. Jason Derulo Marry Me SR0000763207 Warner Records Inc.
632. Jason Derulo Ridin' Solo SR0000685175 Warner Records Inc.
633. Jason Derulo Stupid Love SR0000763207 Warner Records Inc.
Swalla (feat. Nicki Minaj
634. Jason Derulo SR0000809218 Warner Records Inc.
& Ty Dolla $ign)
635. Jason Derulo Talk Dirty (feat. 2 Chainz) SR0000763207 Warner Records Inc.
636. Jason Derulo The Other Side SR0000763207 Warner Records Inc.
Tip Toe (feat. French
637. Jason Derulo SR0000875097 Warner Records Inc.
Montana)
638. Jason Derulo Trumpets SR0000763207 Warner Records Inc.

- 26 -
 Case 1:24-cv-11611 Document 1-2 Filed 06/24/24 Page 27 of 27

639. Jason Derulo Want to Want Me SR0000774211 Warner Records Inc.

640. Jason Derulo Whatcha Say SR0000685175 Warner Records Inc.
Wiggle (feat. Snoop
641. Jason Derulo SR0000763207 Warner Records Inc.
Dogg)
Jason Derulo x Goodbye (feat. Nicki
642. SR0000917911 Warner Records Inc.
David Guetta Minaj & Willy William)
All I Want for Christmas
643. Michael Bublé SR0000704271 Warner Records Inc.
Is You
Christmas (Baby Please
644. Michael Bublé SR0000704271 Warner Records Inc.
Come Home)
645. Michael Bublé Cold December Night SR0000704271 Warner Records Inc.
646. Michael Bublé Everything SR0000406982 Warner Records Inc.
647. Michael Bublé Feeling Good SR0000370205 Warner Records Inc.
Have Yourself a Merry
648. Michael Bublé SR0000704271 Warner Records Inc.
Little Christmas
649. Michael Bublé Haven't Met You Yet SR0000672366 Warner Records Inc.
650. Michael Bublé Holly Jolly Christmas SR0000704271 Warner Records Inc.
651. Michael Bublé Home SR0000370204 Warner Records Inc.
I'll Be Home for
652. Michael Bublé SR0000704271 Warner Records Inc.
Christmas
653. Michael Bublé It's a Beautiful Day SR0000731981 Warner Records Inc.
It's Beginning to Look a
654. Michael Bublé SR0000704271 Warner Records Inc.
Lot like Christmas
Jingle Bells (feat. The
655. Michael Bublé SR0000704271 Warner Records Inc.
Puppini Sisters)
656. Michael Bublé Santa Baby SR0000704271 Warner Records Inc.
Santa Claus Is Coming to
657. Michael Bublé SR0000704271 Warner Records Inc.
Town
Save the Last Dance for
658. Michael Bublé SR0000370205 Warner Records Inc.
Me
659. Michael Bublé Silent Night SR0000704271 Warner Records Inc.
660. Michael Bublé Sway SR0000330696 Warner Records Inc.
661. Michael Bublé White Christmas SR0000944170 Warner Records Inc.
Winter Wonderland (feat.
662. Michael Bublé SR0000948239 Warner Records Inc.
Rod Stewart)

- 27 -
 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 1 of 9

EXHIBIT B

Additional Suno Outputs Resembling Copyrighted Recordings

I. Style and Melody Similarity

Copyrighted Relevant
Suno Output Artist Prompt
Recording Timestamp
One, Two, Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Three O’Clock, Comets Clock comets
Four O’Clock,
r
Wun, Two, Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Three O’Clock, Comets Clock comets
Four O’Clock,
r
One, Two, Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Three O’Clock, Comets Clock comets
Four O’Clock,
r
Hey Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Comets Clock comets
Bun Two, Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Three O’Clock, Comets Clock comets
Four O’Clock,
ro
One, Two, Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Three O’Clock, Comets Clock comets
Four O’Clock,
r
One, Two, Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Three O’Clock, Comets Clock comets
Four O’Clock,
r
Hey Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Comets Clock comets
One, Two, Bill Haley & His Rock Around the 1954 rock and roll bill haley Entire Output
Three O’Clock, Comets Clock comets
Four O’Clock,
r
The Thrill is B.B. King The Thrill is slow minor blues, west coast 0:00-0:10
Gone Gone blues, 12-bar blues, king of the
blues, electric guitar, gritty
confident voice, 1969
The Thrill is B.B. King The Thrill is slow minor blues, west coast 0:10-0:20
Gone Gone blues, 12-bar blues, king of the
blues, electric guitar, gritty
confident voice, 1969
The Thrill is B.B. King The Thrill is slow minor-key blues, west coast 0:03-0:06
Gone Gone blues, 12-bar blues, king of the
blues, electric guitar, gritty
confident voice, 1969
 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 2 of 9

The Thrill is B.B. King The Thrill is slow minor-key blues, west coast 0:28-0:31
Gone Gone blues, 12-bar blues, king of the
blues, electric guitar, gritty
confident voice, 1969
The Thrill is B.B. King The Thrill is slow minor blues, west coast 0:03-0:05
Gone Gone blues, 12-bar blues, king of the
blues, electric guitar, gritty
confident voice, 1969
Thriller Michael Jackson Thriller "post-disco, pop-rock, funk, 0:30-0:33
electronic, r&b, thriller, motown,
famous male singer and dancer,
neverland”
Thriller Michael Jackson Thriller "post-disco, pop-rock, funk, 0:10 (“dark”),
electronic, r&b, thriller, motown, 0:22 (“to
famous male singer and dancer, scream”), 0:30
king of pop, falsetto” (“to freeze”),
0:42 (“no one’s
gonna save”),
0:45 (“fighting
for your life”)
Thriller Michael Jackson Thriller "post-disco pop-rock funk 0:34-0:36
electronic r&b thriller”
Tracks of My Smokey The Tracks of 60s r&b / soul 0:00-0:04
Fears Robinson & The My Tears
Miracles
My Girl The Temptations My Girl 1960s soul 0:07-0:10 (bass
line)
My Girl The Temptations My Girl 60s soul 0:00-0:04 (“I got
sunshine”)
My Girl The Temptations My Girl 1960s soul 0:11-0:13 (“I
guess you’d
say”)
My Girl The Temptations My Girl 1960s soul 0:59-1:01
(“talkin’ ‘bout”)
My Girl The Temptations My Girl 1960s soul, motown, happy, 0:18-0:20
melodic, romantic, warm, (“talkin’ ‘bout
optimistic, sentimental, male my girl”)
vocalist, lush, love, rhythmic,
vocal
Lets Go Frou Frou Let Go Electropop 0:00-0:03
Michael Stevie Wonder Superstition rock and roll 60s 0:00-0:09, 0:21-
Jackson Bad 0:31, etc.
(accompaniment
riff)
Girl, You Ed Sheeran Shape of You Pop, male singer songerwriter Entire Output
Know I Want [sic], artist that rhymes with fred
Your Love sheeran, tropical house, minor
Heroes Enrique Iglesias Hero Latin pop 0:00-0:05
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist

-2-
 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 3 of 9

Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist

-3-
 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 4 of 9

Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist

-4-
 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 5 of 9

Deep Down in Chuck Berry Johnny B. Good 1950s rock and roll, rhythm & Entire Output
Louisiana blues, 12 bar blues, rockabilly,
Close to New energetic male vocalist, singer
Orle guitarist
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:16
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:15
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:19
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:14
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:16
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:13
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:16
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:24
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:15
Nerves and Fire lewis, sun studio
You Rattle My
Br
You Shake My Jerry Lee Lewis Great Balls of 1950s rock and roll, jerry lee 0:00-0:19
Nerves and Fire lewis, sun studio
You Rattle My
Br
Oh, keep your The Doors Roadhouse Blues 1970 blues rock doors 0:00–0:08
eyes on the psychedelic rock los angeles jim
road, your han morrison, kings of acid rock
When marimba Michael Bublé Sway 2004 canadian male singer jazz 0:07-0:18
rhythms start to pop sway latin big band 0:24-0:34
play
When marimba Michael Bublé Sway 2004 canadian male singer jazz 0:00-0:20
rhythms start to pop sway latin big band 0:28-0:53
play

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 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 6 of 9

When marimba Michael Bublé Sway 2004 canadian smooth male 0:00-0:27
start to play singer jazz pop buble sway latin 0:31-0:37
big band
When marimba Michael Bublé Sway 2004 canadian smooth male 0:08-0:45
rhythms start to singer jazz pop buble sway latin
play big band
When marimba Michael Bublé Sway canadian smooth male singer 0:05-0:21
rhythms start to 2004 jazz pop buble sway latin 0:25-0:30
play big band
When marimba Michael Bublé Sway canadian smooth male singer 0:01-0:22
rhythms start to 2004 jazz pop buble sway latin
play big band
When marimba Michael Bublé Sway canadian smooth male singer 0:04-0:29
rhythms start to 2004 jazz pop buble sway latin
play big band mambo
When marimba Michael Bublé Sway canadian smooth male singer 0:04-08
rhythms start to 2004 jazz pop buble sway latin 0:11-0:28
play big band mambo
When marimba Michael Bublé Sway canadian smooth male singer 0:09-0:28
rhythms start to 2004 jazz pop buble sway latin
play mambo
When marimba Michael Bublé Sway canadian smooth male singer 0:09-0:44
rhythms start to 2004 jazz pop buble sway latin
play mambo
When marimba Michael Bublé Sway canadian smooth male singer 0:08-0:42
rhythms start to 2004 jazz pop buble sway latin
play mambo minor key

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 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 7 of 9

II. Style Similarity

Relevant
Suno Output Vocals Prompt
Timestamp
Abba – Thank ABBA pop + abba 80s 70s + uptempo Entire Output
Abba for the Music
Prancing Queen ABBA 70s pop Entire Output
I don't wanna talk ABBA 70s swedish europop, melancholic Entire Output
breakup ballad
Yesterday The Beatles 60s british pop rock, liverpool, abbey Entire Output
road
Yesterday The Beatles 60s british pop rock, liverpool, abbey Entire Output
road
Yesterday The Beatles 60s british pop rock, liverpool, abbey Entire Output
road
Yesterday The Beatles 60s british pop rock, liverpool, abbey Entire Output
road
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, neverland
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop, falsetto
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop, falsetto
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop, falsetto
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop, falsetto
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop, falsetto
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop, falsetto
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop, falsetto
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop
Thriller Michael Jackson post-disco, pop-rock, funk, electronic, Entire Output
r&b, thriller, motown, famous male
singer and dancer, king of pop

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 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 8 of 9

The Anthem Blink-182 a song by a band named blank-184 Entire Output

Sittin' in the Otis Redding southern soul, deep soul, male vocalist, Entire Output
mornin' sun greatest soul singer of the 60s, mellow
Sittin in the Otis Redding southern soul, deep soul, male vocalist, Entire Output
mornin’ sun greatest soul singer of the 60s, mellow
Well Ray Charles 1954 ray rhythm and blues charles Entire Output
energetic fast atlanta
Well Ray Charles 1954 rhythm and blues ray Entire Output
Well Ray Charles 1954 ray rhythm and blues charles Entire Output
atlanta
Well Ray Charles 1954 ray rhythm and blues charles Entire Output
atlanta
Well Ray Charles 1954 ray rhythm and blues charles Entire Output
Well, I got a Ray Charles ray charles rhythm & blues soul 1954 Entire Output
woman, way over atlantic georgia wexler
town
Well, I got a Ray Charles ray charles rhythm & blues soul 1954 Entire Output
woman, way over atlantic georgia
town
Well, I got a Ray Charles ray charles rhythm & blues soul 1954 Entire Output
woman, way over gospel frenetic atlanta georgia wexler
town
Well, I got a Ray Charles ray charles rhythm & blues soul 12 bar Entire Output
woman, way over 1959
town
Well, I got a Ray Charles ray charles rhythm & blues soul 1954 Entire Output
woman, way over gospel frenetic atlanta My Jesus Is All
town the World to Me
Hey mama, don’t Ray Charles ray charles rhythm & blues soul 12 bar Entire Output
you treat me wrong 1959
i get around The Beach Boys 60s surf rock california beach boys Entire Output
get around The Beach Boys 60s california surf rock by the beach Entire Output
boys
It’s been a hard The Beatles 60s rock british Entire Output
day’s night, and
I’ve b
In the Dark Slipknot slip knot Entire Output
Well, it's a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night moondance
for a moond
Well, it's a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night moondance
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male van Entire Output
marvelous night moondance morrison
for a moond
Well, it's a Michael Bublé 2003 vocal pop jazz canadian male van Entire Output
marvelous night moondance morrison
for a moond
Well, it's a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night moondance morrison
for a moond

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 Case 1:24-cv-11611 Document 1-3 Filed 06/24/24 Page 9 of 9

Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night moondance morrison
for a moond
Well, it's a Michael Bublé 2003 vocal pop jazz canadian male van Entire Output
marvelous night moondance morrison soul
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male van Entire Output
marvelous night moondance morrison
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night walking bass van moondance morrison
for a moond minor soul
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male van Entire Output
marvelous night moondance morrison minor soul
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male van Entire Output
marvelous night moondance morrison soul
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night upbeat walking bass minor soul
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night walking bass upbeat minor soul
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night walking bass minor soul
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night walking bass minor soul
for a moond
Well, it’s a Michael Bublé 2003 fast vocal pop jazz canadian male Entire Output
marvelous night upbeat walking bass minor
for a moond
Well, it’s a Michael Bublé 2003 vocal pop jazz canadian male Entire Output
marvelous night walking bass minor
for a moond

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 Case 1:24-cv-11611 Document 1-4 Filed 06/24/24 Page 1 of 1

EXHIBIT C
Thumb Drive of Suno-Generated
Outputs to be Lodged
Separately with the Court